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WASHINGTON, Aug. 6 -- Avangrid Renewables LLC, Boston, Massachusetts, has issued a public comment to the U.S. Department of Interior. The comment was written on Aug. 01, 2022, and posted on Aug. 2, 2022.
The comment, on Docket No. BOEM-2022-0017, was sent to the Pacific Regional Office of the Bureau of Ocean Energy Management.
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Avangrid Renewables, LLC ("Avangrid Renewables") is pleased to submit its comments on the proposed sale notice ("PSN") for commercial offshore wind energy leasing in California. The comments contained herein reflect the extensive experience of Avangrid Renewables and affiliates in developing, operating, and maintaining a global offshore wind portfolio.
Avangrid Renewables, among the three largest wind operators in the United States based on installed capacity, is an indirect subsidiary of AVANGRID, Inc ("AVANGRID"). AVANGRID has approximately $40 billion in assets in our two primary lines of business - Avangrid Networks and Avangrid Renewables. Avangrid Renewables owns and operates approximately 9 gigawatts of electricity capacity, primarily through wind and solar power, with a presence in 22 states across the United States.
AVANGRID supports the achievement of the Sustainable Development Goals approved by the member states of the United Nations and was named among the World's Most Ethical companies in 2019, 2020, and 2021 by the Ethisphere Institute. IBERDROLA S.A, one of the world's largest electricity companies, owns 81.6% of the outstanding common stock of AVANGRID. The IBERDROLA Group is a global energy leader and the leading wind energy producer in the world.
The comments contained herein are in response to Point IV, Questions for Stakeholders.
Thank you for your consideration.
Vice President, Offshore Wind New Business
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Avangrid Renewables, LLC ("Avangrid Renewables" or the "Company") appreciates the opportunity to submit comments on the proposed sale notice ("PSN") for commercial offshore wind energy leasing off the California outer continental shelf ("OCS") in response to Point IV, Questions for Stakeholders, published by the Bureau of Ocean Energy Management ("BOEM") in the Federal Registrar under BOEM-2022-0017 on May 31, 2022.
Avangrid Renewables is a subsidiary of AVANGRID, Inc ("AVANGRID"). AVANGRID has approximately $40 billion in assets across two primary lines of business - Avangrid Networks and Avangrid Renewables. Avangrid Renewables, among the three largest wind energy generators in the United States, owns and operates 9 gigawatts ("GW") of electricity capacity, primarily through wind and solar power, with a presence in 22 states across the United States.
AVANGRID's primary shareholder, IBERDROLA S.A. is a global energy leader and the number one producer of wind power in the world. This relationship enables Avangrid Renewables to benefit from the experience of affiliates, such as ScottishPower Renewable Energy Ltd and Iberdrola Renovables SAS. These affiliates have substantial expertise in offshore and onshore wind development, finance, construction, and operations. Collectively, they own one of the largest offshore wind portfolios in Europe, including nine projects that are already operating, successfully constructed, under construction, or in advanced development stages.
Avangrid Renewables, though its joint venture Vineyard Wind, is developing Vineyard Wind 1 in Lease Area OCS-A 0501- the first commercial-scale offshore wind project in the United States. The project commenced onshore construction in Massachusetts in November 2021. Avangrid Renewables is also developing the Park City Wind project for Connecticut utility customers and the Commonwealth Wind project for Massachusetts utility customers on Lease Area OCS-A 0534.
Avangrid Renewables has also secured an offshore lease (Lease Area OCS-A 0508) for the 122,000acre Kitty Hawk Offshore Wind project, which has the potential to provide over 2,500 MW of clean energy to Virginia and North Carolina.
Through its development of the Vineyard Wind 1, Park City Wind, Commonwealth Wind, and Kitty Hawk Offshore Wind projects, Avangrid Renewables has gained significant domestic offshore wind experience and is at the forefront of the commercial offshore wind industry in the United States. As noted previously, the Company also benefits from the experience of its global affiliates with a proven track record of offshore wind industry success. Leveraging the strength of our global and nationwide resources, and in coordination with active regional stakeholder engagement, Avangrid Renewables will not only enable the regionally based team to construct cost-effective projects off the coast of California, but to also invest in and accelerate the transition of the local offshore wind supply chain, infrastructure, and workforce. Global expertise bolsters our local team's ability to construct reliable, cost-effective offshore wind facilities to provide clean, affordable energy to electricity consumers in California.
