Saturday, May 29, 2021

Gray Whales threatened as Biden and Newsom push huge Pacific Coast wind farm developments

If you follow the news you learned that President Biden and Governor Newsom have successfully added planning for wind turbines to the Pacific Coast (see The Sacramento Bee headline clipping to the right).

Commercial offshore wind farms are proposed in a 399-square-mile area in Morro Bay along central California and another area off the coast of Humboldt in Northern California.

“This is a breakthrough that will allow the siting of offshore wind in the Pacific Ocean,” said White House climate adviser Gina McCarthy.

Governor Gavin Newsom called the proposal "historic" noting: “Developing offshore wind to produce clean, renewable energy could be a game changer to achieving California’s clean energy goals and addressing climate change — all while bolstering the economy and creating new jobs.”

Of course, The Sacramento Bee would include with its headline a photo of a wind turbine existing off the Pacific Coast of Japan. Only one problem exists - the Gray Whale migration route following the Pacific Coast from Alaska to Baja California, as can be seen in the drawing to the left which has appeared in these posts several times.

This blog was begun in 2007 when a serious proposal for wind farms to be constructed in areas off Mendocino County was offered. As can be seen at the bottom of this post, the proposal has been pushed several times since then but always died a natural death.

This time the proposal likely is not going to be withdrawn, perhaps not even successfully opposed. So let's take another look at the idea.

What is proposed this time? According to news articles the proposal includes sufficient wind turbines in Morro Bay and near Humboldt to generate enough electricity to power 1.6 million homes, which could make the California coast one of the largest generators of wind power in the world. In comparison, a new coastal Massachusetts wind farm could have up to 84 giant wind turbines while the California sites could hold more than 300 turbines, according to Newsom.

Is this a serious proposal? The New York Times reports:

    ENBW, a German electric utility that owns and operates four wind farms off the coast of Germany, intends to bid on leases to build a floating wind farm in Morro Bay, said the company’s spokesman, Damian Bednarz. The project, called Castle Wind, would consist of dozens of floating turbines, enough to power hundreds of thousands of homes, he said.
    ...The company has been working with the federal government and the state of California for the past five years in hopes of clearing the way for the Castle Wind project, Mr. Bednarz said.

“We’re totally against this." said Tom Hafer, president of the Morro Bay Commercial Fishermen’s Organization, expressing frustration. "We’re going to lose a whole bunch of fishing grounds. There will be cables in the water. We don’t know how the whales will react. There are a lot of unknowns. People don’t realize how massive this project will be.”

The problem is no serious review of available facts regarding the Eastern Pacific Gray Whale migratory route could lead to the conclusion that this proposal would not do serious harm. But nothing about that is of concern to the private sector nor to the federal or state governments. As the New York Times story explains:

    Offshore wind developers said that the coordinated federal government approach toward approving the wind farms, pushed directly by the president along with his top cabinet secretaries and the California governor, appears to have made a difference in the fate of wind farms in the Pacific.
    “Now there is a strong commitment at the top to making this happen. That’s the big breakthrough here,” said Dan Reicher, who served as assistant secretary at the Department of Energy in the Clinton administration and now is an adviser to Magellan Wind, which develops projects with offshore floating turbines.

As noted here previously, in the next 10 years we do not need to build or continue to research projects like this along the North American Pacific Coast. Just because some engineers and contractors can build something doesn't mean they should. And "alternative" in the term "alternative energy" should not mean let's knowingly cause harm to an "alternative" species other than humans.

We must consider the potential impacts on these residents with whom we share the Eastern Pacific Ocean...

...and the impacts on all the smaller species. It's complex. So we will begin with one of the more curious issues - who owns the ocean?

Tragedy of the Commons

"Tragedy of the Commons" is explained as follows by Wikipedia:

    In economic science, the tragedy of the commons is a situation in which individual users, who have open access to a resource unhampered by shared social structures or formal rules that govern access and use, act independently according to their own self-interest and, contrary to the common good of all users, cause depletion of the resource through their uncoordinated action.

A discussion of the subject must begin with the question: "Who owns the ocean?" Apparently, in the case of the United States, the Bureau of Ocean Energy Management (BOEM) plans to award contracts to the highest bidder intent on erecting electricity generating wind farms. Who or what is the BOEM, you might ask?

