CFAT comments on the Programmatic Environmental Impact Declaration (PEIS) (PEIS) of California Offshore – What

Of CFACT

CFACT comments on the Programmatic Environmental Impact Declaration (PEIS) of California Offshore (PEIS)

By Craig Rucker, president

CFACT

https://www.cfact.org

Sent to https://www.regulans.gov/document/boem-2023-0061-0189

February 12, 2025

General description of our concerns

Boem is taking comments on a draft of the Programmatic Environmental Impact Declaration (PEIS) for its five floating wind leases on the Coast of California. This is the second wind on the high seas of Boem. The first was for a set of leases in New York that presented fixed background turbines. This is the first PEI for floating wind turbines that are very different from the fixed turbines that are built along the Atlantic coast.

The floating wind remains an immature technology with a large number of proposed designs, none of which has been tested at the scale of commercial public services. There are only a handful of small demonstration scale projects in the world.

There are at least two useful things about this peis. First it is a very good tutorial on the floating wind with an approach in the case of California. This is Appendix A, made by the National Renewable Energy Laboratory. An series of design options, including the most popular that have been demonstrated, the float Spar. The wide variety of options showing the immaturity of technology.

Second, the PEIS includes an encyclopedic discussion of numerous potential adverse impacts of a generic floating wind project. These impacts are limited to what is contemplated by each of the five leases, so when they combine for the five leases, it is clear that this program will be environmentally destructive. These adverse impacts cannot be mitigated, so the right decision is that the program should not proceed. The non -action alternative is the right choice.

Here is only a brief list of some of the main defects in the PEIS

1. With much, the greatest defect is that there is no accumulated evaluation of multiple lease impact. The objective of a PEIS is to make such an evaluation for the entire program. The cumulative impact can be much greater than the sum of the impacts of individual projects, especially when two or more projects are closely grouped as in this case. Therefore, simply listing the impacts of the individual project is completely inappropriate.

2. In many cases, an adverse impact is simply mentioned without evaluation of potential damage. This is supposed to be an impact assessment not only an impact list.

3. The systematic harassment of large amounts of endangered species and protected from whales and other animals is certain that it happens, but it is not discussed. In fact, the term “harassment” only occurs twice throughout the main report. Death due to noise harassment that causes deadly behavior is one of the main adverse wind impacts.

4. In addition, floating wind introduces an important form of non -acoustic harassment. This is the potentially 3D network thousands of mooring cables, each of which could be of the order of a long mile. We are talking about hundreds of square miles of deep ocean literally full of cable networks. Harassment is defined by the Law on the Protection of Marine Mammals as a change in behavior by a protected animal and these monstrous networks will certainly do it. This continuous harassment on a large scale should be carefully evaluated.

5. The PEIS briefly mentions the threat of “secondary entanglement” in the networks, lines and other debris that are trapped in the cables over time. The possible adverse effects of this deadly accumulation should be evaluated in detail.

6. Finally, there is an extensive economy section but the cost is not mentioned. The development of these five leases will probably cost taxpayers and taxpayers tens of billions of dollars, possibly hundreds of billions. The entire program should cost more than one billion dollars, but these amazing sums are never quantified. Employment creation is in detail as a benefit when work is a cost. The total cost must be estimated.

It is clear that this PEIS is unfortunately inappropriate. In fact, it specifically avoids those problems that justify the cancellation of the program. The threat of cumulative impact is treated more detail below.

The entire wind energy program on the high Mar West must be evaluated

A new federal report shows that these five leases are small compared to the programmatic programmatic gap created by the Federal Action Plan for wind development on the coast of the West Coast. To start with the full program of California, it is huge compared to the miserable five leases covered by the so -called pei in California. The this PEIS document would be called the starting EIS kit better. In addition, there is a lot of development of Oregon and Washington.

As noted above, the PEIS document does not address the cumulative impact of these five leases; It only analyzes the generic impact of a lease. But what is really missing in action is an environmental impact assessment for the entire west coast program.

The new report has the long title: “An action plan for the development of wind transmission in the high seas in the region of the west coast of the United States” (all limits of the original). The Action Plan is a conceptual design for the transmission of the offshore generation, but to make that design you must know where the generation is, which is included with considerable detail.

Instead of the only five leases considered in this draft of PEIS, the action plan includes approximately one hundred leases by 2035. These generally occur in groups of 5 to 20 leases. In addition, while the total generation capacity for 2035 is 15,000 MW, this grows to 33,000 MW massive in 2050.

Each lease contains numerous huge floating turbines, each anchored at the bottom of the sea thousands of feet under multiple mooring lines. So, the environmental impact of each group is potentially huge.

Worse, a series of these groups basically cover the coast, especially in northern California and southern Oregon. Migratory species can be found and negatively affected by all this series.

The list of endangered species or protected that is threatened is quite long. As noted above these massive 3D cable sets, there is a new form of harassment under the Marine Mammal Protection Law. There are also in danger of extinction, giant rays, etc., in danger.

Peis Appendix says that a single turbine float may require up to 12 mooring lines to keep it stable and instead in a heavy climate. Assuming that 15 MW turbines with a dozen lines, each of the 15,000 MW, would have 12,000 mooring lines. The case of 33,000 MW would have an amazing amount of 26,400 mooring lines, many more than 4,000 feet long.

We are talking about thousands of square miles of deep ocean literally full of cable networks. Harassment is defined by the Law on the Protection of Marine Mammals as a change in behavior by a protected animal and these monstrous networks will certainly do it. This continuous harassment on a large scale should be carefully evaluated.

The PEIS also describes the threat of “secondary tangle” in the networks, lines and other debris that are trapped in these cables over time. The possible adverse effects of this deadly accumulation should be evaluated in detail before the projects are approved on the high seas. Keep in mind that this threat accumulates over time, during the entire life cycle of a project.

Limitation harassment decreases the adverse impact of this wind development in the high seas

The clear solution to these mooring line threats is to severely limit the number of harassment authorizations. With these very limited authorizations, very few wind projects can be built on the high seas. Nor should they be, since they are destructive to the environment. Each project requires a large number of authorizations so drastically that it reduces its number drastically reduces the number of wind projects on the high seas.

The easiest way to do so is to limit the total number of wind authorizations that will be issued throughout the program for a given exposed population. This is analogous to limiting the emission of hazardous pollutants. You could even have a capitalization and commerce program where developers offer authorizations as they now offer for leases. The 1990 capitalization and trade program for sulfur dioxide emissions of the energy plant is an obvious analogue.

If cumulative harassment would be limited to saying that 10% of the exposed population of each threatened species would severely limit wind development.

In summary, the so -called Programmatic Environmental impact declaration of California is none of that. The high seas wind program should be evaluated for the entire west coast before any construction project is approved. This required evaluation in action.

According to this evaluation, cumulative impacts must be minimized. Finishing authorized harassment of each threatened species can be the best way to avoid destructive impacts.

Respectfully sent,

Craig Rucker

President

CFACT

Washington, DC