Avangrid Renewables commends BOEM's collaboration with the state of California to advance the leasing process in northern and central California, which will be vital to meet California's 100% renewable energy target and the Governor's recommended 20 GW by 2045 offshore wind goal, the Biden Administration's urgent offshore wind goal of 30 GW by 2030, and planning for 110 GW by 2050. Avangrid respectfully requests BOEM take into consideration the following priority matters prior to issuing the California Final Sale Notice ("FSN").
Avangrid Renewables believes a fair, transparent, and competitive auction will bring huge climate, community, and economic benefits to California ratepayers and the floating offshore wind industry in the United States. Because California is new to offshore wind, and this auction will be the first in the country for floating-specific technology, it is paramount that the auction offers a level playing field that keeps the costs of offshore wind projects in check to ensure adoption of the resource in the state's planning goals and its successful offtake and monetization. The following summarizes the Company's main priorities for the California lease auction, based on its significant experience developing commercial-scale offshore wind projects:
1. Bidding Credits
a) Avangrid Renewables supports BOEM's suggestion of a multi-factor auction, as well as an increase to the Workforce and Supply Chain credit from BOEM's suggested amount of 20 percent. The Company supports increasing the Community Benefit Agreement credit to 5 percent (from 2.5 percent), but it recommends limiting the total Bidding Credit percentage to a maximum of 30 percent.
b) The bidding credit concept of "domestic supply chain" should be more broadly defined to include not only manufacturing of offshore wind components, but also the construction logistics of marshalling, transmission infrastructure, quayside assembly, and pre-installation activities, all of which will be required for port infrastructure improvements.
c) It is critical that the development of the offshore wind industry on the West Coast benefit as many constituencies and stakeholders as possible. To this end, Avangrid Renewables also supports expanding the scope of the Community Benefit Agreement (CBA) to include and benefit tribal nations and environmental justice communities.
2. Number of Lease Areas per Bidder
a) Avangrid Renewables strongly opposes a simultaneous auction and strongly opposes the option to award multiple leases to a single bidder.
b) The Company strongly recommends a single monetary auction of all five lease areas, in which each bidder can win a maximum of one lease area.
3. Uniform Layouts Flexibility
a) BOEM has asked for comment on whether it should establish uniform turbine layouts, and whether these negate the need for special vessel transit measures. Avangrid Renewables supports the concept of uniform layouts but strongly opposes a requirement for specific uniform layouts. Instead, Avangrid recommends the establishment of agreements between neighboring leaseholders to adopt uniform spacing on a voluntary basis.
Avangrid Renewables' detailed responses to BOEM's Point IV, Questions for Stakeholders are found in the sections below.
Question A: Number, size, orientation, and location of the proposed lease areas
Avangrid Renewables supports BOEM's proposed number and size of the five proposed Lease Areas, with the caveat that it recommends increasing the size of 0561 by reducing the size of 0562, until their acreages are roughly equal. Within the two wind energy areas (Morro Bay and Humboldt), the lease areas as delineated provide similar amounts of energy capacity. While the Humboldt lease areas are approximately 15-20% smaller than the Morro Bay lease areas, each of the five areas can support a commercial-scale offshore wind project.
Avangrid Renewables generally supports both the size and orientation of the Humboldt and Morro Bay lease areas. However, OCS-P 0561 (Humboldt NE) is approximately 10% smaller than OCS-P 0562 (Humboldt SW) and should be right-sized to approximately equivalent acreage. Assuming the developers of the Humboldt lease areas will come to agreement on uniform spacing, shifting the lease boundaries to make OCS-P 0561 and OCS-P 0562 approximately equal acreage will levelize the competitiveness of these two lease areas.
BOEM has solicited feedback on the delineation of lease areas including possible setbacks at lease area boundaries. Avangrid Renewables anticipates the eventual need for lease boundary setbacks to accommodate the mooring system design, but strongly recommends that offsets are considered only in the permitting process and not as a lease stipulation, given the uncertainty around the setback requirements until floater and mooring system designs are selected. With regard to lease boundary offsets, there are a number of factors to consider - but it is premature for BOEM to make any changes prior to the auction. Due to mooring system footprints, as well as the drift of a floating wind turbine generator from its base position (excursion), Avangrid Renewables anticipates that a design offset will eventually be needed to prevent anchors from being sited outside the boundaries of the lease area seabed and prevent wind turbines from drifting outside the boundaries of the lease area.
The amount of required offset is highly sensitive to the mooring system and floater design.
Therefore, this lease boundary offset should be left as a design decision as part of the permitting process, rather than prescribed by lease stipulations, to maintain flexibility for multiple types of floater and mooring system designs. This will ensure that lease boundary offsets are compatible with the mooring system design, which will not be selected in the California leases for years to come as projects progress through the design process.
