Sacrifice Deserts for “Green” Energy?

Sacrifice Deserts for “Green” Energy?

Editor’s note: Contrary to what mainstream environmental organizations assert, so-called “renewable” energy is NOT a solution to the ecological crisis we are facing. It would require a tremendous amount of energy to mine materials; transport and transform them through industrial processes like smelting; turn them into solar panels, wind turbines, batteries, vehicles, infrastructure, and industrial machinery plus installation and maintenance. This is all done using the same systems of power which is currently used for conventional fossil fuels. The resulting emissions from these process will only add to the business as usual emissions. While the wind and sun may be “renewable,” the turbines, solar panels, the raw materials that go into making them, and the lands and oceans they impact certainly are not. They require tons of carbon emissions to produce so they are not carbon free and not green. Calling them “green” is greenwashing.

The proposed mass adoption of “renewable” energy on a hitherto undreamed of scale has made the issue of energy (power) density extremely important . In its simplest terms, power density can be understood as: ‘how big does my power station have to be, in order to generate the power I want?’ The most useful metric is the land (or sea) area that will be used up. Here, we encounter the most easily understood, and the most insoluble of “renewable” energy’s problems. Compared to fossil fuel, it’s power density is very very low. Thus, they require larger areas of land to produce. This land is someone’s home, someone’s sacred site, someone’s source of food, water and air. We just don’t hear about them, because they are the wild beings, the nonhumans treated as disposables by civilization. The humans that inhabit the land are indigenous peoples who are yet to be fully assimilated into the industrial culture. Here, we can see colonialism and extractive economics come together.

The following article describes the plans for different “renewable” energy plants in California and Nevada. The article also demonstrates how the plans for big “renewables” actively reinforce the existing structures of power, with the energy companies lobbying to disincentivize decentralized and community-controlled rooftop solars in favor of big projects that are destroying the neighbors.


By Joshua Frank/Counterpunch

There is a lot of hot air blowing around the West these days, blustery claims that geothermal, wind, massive solar installations, nuclear power, along with a smattering of hydroelectric dams, will help the country achieve a much-needed reduction in climate-altering emissions. Certainly, there is money to be made off of this energy transition, and on paper, a few do appear to be far less damaging than coal-fired power plants and natural gas operations.

That’s if, of course, you ignore the toll these energy ventures have on the lands and people they exploit. Right now, not far from where I live in Southern California, solar companies are gobbling up public and private lands for future solar and wind projects.

Across the border in Nevada, desert is under threat of being developed in the name of fighting climate change. In the rich and biodiverse Dixie Valley, located in the middle of sacred Shoshone and Paiute lands, a massive geothermal project called the Dixie Meadows Geothermal Development Project faced a fierce legal challenge this past year. Geothermal, like hydroelectric dams, is often cited as a renewable energy source, since the technology harnesses heat from the earth to produce electricity, which in theory (as long as it doesn’t stop raining, surprise!), is endless.

Even so, large geothermal plants consume a lot of land and spit out a lot of water. The Dixie Meadows project, which was proposed in Nevada, was one such “green” energy plan that, if built, would suck up over 40,000 thousand acre-feet of water every single year, the result of which would be devasting. Dixie’s delicate wetlands habitat, unique to this stretch of the Great Basin, is home to the imperiled black-freckled Dixie Valley toad, and even a slight alteration of surface water conditions could spell extinction for this rare little toad. Birds too use Dixie’s natural spring water as migratory stopovers. Dixie Meadows is a literal oasis in the desert and has been for tens of thousands of years.

“The United States has repeatedly promised to honor and protect indigenous sacred sites, but then the BLM approved a major construction project nearly on top of our most sacred hot springs. It just feels like more empty words,” said Fallon Paiute-Shoshone Tribal Chairwoman Cathi Tuni following the announcement of the Dixie Meadows project. “This location has long been recognized as being of vital significance to the Tribe. There are geothermal plants elsewhere in Dixie Valley and the Great Basin that we have not opposed, but construction of this plant would build industrial power plants right next to a sacred place of healing and reflection, and risks damaging the water in the springs forever. We have a duty to protect the hot springs and its surroundings, and we will do so.”

On December 16, 2021, The Fallon Paiute-Shoshone Tribe and the Center of Biological Diversity (Center) sued the BLM over its approval of the Dixie Meadows geothermal project, and in early August were successful in stopping it from moving forward.

“I’m thrilled that yet again the bulldozers are grinding to a halt as a result of our legal actions,” said Patrick Donnelly, Great Basin director at the Center. “Nearly every scientist who has evaluated this project agrees that it puts the Dixie Valley toad in the crosshairs of extinction. This agreement gives the toad a fighting shot.”

***

About 270 miles south of Dixie Meadows, another “green” energy plan is in the works near the remote Searchlight, Nevada. The Kulning Wind Project, proposed by Eolus Vind AB, a Swedish power developer, is not unlike other wind projects that were halted in 2017 and 2018 after an outcry from local Tribes and conservationists. Kulning, like the prospects that were shot down, is massive and would include 68 wind turbines spanning 9,300 acres of federal lands on the site of the proposed Avi Kwa Ame (Ah-VEE kwa-meh) National Monument. Like Dixie Meadows, Kulning would greatly impact local wildlife.

“[The] development would likely undermine the use of the region by bighorn sheep and would introduce an unnecessary wildfire risk, threatening Wee Thump and South McCullough wildernesses, among many other concerns,” says Paul Selberg, director of Nevada Conservation League. “Decisions on where to develop renewable energy must be evaluated critically and placed in areas that are appropriate.”

The real question is; are expansive energy projects, be they fossil fuels or “green”, ever really “appropriate”? Indigenous communities and conservationists are wary.

The land outside Searchlight where these huge twirling wings are to be erected is considered a sacred “place of creation” to 12 local tribes, including the Havasupai, Hualapai, Kumeyaay, Maricopa, Mojave, Pai Pai, Quechan, and Yavapai. Opponents of the development, led by a broad coalition of tribes, point out that this stretch of the Mojave is some of the most pristine, in-tact wilderness in the Southwest.

Joshua trees (known as sovarampi to the Southern Paiute) in this area, which make up the largest Joshua forest in Nevada, will be destroyed if the project moves forward. These distinctive, twisted trees are already facing a bleak future in the West. Mojave’s high desert is becoming even hotter and drier than normal, dropping nearly 2 inches from its average of just over 4.5 inches of annual rainfall just a decade ago. The result: younger Joshua trees, which grow at a snail’s pace of 3 inches per year, are perishing before they reach a foot in height. Their vanishing is an indicator that these peculiar trees will not be replenished once they grow old and die, and they are dying at a startling rate.

While it has not received as much attention as Bears Ears or Gold Butte, Avi Kwa Ame National Monument is equally important as an ecological and cultural site, which would span 450,000 acres, protecting the delicate landscape from energy developers (to support the proposed monument, you can sign a petition here).

At the center of this onslaught of development is California’s quest to end the use of fossil fuels. Most of the energy in the state, one of the largest energy consumers in the country, is generated from utility-scale wind and solar, which, as of 2016, has required over 400,000 square kilometers of land to produce. This development, because it is billed as “green” energy, has received little scrutiny from the broader environmental movement. As a result, studies on the effects on biodiversity and threatened species, like the Desert Tortoise, are virtually non-existent.

***

In Northern Nevada, a similar fight is raging over Thacker Pass, where a proposed mine would produce upwards of 80,000 tons of lithium per year, a mineral that is crucial for most electric car batteries. Lithium Nevada, the company spearheading the Thacker project, is facing strong pushback from activists and members of Fort McDermitt Paiute and Shoshone, among others.

