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USCG Issues Public Comment to Interior Dept.

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,, Springfield, Virginia; 703/304-1897;

    WASHINGTON, Sept. 8 -- The U.S. Coast Guard has issued a public comment to the U.S. Department of the Interior. The comment was written on Aug. 30, 2022, and posted on Sept. 6, 2022.

    The comment, on Docket No. BOEM-2022-0036-0001, was sent to the Office of Renewable Energy and Gulf of Mexico Region Office at the Bureau of Ocean Energy Management.

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    The Coast Guard has reviewed the Bureau of Ocean Energy Management (BOEM) announcement seeking public comment on two draft Wind Energy Areas (WEAs) on the Outer Continental Shelf in the Gulf of Mexico (GOM). The announcement was posted on, Docket No. BOEM-2022-0036. The Coast Guard acknowledges BOEM's goal is to identify offshore locations that appear most suitable for wind energy development, taking into consideration potential impacts to resources and ocean users. The Coast Guard appreciates the opportunity to provide comments.

    In our capacity as a cooperating agency, the Coast Guard has several equities tied to offshore renewable energy leasing opportunities. Our statutory responsibilities include safeguarding the viability of the Marine Transportation System (MTS), emergency management, navigation safety, and maritime security. The Coast Guard opposes priorities that place undue strain on the MTS or impede the execution of our statutory missions. These factors must be considered in the WEA identification process and it is critical for BOEM to resolve navigation conflicts prior to publishing an Area Identification memorandum or considering potential lease areas in the GOM.

    WEA Option Concerns

    The Coast Guard appreciates BOEM's consideration to remove any portion of Option I and Option M WEAs from future lease area consideration within two nautical miles of proposed fairway anchorages off Sabine Pass, Texas and existing shipping safety fairways, fairway anchorages, and federal lightering zones and prohibited areas as codified in Title 33 Code of Federal Regulations Subpart C.

    In addition to federal lightering zones, the Coast Guard recommends BOEM consider the navigational impacts to traditional lightering areas identified within WEA Option I. Traditional lightering areas are used extensively in the Gulf of Mexico, and while these areas are not federally designated, they are commonly used by mariners to avoid busy fairways and large concentrations of offshore exploration and production platforms. Mariners who navigate the waters in and around Option I have come to expect lightering operations to be common practice within traditional lightering areas. Preliminary vessel Automatic Identification System (AIS) data illustrates substantial tank vessel traffic indicative of lightering operations throughout Option I. The Coast Guard's initial outreach with shipping industry stakeholders regarding the use of traditional lightering areas near the proposed WEAs suggests Option I would have a significant impact on lightering operations conducted offshore Galveston and Freeport, Texas.

    Wind energy development in traditional lightering areas could restrict where and how vessels carry out their cargo transfer operations, potentially impacting access to ports, safety of navigation, and the facilitation of commerce. The Coast Guard recommends BOEM continue to conduct more extensive outreach with affected shipping industry stakeholders to identify, quantify, and mitigate potential impacts and risks to lightering operations within traditional use areas.

    Lastly, the Coast Guard would like to call BOEM's attention to figures 26 and 29 of the draft Area Identification memorandum for the GOM. Figures 26 and 29 indicate setbacks of 3,219 meters from proposed and existing fairways. This measurement equates to two statute miles, not nautical miles. The Coast Guard requests these figures be updated to reflect the agreed upon setback distance of 3,704 meters, which equates to two nautical miles. The Coast Guard appreciates BOEM's attention to remove any aliquot from leasing that encroaches upon the two nautical mile setback.

    Port Access Route Studies

    The Ports and Waterways Safety Act (PWSA) (46 U.S.C. Sec.70003) directs the Coast Guard to provide safe access routes for the movement of vessel traffic proceeding to or from ports, or places subject to the jurisdiction of the United States, by designating fairways and traffic separation schemes in the territorial seas and high seas approaches to such places. The PWSA directs the Coast Guard to protect port access routes from conflicting uses of the offshore waters by conducting a study before determining the need for, establishing, or adjusting fairways or traffic separation schemes. These evaluations are called Port Access Route Studies (PARS). The designation of fairways and traffic separation schemes as a result of a PARS recognizes the paramount right of navigation over all other uses in the applicable areas, subject to certain preexisting rights granted through leases or permits.

    The Commander of the Eighth Coast Guard District is considering the necessity of conducting a PARS for the GOM. The Coast Guard has authority to establish fairways and traffic separation schemes in areas of the Outer Continental Shelf-leased by BOEM if notice of a PARS is published in the Federal Register prior to the vesting of rights under the lease, or the notice is subsequent to the date of the lease and the fairway or traffic separation scheme would not deprive the lessee the effective exercise of a vested right granted by the lease. If a PARS for the GOM is undertaken, the Coast Guard will publish a notice in the Federal Register and collaborate with BOEM during the one to two year study period.

    Marine Planning Guidelines

    When finalizing specific WEAs, lease areas, or when approving the siting of wind energy installations once an area has been leased, the Coast Guard insists BOEM apply the Marine Planning Guidelines detailed in Enclosure 3 to Navigation and Vessel Inspection Circular 01-19.

    In addition, as the leasing process moves forward, the Coast Guard recommends BOEM require certain consistencies in the development of wind farm layouts in the GOM. Each wind farm should be organized in straight rows and columns, creating a grid pattern consisting of two lines of orientation. Common turbine spacing and layout will help facilitate navigation safety, consistent and continuous marking and lighting, search and rescue, and other uses.

    When multiple wind projects share a border, the Coast Guard recommends lessees adopt the same spacing and layout across project borders to present a single wind farm with consistent straight-line routes for transiting vessels. In the absence of common spacing and layout, the Coast Guard recommends a setback from the shared border to create a space between projects that is noticeably greater than any turbine spacing within either wind farm, providing a clear visual reference for the prudent mariner to easily distinguish two separate wind farms.

    Based on the circumstances of the project, if a noticeable space between adjacent wind farms is not feasible, additional marking and lighting to include AIS Aids to Navigation should be used to alert mariners of the change in spacing and/or orientation. Lastly, regardless of the turbine layout and location, the Coast Guard insists all mooring systems and ancillary equipment be contained inside the approved lease area as a requirement under the terms and conditions of a specific lease.

    The Coast Guard appreciates the opportunity to comment and we are committed to working collaboratively with BOEM to ensure the WEA identification process addresses navigation safety. Should you have any questions, please contact LCDR Jacob Aulner, Coast Guard Office of Navigation Systems, at, or (202) 372-3243.

    Copy: CG LANT AREA (LANT-5)

    CGD EIGHT (dpw)



    Director, Marine Transportation Systems

    U.S. Coast Guard

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    Original text here:

    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,, Springfield, Virginia; 703/304-1897;


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