For example, while catenary mooring systems have been used for floating wind projects in intermediate depths to date, other solutions such as taut or semi-taut mooring lines solutions may be used at the depths of the California leases to minimize mooring footprint and excursion. These mooring systems are compatible with floater types such as semi-submersibles, spars, and barges.
Furthermore, a taut or semi-taut system can be designed with many different hang-off angles and number of mooring lines, resulting in different mooring footprints & watch circles (the radius of excursion). Tension leg platforms also offer another mooring solution that will have lower mooring footprint but also more excursion.
Because of the high degree of variability in mooring designs for floating wind farms and the ability to design these systems to different operating conditions for allowable excursion and mooring footprint, Avangrid Renewables strongly recommends that the question of lease boundary offsets not be addressed in the lease requirements themselves, but rather at the design stage.
Stipulating lease boundary offsets due to mooring constraints at this stage poses major risk of either an overly prescriptive or under-designed offset requirement that is not compatible with the preferred mooring technology at the time of project design and construction, thereby reducing lease area capacity and energy production or not providing sufficient offset. As such, Avangrid Renewables recommends that BOEM consider lease boundary offsets only at the design review stage for the Construction and Operations Plan (COP), and not as a lease auction requirement.
These offsets can be made a requirement in the COP such that mooring anchors are sited within the lease boundaries and wind turbines are not allowed to drift outside of the lease boundaries, but the various solutions that are available make this a more appropriate consideration for the project design envelope rather than a BOEM lease area stipulation.
Lastly, Avangrid Renewables requests clarification on potential future restrictions of the lease areas under consideration, specifically potential designation of areas of no surface occupancy due to designation of national marine sanctuaries, the USCG PACPARS study, the BIFROST and ECHO submarine cable systems, and Department of Defense activities. It is vital that bidders are aware of the extent to which acreage may be reduced due these restrictions or other activities prior to the California BOEM lease auction, to make informed bidding decisions. To the extent possible, Avangrid Renewables requests BOEM to publish these restrictions in the FSN to ensure the successful development of leases to their greatest allowable extent.
Question B: Engaging underserved communities
Avangrid Renewables supports the current PSN lease stipulations related to underserved communities considered in the California PSN. As a current lessee in the Atlantic OCS, and a potential future lessee in the Pacific OCS, we support investments in a clean energy economy which engage and serve local communities, particularly underserved communities, throughout the offshore wind energy development process. Lessees' project proposals should be informed by or altered to address impacts and benefits to these communities. To that end, the Company supports the requirements for increased coordination between the lessor, lessee, and stakeholders through the Native American Tribes Communications Plan (NATCP), Fisheries Communication Plan (FCP), and Agency Communications Plan (ACP) to progress communication.
As Avangrid Renewables' existing offshore wind projects, Vineyard Wind 1, Park City Wind, Commonwealth Wind, and Kitty Hawk Offshore Wind have demonstrated, coordinated and inclusive stakeholder engagement is a cornerstone of any collaborative, well-informed, and well-sited offshore wind project - including future California projects. The Company supports BOEM's and the State of California's coordinated efforts to date, and recommends continued alignment between BOEM and the State of California on reporting requirements, as stated in the California Coastal Commission's Concurrence Letter for the environmental assessment of the Humboldt and Morro Bay Wind Energy Areas:
"Condition 5. Engagement with environmental justice and local communities: BOEM will require lessees to make reasonable efforts to conduct outreach with local affected communities--and in particular to demonstrate long-term engagement with environmental justice communities, including but not limited to low-income communities and communities of color--on all elements of the lessees' project development process, including, but not limited to, a workforce plan, survey plan and SAPs, and a construction and operations plan (COP). This engagement should be coordinated to the maximum extent practicable with other Lessees in the region to reduce the burden on communities. The Lessee is strongly encouraged to compensate members of environmental justice communities for their time participating in engagement activities and events. Development of any Engagement Plan should be conducted in coordination with communities and should include strategies to reach individuals with Limited English Proficiency who may be affected by future offshore wind development."
As the United States offshore wind industry continues to grow, Avangrid Renewables aims to promote a diverse, just, and inclusive industry through active stakeholder partnerships that reflect the communities in which we work. Consistent with the Biden Administration's goal, Avangrid Renewables will advance offshore wind development "in a manner that protects coastal and marine ecosystem and advances social and racial equity and environmental justice," and already supports a wide range of initiatives through the Vineyard Wind 1, Park City Wind, Commonwealth Wind, and Kitty Hawk Offshore Wind projects. The Company looks forward to continued collaboration with environmental justice communities on socio-economic and biological resource management issues in the development of its projects.
