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    OW Ocean Winds East Issues Public Comment to Interior Dept.


    September 6, 2022 - Targeted News Service

     

      TARGETED NEWS SERVICE (founded 2004) features non-partisan 'edited journalism' news briefs and information for news organizations, public policy groups and individuals; as well as 'gathered' public policy information, including news releases, reports, speeches. For more information contact MYRON STRUCK, editor, editor@targetednews.com, Springfield, Virginia; 703/304-1897; https://targetednews.com

      WASHINGTON, Sept. 5 -- OW Ocean Winds East LLC, Madrid, Spain, has issued a public comment to the U.S. Department of the Interior. The comment was written on Aug. 29, 2022, and posted on Aug. 31, 2022.

      The comment, on Docket No. BOEM-2022-0034, was sent to the Office of Environmental Programs at the Bureau of Ocean Energy Management.

      * * *

      OW Ocean Winds East, LLC (OW East) appreciates this opportunity for engagement with the Bureau of Ocean Energy Management (BOEM) Office of Environmental Programs concerning the Programmatic Environmental Impact Statement (PEIS) for the NY Bight offshore wind leases. The following comments are offered in response to the Notice of Intent (NOI) to Conduct a PEIS published in the Federal Register on July 15, 2022 (Docket No. BOEM-2022- 0034). As a NY Bight leaseholder, OW East comments are intended to address the potential effects that the PEIS process may have on the development of the OW East offshore wind project (Project).

      OW East, a partnership between Ocean Winds (OW), an international offshore wind energy company created by EDP Renewables (EDPR) and ENGIE (50:50), and New York-based Global Infrastructure Partners, was awarded offshore Lease Area OCS-A 0537 (Lease Area) in February 2022 by BOEM in the NY Bight area. The Lease Area covers 71,522 acres and is located 38 nautical miles (nm) off the coast of New York and 53 nm off the coast of New Jersey.

      OW East is strongly committed to sustainability and the protection of our natural resources. It is our intention to work with BOEM, other federal, state and local agencies, Native American Tribes, environmental organizations, the fishing industry, research institutions, and other key stakeholders to responsibly develop the Lease Area.

      OW East is supportive of the comments submitted by the American Clean Power Association. We provide the following additional comments for consideration by BOEM.

      OW East Supports the Goals and Intent of the PEIS Process

      OWE supports the goals of PEIS process: reducing the timeframe for the overall National Environmental Policy Act (NEPA) environmental review and Construction and Operations (COP) approval, accelerating the deployment of offshore wind in the NY Bight to meet the Administration's goal of 30 gigawatts (GW) of offshore wind by 2030 (30x30 goals), and facilitating agency consultation early in the process and ensure alignment of policies and actions across all federal agencies. Given the many offshore wind projects and COPs that have received approval, or are continuing through the COP approval processes, we believe that much can be gained by incorporating lessons learned from the previous evolving processes undertaken to date to create a more efficient process for future projects in the NY Bight.

      The PEIS Should Include a Clear Recognition and Robust Assessment of Project Benefits

      The PEIS should include robust assessments of the climate change benefits of offshore wind in support of the Purpose and Need to meet the Administration's 30x30 goals and New Jersey's and New York's clean energy goals. Major progress towards meeting these goals will result in mitigation of the severity of effects of climate change, protection of communities and the ocean ecosystem from the impacts of warming oceans, storms, erosion, and sea level rise, creation of artificial reef habitat, advancement of environmental justice and creation of tens of thousands of jobs and economic opportunity.

      To support the Purpose and Need, these benefits should be assessed in the PEIS across resource areas and all alternatives being considered should maximize the generation of clean renewable energy and minimize any "no surface occupancy" on all leases. A robust analysis of the benefits of clean energy should be included in all alternatives and be compared to the impacts (air quality, water quality, etc.) that would flow from fossil fuel use inherent in the No Action alternative.

      PEIS Assessments and Avoidance, Minimization, Mitigation and Monitoring (AMMMs) Measures should be Adaptable to a Wide Range of Project Designs and NY Bight Conditions

      The NY Bight is a vast area with variable conditions. The leases differ with respect to distance from shore, proximity to other leases, water depth, habitat, etc. We are very supportive of BOEM's approach of considering a range of project designs, rather than a maximum design scenario, and to assess the impacts of those project design ranges for each lease area. We would like to see BOEM apply this approach for all impact assessments to ensure that the PEIS assessments and AMMMs capture the reality of the wide range of scenarios.

      The OW East Lease Area is the furthest from shore of the lease areas that would be considered in the PEIS and is not contiguous with other lease areas. Accordingly, OW East would be especially concerned about a PEIS assessment that does not take into account the variability of conditions and project designs across the NY Bight. A one-size-fits-all assessment could overstate the impacts and need for AMMMs that would be recommended in the PEIS as applied to the OW East site and necessitate a significant amount of additional environmental assessment to demonstrate alternative AMMMs that are less stringent and more appropriate.

      Getting the Representative Project Design Envelope (RPDE) Right is Essential

      Developing the RPDE is an essential component of the PEIS that will provide the basis for all environmental assessments and determine the list of AMMMs. It is critical to get it right. In accordance with the Outer Continental Shelf Lands Act (OCSLA) (43 USC 1337(p)(4)(C)), the RPDE should reflect optimal lease utilization and not reduce the energy generation potential of a lease area to help meet the nation's clean energy and climate protection goals.