The first thing we need to clear up is that BOEM is not the National Oceanic and Atmospheric Administration (NOAA):

The BOEM is not even in the same department as NOAA. Again, let's refer to Wikipedia:

    The Bureau of Ocean Energy Management (BOEM) is an agency within the United States Department of the Interior, established in 2010 by Secretarial Order.
    The Outer Continental Shelf Lands Act (OCSLA) states: "...the outer Continental Shelf is a vital national resource reserve held by the Federal Government for the public, which should be made available for expeditious and orderly development, subject to environmental safeguards, in a manner which is consistent with the maintenance of competition and other national needs."
    BOEM and its sister agency, the Bureau of Safety and Environmental Enforcement are the agencies to which this responsibility is delegated. They exercise the oil, gas, and renewable energy-related management functions formerly under the purview of the Minerals Management Service (MMS). Specifically, BOEM activities involve resource evaluation, planning, and leasing.

Subsequent to the passage of the Federal Oil and Gas Royalty Management Act in 1982, the Secretary of the Interior designated the Minerals Management Service (MMS) as the administrative agency responsible for the mineral leasing of submerged OCS lands and for the supervision of offshore operations. It wasn't until 28 years later, in 2010, that the MMS was renamed the Bureau of Ocean Energy Management, Regulation and Enforcement which was divided into the Bureau of Safety and Environmental Enforcement (BSEE).

Again, the BOEM handles leasing within the 200 mile limit (it is more complicated than that, but the 200 mile limit is roughly what defines offshore lands). More specifically the BOEM is assigned "oil, gas, and renewable energy-related management functions."

In the third year of the Obama Administration the BOEM began the planning and implementation process to lease lands within the Continental Shelf to private companies. To get a feeling for what that the process means in the Biden Administration, you may want to read the February news story Traffic lane, habitat alternatives for South Fork offshore wind project.

Historically the fishing industry has been the beneficiary of the "Tragedy of the Commons" as, effectively armed with "rights", fishermen sailed to location they knew and took what they could catch until the area was fished out.

Plans for the Atlantic Outer Continental Shelf (OCS) have been given priority because the entire Pacific OCS falls within the Gray Whale migratory route. So at this time we can only learn from what is the situation on the East Coast as described last month in The Connecticut Examiner:

    The first major commercial windfarm in US waters is Vineyard Wind which potentially will encompass over 1,000 square nautical miles into which Denmark and its private investors plan to erect close to 200 six-hundred-foot-tall wind turbines each weighing over 300 tons. That geography represents a mass slightly larger than the entire size of Rhode Island.
    The BOEM regulations under which the wind farms will operate (construction and operations plans COP) recognizes that such marine construction will damage the environment, and the fisheries that operate in there—to some extent.
    But these waters already support multiple users regulated by the government, especially the fisheries. Tugboats and commercial traffic, the U. S. Coast Guard and U. S. Navy, commercial air traffic, marine scientific research done by universities, the governments, and fishing organizations.
    In college we would describe this as a cluster #@#$%^&*!
    These waters are further complicated by the Endangered Species Act attempting to stem the demise of right whales which annually spawn IN THIS CONSTRUCTION AREA.
    The federal government would protect the whales in this wind leased area by removing over 10,000 lobster traps and their buoy lines. But it would approve construction of the largest marine structure in the world here?
    In these commons the sheep are told to leave and not graze here. But the goats and cows can have at it at will.
    More than 3,000 miles of ocean bottom will have to be dug up to bury electric cables run among the towers and to the shore stations. These bottoms are sensitive habitat. And the cable industry experience with wind projects is that there will be breaks—expensive and complicated to repair—closing off large areas to all other legitimate established users.
    The five turbines in the test wind field off Block Island, failing to follow good engineering practice, are now faced with a $50 million plus repair bill to re-route cables to the island and separately to the mainland.
    The problem here is that no one has any ownership interest to protect. Worse, the federal government law requires the wind interests to secure a formal letter giving them permission to kill whales and sea turtles in the course of building the wind farms.

Offshore Oil and Gas Versus Wind

Many Californians do not know about existing offshore oil and gas wells

In the 1920's the Ellwood Oil Field was first developed off Goleta. Its claim to fame was being bombarded by the Japanese during WWII. The Wilmington Oil Field located off Los Angeles was first developed in the early 1930's. It is the third largest oil field in the United States in terms of cumulative oil production. Additional development followed.

Unfortunately for oil companies, the promise of expanding future oil production was spoiled by the 1969 Santa Barbara oil spill that resulted in the deaths of an estimated 3,500 sea birds as well as marine animals such as dolphins, elephant seals, and sea lions. The outrage resulted in legislation that forms the legal and regulatory framework for the modern environmental movement in the U.S. It's complicated, but it severely limited oil production off the California coast.