Question C: Bidding Credits
Avangrid Renewables supports BOEM's proposal to use a multiple-factor auction format for the California lease sale as authorized under 30 CFR 585.220(a)(4) and 585.221(a)(6), however, encourages BOEM to incorporate the following modifications to the proposed bidding credits: Avangrid Renewables considers the proposed multi-factor auction format to be a strong example of an effective mechanism to promote economic development, ensure long-term benefits to local and underserved communities, and maintain a fair and equal auction competition. Therefore, Avangrid Renewables suggests an increase of the Community Benefit Agreement (CBA) credit value to 5 percent total. The Company supports other additional increases of 0% to 5% in any category, so long as the total Bidding Credit percentage is no more than 30 percent between the two categories. Specifics regarding the Workforce and Supply Chain Bidding Credits and Stakeholders' CBA are in their corresponding headings below.
Avangrid Renewables recommends that BOEM allow flexibility in the earliest funding distribution commitment deadline. In the Bidders Financial Form Addendum, BOEM states "The Lessee must provide documentation showing that it has met at least 25% of its commitment and complied with the applicable bidding credit requirements no later than the submission to BOEM of its first Construction and Operations Plan (COP) and must provide such documentation concerning the remainder of its commitment no later than the submission to BOEM of its first Facility Design Report (FDR) for the lease." Avangrid Renewables favors BOEM's approach as stated in its Carolina Long Bay PSN earlier this year, which was less prescriptive its timeline with respect to the funding distribution commitment deadline. Deferring the Bidding Credit payment commitment until FDR enables the lessees to identify the programs and recipients best suited to meet the bidding credit purpose and goals.
Particularly for the West Coast, the floating offshore wind supply chain needs further time to develop. Avangrid Renewables believes this flexibility should remain in place. Greater flexibility in the commitment deadline would allow developers to suitably allocate funds to where investment is needed most, and to potentially align private and public investments, closer to the time of project development.
WORKFORCE & SUPPLY CHAIN BIDDING CREDIT
The promising California offshore wind energy industry will require significant investments from offshore wind developers, supply chain, and local workforce development institutions to build commercial-scale floating offshore wind, meet the state's renewable energy goals, and advance the Biden-Harris administration targets of 30 GW by 2030 and 110 GW by 2050. Therefore, Avangrid Renewables supports the current proposed 20 percent bidding credit value for Workforce and Supply Chain and BOEM's proposed financial Contribution of 80 percent of the bidding credit cash value towards supply chain and workforce development. The Company also supports an increase in the percentage of credit value, but it recommends limiting the total Bidding Credit percentage to a maximum of 30 percent as stated above. The absence of a procurement mechanism or other state initiatives in California's nascent market creates uncertainty and divergence among bidders related to the bidding credit. A significant increase to the bidding credit would exacerbate these divergences and would create inefficient outcomes on auction day.
BOEM should allow other critical activities - infrastructure developments such as ports and transmission upgrades - to qualify for the bidding credit, in addition to the examples it offers in the Bidder Financial Form ("BFF") Addendum.
The large and heavy dimensions of supply chain materials (floating substructures, nacelles, blades, cables, etc.) typically require waterfront port infrastructure with quayside access for efficient logistics. Studies on the potential of the West Coast OSW Industry/1 point out that the current availability of ports facilities for different OSW activities could limit the progress and deployment of projects and their creation would benefit the supply chain and workforce. The use of the bidding credits to support the redevelopment of new and existing port facilities will provide meaningful benefits to further BOEM's goal of supporting "a more stable domestic supply chain by reducing the upfront capital or certification cost for manufacturing offshore wind components." Avangrid Renewables recommends that BOEM define the bidding credit concept of "domestic supply chain" more broadly to include not only manufacturing of offshore wind components, but also the construction logistics of marshalling, quayside assembly, and pre-installation activities, all of which require port infrastructure improvements for the efficient and cost-effective buildout of offshore wind in California.
As evidenced by Vineyard Wind 1 and Avangrid Renewables' other US East Coast offshore wind projects, reconstruction of port infrastructure to support offshore wind construction results in both port construction and offshore wind construction jobs that lead to a more stable domestic workforce and construction logistics supply chain. Vineyard Wind 1 construction activities will drive the creation of domestic offshore wind jobs at the New Bedford Marine Commerce Terminal. The redevelopment of Salem Harbor as a wind turbine marshalling port for Commonwealth Wind and Park City Wind will result in domestic port construction and offshore wind jobs. Avangrid Renewables recommends that BOEM expand the eligible bidding credits to include port development that will drive necessary port improvements that in turn support both construction and manufacturing jobs in California.