      The process to establish an RPDE is difficult given the variety of potential build years and possible design alternatives. Leaseholders, including OW East, will be suggesting an array of potential RPDE parameters. Confidentiality issues, especially going into OREC bid processes, will limit the amount of collaboration amongst leaseholders and the expectation is that BOEM will need to undertake much of the process to aggregate the information and select the ranges for analysis. Onshore components are particularly confidential and uncertain given that developers do not yet know where they will be making landfall/interconnecting, ongoing regulatory processes with PJM and FERC, and external forces and processes that are reshaping the transmission siting picture, like the PJM/NJ BPU's State Agreement Approach (SAA).

      In addition to requesting data from offshore wind developers, we support BOEM consulting with equipment manufacturers (OEMs) to get input for offshore elements and with NYSERDA and NJBPU to get input on onshore elements (e.g. POIs, ports, etc.). This input will ensure a more defensible PEIS.

      Once BOEM develops the range of scenarios for the RPDE parameters based on its evaluation and the above feedback, BOEM should present them to the leaseholders for comment. This will ensure a more realistic RPDE as the basis for the assessments.

      Agency Consultation and the Identification of Alternatives and AMMMs Should Maximize Lease Area Utilization and Reduce Tier 2 Environmental Review to Meet Clean Energy Goals as Expeditiously as Possible

      OW East is concerned about the outcomes of agency consultations during the PEIS process and the extent to which they will reduce consultation needs during the Tier 2 process. BOEM has stated that a key goal of the PEIS process is to reduce the amount of agency consultation needed during Tier 2. It is critical that significant progress is made to get agency input and buy-in for minimizing additional environmental review post-PEIS and that this input is provided in a timely fashion to meet PEIS timeframes presented by BOEM.

      The alternatives being considered should be realistic alternatives that maximize site utilization and do not put project viability at risk. We expect that BOEM will use its newly published guidance on the identification of reasonable NEPA alternatives to guide the development of alternatives that meet the Purpose and Need of the projects and are economically, technically, and commercially viable.

      The PEIS should clearly acknowledge and consider the considerable pre-auction reduction in the NY Bight WEAs; given that prior reduction any alternatives that further significantly reduce site utilization would both be unnecessary and run counter to federal and state clean energy goals.

      The AMMMs should address a wide range of conditions. We therefore support flexibility in the AMMMs such as performance-based approaches, to the extent possible, that allow for flexibility in design and the ability to apply lesser AMMMs based on particular site conditions during Tier 2.

      Data needs to support Section 7, EFH, and Section 106 consultations are amongst the most resource-intensive and it is unclear how the PEIS process will reduce the need for detailed Tier 2 review and consultation in these areas. BOEM and the consulting agencies should consider the availability of regional data to reduce the amount of site-specific data collection needed to support Tier 2 environmental review and consultation. Additional surveying and monitoring AMMMs should be designed to fill in specific data gaps rather than a one-size-fits-all prescriptive approach across all lease areas. There has been significant data collection in the NY Bight and it is expected that those data can support much of the development AMMMs without the need for significant additional field work to support Tier 2 environmental review.

      PEIS Assessments should Inform Parallel COP Development

      Leaseholders will be developing their COPs in parallel with the PEIS process. To minimize delays in incorporating PEIS strategies and AMMMs into the COPs, there is a need for regular and ongoing status updates and coordination with NYB leaseholders well before the Sept 2023 DEIS is issued. In addition, leaseholders should be kept apprised of resource areas that are judged to have negligible to minor impacts so resources are not spent on potentially expensive studies to assess these impacts.

      Uncertainties due to Delays in the Process would Create Risks to the Project

      The PEIS process for offshore wind is new and untested. Such uncertainty has the potential to significantly impact our Project including, for example, our ability to obtain financing. One of the main goals for the PEIS process is to reduce the overall environmental review timeframes for the NY Bight projects. Keeping to the PEIS schedule as presented by BOEM, with completion in 1st half of 2024, is critical to mitigating this very real risk to the timing for bringing critical clean energy ashore and to ensuring some level of predictability in the face of an inherently complex and uncertain process.

      Conclusion

      OW East recognizes the potential of the PEIS to create a more efficient and predictable process based on incorporation of lessons learned and early consultation and agreement on AMMMs with agencies. The AMMMs should be flexible and allow for the rapid pace of technology development and the variability of the lease areas with the NY Bight. As offshore wind is positioned to provide major contributions to the national and regional effort to mitigate climate change, timely environmental review and the development of AMMMs and alternatives that do not risk project viability are crucial.

      Thank you for your consideration of these comments. We look forward to continuing to work with BOEM throughout the PEIS process. It is our expectation that BOEM will undertake the PEIS process in keeping with the need to remove barriers and accelerate growth in America's renewable energy industries to address the climate crisis.

      Sincerely,

      John Dempsey

      Chief Executive Officer, OW East

      * * *

      Original text here: https://downloads.regulations.gov/BOEM-2022-0034-0019/attachment_1.pdf

      TARGETED NEWS SERVICE (founded 2004) features non-partisan 'edited journalism' news briefs and information for news organizations, public policy groups and individuals; as well as 'gathered' public policy information, including news releases, reports, speeches. For more information contact MYRON STRUCK, editor, editor@targetednews.com, Springfield, Virginia; 703/304-1897; https://targetednews.com

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