Energy Central-News Article

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. 13 -- People for Offshore Wind Energy Resources has issued a public comment to the U.S. Department of the Interior. The comment was posted on Sept. 11, 2023.

The comment was on Docket No. BOEM-2023-0034-0001.

* * *

Thank you for this opportunity to respond to DOCKET NO. BOEM-2023-0034.

Of special interest to Delawareans is the 101,167 acre wind energy area (WEA) 26 nautical miles off Delaware Bay and the 78,285 acre WEA 23 nautical miles off the coast of Ocean City, Maryland, a combined 180,052 acres. A WEA off the coast of Virginia makes up the other half of the total newly proposed lease area. Although NJ developers can also access lease areas in the NJ bight, they will be competing with NY for those. So we may expect competition for ocean space with NJ as well.

The two WEAs off the Delaware and Maryland coasts comprise about half of the total that BOEM says will provide enough space for 4-8 gigawatts (GW) of offshore wind turbines. So since we're only considering half of the total lease area, we'll need to reduce the total number of proposed GW by half. Half of 4-8 GW gives us 2-4 GW. That sounds like a lot, right? Plenty for all three states, Delaware, Maryland, and New Jersey, right?

Probably not. Maryland alone has an offshore wind goal of 8.5 GW. New Jersey's offshore wind goal is 11 GW. Though Delaware hasn't settled on an offshore wind goal, the Climate Change Solutions Act requires that the state achieve net zero emissions by 2050. There is no doubt that a state lacking natural resources like rolling hills to support onshore wind and massive rivers to support hydropower will need to turn to offshore wind to meet its emission reduction goals. Just one 800 MW offshore wind project could supply Delaware with 28% of its energy needs. So for argument's sake, let's add a modest 2 GW as Delaware's goal. That brings the total need for the tri-state area to 21.5 GW of offshore wind power. The 2-4 GW's worth of ocean space proposed by BOEM begins to look fairly scanty.

Even adding onto this 2-4 GW the excess capacity of both the US Wind and 0rsted Maryland projects underway now off Delaware's coast (1.8 GW and a bit less than 1 GW, respectively), we arrive at a new total of available offshore wind development potential of only 4.8-6.8 GW. That's just 4.8 to 6.8 GW to serve a projected need of 21.5 GW. This clearly represents an inadequate provision for the current requirements.

It wouldn't be surprising if the upcoming auction for lease sites would bring unusually large sums to federal coffers because of the scarcity of total acreage. (Scarcity leads to higher lease costs, which leads to higher rate payer costs.) Experience with the 2022 auction for leases in the New York Bight shows that competition is keen for offshore wind sites, with six developers there bidding a total of $4.37 billion for 6 sites totaling 488,000 acres.

Of course, we recognize that sites east of the current sites and then even further out, off the Continental Shelf, will probably be designated in the future. The sites farthest out will undoubtedly require floating turbines, a technology that will cost more, but will not only be out of view and interfere less with ocean uses closer to shore but will also be in higher wind speed locations. The biggest hang-up here may be in timing. BOEM hasn't even begun to start the public process of examining such areas. These further-out sites may not be available when the states are ready to move, impeding both economic development and climate mitigation goals.

POWER urges BOEM to increase the size allotted to development as offshore wind farms. With goals for the tri-state MD/DE/NJ region in the 21.5 GW range, a 4.8 to 6.8 GW space will not begin to meet the need.

* * *

Original text here: https://www.regulations.gov/comment/BOEM-2023-0034-0069