The infrastructure requirements for successfully progressing offshore wind deployment in California also include the need to expand and improve the onshore transmission grid. While network transmission upgrades may be recoverable or funded through the grid operator, project developers are typically responsible for the portion of onshore transmission upgrades that are triggered by a project's interconnection to the grid. These grid upgrades are a major source of domestic job creation, with the improvement or construction of new transmission lines and substations, much of which can be constructed by US workers. By expanding the bidding credit eligibility to include transmission, developers will have the flexibility to allocate the bidding credit funds to the most needed and job-creating activities that will be vital for the successful buildout of offshore wind in California.
The success of East Coast investments in OSW supply chain, port infrastructure, and workforce development has predominantly been driven by individual state-led economic benefit priorities as prescribed in their competitive requests for proposals. These state goals can be further met through the implementation of BOEM's bidding credits system, which is still in alignment with the federal fair return goals of Outer Continental Shelf Lands Act (OCSLA).
COMMUNITY BENEFIT AGREEMENT (CBA) BIDDING CREDIT
Avangrid Renewables supports the adoption of a CBA bidding credit and believes this credit should apply to potential programs with fishing groups as well as tribal and environmental justice groups.
Long-term success for commercial-scale offshore wind is possible only with early and frequent engagement and collaboration with local communities and shared ocean-users. To that end, Avangrid wishes to echo the considerations voiced by stakeholders and encourages BOEM to increase the CBA bidding credit from 2.5% up to 5%.
Avangrid Renewables supports the BFF Addendum proposed requirements for fair and equal auction competition and fair return. The Company also supports BOEM's rationale that "Deferring the fulfilment of the commitment until the first FDR would enable the Lessee to identify stakeholders with impacts in need of mitigation or the greatest potential to expedite or facilitate orderly OCS renewable energy development." This proposed timing allows for additional due diligence and flexibility for comprehensive stakeholder engagement to shape a CBA that can achieve a shared vision, as well as align with standard best-practice federal and state permitting timelines to support assessment and inform commercial-scale project concepts. Avangrid Renewables requests BOEM to clarify the "fulfilment of the commitment" means the execution of a CBA documentation by FDR, and that the CBA funds will be distributed over the lifetime of the project during O&M, per industry standard.
We strongly support maintaining a fair and equal playing field for community benefits, as BOEM has provided: "No part of any CBA otherwise eligible for this credit may include exclusivity or preferential clauses that prevent or disincentivize an entity, community, or stakeholder from entering into similar agreements with other OCS lessees or potential lessees." For the same reasons, we oppose any retroactive crediting to bidders for activities performed prior to the auction.
Question D: Limits on the Number of
Lease Areas per Bidder
Avangrid Renewables strongly opposes both the differentiation of California sea-space into two regions and the proposed auction format which would allow each qualified entity to bid for one lease per region and potentially acquire two California Lease Areas. The Company also strongly opposes the simultaneous auction concept that the multiple regions approach would require.
Avangrid Renewables recommends that all the Lease Areas be offered in a single auction, and that BOEM make no distinctions between the North Coast and Central Coast Regions within the auction process.
Avangrid Renewables supports one lease area per bidder in a single auction due to a variety of factors. Although the Morro Bay and Humboldt Wind Energy Areas are geographically separated, both Wind Energy Areas are ultimately intended to delivery offshore wind energy into the California market within the California Independent System Operator (CAISO). In essence, all five lease areas are within the same market and BOEM should treat them together as a single group. A single monetary auction is well-suited to manage the differences between lease areas, allowing bidders to bid different amounts for differently valued lease areas. Bidders did just that in the New York Bight auction, where the most expensive lease area sold for nearly four times the price of the least expensive lease area.
Running two simultaneous auctions will introduce at least double the complexity for bidders and auction operators versus a single auction, in what is already a high-intensity, high-focus activity.
Simplicity in this environment is paramount to avoid both bidder and operator error, both of which can be challenging or impossible to remedy after being committed.
Just as worrisome, two simultaneous auctions allow for a single bidder to win multiple lease areas in the same market. Just as in New York Bight, Avangrid opposes multiple lease areas per bidder as it introduces competitive concerns for the market. Electricity consumer concerns should be an auction design priority. Allowing one lease area per bidder benefits electricity consumers in two ways: (1) it increases the number of individual winning leaseholders and should reduce the final lease sale price (which will ultimately flow through to electricity ratepayers) and (2) it provides for greater energy supply and offtake competition and (3) eliminates the potential that a leaseholder holding two leases will hold project proposals back to concentrate on a single, initial project. Project delivery competition in north-eastern markets has consistently reduced pricing by causing project developers to compete, innovate, seek least cost options, and pursue the best procurement alternatives.