“Places like Thacker Pass are what gets sacrificed to create that so-called clean energy,” says author and activist Max Wilbert. “It is easy to say the sacrifice is justifiable if you do not live here.”

Indigenous communities are equally upset at the plan.

“Annihilating old-growth sagebrush, Indigenous peoples’ medicines, food, and ceremonial grounds for electric vehicles isn’t very climate conscious,” said Arlan Melendez, the chair of the Reno-Sparks Indian Colony.

Opposition to the lithium mine has invigorated a new, vibrant protest movement in Nevada, led by Indigenous activists that see these developments for what they are: a continuation of settler-colonialism, an onslaught fully supported by the Democrats and the Biden Administration. In the case of EVs, Biden’s 2021 American Jobs Plan earmarked $174 billion to promote electric vehicles. The Thacker mine, claims Lithium Nevada, is central to those efforts.

There are also alternatives to lithium like seawater, sodium, and glass batteries. While none are environmentally benign, the impacts do vary. Maria Helena Braga a scientist at the University of Porto in Portugal, who has been researching glass battery technology, believes glass has the brightest future. “It’s the most eco-friendly cell you can find,” claims Braga.

Recently, researchers at the University of California San Diego’s Center for Interdisciplinary Environmental Justice disagreed that we need to mine our way out of climate change, stating that in order to curb greenhouse gas emissions we would have to decrease our output by 80% over the next thirty years. EVs, they claim, would only reduce greenhouse gases by 6%. In other words, the destruction these mines cause is not worth such little benefit. A larger, far more significant transition is needed.

***

In addition to technological advances (and the need to consume less), the energy grid itself must be revamped, from centralized sources of energy like coal or natural gas to a decentralized network of producers, where existing homes and commercial buildings are required to install solar on their rooftops. Big utilities, like PG&E in California, which has been responsible for causing over 1,500 fires and hundreds of deaths in the state, are not pleased with the push for community-controlled, decentralized power. In fact, in an effort to disincentivize rooftop solar, California regulators, after heavy lobbying from energy companies, are currently pushing to slash residential solar incentives, making the transition even more difficult, while supporting large desert developments in the process.

Hundreds of plans for large renewable energy projects are currently in the works in California, New Mexico, and Nevada, and one by one they are set to destroy vast stretches of desert habitat. In 2015, researchers from UC Berkeley and UC Riverside looked at 161 proposed and operational solar plants. What they found was startling. Only 10-15 percent of the projects in California were located in areas that would have little impact on their surroundings. In other words, 85% of these would harm the environments where they’re located.

“We would hope that if a developer was on the ground and saw that, oh, this is a really important area for migratory birds, maybe we should look at that Walmart commercial roof down the road, and collaborate with them rather than putting it here,” said the study’s lead author Rebecca Hernandez, a scientist at UC Berkeley.

While the push for decentralizing is paramount, some argue that locating green energy installations in already impacted areas, like brownfields, is a good alternative. Yet this is rarely the most profitable choice. At the heart of the problem is that public lands in the desert west are inexpensive. The Bureau of Land Management leases huge parcels of these lands for dirt cheap, which in turn incentivizes large-scale wind and solar projects — projects that support Biden’s climate plan, where companies like PG&E will continue to control the grid and small-scale projects will be difficult and expensive to build.

If the goal of clean, green energy is to offset the wrath of climate catastrophe, yet damages sensitive habitats in the process, are these projects even worthwhile? That’s a question environmentalists and others must grapple with. Certainly, they are good for profit margins, but the evidence is mounting that they are also devastating to desert ecology.


JOSHUA FRANK is the managing editor of CounterPunch. He is the author of the forthcoming book, Atomic Days: The Untold Story of the Most Toxic Place in America, published by Haymarket Books. He can be reached at joshua@counterpunch.org. You can troll him on Twitter @joshua__frank.

Featured image by Antonio Garcia via Unsplash

New Lawsuit Against Offshore Wind

New Lawsuit Against Offshore Wind

FOR IMMEDIATE RELEASE

Organization: Save Long Beach Island, Inc. (Save LBI)

Contact: Bob Stern, Ph.D., President
Email: info@savelbi.org
Phone: 917-952-5016

Contact: Attorney – Thomas Stavola, Jr., Esq.                                                       Email: tstavolajr@stavolalaw.com
Phone: 732-539-7244

January 13, 2025

Save LBI Sues U.S. Agencies and Atlantic Shores Offshore Wind, Challenging Federal Approvals Greenlighting Marine Ecosystem Devastation, Including Risks to Critically Endangered Whales

LONG BEACH ISLAND (LBI), NEW JERSEY, January 13, 2025 – Save LBI, an organization that has been actively litigating issues surrounding marine mammal, human health, economic and other impacts connected to offshore wind industrialization off New Jersey since 2022, has filed suit against the U.S. Department of Commerce, National Marine Fisheries Service, Bureau of Ocean Energy Management, U.S. Department of Interior, and the Atlantic Shores Offshore Wind project for violations of a number of federal environmental statutes.

“This lawsuit serves as the first of its kind, launching a wide-ranging challenge against Atlantic Shores’ federal approvals, based on violations of environmental statutes such as the National Environmental Policy Act, the Endangered Species Act, the Marine Mammal Protection Act, the Outer Continental Shelf Lands Act, the Coastal Zone Management Act, and the Clean Air Act,” said Thomas Stavola, Jr., Esq., the attorney representing Save LBI. “We believe we have organized a compelling case that will demonstrate that these federal agencies were derelict in their respective duties to take critical information into account, and moreover, made arbitrary assumptions that entirely failed to disclose and consider the injurious impacts of the Atlantic Shores South project.”

 

Bob Stern, Ph.D., the primary plaintiff and president of Save LBI, further explained, “For example, “the agencies assume, incorrectly, that no North Atlantic right whales will suffer injury or death as a result of the Atlantic Shores South project. The evidence contradicts that assumption. In fact, our review and independent mathematical analyses shows a systemic underestimation of impact, and clearly indicate that the noise caused by pile driving, and, soon after, perpetual operational noise, will injure and kill high numbers of marine mammals — and, yes, injure and kill a number of North Atlantic right whales, a critically endangered animal that cannot afford to suffer any deaths given their numbers are now less than 340 total.”

The lawsuit ultimately seeks to have all federal approvals rescinded and the Atlantic Shores South project halted — stopping construction and preventing devastation to marine mammal life in the NJ/NY Bight regional waters. Eight other co-plaintiffs have joined Save LBI in this action, many of whom will be severely economically impacted due to the egregious harm to the marine ecosystem and the aesthetic, recreational blight imposed on the Jersey Shore via the circa 200 1,000-foot-plus high monstrosities slated to be constructed starting less than 9 miles east of Long Beach Island.

These inexcusable damages by the Atlantic Shores South project are not limited to marine mammal devastation, but also include significant impacts to tourism, shore economies, statewide energy bills, national defense, vessel navigation, and home values — all of which have been swept under the rug by much of the mainstream media, many elected officials, the Atlantic Shores company, and the federal agencies in their inexplicable haste to approve a project still in search of a clear purpose and need.

“We hope this lawsuit will serve as the vehicle to finally illuminate the damage being wrought here and to impose significant pressure on Atlantic Shores to withdraw, as their obfuscation of the project’s true effects are indefensible. The agencies simply cannot objectively argue that their approvals were made in accordance with the best science,” concluded Bob Stern.

