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.
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 thetruth, 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 aredoomed to failure. And you also don’t have to belinked 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 tofossil fuel companies. In reality what is really going on is aboondoggle, that you won’t hear about in mainstream corporate media because they only givedisinformation. 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. From61 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 the37 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. Thepercent 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 theseenergy intense extractive technologies require massive amounts of fossil fuels to produce and those emissions areadding 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 theEnergy 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 arenot clean except through greenwashing and are only making ourpredicament worse. The trillions in government subsidies given to this sector only makes therich 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 utilityratepayer. This is ascam that is notfinancially 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 forfishing, 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.
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 NeighborHost 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 intoagreement with offshore wind: Natural Resources Defense Council, National Wildlife Federation, and Conservation Law Foundation andtaken 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 andtourism, 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.
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) 491–1600 bmartin@scompr.com
GREEN OCEANS LEADS35CO–PLAINTIFFSINLAWSUITALLEGINGU.S. AGENCIES ILLEGALLYAPPROVEDOFFSHORE 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/.
In the last few years whales stranded on the beaches of the East Coast have become common. In just the past two months there have been over a dozen. And that does not include the whales who have died in that time and sank to the bottom of the ocean. Fishermen blame industrial wind farm surveys, the wind industry blames climate change, and the vessel strikes of the global supply chains of civilization will not slow down. All the while mainstream “environmental” groups have become PR people for industrial energy. That stance is mutually exclusive from their professed goal to protect wildlife like desert tortoise, sage grouse, bats and to Save The Whales.
NOAA declared an official “unusual mortality event” for humpback whales in 2016, when the number of deaths on the East Coast more than doubled from the average in previous years. Coincidentally that is the same year when offshore wind development began, which coincides with the huge jump in NOAA Incidental Harassment Authorizations. The claim that this huge jump in mortality predates offshore wind preparation activities is patently false. This strong correlation is strong evidence of causation, especially since no other possible cause has appeared. It also seems odd that dead whales are now showing up on the west coast just as wind development is starting up there as well.
If what we are seeing is what happens during the surveying process for an offshore wind farm, we can only imagine what will happen when major construction begins. If vessel strikes are a leading cause of death, why on earth would you diminish habitat and increase vessel traffic with the construction of wind turbines? Yet in the recent denial of a vessel speed reduction, NOAA said it was “focused on implementing long-term, substantive vessel strike risk reduction measures.” Hopefully that will include the cancellation of any further wind farm construction. We certainly should not be increasing vessel traffic at this time, we should be restricting it. Vessel strikes and ocean noise from these extra ships and their sonar mapping is killing whales.
Noise interrupts the normal behavior of whales and interferes with their communication. It also reduces their ability to detect and avoid predators and human hazards, navigate, identify physical surroundings, find food and find mates. Such effects make it difficult for whales to avoid ships. It is one of NOAA’s four threats, along with vessel strikes, fishing gear entanglements and climate change.
Sound travels farther and four times faster in water than in air (at a speed of almost 1,500 meters per second). The noise produced by humans can therefore spread considerable distances underwater. These sounds can be relatively constant, such as the noise produced by a ship’s engine and propeller, or sudden and acute in the case of naval sonar and seismic air guns. The sound produced by a seismic air gun can cause permanent hearing loss, tissue damage and even death in nearby animals.
Evidence for the lethal effects of noise can be hard to document in the open ocean, but seismic surveys have been linked to the mass mortality of squid and zooplankton. In 2017, research revealed that a single air gun caused the death rate of zooplankton to increase from 18% to 40–60% over a 1.2 kilometer stretch of the ocean off the coast of southern Tasmania.
Examination of the dead whales revealed they had suffered trauma similar to decompression sickness. This was believed to have been caused by sudden changes in their deep diving behavior following exposure to sonar. The wind companies are using sonar in the geotechnical and site characterization surveys. There is also the detonation of unexploded ordnance (UXO) items from ship wrecks at this time, accidental and intentional.
Noise increases animals’ physiological stress. Research found that a reduction in shipping following the 9/11 terrorist attacks led to a six decibel drop in noise levels in the Bay of Fundy on Canada’s Atlantic coast. This coincided with lower levels of physiological stress detected in North Atlantic right whales when researchers measured stress hormones from floating whale feces.
During construction of the turbines, high-duty cycle impact pile driving (one strike every ~two seconds) will be used. And the pile driving is expected to occur for approximately four hours at one time for monopile installation, and 6 hours per pile for piled jacket installation.
This takes us to the biggest threat to whales and the ocean ecosystem that they live in: climate change. Climate change is caused by greenhouse gas emissions. These are created by industrial development. So climate change is a symptom of industrial development. That is the extractive industries of mining, deforestation, agriculture, factory fishing and dams which provide — through production, manufacture, transport, installation and operation — the current conveniences of a modern way of human life.
Industrial development destroys ecosystems. More industrial development, by the installation of thousands of offshore wind turbines, will not solve the problem of climate change. There’s one inescapable truth about the headlong rush to cover vast swaths of our countryside and oceans with 800-foot-high wind turbines: the more turbines that get built, the more wildlife will be harmed or killed. And no amount of greenwashing can change that fact. So it is distressing to see the numbers of whales washing up on our beaches. NOAA also says there is no proof that offshore wind is killing the whales. We must remember the onus isn’t on whales to prove guilt, it’s on industrial development to prove their innocence.