Question E: The Definition of "Affiliated Entities"
Avangrid is concerned that the current definition of "affiliate" proposed by BOEM is too broad and could result in parties being considered "affiliates" for purposes of the California lease auction even where there is no degree of control that could affect the parties behavior in the auction. For instance, if two bidders in the California auction have partnered on a project in another market or region, and by virtue of that partnership both have ownership in a common subsidiary, then under the new definition of "affiliate" proposed by BOEM those two bidders would appear to be "affiliates" for purposes of the California lease auction, even if the shared subsidiary is not participating in the California auction and the bidders themselves do not share common ownership, do not have the ability to exercise control over each other, and are not partnering for development of the California leases.
We think this issue could be fixed by more closely aligning the definition of "affiliate" with 30 CFR 1206.20, which was used in prior auctions, as follows:
"BOEM considers two entities to be affiliated if (a) one entity (or its parent or subsidiary) has or retains a right, title, or interest in the other entity (or its parent or subsidiary), including the ability to control or direct actions with respect to such entity, either directly or indirectly, individually or through any other party controls, is controlled by, or is under common control with another entity; . . ."
Question F: Tribal Governments, Ocean Users, Underserved Communities, Agencies, and Other Stakeholders Engagement and Reporting
Avangrid Renewables supports the current PSN stipulations requiring regular engagement with Native American Tribes, ocean users, and stakeholders. The Company recommends additional federal-state coordination (as recommended in Question H) to align progress report timing and improve project-by-project assessments and determinations, ultimately enhancing transparency and improving outcome resolution.
Avangrid Renewables currently provides regular progress updates to Native American Tribes, ocean users, and other stakeholders on its projects. The Company intends to leverage and build off its current approach to stakeholder engagement as a prospective California leaseholder. For its Kitty Hawk Offshore Wind project for example, the Company employs a former chair of the Mid-Atlantic Fishery Management Council as its fisheries liaison officer ("FLO"). As a well-respected member of the commercial and recreational fishing communities, the FLO is responsible for community outreach. Kitty Hawk Offshore Wind has met with Federally recognized Tribes throughout project development. The project is also preparing to launch a series of public open house meetings to inform stakeholders on project development details and offshore and onshore cable routes.
Question G: Uniform layouts
Avangrid Renewables wishes to comment on question G in the PSN on whether "BOEM should consider uniform and aligned turbine layouts in the Lease Areas. Would the establishment of uniform turbine layouts negate the need for vessel transit measures and/or areas of no surface occupancy?" Avangrid Renewables supports the concept of uniform layouts but strongly opposes the idea that BOEM require specific uniform layouts. Instead, Avangrid recommends developers be permitted to voluntarily establish agreements between neighboring leaseholders and relevant stakeholders to adopt uniform spacing, similar to the New England agreements. Layout and spacing determination are complex processes involving wind direction and wake impact analysis, mooring optimization, and navigability considerations, among other engineering considerations. Therefore, the development of uniform layouts should be the responsibility of developers and their neighbors rather than BOEM.
Avangrid Renewables notes that historically, neighboring developers have worked with relevant stakeholders, such as the USCG, fisheries, and other marine users to agree on uniform layouts among themselves. In New England, developers adopted 1x1 nm spacing to accommodate fisheries and navigation safety stakeholders. Other East Coast offshore wind projects have proposed varying uniform layouts (0.6x1nm, 0.8x1nm, 0.64x0.64nm) that have been selected via engineering design and stakeholder outreach by the developers. Avangrid Renewables recommends BOEM follow a similar approach in California, particularly considering the complex nature of floating offshore wind engineering.
Floating offshore wind complexity far outstrips that of fixed bottom offshore wind. Floating wind farm layouts must consider turbine excursion, mooring footprints, wake effects and wind direction, dynamic cable design, and navigability around turbines that are in motion. Additionally, there are several technology options for mooring configuration and platform design that could impact turbine spacing. For example, if a developer selects steel chain catenary moorings, the spacing between turbines may be impacted in ultradeep waters due to the long length of the mooring lines. If a developer should select a TLP or taut mooring design, spacing may not be impacted but other design considerations, such as the requirement for different anchor types and the installation implications of using a tensioned mooring system, will need to be analyzed. These are complicated design decisions that developers will carefully consider during the design state of a project as part of COP submission.