This lawsuit was filed in federal court in the United States for the District of New Jersey on January 10, 2025.

About Save LBI

Save Long Beach Island (Save LBI) is an organization of citizens and businesses on and off the Island working together to protect the ocean and Long Beach Island and neighboring communities from the destructive impact of the Atlantic Shores project and potentially other offshore wind projects. As a not-for-profit, non-partisan entity, we do not endorse any political candidates but vigorously pursue policies and actions that protect the Island and New Jersey communities. The organization is led by Beach Haven resident Bob Stern, a Ph.D. engineer with

experience in environmental law who previously managed the U.S. Department of Energy’s office overseeing environment protection related to energy programs and projects.

Save LBI is fighting to stop the ill-conceived Atlantic Shores projects. Please visit SaveLBI.org to join the fight and consider making a donation.


 

ACK for Whales To File New Suits to Stop Environment-Destroying New England Wind Offshore Turbine Project
Grassroots Group Has sent Notices to Federal Government Warning of Litigation Because Government Broke Multiple Federal Laws
“We’re not going to stop fighting for the environment.”

NANTUCKET, MA, January 13, 2025 – ACK for Whales, the Nantucket grassroots group (formally known as Nantucket Residents Against Turbines) fighting to protect the environment from the devastation posed by New England Wind’s giant offshore wind project, said today that it has filed two Notices of Intent to sue the Department of Interior and other federal agencies for violating federal laws intended to protect the environment and endangered species.

The announcement comes as the group revealed the United States Supreme Court declined on Monday to hear the group’s petition for certiorari from lower court decisions on a different legal issue and involving a different project.

The new litigation is broader in scope than the suit previously filed against Vineyard Wind and seeks to halt and preclude construction by New England Wind of offshore wind turbines.

“New England Wind is an existential threat to our environment and while we are disappointed by the Court’s decision to not hear our appeal, we’re not going to stop fighting for the environment,” ACK for Whales President Vallorie Oliver said.

The Notices of Intent were sent Monday to the Departments of the Interior and Commerce, the Army Corps of Engineers, the Environmental Protection Agency, the Bureau of Ocean Energy Management (BOEM), and the National Oceanic and Atmospheric Administration and informed the federal agencies that decisions made to allow New England Wind’s project to build turbines off Nantucket and Martha’s Vineyard violate the Endangered Species, Marine Mammal Protection, National Historic Preservation, and Outer Continental Shelf Land Acts.

The letters warn that if the agencies do not reverse their approvals, ACK for Whales will proceed with its suits when the 60 day Notice period expires to prevent “substantial” harm to biological resources, including the endangered North Atlantic Right Whale, interference with economic activities in the high seas and territorial seas, including tourism, commercial fishing, and whale watching.

“The government continues to mislead the people of Massachusetts,” Oliver said, “making their usual false claims about offshore wind. The state’s press release claimed building these whale- killing monstrosities will ‘reduce the state’s carbon emissions by the equivalent of taking one million gas-powered cars off the road. Collectively, these projects will create thousands of jobs and generate billions of economic activity.’

“The State made the same false claims about Vineyard Wind and since that project was begun, BOEM has admitted building offshore wind will have no meaningful impact on reducing climate change, Vineyard Wind admits it’s not keeping track of the jobs it allegedly creates in Massachusetts, and its CEO admits that our power bills are going up.

“We can’t figure out why the government keeps giving away the store to foreign energy companies like Avangrid,” Oliver said. “We’re a non-partisan organization, we don’t do politics, but we hope Mr. Trump keeps his word and ends this madness on Day One of his Administration,” Oliver said.

About ACK for Whales

ACK for Whales is a group of Nantucket community members who are concerned about the negative impacts of offshore wind development off the south shores of our beloved Island. The Massachusetts/Rhode Island wind area is bigger than the state of Rhode Island and will ultimately be occupied by 2,400 turbines, each taller than the John Hancock building in Boston, connected by thousands of miles of high voltage cables. There are many unanswered questions, and the permitting of these massive utility projects has happened largely out of the public eye. We provide a community group of neighbors and friends, who all love the same place.

Contacts

Media: Mark Herr
203-517-8957

Mark@MarkHerrCommunications.net

Photo by Chloe Christine on Unsplash

8 Steps Used By Offshore Wind to Create Agreements

8 Steps Used By Offshore Wind to Create Agreements

Editor’s note: While this article could have been written about any extractive industry, it has focused on offshore wind turbine farms. These destructive projects should require at least as much scrutiny as an offshore oil rig, but they are not. Because in the name of climate mitigation, they are rushed through without consideration for the damage they will cause, or even their effectiveness in serving this purpose and need for existence. Which is usually just based only on government mandates. And this is all done in the name of Big Environmentalism. DGR does not believe the Bright Green Lies of mainstream environmental NGOs.


By Carl van Warmerdam

People who believe that offshore wind turbines can help solve climate change are misinformed. Because the facts are that they will not. Even the companies building them make no such claim. And the truth, based on facts, will always trump belief. I am not a climate denier, but you don’t have to be a climate denier to know that these things are bad and are doomed to failure. And you also don’t have to be linked to the fossil fuel industry, the same people that knew they were causing global warming and therefore threatening the very existence of the planet. Yet, in pursuit of profit, fossil fuel executives not only refused to publicly acknowledge what they had learned but, year after year, lied about the existential threat that climate change posed for our planet. “Renewable” energy projects should require just as must scrutiny from regulators and environmentalists as fossil fuel projects.

Truth be told, most rebuildable “renewable” energy extractive companies are also liars, and have ties to fossil fuel companies. In reality what is really going on is a boondoggle, that you won’t hear about in mainstream corporate media because they only give disinformation. After years of rebuildable energy – solar and wind infrastructure – the world used more fossil fuels in 2023 than it did in 2022, as it did the year before that and the year before that. We are in fact using more fossil fuel than ever before. From 61 thousand terawatts-hours of primary energy consumption in 1973, which was the year of the OPEC oil embargo, when governments began to massively support research and development of large wind turbines and solar panels, to 137 thousand today. This is well over twice as much. In that same period, emissions grew from 17 billion metric tons of CO2 emissions to the 37 billion metric tons today. A 20 billion metric ton increase in the last 50 years. And after all of that, 80 percent of our energy use still comes from fossil fuels. The percent of US energy use from electricity has remained the same, about 20 percent. Of that, wind turbines account for 7 percent and solar energy provides 2 percent of total US electricity used. So the dream of a 100 percent electric power supply is just that, a dream.

 Why? Because these energy intense extractive technologies require massive amounts of fossil fuels to produce and those emissions are adding onto what is already being used, not reducing it (Jevons paradox). Thus spewing more planet-heating carbon dioxide into the atmosphere at a time when greenhouse gas emissions world wide must nosedive to stop extreme weather from growing more unpredictable and violent. The only reason CO2 emission may drop in countries installing rebuildable extractive energy and electric vehicles is because they have outsourced the mining and manufacture of these machines to other countries, thus increasing the CO2 emissions in those countries. LNG has replaced dirty coal to run power plants.  Add on to all of this, easy access resources are gone. So the Energy Return On Investment (EROI) has gone down sharply in that time. Instead of Jeb shooting for some food, we have to use fracking and offshore drilling, mountaintop removal and deep sea mining. In the foreseeable future, the energy needed to produce our energy needs could approach unsustainable levels, a phenomenon called “energy cannibalism.”