The production of the materials as well as the manufacturing processes for wind turbines and associated infrastructure of the extracted energy storage and transmission are made possible by burning fossil fuels. To obtain the raw material used in wind turbines, habitat is destroyed through open pit mining and mountaintop removal. The raw materials are then transported to processing plants to be turned into the component parts. It will take a tremendous amount of energy to mine the materials; transport and transform them through industrial processes like smelting; turn them into wind turbines, batteries, infrastructure and industrial machinery; install all of the above; and do this at a sufficient scale to replace our current fossil-fuel-based industrial system. In the early stages of the process, this energy will have to come mostly from fossil fuels, since they supply about 80 percent of current global energy. Their emissions will be added to the current use emissions. After manufacture, the turbine parts need to be transported to the project location. The construction and operation of offshore wind farms increase boat traffic, also leading to more greenhouse gas emissions and pollution. All of which adds to a non-existent carbon budget and thus increasing climate change. Not to mention the increased risk of marine mammal vessel strikes.
All of that energy use has a carbon payback period to plan, build, maintain and decommission the processes involved in an offshore wind turbine and its required infrastructure amounting to many years. This could be up to a quarter of its expected lifecycle. But this does not take into account the wildlife loss and habitat destruction from those processes. And then in 20 years the process must be done all over again. So this is not renewable. Also there are not enough metals on the planet to produce even the first generation of a total electric energy extracting transition, even if we mine the deep sea as we are starting to do.
Currently only 20% of our energy is electric. The other 80% is fossil fuel, the bulk of which is used by industry. The industrial advantage of fossil fuel is that it is stored energy that is extracted rather than an energy extracting device that requires storage and transmission infrastructure.
The paradox of “renewables” is that they need unprecedented volumes of non-renewable mined materials. Increasing “renewables” means large upticks in battery metals such as copper, cobalt, lithium and nickel. Wind turbines need rare earth metals such as neodymium of which there are scarce amounts. But the work wouldn’t stop there.
Closed mines themselves are a huge source of devastation. If all mining stopped today there would still be an area at least the size of Austria with degrading and, in some cases, dangerous levels of heavy metals. Mining brings materials that have been locked up in concentrations underground and lets them out into the world. Mines usually operate at depths below the water table — they need to be constantly dewatered using pumps. When a mine is abandoned, the ground water gradually re-floods underground passages and mineral seams over many months, creating acidic reservoirs of water. Above ground there are tailings ponds and piles of low-grade ore with traces of heavy metals. All of this material is exposed to oxygen and water. Exposing such elements wreaks havoc on ecosystems, soils and water supplies through acid leaching. A mine that is abandoned can have chronic pollution for hundreds if not thousands of years.
Cleaning up a mine consists of reducing water acidity, detoxifying the soil and treating waste before reintroducing flora and fauna to the site. It’s a lengthy, expensive process and can cost billions for a single large mine. Avoiding an environmental catastrophe and cleaning all the world’s mines at once would cost hundreds of billions or even trillions of dollars. So mining the materials needed for renewable energy will increase the threats to biodiversity. These threats will surpass those avoided by “renewable” climate change mitigation.
The concept of material footprints, in addition to carbon footprints, should be taken into consideration by governments. If not, the planet’s scarce non-renewable resources will continue to be destroyed. These factors will more than offset BOEMs calculations for climate change in the DEIS.
During their operation wind turbines create a disturbance in the air that can have far-reaching effects on the environment. The turbulence created is known to warm up the surface temperature around them by up to 2℉. This will change the climate by taking away the cooling breeze. Wind turbines will change weather patterns and currents which will create more and stronger storms.
Michael Moore, a senior scientist at the Woods Hole Oceanographic Institution, said whales face “a suite of risks” as turbines are built, such as increased vessel traffic and potential changes to the ecology. But that ecological change, he said, “needs significant further study to truly understand its significance.”
As Sunrise Wind admits, their planned construction and operations activities are not expected to “take” MORE than small numbers of marine mammals. They say incidental long-term impacts that have negative effects on large whales from the presence of turbine foundations is uncertain. For the right whale, according to NOAA Fisheries, “The potential biological removal 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.” This means the death of a single right whale could make the difference between extinction and recovery.
There is no question wind turbines kill wildlife. Humans and domestic animals account for 96% mammal biomass on the planet. Only 4% is wild. Our activity has reduced the biomass of wild marine and terrestrial mammals by six times. Humanity has wiped out 60% of mammals, birds, fish and reptiles since 1970, leading the world’s foremost experts to warn that the annihilation of wildlife is now an emergency that threatens all life on the planet.
Jennifer Jacquet, a professor of environmental studies at New York University, said, “But we know that even in the face of a shifting climate, direct exploitation remains the largest factor affecting aquatic animals.”
BOEM is basing its conclusions in the DEIS on a false analysis that offshore wind turbines will reduce climate change. They will not. It makes no sense to increase disturbance to whales when they are suffering through an unusual mortality event. Whales as a keystone species are the canary in the coal mine. As they go, so do we. That in the effort to save the climate and continuance of business as usual, we are destroying the environment. If this offshore wind project continues, it will be humans who experience an unusual mortality event.
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 North Atlantic 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.
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?
“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 generatorsand 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
“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.
