On November 14, 2024, the Bureau of Ocean Energy Management (BOEM) published a “Notice of Availability of a Draft Programmatic Environmental Impact Statement (DPEIS) for Expected Wind Energy Development in California in the Federal Register.” The full DPEIS is 659 pages long and has an additional 441 pages of appendices. The 90-day public comment period for the DPEIS ends on February 12, 2025.
After reading through the DPEIS, I am left with several thoughts and concerns that I’d like to share. First, it’s important to emphasize that this document is not the final word on offshore wind. Neither RWE nor Vineyard Offshore have submitted Construction and Operations Plans, and likely won’t do so for several years, during which they will gather site information in order to inform project design. That process, thankfully, also gives scientists time to gather baseline data about the ecosystem these turbines will be placed in – which will also inform final project design. Because of this, we and BOEM don’t yet know the specific dimensions of the projects. How many turbines will each project have? We don’t know. How spaced out will they be? We don’t know. Once each project submits a specific Construction and Operation Plan, BOEM will require an additional Environmental Impact Statement specific to each plan – but that is many years down the road.
Given this uncertainty, it’s difficult at this time to determine the environmental impacts of the proposed project. But BOEM doesn’t want to just sit on its hands for the next several years. To help solve this problem, the National Renewable Energies Laboratory (NREL) created their best estimate of what a floating offshore wind project could look like by soliciting feedback from the offshore wind leaseholders, and produced a Representative Project Design Envelope (RPDE) that attempts to capture the range of possibilities. How many wind turbines will each project have? Between 30 and 200. How spaced out will they be? Between 0.5 and 1.6 nautical miles apart. The RPDE is located in Appendix A of the DPEIS.
The DPEIS then attempts to consider the impacts of the “maximum case scenario” for floating offshore wind given what we currently know about the offshore environment, and presents a list of mitigation measures (MMs) designed to mitigate those impacts. Importantly, the DPEIS is explicit that BOEM is not requiring these measures at this time; rather, it is merely identifying and analyzing potential MMs that BOEM can, but may not necessarily, require as conditions of approval for future Construction and Operation Plans. This gives the public and the leaseholders themselves an opportunity to understand the kinds of mitigation measures that may be required in the future. BOEM is also explicit that this is not an exhaustive list and that additional mitigation measures may be required given future understanding of impacts.
So, how effective are the recommended MMs included in the DPEIS? In my opinion, based on the limited information we currently have to go off of, they’re pretty good. MM-4 and MM-8 would institute a 10-knot speed limit and require protected species observers on OSW-related vessels respectively, which would significantly reduce the risk of a vessel striking a marine mammal or other sea creature. MM-15 would require bird and bat monitoring, while MM-16 would require bird and bat deterrent devices on the turbines in order to reduce the risk of bird strikes. MM-12 goes a step further by potentially requiring a seasonal cut in wind turbine blade speed in order to protect bats and birds during migrations. You can read the 40 recommended mitigation measures in Appendix E of the DPEIS.
The flipside is that these mitigation measures aren’t required yet. My comments to the DPEIS, therefore, focus on identifying mitigation measures I believe are absolutely essential and explaining to BOEM why that is the case. The ones I mentioned above are some of the highest on that list. So, take a look at the mitigation measures in Appendix E and think about which ones are the most important to you. Is there a mitigation measure missing that you believe should be considered? Now is your chance to let BOEM know. Comments may be submitted until February 12th.