If this continues, the so called “green” energy transition will in fact be an energy correction, complements of Mother Nature, bigger and more storms, flooding, fire, drought and biodiversity collapse. These are no longer natural disasters, instead these more powerful weather events are man made.

Nature is not more complicated than you think, it is more complicated than you CAN think” ~Frank Edwin Egler

Rebuildable extractive energy capturing machines are not clean except through greenwashing and are only making our predicament worse. The trillions in government subsidies given to this sector only makes the rich richer. The Inflation Reduction Act (IRA) should more appropriately be called the 4th Industrial Revolution Act. This is government redistribution of wealth from the working class to offshore transnational state sponsored corporations and the wealthy financial class, which are also principally owned by fossil fuel companies. Ultimately any money that is offered by them as payouts for grants, agreements, promotion or mitigation will come from the utility ratepayer. This is a scam that is not financially feasible without trillions in government subsidies. This is what their balance sheet looks like. What is done to the natural environment is even worse.  

Wildlife and wind turbines are an uncomfortable mix. Rotating turbine blades can make short work of anyone or anything unlucky enough to collide with them, but direct mortality is only part of the story. Having reviewed the available evidence from around the world, biologists in Finland have found that 63 percent of bird species, 72 percent of bats and 67 percent of terrestrial mammals are displaced from areas where turbines are installed. The same holds true for offshore wind farms, to include fish and marine mammals. Wind turbines are an invasive species to functioning ecosystems that took millions of years to create. The building process is a war zone. The noise and devastation are a disaster to fragile ecosystem habitats. Consider how you would feel if these massive monsters were put up next to your house in your town. The oceans, from which we came, are the lungs of the planet. Life can not exist if the delicate balance is disrupted. These projects are doomed to failure in more ways than one.

True resilience and sustainability comes by thinking globally and acting locally. The land base that people live on should be able to, on its own, continually feed, clothe and house the people who live on it. It makes no sense to destroy the sustainable food provided by the ocean in order to keep the lights on. It is preferable to eat in the dark than to starve in the light. Also know that fish farms are in the same league as wind farms. It is an enclosure of the commons for corporate control of our food supply, what they call “The Blue Economy”.    

How do we know that offshore wind will be a “pain” now and into the future for fishing, tourism, cultural heritage, beauty, integrity, stability, sustainability, ecological balance and quality of life? Millions of dollars are offered up to mitigate (bribe) it. Money would better be spent to mitigate the already abandon mines, fossil fuel wells and habitat degradation. This is where our good paying jobs should be working, to protect the planet. Life on the planet can be saved, a modern industrial lifestyle cannot.

How to Convince a Community to Destroy Their Future 

 

Step 1. Create an effective advertising campaign for Your Destructive Offshore Wind Project

Use a name that has a certain historical, cultural, or environmental value for the communities. Change the name from Pilgrim and Mayflower(tone deaf) to South Coast Wind or Vineyard Wind(more like Graveyard). Call it “clean”, “green”, “renewable” energy that is the solution to climate change and save our lifestyle. With the right branding, people will drink any poison, pinwheels for everyone.

Step 2. Get the Local Government on Your Side

Pay off the local politicians to agree and hand out licenses. Tell them there is nothing they can do to stop it, so they should just get the best Good Neighbor Host Agreement possible or get nothing.

Step 3. Lobby as Much as Possible to Bend the Law in Favor Offshore Wind

Create legal loopholes and tax credits for corporations, behind closed doors. Speed up the “permit” your destruction process. Buy-off federal and state politicians and corporate capture regulatory agencies. Nobody wants these in their backyard, let’s just put them out to sea. 

Step 4. Presents! Buy Off Public Opinion

Build a new school, library(Carnegie) or sewer system. Or just offer money as compensation to do with as you wish. The major ENGOs have entered into agreement with offshore wind: Natural Resources Defense Council, National Wildlife Federation, and Conservation Law Foundation and taken money; Audubon Society, The Nature Conservancy, World Wildlife Fund, Environmental League of Mass., Sierra Club, etc. along with aquariums, universities and the media. 

Step 5. Offer a Compromise

Let us destroy this land/sea here and we will protect some other land/sea. Or agree with us and we will let you have a say in how the destruction will occur. This project has to be done to stop climate change, we have to destroy the planet to save it. There must be sacrifice zones. Sorry that your home is being destroyed but don’t be a NIMBY(Not In My Backyard). Actually when respondents of national surveys begin to think about ideas of what rebuildable energy entails, such as offshore wind, their support often diminishes. There will be painful trade-offs, trying to preserve comfortable lives. Most of that pain will come from other species. But if we acknowledge that our modern industrial lifestyle is causing the end of life on the planet, we must say NOPE(Not On Planet Earth).

Step 6. Threats Are Effective Deterrents

If you file a law suit against this project, we will file a lawsuit against you, a SLAPP(Strategic Lawsuit Against Public Participation). Focus on the leaders of the struggle. Scaring people works. This smear tactic was conducted by the prestigious Ivy League College Brown against the opponents to offshore wind. Attack the messenger. In the global south, this is done literally. Real nice place you got here, it would be a sham if something bad happened to it.

Step 7. Create Chaos and Conflict; Divide the Community in Two Camps

Tout the temporary “good paying union” jobs you will create over the permanent sustainable jobs, fishing and tourism, destroyed forever. Destroying a food source never makes good sense. What is truly needed, at this time of ecological collapse, is food sovereignty. Where jobs are hard to come by this is called poverty pimping. Then don’t forget to accuse those opposed to offshore wind of promoting “disinformation“. Push it as a choice in political values, Republicans against Democrats. There is a backlash against “renewable” energy. It’s turned Democrats into Republicans.

Step 8. Having Wrought Havoc, Now Frame It as a Successful Story of Growth and Prosperity

Welcome to the great big beautiful tomorrow, shining at the end of every day. Technology has fixed the problem that it has created! Too bad it is a dystopian science fiction. No one willingly wants to destroy their environment. It is done because of the Golden Rule: Whoever has the gold, makes the rules! Not to mention that these companies have gotten out of paying most of the taxes required of multinationals. And avoid putting emphasis on the fact that the jobs are short term, while the environmental damage is forever.

The Community Environment Legal Defense Fund can help to fight these corporate criminals from destroying your town.

If you would like to help stop The Blue Economy of offshore wind, see Green Oceans https://green-oceans.org/


FOR IMMEDIATE RELEASE

Contact: Ben Martin
Steinreich Communications

(212) 4911600

bmartin@scompr.com

GREEN OCEANS LEADS 35 COPLAINTIFFS IN LAWSUIT ALLEGING U.S. AGENCIES
ILLEGALLY APPROVED OFFSHORE WIND PROJECTS

LITTLE COMPTON, R.I. – Rhode Island-based Green Oceans, a non-partisan, grassroots not-for-profit organization dedicated to protecting the ocean and the ecosystems it sustains, filed a lawsuit in U.S. District Court for the District of Columbia, alleging four federal agencies shortcut statutory and regulatory procedures and violated environmental protection laws by approving the South Fork and Revolution Wind projects. An additional 35 co-plaintiffs joined the litigation.

The suit alleges that the U.S. Department of the Interior, Bureau of Ocean Energy Management (BOEM), National Marine Fisheries Service (NMFS), the U.S. Army Corps of Engineers and their respective administrative leaders, issued permits for the two projects on the critical marine habitat known as Coxes Ledge, despite the acknowledgment of serious irreversible harm and without adequate environmental impact studies. The lawsuit asks the court to invalidate the approvals for both projects until the government complies with all relevant statutes and regulations.

