Tag Archives: Save Right Whales Coalition (SRWC)

Official CFACT statement on Maryland offshore wind

There is a rise on whales death and dead birds. This is not caused by climate change but by offshore wind farms.

From  CFACT.

From Craig Rucker, President
CFACT

The Draft Environmental Impact Statement (DEIS) Executive Summary makes it clear it is intended to be the principal EIS for the Letter of Authorization (LOA) issued by the National Marine Fisheries Service (NMFS) under the Marine Mammal Protection Act (MMPA). The central purpose of the LOA is to authorize the incidental harassment of marine mammals that will be adversely impacted by project noise.

That there will be such a LOA is certain because US Wind applied for one six months ago. That this application is not mentioned in the DEIS is a major omission. The application proposes the harassment of over 6,000 marine mammals, listed by species. A significant number of these harassments are of endangered species, including the extremely endangered North Atlantic Right Whale.

This multitude of harassments is arguably the greatest environmental impact that will be manifested by the Maryland Wind project. These harassments should be a central focus of the DEIS, but amazingly, they are never mentioned. In fact, the word “harassment” never even occurs substantively, as it is only found three times in a “definition” section. Thus, there is no assessment of harassment or its impacts — an incredible omission.

If the projected harassments are never discussed and weighed, then this DEIS cannot be the EIS for the LOA. If this is to be the LOA EIS, then it will have to be extensively reworked and expanded. This cannot be done until the LOA is issued, at which time the actual authorized harassment numbers will be available for assessment. Even if this is not the LOA EIS, the projected numerous harassments must be analyzed and their impact assessed to comply with the National Environmental Policy Act (NEPA). Here, several issues arise, which are presented briefly below.

Harassment is itself an adverse impact. This is because harassment can easily lead to far worse impacts, up to and including the death of the animal. The Bureau of Ocean Energy Management (BOEM) seems to concur, explaining in the following statement that harassment can cause harm. It refers to “pile driving” in particular, but the argument it contains holds for all harassments.

“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 DEIS v.1, Page 3.15-14, PDF page 372

We maintain the Maryland Wind DEIS is inadequate and needs to be revised for the following reasons:

1. The Maryland Wind DEIS does not analyze and assess harassment-induced impacts, and this is a major omission.

The DEIS projects there will be a likely increase in boat and ship accident frequency as a consequence of the project, finding it roughly doubles. (See Table 3.6.6-5 and related text.) A similar analysis must be made to assess similar adverse impacts, such as increased ship strikes on whales. Harassing whales into heavy-traffic ship lanes is a likely feature of the Maryland Wind project. And since ship strikes are a major cause of whale mortality and smaller marine mammals, then each of the impacts described in the Empire Wind quote above needs to be carefully assessed, species by species.

2. With pile driving, there is a major omission in the DEIS: alternative energy sources.

The alternative of nuclear power or even floating wind instead of using monopile foundations is not considered. Given that pile driving is projected to be the leading cause of harassment, other forms of energy alternatives might offer better mitigation and should be considered. Moreover, BOEM just let five leases off California specifically for floating wind, demonstrating the technology is feasible. Dominion Energy’s latest Integrated Resource Plan includes adding a number of modular nuclear reactors so that technology is also feasible. The present DEIS only includes a “no action” alternative, so it mistakenly omits other viable alternatives.

3. There is also a major unresolved issue with sonar harassment, the actual noise level.

Recent measurements by the Save Right Whales Coalition (SRWC) discovered that sonar survey sound levels were markedly higher than those being used to estimate harassment numbers. They were so much higher that a revised harassment projection might include five times as many harassments for sonar work. SRWC notified National Oceanic and Atmospheric Administration (NOAA) Administrator Dr. Richard Spinrad of these troublesome findings on September 8, 2023, well before the release of this DEIS. That notification and related materials are at https://saverightwhales.org/. This issue must be resolved for the sonar used at Maryland Wind, so that the correct harassment numbers are used for impact assessment.

4. A huge omission is the lack of assessment of harassment from operational noise.

Neither the NMFS LOA application nor this DEIS addresses this issue. They seem to assume that operational noise is harmless. However, Dr. Bob Stern, the former director of the Office of Environmental Compliance at the U.S. Department of Energy, presented a paper at the 2022 meeting of the North Atlantic Right Whale Consortium to the effect that large-scale operational noise was likely to create widespread harassment. The scale in question is that planned for Maryland Wind. This operational noise issue needs to be investigated and resolved in a revised DEIS.

5. The major issue of cumulative impact is not addressed.

This project is just one of many presently proposed to be built and operated simultaneously. The cumulative harassment impacts could be very large and must be assessed under NEPA for the Maryland Wind project. NMFS has deemed that harassment authorizations are limited to 30% of the stock population. At present, the simultaneous cumulative harassment requests exceed several hundred percent of the severely endangered North Atlantic Right Whale population. Such an impact needs to be cut back to 30% or less.

6. Life cycle harassment impact is a major omission.

The LOA is only for five years, while this EIS covers the impacts over the entire project life cycle. Thus, a separate harassment impact estimate, by species, will be needed for that longer period, especially given the harassment potential of operational noise.

