Tag Archives: North Atlantic Right Whale (NARW)

Offshore wind cumulative impact issue analysis

From CFACT

By David Wojick

When the Feds finally do the cumulative environmental impact analysis for whales as mandated by the Endangered Species Act there are a number of basic issues to be resolved. Here is a quick look at some for the desperately endangered North Atlantic Right Whale (NARW).

Cumulative refers to the combined impact of multiple offshore projects. The first issue is which projects to combine for analysis. NARW are found along the entire Atlantic coastal waters which bounds the geography. Other endangered critters are found along the Gulf and West Coasts.

Projects can be in very different stages of development. Here is a hierarchy of sorts that gives several obvious options, from relatively small to enormous.

1. Projects built or approved for construction. There are about 10 of these. They are the immediate threat, but the overall threat to the NARW is, of course, much greater than this. Given that they have been approved for construction, it might be difficult to make big changes to protect the NARW, although not impossible.

2. The above, plus the projects actively seeking near-term approval. This is more like 30 projects, and the combined threat is very real. Cumulative impact analysis might seriously constrain this long list.

3. Next come the many projects listed in “AN ACTION PLAN FOR OFFSHORE WIND TRANSMISSION DEVELOPMENT IN THE U.S. ATLANTIC REGION“. This Action Plan is from the Energy Department and the Bureau of Ocean Energy Management (BOEM), which is actually building the combined offshore wind monster.

The Action Plan shows specific projects in ever-increasing numbers by five-year increments, from 30,000 MW in 2030 to 85,000 MW in 2050. These projects are somewhat speculative, but since this is a BOEM Plan, its cumulative impact on the NARW should certainly be assessed for each five-year increment. It is likely that such a massive plan would be constrained by the results of this assessment.

For each cumulative impact assessment, the next question is, what potential impacts on the NARW to look at? Here are some obvious examples that I have discussed in prior articles.

A. Acoustic noise harassment from sources such as sonar surveys, site construction, as well as operation. Given that some approved individual projects have construction harassment estimates alone over 200 NARW each, the combined total harassment for all projects and sources could be enormous.

B. Moreover, it is likely that combined noises will create new levels of harassment. The potential for NARW extinction is obvious, given that their entire population is less than 350, with just 70 or so breeding females.

C. Adverse wake effects, such as reduced-energy air plumes and suspended sediment plumes that reduce food supplies. Here, clusters of nearby projects will be especially important. The Action Plan consists of numerous large clusters of projects.

D. Forced changes in navigation routes and fishing grounds which can lead to concentrated threats of deadly ship strikes and entanglement drownings. It is easy to forget that whales cannot breathe underwater.

It should be noted that adverse impacts can combine over time as well as space. The migratory NARW will be forced to run a gauntlet of successive projects stretching at least from Georgia to Maine.

Here is BOEM’s own discussion of the combined impacts over time for pile driving during construction of projects. I could not have said it better.

“It is possible that pile driving could displace animals into areas with lower habitat quality or higher risk of vessel collision or fisheries interaction. Multiple construction activities within the same calendar year could potentially affect migration, foraging, calving, and individual fitness. The magnitude of impacts would depend upon the locations, duration, and timing of concurrent construction. Such impacts could be long term, of high intensity, and of high exposure level. Generally, the more frequently an individual’s normal behaviors are disrupted or the longer the duration of the disruption, the greater the potential for biologically significant consequences to individual fitness. The potential for biologically significant effects is expected to increase with the number of pile-driving events to which an individual is exposed.”

Empire Wind, Draft Environmental Impact Statement v.1, Page 3.15-14, PDF page 372

No doubt there are other important issues to consider in a proper cumulative impact analysis.

Collectively, offshore wind is a massive proposed multi-project program with equally massive combined environmental impacts. These cumulative impacts must be assessed under the Endangered Species Act for the desperately endangered North Atlantic Right Whale and all the other listed critters that would be affected.

Constraint in project impact should be the order of the day.

Boston Globe’s whale protection contradiction

From CFACT

By David Wojick

The Boston Globe recently ran a silly story about the CFACT et al. whale protection lawsuit. As this title indicates, it is basically a political hit piece — “Activists are spreading misinformation about whale deaths to obstruct clean energy policies, researchers find”.

https://www.bostonglobe.com/2024/03/25/science/activists-use-whales-to-fight-wind

What the researchers actually found is that CFACT, Heartland, etc. are conservatives. Ten minutes on their websites would make that clear, but apparently, it is a research result if you put a lot of work into it.