“In a rush to meet state mandates, we cannot short-circuit our country’s most important environmental and natural resource policies. This suit will ensure the federal government follows its own rules and regulations,” said Green Ocean’s Co-founder and President Dr. Elizabeth Quattrocki Knight. 

Filed under the Administrative Procedure Act, the suit intends to prove that the federal agencies violated eight statutes, including the National Environmental Policy Act, Endangered Species Act, Marine Mammal Protection Act, Migratory Bird Treaty Act, Coastal Zone Management Act, National Historic Preservation Act, Outer Continental Shelf Lands Act, Clean Water Act, and their associated regulatory programs.

The suit highlights the alarming scale of proposed offshore wind plans – up to 1,000 turbines, each towering over 870 feet high. The closest turbines will reside just 12.9 nautical miles from the Rhode Island coast. Collectively, the nine projects planned for the waters off the coast of Rhode Island represent the largest offshore development anywhere in the world. The Green Oceans suit alleges that BOEM did not adequately consider the cumulative impact of the entire lease area, a legal requirement. No geographic boundaries exist between the nine different projects planned for the 1,400 square miles of coastal waters between Massachusetts and Rhode Island.

“Marine mammals will not appreciate whether any given turbine belongs to one project or another. Legally, BOEM must evaluate the collective impact, not just each project in isolation,” Dr. Quattrocki Knight emphasized. The projects threaten to permanently alter the environmentally sensitive Coxes Ledge, one of the last remaining spawning grounds for Southern New England cod and an important habitat for the North Atlantic right whale and four other endangered whale species.

Barbara Chapman, a Green Oceans trustee, added, “Even people who support the concept of wind power understand the threat to sea life. On the official NOAA site, they have granted the developer of Revolution Wind, just one project of many, permission to harm and harass over 13,000 marine animals, including 568 whales, during the course of a single year. We do not consider 13,000 a small number.”

“BOEM admits the projects will have adverse impacts on the health of our fisheries, navigation safety, historic resources, the North Atlantic right whale, and environmental justice populations, while having no effect on climate change. Why accept this irreversible environmental damage for no overall gain?” questions Green Ocean’s Co-founder and Vice President, Bill Thompson.

Co-plaintiffs to the suit include the Responsible Offshore Development Alliance, Save Right Whales Coalition, New England Fishermen’s Stewardship Association, Bat World Sanctuary, three former Rhode Island Fisherman’s Advisory Board members, along with local and regional recreational fishermen, sailors, boaters, pilots, conservationists, residents, and leading members of the business community.

Green Oceans is a nonprofit, non-partisan group of community members dedicated to combating climate change without jeopardizing biodiversity or the health of the ocean. For more information or to get involved, visit: https://green-oceans.org/.

Featured photo by Pete Godfrey on Unsplash

Right Whales Threatened With Extinction by Offshore Wind

Right Whales Threatened With Extinction by Offshore Wind

Editor’s Note: With the increase in offshore wind energy surveys, the number of stranded North Atlantic Right Whales on East Coast beaches has also increased. Right Whales were declared as a critically endangered species by the US National Oceanographic and Administrative Administration (NOAA) in 2020. Survey and construction for offshore wind requires sonar to inform about the condition of the seabed where the wind turbines are supposed to be embedded. Right whales depend of whale calls to maintain contact with each other, gather to feed and to find mates. The oceanic noise pollution caused by the sonar disrupts all of this.

Save Right Whales Coalition is comprised of 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 their ocean habitat through large-scale offshore wind energy development across the eastern seaboard. The following piece is a compilation of a press release and an open letter to the public. Both of these were taken from the Save Right Whales website.


Whale Conservation Group Calls on NOAA to Halt All Offshore Wind Sonar Surveys After Discovering Mitigations are Ineffective

Contact: Lisa Linowes
603.838.6588
info@saverightwhales.org

Report finds marine mammals are being exposed to much louder noise levels than NOAA has stated which could be the cause for whale deaths

September 11, 2023 – An investigation into recent whale deaths in the Atlantic has found that the noise produced by offshore wind sonar activities is much louder than NOAA Fisheries’ National Marine Fisheries Service (NMFS) has reported. Consequently, the setback distances adopted by NMFS to protect ocean life from the noise are too short and place whales and other marine mammals at a high risk of encountering harmful levels.

The Save Right Whales Coalition (SRWC), a group of long-time environmental activists dedicated to protecting the critically-endangered North Atlantic right whale from the industrialization of its ocean habitat, issued this letter to NOAA Administrator Richard Spinrad exposing the problem. According to the letter, “inadequate mitigations during a sonar survey could result in marine mammals experiencing sound levels that may injure or kill.” Since the only mitigation for sonar noise is distance, the shortened distances enforced by NMFS have “rendered any expected mitigations useless.”

SRWC’s finding is supported by a sound study conducted by Rand Acoustics, LLC, a leading acoustics firm in Maine. Earlier this year, Rand captured actual high decibel noise levels at a wind survey site approximately 43 nautical miles east of Barnegat Light, NJ. Rand found that the frequency and sound power levels he recorded did not match the equipment NMFS and the project sponsor said would be used. Rand’s data show the noise emitted from the sonar was much louder. This finding prompted a comprehensive review of the incidental harassment authorizations (IHAs) issued by NMFS which revealed a regular pattern of NMFS applying mitigations based on quieter sonar devices than those actually in use.

“In our review, we found that NMFS simply accepted the sonar sound levels provided by the wind developers without independently validating these levels,” said Lisa Linowes, a co-founder of SRWC. She warned that all mitigations relating to sonar noise in the IHAs are predicated on the loudness of the sonar devices. Underestimating the actual noise level of sonar used by survey boats would lead to the specification of shorter ‘safe’ distances from marine mammals than were necessary for their protection. The setback distances also play a key role in calculating the number of marine mammal ‘takes’ NMFS authorized for the sonar activity. “Had NMFS applied the correct sonar sound levels when issuing the IHAs, the number of takes would have been materially greater,” Linowes said.

This finding suggests that there has been a complete breakdown in the system designed to protect marine wildlife and protect the North Atlantic right whale from extinction. SRWC has requested emergency action by NMFS and BOEM to address this matter beginning with the immediate revocation of IHAs now active.

The SRWC letter sent to NOAA can be found at this link.

The investigations of SRWC and Rand Acoustics, LLC are featured in the powerful new documentary released by Michael Shellenberger’s PUBLIC titled Thrown to the Wind. The film can be viewed at this link.


Whistleblower Speaks Out: Offshore Wind Will Drive Whales to Extinction

Dear Fellow Concerned Members of the Public,

The critically-endangered North Atlantic right whale, one of the most imperiled mammals in the world, seemed until just a few years ago to be on a path to recovery. It was our nation’s energy policy in the 18th century to kill the right whales for their oil, but the species was recovering after the 1982 ban on whaling took effect.

Today, the whale is in more danger than ever. An “unusual mortality event” beginning in 2017 has reduced the population by 30 percent. The North Atlantic Right Whale Consortium’s October 2022 count estimates that only 340 individuals survive, with fewer than 70 breeding females and an overall decline in body size. Major sources of stress today include fishing gear entanglements, vehicle collisions, and climate change.

But one source of danger to the right whale is rarely discussed: the industrialization of their habitat by offshore wind companies, enabled by two government agencies, the National Oceanic and Atmospheric Administration Fisheries (NOAA Fisheries) and the Bureau of Ocean Energy Management (BOEM). The head of New England Aquarium’s whale impact monitoring program has openly stated that the first offshore wind projects will serve as a “test bed” to study their impacts on the whale.