Further, as floating wind farms are built out globally throughout the next decade, design preferences and lessons learned may evolve, impacting developer decisions surrounding layout design.
Due to the variability of design decisions that could impact floating wind farm layout design, Avangrid Renewables recommends that a uniform layout not be stipulated by BOEM at the leasing stage. Rather, uniform layouts should be determined by a developer-led process involving engineering design and stakeholder/ocean user input. Safe navigation and vessel transit considerations would be assessed in addition to the strong engineering design component that influences floating wind farm layout design. This may be achieved by requirements in BOEM leases that lessees come to agreement for uniform layouts with adjacent leases or else be required to have a setback from the lease boundary, as was stipulated by BOEM in the New York Bight lease auction.
Question H: Industry standards for environmental protection
Regarding the question on whether there are new industry standards (e.g., technology standards, vessel standards, etc.) for environmental protection for any phase of development that BOEM should consider as requirements, the Company believes that pre-determining requirements may limit an offshore wind project's ability to utilize the best commercially available technology aligned with any phase of development. Avangrid Renewables respects BOEM's interest in considering including standards for specific environmental protection measures as lease stipulations. However, these standards (e.g., technology standards, vessel standards, etc.) will apply to future survey work in support of the Site Assessment Plans ("SAPs") and COPs, and their associated permitting processes, through formal consultation procedures. Setting these standards at the leasing stage is premature.
Question I: Vessel Transit
Avangrid Renewables is encouraged that BOEM is actively coordinating with USCG on the draft PACPARS input prior to the FSN. This is important to provide as much transparency as possible on potential reductions to lease boundaries for navigability. The Company understands the importance of evaluating safe access routes for the movement of vessel traffic, however, given the Humboldt and Morro Bay leases have much smaller contiguous zones than the East Coast lease areas, the Company anticipates that California offshore wind is compatible with vessel navigation without the further reduction of the leases for transit lanes.
Avangrid Renewables encourages BOEM to provide the most possible certainty on the developable acres considered for each of the lease areas prior to the Final Sale Notice. Specifically, clarity is needed on BOEM's potential designation of areas of no surface occupancy in the leases as part of the FSN. While it is understood that the results of the West Coast PACPARS will not be finalized prior to the BOEM lease auction, Avangrid Renewables encourages BOEM to coordinate with the ongoing work of the study to minimize potential impacts, particularly considering new fairways or vessel transit lanes that may be implemented within the lease areas after the BOEM lease auction. A preliminary warning from BOEM about potential future designation of transit lanes does not provide enough information on the developable acreage for developers to make informed decisions on project viability during the lease auction. Adding transit lanes to lease areas after they have been leased presents challenges for assessing the project viability and sizing for efficient use of the lease area prior to the auction.
The Morro Bay leases have a total of 240,898 acres and Humboldt leases a total of 132,369 acres, much smaller than or comparable to the contiguous leases on the East Coast. Additionally, there is substantial navigable ocean in the areas surrounding the West Coast leases. As such, it is expected that larger vessels will navigate around these lease areas and smaller vessels will transit around or through developer-proposed uniform layouts. Comparing lease sizes across regions, the California leases are much smaller than contiguous lease areas auctioned so far on the East Coast, even without transit lanes. New England leases have a total of 810,230 acres without designated transit lanes; instead, vessel transit has been facilitated with the developer-agreed 1 x 1 nm uniform layout spacing. Likewise, the NJ lease areas have 343,833 acres without transit lanes, and irregular proposed spacing between OCS-A 499 (0.6 x 1 nm) and OCS-A 498 (0.8 x 1 nm). In the NY Bight, OCS-A 512 and OCS-A 544 have contiguous 122,406 acres without dedicated transit lanes, provided developers can reach agreement for uniform spacing. Kitty Hawk (OCS-A 508) and Coastal Virginia Offshore Wind (OCS-A 483 and OCS-A 497) are single leases with acreage on par with the Humboldt area, with 122,405 and 114,934 acres respectively. The recent Carolina Long Bay leases, OCS-A 545, and OCS-A 546, have a combined 110,091 acres without dedicated transit lanes. All these regions enable vessel transit by implementing uniform layouts, rather than dedicated transit lanes.
New York Bight leases are the exception to this, with dedicated transit lanes between some leases on the northeast and southwest of OCS-A 539. Still, there is a precedent of 125,964 acres for OCS-A 539 without transit lanes through the zone, and between OCS-A 541 and OCS-A 542 there are contiguous 163,327 acres without dedicated transit lanes through this area (with a requirement for a yet-to-be-determined uniform spacing).