On the other hand, wind is not oil. And we have not yet had the equivalent to the Santa Barbara oil spill. So despite the failed engineering practices associated with the five test wind fields off Block Island, plus known past design failures associated with around 600 of Europe's installed offshore wind turbines such as dissolved grouting, massive political pressure exists to develop wind energy to deal with climate change.

After all, what could possibly go wrong? After all, this is not nuclear power as mentioned here in my February 25, 2012, post. And this isn't the Agu├žadoura Wave Park which opened in on September 23, 2008, but shut down in November due to mechanical problems, which was discussed in that post.

From the February 25, 2012 Post

Speaking of that post, remaining critical environmental impact issues deserve a reprint from that post for those who can stand a refresher:

As noted earlier, from our technocrats here in California we have the November 2008 study prepared for the California Energy Commission and the California Ocean Protection Council titled DEVELOPING WAVE ENERGY IN COASTAL CALIFORNIA: POTENTIAL SOCIO-ECONOMIC AND ENVIRONMENTAL EFFECTS which offers this thinking:

Gray Whale: Potential for Interaction: High

Gray whales are one of the most commonly sighted whales off California with approximately 18,000 individuals migrating or resident in nearshore waters. The entire northeastern Pacific population of gray whales may migrate through or reside within habitat slated for WEC/wave parks in California. The potential for interaction is high due to this extreme habitat overlap. Potential interactions include entanglement and subsurface collision potential with WEC and associated supports, increased vulnerability to predation, changes to prey availability, and foraging behavior (of resident whales). Gray whales were formally listed as "Endangered", but have been delisted. (pp. 138-139) Electromagnetic Field (EMF) Considerations

Electromagnetic fields (EMF) have been shown to affect a host of higher vertebrates (Kirschvink et al. 2001), though little is known about the effects of EMF on marine mammals. Some studies indicate dolphins, porpoises and whales respond to the magnetic portion of an electromagnetic field (Scottish Government 2007). Based on this information, the primary concern may be for the physiological effects of EMF and/or if the marine mammals occupy an area around wave energy converters (Fernie and Reynolds 2005). Further investigation is needed in this area. (p 130)

Benefits to California

In 2006, the California Legislature passed the California Global Warming Solutions Act (AB 32). Among other important requirements, this legislation requires the California Air Resources Board to adopt regulations such that greenhouse gases are reduced to 1990 levels by 2020. Wave energy could assist in reducing California’s greenhouse gas emissions by providing a renewable and reliable energy source. Other benefits to California include job creation and other forms of economic opportunity. Wave energy could meet a significant proportion of the state’s energy demand. While significant technological and economic issues remain, ecological issues, at this stage, appear manageable. (p. 5)
Let me summarize what it says for any Eastern North Pacific Gray Whales out there reading this.

Facts Presented. The Eastern North Pacific Gray Whale will most assuredly have problems with the mere physical presence of wave energy equipment and we don't know anything about the effects on whales of electromagnetic fields that affect a host of higher vertebrates, except that some studies indicate they respond to the magnetic portion of an electromagnetic field.

Conclusion Reached. Ecological issues appear manageable.

The report is not an environmental impact report either under federal law or CEQA. It obviously was written as requested by California officials to cheer on development of wave energy.

To be fair, the "Abstract" provided at the beginning reflects a "suitably cautious" disclaimer tone for humans:
Dramatic ecological, social, or economic effects are not clearly indicated by this study, but a strong case for caution is supported when developing wave energy conversion technology off the California coast. Impacts to human activities, wave exposure, benthic communities, fishes, birds and mammals are all virtually certain, but the impacts’ magnitudes and the cumulative effects remain difficult to anticipate.
From the point of view of Gray Whales, the use of the "get-out-of-jail free card" is disturbing:
Gray whales were formally listed as "Endangered", but have been delisted.
This card was played in the environmental documents of a permitted wave energy power plant in Oregon, sponsored in part by the Pacific Northwest Generating Cooperative (PNGC), a group of utility cooperatives located in Oregon, Idaho, Washington and Montana. It is the Reedsport OPT Wave Park project to be owned and operated by Reedsport OPT Wave Park, LLC., an "affiliate" of Ocean Power Technologies (OPT).