A recently-surfaced letter from a whistleblower indicates that BOEM and NOAA were aware in May 2022 that offshore wind construction and operation posed a direct danger to the North Atlantic right whale.

The author, NOAA’s own Chief of Endangered Species, Dr. Sean Hayes, bravely sounded the alarm, noting that not only the construction but also the operation of wind turbines could result in extinction.

Yet these agencies have failed to put in place any meaningful measures to protect this critically endangered species from extinction.

By NOAA Fisheries’ own admission, “The potential biological removal (PBR) level for the species, defined as the maximum number of animals that can be removed annually while allowing the stock to reach or maintain its optimal sustainable population level, is less than 1.” In plain language, this means the death of a single whale could make the difference between extinction and recovery.

Recent data collection finds the whales are increasingly relying on the southern Massachusetts wind lease area as a last refuge for foraging and raising their young. Because the federally-designated critical right whale habitat is out of date, these very same areas have been approved by the federal government for industrialization by offshore wind companies.

For a long time it was unclear what effects the plants’ construction and operation might have on whales. Several groups including our coalition raised the alarm and called for a moratorium until more studies could be conducted.

In response to these concerns, NOAA Fisheries and the Bureau of Ocean Energy Management (BOEM) in October this year released a draft joint strategy to “to protect and promote the recovery of North Atlantic right whales while responsibly developing offshore wind energy.” But this strategy is misleading – the authors frame their plan to meet their obligations under the Endangered Species Act as a mere “vision,” and there is little evidence that the proposed mitigation measures are effective, practicable or backed up by sufficient funds.

Our coalition’s public comments can be found here.

In order for the development of the projects to go forward, an Incidental Harassment Authorization (IHA) must be issued by NOAA when a federally listed marine mammal may be harmed. The issuance of an IHA requires that it is possible to fully mitigate the effects of any harassment, and from Hayes’ letter it is clear that this is not the case.

Hayes’ letter stresses that the presence of wind turbines would disrupt the dense populations of zooplankton that right whales rely on for food. Hayes describes the wind lease area as “the only known winter foraging area for right whales” and warns against the impacts not only from construction but also from the expected 30-year operation of offshore wind turbines on foraging grounds, which could “vary from hundreds of meters for local individual turbine impacts…to large-scale dipoles of surface elevation changes stretching hundreds of kilometers.”

Most damningly, he states, “impacts from installed and operating turbines cannot be mitigated for the 30-year lifespan of the project, unless they are decommissioned.”

A lawyer from the Conservation Law Foundation, an organization that is “strongly supportive of offshore wind,” acknowledged that the area slated for wind development was poorly surveyed for right whales prior to the permitting agencies selling 1,400 square miles of our federal waters to foreign wind energy companies.

NOAA and BOEM’s draft mitigation plan fails to address Hayes’ concerns. Additionally, it is interesting that the letter was not made available to the public until November when a local newspaper, the New Bedford Light, accessed it through a Freedom of Information Act request.

Hayes has risked his career and reputation by writing a letter of this seriousness. The international offshore wind industry is estimated to be worth $31.2 billion. Major conservation organizations, including the New England Aquarium and the Environmental League of Massachusetts, receive funding and sponsorships from offshore wind companies. Not to mention the weight of the Biden-Harris’s administration’s pro-offshore wind policy, backed by numerous large government agencies.

But evidence continues to mount. On November 24th, scientists published stronger evidence indicating that offshore wind operations “can have a substantial impact on the structuring of coastal marine ecosystems,” with effects far beyond the area of the turbines themselves.

With fewer than 350 North Atlantic right whales alive today, we must heed the science and call on the government to fulfill its obligations. The first large-scale offshore wind projects cannot serve as test beds to determine the impacts of turbines on a critically endangered species. And while climate change is an imperative, it is indefensible for any industrial project to push a species to extinction.

It was our own whaling industry that pushed the right whale to the brink. Today, our energy industry seems to be repeating its mistakes.

With this in mind, we are no longer calling for a moratorium. We are calling for the project to be canceled outright.

It is unacceptable for the government to allow large-scale industrial experiments in critical habitat for a species on the brink of extinction. The construction of industrial wind projects in any North Atlantic right whale habitat is, at this point, a clear violation of the Endangered Species Act.

Sincerely,

The Save Right Whales Coalition

Photo by Nicholas Doherty on Unsplash

Offshore Wind Wrong for the Right Whale

Offshore Wind Wrong for the Right Whale

By Carl van Warmerdam

The North Atlantic Right Whale (NARW) are among the rarest of all marine mammal species in the Atlantic Ocean. They average approximately 15 m (50 ft) in length. They have stocky, black bodies with no dorsal fin, and bumpy, coarse patches of skin on their heads called callosities. The NARW is one of the world’s most endangered whales. Once common along the eastern U.S. seaboard, the whale was hunted to near-extinction by the 1750s. The species gets its names from early whalers, who considered them to be the “right” whales to hunt. By the early 1900s the population off Europe had been virtually extirpated while a small population of perhaps a hundred or fewer survived in the western North Atlantic off the United States and Canada. After 1935, when an international agreement went into effect banning the hunting of all right whales, their numbers began to increase slowly. In recent decades, this slow recovery has been impeded by mortality and serious injury from ship strikes, entanglement in fishing gear, underwater noise and separation from calving areas because of shipping traffic. NARW now occur almost exclusively along the east coasts of the United States and Canada, where they rely on a calanoid copepod, Calanus finmarchicus, as their primary food source. Beyond eating a lot, whales also produce lots of plumes (a gassy form of underwater poop). These plumes fertilize the ocean and help feed small organisms called phytoplankton. These organisms, in turn, produce 50% of the world’s oxygen – every other breath humans take. Over their lifetimes, NARW also accumulate tons of carbon in their bodies – helping to mitigate climate change. The importance of whales for the ecosystem cannot be overstated. 

An 8-year analysis of NARW sightings within Southern New England (SNE) show that the NARW distribution has been shifting (Quintana- Rizzo et al. 2021). A study area of SNE (shores of Martha’s Vineyard and Nantucket to and covering all the offshore wind lease sites of Massachusetts and Rhode Island) recorded sightings of NARW in almost all months of the year. A population trend analysis conducted on the abundance estimates from 1990 to 2011 suggest an increase at about 2.8% per year from an initial abundance estimate of 270 individuals in 1998 (Hayes et al. 2020). However, modeling conducted by Pace et al. (2017) showed a decline in annual abundance after 2011, which has likely continued as evidenced by the decrease in the abundance estimate from 451 in 2018 (Hayes et al. 2019) to 412 in 2020 (Hayes et al. 2020). This decrease correlates to when the Block Island wind turbines were constructed. The only offshore wind Turbines in the Americas.

With an estimated population of fewer than 350 individuals, scientists have been raising the alarm about the dwindling number of reproductive females needed to sustain the population. For a new paper published in the journal Frontiers, lead author Joshua Reed, a PhD candidate from the School of Natural Sciences at Macquarie University, used individual female whales’ reproductive history, rather than age, when modeling population trends to provide a better insight into their numbers. “Our research found that of the estimated 142 female right whales alive in the population at the beginning of 2018, only 72 were actually capable of reproducing. This has certainly influenced the species’ decline in recent years,” said Reed. The researchers also found that in recent years, young females are less likely to start calving when they reach 10 years of age. Ten was the age at which right whales used to have their first calf in the years up to the turn of the century. Right Whales can and should live for up to 75 years. But that number is quickly declining. Scientists identify individual right whales through photographs and compare these images throughout time to learn about their lifespan. And, according to recent estimates, female right whales are barely making it to middle age. But many right whales don’t even make it that far.