In addition to BOEM's specifically requested comments, Avangrid Renewables would like to take this opportunity to comment on the following matters:
Avangrid Renewables encourages BOEM to investigate mechanisms available to disincentivize "inflationary" bidders from placing Live Bids with the primary purpose of increasing the price of the Lease Area - with low to no risk that they themselves will ultimately win the Lease Area.
Under the current rules, a bidder can, with very low risk of winning it, increase the price of a Lease Area by placing a Live Bid in that area (as long as there is at least one other bidder there in the current round). In this case, the bidder is guaranteed to generate excess demand in the subsequent round which: i) increases the price for the next round, ii) guarantees the Auction will not meet its closing conditions (eliminating the risk that the inflationary bidder will actually have to pay its bid), and iii) allows the bidder to leave the high-priced Lease Area for a lower-priced option on the very next round.
This aspect of the current rules allows this inflationary bidder to "jump" into high-price lease areas to "punish" the higher-budget bidders who are likely to ultimately win them, and safely "jump" back to lower-budget areas or out of the auction afterwards. In the end, because this dynamic allows for nonserious bidders to drive pricing for lots they do not ultimately win, the higher value lots could be relatively overpriced as a result - still within the budget of the winning bidders, but at higher pricetovalue ratio than the cheaper lots.
This outcome is inefficient for both developers and ratepayers, and the Company encourages BOEM to investigate opportunities to increase the cost of opportunistic "jumping" - but with a close eye to avoid unintended consequences that could create other problems. We recommend BOEM retain outside expertise to ensure that any fix for this issue does not create new or additional inefficiencies or unnecessary complexity to the auction.
MITIGATE CONFLICTS WITH DEPARTMENT OF DEFENSE (DOD) ACTIVITIES AND SUBMARINE CABLES
Avangrid Renewables encourages BOEM to deconflict lease areas from other federal agency activity which may impede offshore wind development. In the PSN, BOEM acknowledges it "is aware of two planned submarine cable systems that are scheduled for installation in cable corridors that overlap the proposed Lease Areas. A planned submarine telecommunications cable system, known as BIFROST, is expected to be installed in 2023 in a cable corridor that would overlap with the southern portion of the proposed Morro Bay E Lease Area (OCS-P 0565). A planned telecommunications cable, known as ECHO, is expected to be installed in Eureka, California, in 2023 and would overlap with both proposed Humboldt Lease Areas."
With regard to DoD activity, the PSN further states: prospective bidders should be aware that site specific stipulations may be required in consultation with DoD for development within the Lease Areas. For example, the North American Aerospace Defense Command mission may be affected by the development of the Lease Areas. BOEM will coordinate with DoD and the Lessee to deconflict these potential impacts throughout the project review stage. Mitigation measures or terms and conditions of a plan approval may result from this coordination effort."
Avangrid Renewables requests that BOEM clearly stipulate that any parties need to coordinate on the placement of cables with the eventual leaseholder, regardless of whether they are installed preor post-project to deconflict the development of the area. Avangrid Renewables encourages BOEM to facilitate collaborative solutions with the DoD to allow for mixed use of the seaspace, and to identify and harmonize mitigation solutions across the three Morro Bay lease areas early as possible so that offshore wind lease areas are able to be developed to their full potential.
NATIONAL MARINE SANCTUARIES (NMS) AND SUBMARINE EXPORT CABLE ROUTES
Avangrid Renewables has identified that submarine export cable routes from Humboldt and Morro Bay Call Areas may conflict with both existing and planned National Marine Sanctuaries. Authority and processes to determine permitting for cable routing activities within NMSs are uncertain.
Avangrid Renewables asks that BOEM engages with NOAA and ONMS to provide clarity prior to publishing the FSN and encourages BOEM to coordinate with ONMS to address NMS resources within BOEM's NEPA process. The proposed Chumash NMS further increases uncertainty and presents risks - a preferred cable routing plan could be accomplished with proposed NMS boundary adjustments./2
The lease stipulation would make explicit BOEM's reservation of the right to access the lease area for purposes of future research and other activities. Avangrid Renewables encourages BOEM to provide greater transparency and communication around Research Site Access from ocean-user safety perspective. Avangrid Renewables asks that BOEM consider a standard communication protocol, including stipulation for a notification period for Site Access, rather than the current "goodfaith efforts" approach.
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Original text here: https://downloads.regulations.gov/BOEM-2022-0017-0046/attachment_1.pdf
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