The article talks about, but never addresses, the lawsuit. Its basic (and obvious) point is that the Feds in charge of environmental impact assessment have failed to consider the cumulative impact on the severely endangered North Atlantic Right Whale (NARW) from lining the Atlantic coast with huge wind facilities.

Cumulative impact analysis is specifically called for by the Endangered Species Act, and the lawsuit simply asks that this law be enforced by the Court. There is no misinformation.

First, in the Globe article comes a lengthy, nonsensical attack on some of the conservative groups fighting to save the whales from green industrialization on the grounds that conservatives cannot or should not do this. No comment needed.

But then the article wanders into impact science, where they unwittingly present a telling contradiction. First, it says this:

““At this point, there is no scientific evidence that noise resulting from offshore wind site characterization surveys could potentially cause whale deaths,” NOAA said on a website dedicated to questions about whales and wind.”

Note no evidence of POTENTIAL. NOAA used to say there was no evidence of actual killing of whales. Now, they have upped their denial to no potential. No potential means no risk, which is sheer nonsense.

But then they make the mistake of talking to an actual whale scientist. The scientist says this, which clearly describes several potentials, thus contradicting NOAA:

“That said, offshore wind development isn’t risk-free for whales, said Jessica Redfern, associate vice president of ocean conservation science at the New England Aquarium. She and other scientists studying the potential impacts of offshore wind are watching to see if the development forces them to change migration paths and whether the noise from construction could hamper a mother’s ability to nurse her calf or cause stress. And they’re watching what wind development might do to the whales’ prey.”

Mind you, Redfern’s description of some of the well-known risks is itself symptomatic of the neglect CFACT et al‘s lawsuit seeks to correct. She refers to “watching to see” what, in fact, cannot be seen because the severely endangered whales live underwater. The whole federally funded strategy at this point is to just wait and see what happens, as though extinction were reversible.

And, as usual, there is no mention of the huge federal harassment prediction numbers for sonar and construction, which create a huge potential for killing endangered critters. NOAA itself estimates that both sonar site surveys and construction pile driving expose a lot of whales and other protected marine mammals to dangerous noise levels.

Getting back to NOAA’s purely political see-no-evil pronouncement of no risk, they officially know better. Over a year ago, they took comments on a draft North American Right Whale (wait and see) protection strategy. A coalition of ten expert whale protection groups warned them in no uncertain terms about the clear threat from site characterization sonar surveys.

Here is the technical heart of their warning: “The Draft EA for the Empire Wind, for example, shows the brand and model of Sparkers and Seismic Air guns (so-called “bubble” guns) that are representative of those expected to be used. This equipment will emit sounds of the same sound frequencies as the calls of the NARW, which anthropogenic sounds are received by the NARW louder (188dB and 192dB respectively) than are the natural calls of the NARW, and thus are reasonably expected to “mask” them, or in common terms, drown them out. Right whales are highly dependent upon sound to maintain contact; they emit contact calls to communicate with conspecifics to keep aware of each other’s locations. Additionally, mothers and young calves must maintain close proximity in order for the calf to nurse and for the mother to be able to protect her calf by placing herself between her calf and predators, and NARW uses contact calls to do this.”

“It is important to understand that the decibel scale is a logarithmic one. So, as is the case here (example above taken from actual developer’s plans), sound emissions with a dB level that is 25 to 35 dB higher than the whale’s call have a loudness level of about six to ten times the whale call’s loudness.”

See my “Ten whale groups slam Atlantic OSW” at https://www.cfact.org/2022/12/21/ten-whale-groups-slam-atlantic-osw/

In short, even the evergreen Boston Globe had to admit that the potential for offshore wind development harming whales is significant. Moreover NOAA has clearly been warned about this threat.

The CFACT et al lawsuit is simply calling for this risk to be properly evaluated by NOAA for North Atlantic Right Whales as required by the Endangered Species Act. This is a risk that NOAA has carefully ignored in the headlong rush to needlessly industrialize the ocean with thousands of enormous wind towers.