In its 2020 update of its “Red List of Threatened Species,” the International Union for Conservation of Nature declared NARW “critically endangered,” the most serious category of risk, with such a small, slow-growing population, any threatening factor may have a significant impact.

Offshore Wind or North Atlantic Right Whale?

wind

“North Atlantic right whale” by FWC Research is licensed under CC BY-NC-ND 2.0.

The Bureau of Ocean Energy Management (BOEM) plans, by 2025, to hold up to five additional, to the Revolution Wind, Offshore Wind (OSW) lease sales and complete the review of at least 16 plans to construct and operate commercial OSW facilities, which would represent more than 22 gigawatts of “clean” energy for the nation. That means thousands of wind turbines along the Eastern Seaboard.

BOEM and the National Oceanic and Atmospheric Administration (NOAA) Fisheries initiated development of a shared Draft North Atlantic Right Whale and Offshore Wind Strategy (hereinafter called “Strategy”) to focus and integrate past, present, and future efforts related to NARW and OSW development. In response to Executive Order 14008, both agencies share a common vision to protect and promote the recovery of NARW while responsibly developing offshore wind energy. The announcement initiated a 45-day public review and comment period on the draft strategy. Comments on the guidance can be submitted via regulations.gov from October 21 to December 4, 2022 under Docket Number BOEM-2022-0066. For more information about the draft strategy and how to submit comments, visit BOEM’s website.

The following is my comment. Please use this opportunity to express your concerns in this regard.

The NARW species provides important ecosystem services, and its potential extinction could be a leading indicator for other ecosystem disruptions (Pershing et al. 2021). The extinction of the Right Whale will be the precursor of the extinction of our own species. Both will be caused by the disturbances to functioning ecosystems by human expansion. And it does not need to be this way. OSW development will result in the destruction or adverse modification of designated critical habitat. Only a “jeopardy” or “adverse modification” conclusion can be reached. Whales and turbines do not mix. Please do not allow this “development” to proceed while the NARW survival is in the balance. There is still time, but the time is now because there is so little left.

Climate change does in-fact pose a significant global threat that will cause planet-wide physical, chemical, and biological changes that substantially affect the world’s oceans, lands, and atmosphere. But climate change is a symptom of industrial civilization and driven by the disease of a consumer culture. A new study finds a 69% average drop in animal populations since 1970. Over those five decades most of the decline can be traced to habitat destruction. The human desire for ever more growth played out over the years, city by city, road by road, acre by acre, across the globe. “Biological diversity is the variety of life on Earth and the natural patterns it forms. The biodiversity seen today is the result of 4.5 billion years of evolution and, increasingly, of human influence as well. It forms the web of life, of which humans are integral and upon which people and the planet so fully depend. The planet is currently in biodiversity breakdown. Species are now disappearing hundreds, or even thousands, of times faster than the natural background rate of extinction. The scientific community has repeatedly sounded the alarm on the triple planetary crisis of climate change, nature and biodiversity loss, and pollution and waste. Over half the world’s total GDP is moderately or highly dependent on nature, which also provides medicine and social benefits.” We are in a biodiversity emergency. With scores of species dying each day, we are in a mass extinction event. Although many of those species may not be as impressive as the megafauna they are just as important to protect the complex balance of nature which all of life is dependent upon.

Without significant reductions in anthropocentric consumption of the natural world, greenhouse gas emissions, extinctions and transformative impacts on all ecosystems cannot be avoided. Our options in what reductions will then be impose by such limits will create harsher impacts on the economic, recreational, and subsistence activities they support.

OSW is abundant and renewable but extracting that energy with turbines will be neither efficient or clean or an alternative domestic energy resource. Wind turbines are not renewable. Heavy industries use a lot of energy to create the components for wind turbines. Coal and other fossil fuels are utilized to power the machinery and furnaces in these factories. According to estimates, the energy utilized by the present United States’ heavy industries is equivalent to the energy necessary to power the country’s entire electrical grid.

The need for energy in the heavy industries grows in tandem with the demand for wind turbines, producing a feedback mechanism in which the more wind power we use, the more reliant we are on the heavy industry, and thus the more fossil fuels we need. Production of wind turbines to extract wind energy will require the release of more emissions that can pollute the air or water without exceptions, and using turbines to extract wind energy has greater effects on the environment than many other energy sources. Wind turbines will not reduce the amount of electricity generation from fossil fuels, and will result in greater total air pollution and carbon dioxide emissions. Transitioning to their use will precipitate a far higher biodiversity loss in their manufacturing process. Already the wind power boom is driving deforestation in the Amazon with its demand for balsa wood. 

The major coastal cities, where more than half of the U.S. population resides and energy needs are high, must reduce their energy consumption, as all cities must do. Compared to onshore wind, offshore wind challenges that also need to be considered are higher cost due to specialized installation, equipment, and more expensive support structures; (2) more difficult working conditions; (3) higher wind speeds; (4) decreased availability due to limited accessibility for maintenance; and (5) necessity for special corrosion prevention measures. Hence the lower life cycle of 15 years for offshore wind. Then at the end of their lifecycle they end up in a landfill because they are economically infeasible to recycle. Not to mention that these particular turbines will be built in the home of the NARW.

Without the Departments of the Interior, Energy, and Commerce announced national goal to deploy 30 gigawatts of OSW by 2032 and accompanying subsidies, there wouldn’t be increasing interest in developing OSW. This goal is stated to be achieved while protecting biodiversity and promoting ocean co-use. It can be appreciated that in an attempt to resolve these conflicting goals the BOEM and NOAA Fisheries North Atlantic Right Whale and Offshore Wind Strategy has been put forth.

The Outer Continental Shelf (OCS) Lands Act directs BOEM to study and consider coastal, marine, and human environmental impacts, and BOEM must also comply with many other statutes, regulations, executive orders, and policies in making decisions—including the Endangered Species Act (ESA). 

The ESA requires BOEM to ensure that any action it takes to implement the OCS Renewable Energy Program is not likely to jeopardize the continued existence of any listed species or result in the destruction or adverse modification of critical habitat determined for any listed species, including the NARW (ESA section 7(a)(2)). Additionally, section 7(a)(1) of the ESA requires BOEM (and all other Federal agencies) to “utilize their authorities in furtherance of the purposes of this Act by carrying out programs for the conservation of endangered species.”

NOAA Fisheries strives to take an ecosystem-based approach to managing living marine resources, recognizing the interconnectedness of ecosystem components and the value of resilient and productive ecosystems to living marine resources. This connectedness should also be applicable to places where the metals and material are mined to make wind turbines, for example deep sea mining. A declaration of oceanic rights from the United Nations could recognize the ocean as a living entity that has its own inherent entitlements, such as those to life and health, along with the right to continue its vital natural cycle.

NOAA Fisheries and NOAA National Marine Sanctuaries share NOAA’s mission to 1) understand and predict changes in climate, weather, ocean and coasts; 2) share that knowledge and information with others; and 3) conserve and manage coastal and marine ecosystems and resources. So coastal and marine ecosystems then are not resources to conserve and manage for the continuation of extractive industries. They function best when left alone.