In the January 2010 REEDSPORT OPT WAVE PARK - FERC PROJECT NO. 12713 - APPLICATION FOR A MAJOR LICENSE (Vol IV, Appendix A pp 4, PDF pp. 8) we learn:
Gray Whale

The gray whale is a large baleen whale that is composed of an eastern and western stock (Figure 6). The eastern stock inhabits the Pacific Coast and was de-listed from federal protection in 1994. The western stock is found along the Korean coastline and remains classified as endangered.
And in the chart on the following page the reader is informed:
Species was delisted in 1994 and is making a marked recovery. Population is currently over 20,000 individuals.
On page Appendix A-11 (PDF page 15) the document states:
2.2 Cetaceans - ESA Listed

OPT has contacted NMFS and requested information on species in the project vicinity that are protected under the ESA, most recently in a letter dated October 11, 2007 and during various phone conversations and meetings. Federally listed threatened or endangered cetacean species that may occur in the project area are listed in Table 2.
The Gray Whale is conspicuously absent from the table. The NMFS is the National Marine Fisheries Service and the Gray Whale was delisted. From its web site (emphasis added):
NOAA's National Marine Fisheries Service is the federal agency, a division of the Department of Commerce, responsible for the stewardship of the nation's living marine resources and their habitat. NOAA's National Marine Fisheries Service is responsible for the management, conservation and protection of living marine resources within the United States' Exclusive Economic Zone (water three to 200 mile offshore). ...Under the Marine Mammal Protection Act and the Endangered Species Act, NOAA's National Marine Fisheries Service recovers protected marine species (i.e. whales, turtles) without unnecessarily impeding economic and recreational opportunities....
As I explained previously, the State of Oregon Department of Fish and Wildlife lists the Gray Whale as Endangered. Curiously, Volume II (pp. 9-4 & 5) of the project study assures us:
Other Wildlife

■ Oregon Department of Fish and Wildlife. 1993. Oregon wildlife diversity plan. Portland, Oregon. [Online]

The Oregon Fish and Wildlife Commission adopted the Oregon Wildlife Diversity Plan in 1993 and updated it in 1999. The plan established the goals, objectives, and strategies for the ODFW’s Wildlife Diversity (formerly Nongame) Program. The Diversity Plan includes a list of state-designated endangered, threatened, and sensitive species. State-listed species that may occur in the vicinity of the proposed project are discussed in Sections 5.C.3. and 5.C.4. Because the proposed Reedsport Project is not expected to adversely impact state-listed wildlife, OPT believes that the Reedsport Project is consistent with the Oregon Wildlife Diversity Plan.
Any hope I had that the State's listing is mentioned in the indicated Sections was initially dashed, When I checked Section 5.C.3. I first found the same exact language quoted above referring to the delisting by the U.S. Government including the table. But, on pp. 5-66 & 67 (PDF pp 139-140) we have a long discussion of the Gray Whale including this paragraph:
Gray whales are a success story for recovery of endangered species with current populations estimated to be over 20,000 whales (Rugh et al. 1999; NOAA 2007d). The population is thought to be near pre-exploitation population levels (NMFS 2002). Even though gray whales are not federally listed as endangered, they are listed as endangered on Oregon’s state threatened and endangered species list.
This language uses the dismissive "get-out-of-jail free card" by noting the delisting by the U.S. Government in a State that lists the species as Endangered.

Nonetheless, the project documentation includes a Study Plan (beginning on Volume II Page Appendix C-26 PDF p. 477) that does include the Gray Whale. What we need to keep in mind is the wave energy power plant involved is described as follows (Volume II p. Appendix C-1 PDF p. 452):
The project would consist of deployment and operation of 10 PowerBuoy® wave energy converters (WEC) having a total capacity of 1.5 megawatts (MW), to be located approximately 2.5 miles (4 kilometers) off the coast of Gardiner in Douglas County, Oregon (Figure 1). The ½-mile-by-½-mile (0.25 square miles) project area represents the area within which the 10-PowerBuoy array would be deployed. The actual footprint of the constructed array is expected to be only about 1,000 feet by 1,300 feet (300 meters by 400 meters) or approximately 30 acres (0.05 square miles), excluding the navigation safety zone.

This 0.25 square mile 1.5 megawatt wave energy power plant must be considered in the context of the ambitious California plan discussed above that anticipates allocating 160 square miles to generate eight gigawatts from commercial projects each with a generating capacity of 100 to 150 megawatts.

Given the small size of the Oregon project, the study results will be of limited benefit to FERC and California agencies. And the study does not anticipate evaluating the effects of electromagnetic fields.

Nonetheless, this project represents the best one could hope for as the Marine Mammal Institute of Oregon State University was funded by the Oregon Wave Energy Trust to conduct an ongoing study. The problem is that there is an Oregon Wave Energy Trust which is primarily an advocate for the use of wave energy.

Hopefully, the above reprint will assist those seeking to oppose the new proposal.

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