Read CFACT’s Maryland Offshore Wind DEIS Comments as a PDF

Maryland-Offshore-Wind-DEIS-Comments-CFACT-1Herunterladen

Author


Craig Rucker

Craig Rucker is a co-founder of CFACT and currently serves as its president.

Widely heralded as a leader in the free market environmental, think tank community in Washington, D.C., Rucker is a frequent guest on radio talk shows, written extensively in numerous publications, and has appeared in such media outlets as Fox News, OANN, Washington Times, The Wall Street Journal, and The Hill, among many others.

Rucker is also the co-producer of the award-winning film “Climate Hustle,” which was the #1 box-office film in America during its one night showing in 2016, as well as the acclaimed “Climate Hustle 2” staring Hollywood actor Kevin Sorbo released in 2020.

As an accredited observer to the United Nations, Rucker has also led CFACT delegations to some 30 major UN conferences, including those in Copenhagen, Istanbul, Kyoto, Bonn, Marrakesh, Rio de Janeiro, and Warsaw, to name a few.

A tale of two whale protection groups

From CFACT

By David Wojick 

There are two groups specializing in trying to protect the severely endangered North Atlantic Right Whale, of which only about 340 critters remain alive, fewer every month, it seems. One is new and small, while the other is old and big.

The small group says that offshore wind development is killing whales, which I, too, believe, but NOAA denies. The big group, which includes NOAA and some of their funded researchers, is now up to thinking about the possibility that offshore wind might actually affect the whales. This dramatic difference is worth exploring a bit.

The small group is the Save Right Whales Coalition (SRWC) at https://saverightwhales.org/. The really big group, founded in 1986, is the North Atlantic Right Whale Consortium (NARWC) at https://www.narwc.org/. The members of NARWC are a wealthy lot indeed.

The small Coalition is focused on wind, saying, “We are an alliance of grassroots environmental and community organizations, scientists, and conservationists working to protect the critically endangered North Atlantic right whale and other marine life from the industrialization of our ocean habitat through large-scale offshore wind energy development.”

The big Consortium says its mission is to “Eliminate human-caused mortality to right whales in critical habitats and migration corridors”. But their focus is on the old threats of fishing gear entanglement and ship strikes, never mentioning that both can be caused by the new and ongoing whale harassment noise from wind development.

Mind you, the big Consortium is now at least thinking about offshore wind. Their upcoming annual meeting has a session on it. Here are the presentations:

Session 2: Offshore Wind Interactions and Mitigation

— Upcalling behavior and patterns in North Atlantic right whales, implications for wind energy development

— Recommendations for real-time passive acoustic monitoring near offshore wind energy development activities to help mitigate risks to North Atlantic right whales

— From wind to whales: Potential hydrodynamic impacts of offshore wind on Nantucket Shoals region ecosystems

— Exploring overlap between NARW and ocean features: An autonomous-based oceanographic and ecological baseline

— BOEM-NOAA North Atlantic right whale and offshore wind strategy

Not exactly ‘save the whales from death’ stuff. Note that two of the five talks are by NOAA people, and the rest are their well-funded researchers. Regarding the so-called strategy in the last talk, I wrote about that: https://www.cfact.org/2022/12/21/ten-whale-groups-slam-atlantic-osw/. There is no strategy.

In dramatic contrast, the Save Right Whales Coalition recently sent a letter of deep concern to NOAA Administrator Richard Spinrad. The Coalition has been doing its own research on harmful sonar noise, with disturbing results. Here is the beginning of their letter:

“Dear Dr. Spinrad: We are writing to alert your attention to urgent and credible information involving offshore sonar activity occurring within wind lease areas in the Atlantic. Specifically, our data show that the sonar is producing Level B harassment noise levels at distances that exceed those set by NOAA Fisheries (NMFS). Consequently, the protective distances adopted in NMFS issued Incidental Harassment Authorizations (IHAs) for offshore wind sonar work are not protective at all. Rather, marine mammals are likely getting much closer to the sonar than should be allowed. We believe this is a major factor behind the recent spate of whale deaths in the Atlantic Ocean since December 1, 2022 and the ongoing Unusual Mortality Events (UMEs) dating back to 2017-18. The only mitigation for noise is distance. The shortened Level B the IHAs have, in effect, rendered any expected mitigations useless.”

A 5-page summary of these disturbing findings follows. See 

SRWC-NOAALetter2023-09-08FINALHerunterladen

This is by no means the first time NOAA has been given technical information regarding the threat of excessive noise from offshore wind development. Such noise can easily cause deadly behavior by whales, including ship strikes, entanglements, and reproductive decline.

We shall see how NOAA responds to this serious letter of concern from the Save Right Whales Coalition. Their ongoing research is also of great interest to us, especially since the rich North Atlantic Right Whale Consortium seems to be doing little or nothing about offshore wind.

Author


David Wojick

David Wojick, Ph.D. is an independent analyst working at the intersection of science, technology and policy.

For origins see http://www.stemed.info/engineer_tackles_confusion.html For over 100 prior articles for CFACT see http://www.cfact.org/author/david-wojick-ph-d/ Available for confidential research and consulting.