As noted above, section 7(a)(2) of the ESA requires BOEM, in consultation with NOAA Fisheries, to ensure that any action the agencies authorize, fund, or carry out is not likely to jeopardize the continued existence of any endangered species or result in the destruction or adverse modification of designated critical habitat; this coordination is accomplished through ESA section 7 consultations. The Strategy does not state that when a Federal agency’s action “may affect” a protected species, that agency is required to consult with the National Marine Fisheries Service (NMFS) or the U.S. Fish and Wildlife Service (USFWS). This requirement needs to go upstream to the threatened species caused by mining for the materials of the construction of the wind turbines. 

In response to a request for consultation, NOAA Fisheries prepares a Biological Opinion detailing how an agency (i.e., BOEM) action affects a threatened or endangered species and/or its critical habitat and a conclusion as to whether the proposed action is likely to jeopardize the continued existence of the species. It considers whether the action will result in reductions in reproduction, numbers, or distribution of the species and then considering whether these reductions would reduce appreciably the likelihood of both the survival and recovery of the species, as those terms are defined for purposes of the ESA. The Biological Opinion also includes a determination as to whether the proposed action is likely to result in the destruction or adverse modification of designated critical habitat. If a “jeopardy” or “adverse modification” conclusion is reached, the Biological Opinion would include one or more Reasonable and Prudent Alternatives to the proposed action that would avoid the likelihood of jeopardizing the continued existence of the listed species or the destruction or adverse modification of designated critical habitat. 

If a “no jeopardy” conclusion is reached, either based on the proposed action and its mitigation or after adopting a Reasonable and Prudent Alternative, NOAA Fisheries may issue an Incidental Take Statement that exempts a certain amount and type of take from the ESA section 9 prohibitions on take. The Strategy should include the following definition: The ESA broadly defines “take” to include “harass, harm, pursue, hunt, shoot, wound, kill, trap, capture, or collect.” In the case of the NARW this should not be allowed.

According to the Petition for Incidental Take Regulations for the Construction and Operation of the Revolution Wind Offshore Wind Farm :

NARW feed mostly on zooplankton and copepods belonging to the Calanus and Pseudocalanus genera (Hayes et al. 2020). NARWs are slow-moving grazers that feed on dense concentrations of prey at or below the water’s surface, as well as at depth (NMFS 2021l). Research suggests that NARWs must locate and exploit extremely dense patches of zooplankton to feed efficiently (Mayo and Marx 1990). 

2.3.2 • Likely changes in copepod distribution between pre- and post-OSW construction. This must be tested to verify. CRITICAL what effect do the present in-place turbines have on prey food?

Currently there are no quantitative data on how large whale species (i.e., mysticetes) may be impacted by offshore wind farms (Kraus et al. 2019). Navigation through or foraging within the Revolution Wind Farm by large whales could be impeded by the presence of the wind turbine generators and offshore substations foundations, which range in diameter from 12 to 15 m with approximately 1.15 mi (1.8 km) spacing between foundations (Section 1). Additionally, wakes in water currents created by the presence of the foundations could alter the distribution of zooplankton within the water column, which would impact prey availability for some marine mammal species (Kraus et al. 2019).

What is the effect the extraction of wind energy from the surface of the ocean in regards to water temperature and currents? 

WIND ENERGY EXTRACTION

wind

“Horns rev offshore wind farm” by Vattenfall is licensed under CC BY-ND 2.0.

Climatic Impacts of Wind Power

• Wind turbines raise local temperatures by making the air flow more turbulent and so increasing the mixing of the boundary layers.

• However, because wind turbines have a low output density, the number of them required has a warming impact on a continental scale. During the day, the surface temperature rises by 0.24 degrees Celsius, while at night, it may reach 1.5 degrees Celsius. This impact happens immediately.

• Considering simply this, the consequences of switching to wind power now would be comparable to those of continuing to use fossil fuels till the end of the century.

In general, BOEM will consider recommendations from NOAA Fisheries and attempt to avoid issuing new leases in areas that may impact potential high-value habitat and/or high-density/use areas for important life history functions such as NARW foraging, migrating, mating, or calving. BOEM and NOAA Fisheries will include potential lessees in these conversations as early as possible to raise awareness of concerns over impacts to NARW. 

If issuing new leases in these areas is not avoidable they still must avoid the likelihood of jeopardizing the continued existence of the listed species or the destruction or adverse modification of designated critical habitat. Under what condition would they be unavoidable? 

Developers should avoid proposing development in areas that may impact high-value habitat and/or high-density/use areas used for important life history functions such as NARW foraging, migrating, mating, or calving. If avoidance is not possible, include measures to avoid and minimize impacts to NARW and their habitat. In this situation the developer should have alternative proposals in different areas. 

BOEM will work with NOAA Fisheries to ensure environmental review under applicable statutes evaluate measures to avoid (primary goal) or minimize (secondary goal) impacts to NARW and high-value habitat and/or high-density/use areas for important life history functions such as NARW foraging, migrating, mating, or calving. The results of these environmental reviews will ultimately inform Construction and Operation Plan (COP) conditions of approval. 

THIS IS GOOD: If new information becomes available indicating that activities previously authorized by BOEM through a plan approval (e.g., COP, Site Assessment Plan, General Activities Plan) are now resulting in an imminent threat of serious or irreparable harm or damage to NARW, BOEM has the authority to suspend operations. 

  • Protected Species Observers (PSOs): Use trained, third-party PSOs with no duties other than to effectively implement mitigation and monitoring measures during construction and operations. Adopt standards for protected species monitoring (e.g., minimum visibility, PSO protocols, etc.). Use only independent, third-party PSOs (i.e., not construction personnel) that are approved by NOAA Fisheries. Locate PSOs safely at the best vantage point(s) to ensure coverage of the entire visual Clearance and Shutdown Zones, and as much of the behavioral harassment zones as possible. Ensure PSOs do not exceed 4 consecutive watch hours on duty at any time, have a two- hour (minimum) break between watches, and do not exceed a combined watch schedule of more than 12 hours in a 24-hour period. These PSO should not be contractors of the developer. They must be payed through a government agency which can be covered through developer fees.

For the success of  “DRAFT BOEM and NOAA Fisheries North Atlantic Right Whale and Offshore Wind Strategy” what exactly is that? To promote the recovery of NARW while responsibly developing OSW. What happens if these two are mutually exclusive? Would it be a success if Right Whales continue to survive but wind turbines do not? Must NOAA Fisheries meet the shared vision to protect and promote the recovery of NARW while responsibly developing offshore wind energy? So long as the NARW numbers are declining there should be no disturbance of their habitat. 

There are no time tables in this Strategy so is it understood then that no action shall be taken until such time as the appropriate data is collected? Although it is long on data collection there is no mention of inspection. All of these actions will require funding but these extra expenses can not be covered in the normal operating budgets of the agencies. Where will it come from and where will it go?

I commend BOEM and NOAA Fisheries for producing a strategy in regard to the NARW. I also acknowledge that in order to maintain functioning ecosystems, this type of Strategy should be implemented for all of the new mining operations, logistics, transportation and infrastructure that will be required to build all of the proposed turbines needed to transition to an energy capturing economy.

Carl van Warmerdam has lived his life on the West Coast of Turtle Island. He has always aligned with the counter culture ideals there. Now he currently lives on the coast of New England, the ancestral home of the Right Whale. If you would like to help save the whales email Lafongcarl@protonmail.com. We stopped offshore wind before, we can do it again.

Save the Right Whales Coalition                    (ACKRATS) Nantucket Residents Against Turbines

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Featured image: Help North Atlantic Right Whales sign, Belfast, Maine by DrStew82 via Wikimedia Commons is licensed under CC BY-SA 4.0.