CFACT, the Heartland Institute, and the American Coalition for Ocean Protection submitted joint comments representing their Save the Right Whale Coalition to the Bureau of Ocean Energy Management (BOEM) criticizing BOEM’s North Atlantic Right Whale (NARW) offshore wind strategy (OSW). The comments can be read in full here:
To: Bureau of Ocean Energy Management
Re: Docket ID: Boem-2022-0066-0003
December 2, 2023
BOEM and NOAA fisheries North Atlantic right whale and offshore wind strategy
CFACT, along with the Heartland Institute and the American Coalition for Ocean Protection, respectfully submit the following comments on “DRAFT BOEM and NOAA Fisheries North Atlantic Right Whale and Offshore Wind Strategy, October 2022″
The proposed NARW/OSW Strategy fails to properly address the clearly great risks to the NARW population posed by OSW operational noise. It also does not address the extensive research required to accurately assess these risks. This alarming threat is explained below.
To begin with, the general OSW risks are laid out as a series of scientific hypotheses in this BOEM document: Kraus SD, Kenney RD, Thomas L, 2019. A framework for studying the effects of offshore wind development on marine mammals and turtles. Boston (MA): Massachusetts Clean Energy Center and U.S. Department of the Interior, Bureau of Ocean Energy Management. 48 p.
The six listed adverse impact hypotheses are these:
Hypotheses relating to short‐term effects of wind energy developmentHypothesis 1: Construction activities result in displacement of whales or sea turtles away from activity locations.
Hypothesis 2: Construction activities disrupt critical behaviors of whales or sea turtles, such as feeding, socializing, or nursing.
Hypothesis 3: Construction activities cause elevated stress hormone levels in whales or sea turtles.
Hypothesis 4: Construction activities cause zooplankton or fish prey to change their vertical distribution, density or patch structure.
Hypotheses relating to long‐term effects of wind energy operation
Hypothesis 1: Wind turbine presence either excludes or attracts whales and sea turtles. Hypothesis 2: Wind turbine presence affects long‐term feeding opportunities for whales and sea turtles.
Note that the four construction risk hypotheses specifically refer to things like displacement, disrupting critical behaviors, elevated stresses and prey effects. In contrast the two operational risks are very vague.
This unfortunate focus on construction risks is continued in the Strategy, which says this:
“Though many activities associated with OSW operation and construction produce noise, this Strategy currently focuses on quieting pile-driving and vessel noise.”
Recent research, however, indicates that operational noise may be by far the biggest threat, to an alarming degree. See: Impact of continual large turbine operational noise on the migration of the North Atlantic right whale; Presentation to the North Atlantic Right Whale Consortium, by Bob Jones, October 26, 2022.
In round numbers some preliminary research results and key issues are listed below, in greatly simplified form.
The extreme threat of operational noise — 10 key issues
1. NOAA guidance lists 120 decibels (dB) as a safe limit for underwater sound.
(Note: underwater dB readings are 62 dB greater than airborne dB for the same sound level.)
2. Research suggests that a 10 MW turbine generates 180 dB underwater, which greatly exceeds the 120 limit.
3. Moreover the distance until the level drops to 120 dB might be over 20 miles, depending on conditions. This gives a circle of over 1,200 square miles that is over the safe 120 dB, for each turbine.
4. Thus in a wind farm the above 120 dB noise from each turbine overlaps and combines with the over 120 dB noise from ALL the other turbines. The complexity of shallow water acoustics and wind variability could easily cause these combined sounds to be confusing to the whales. Disruption of migrating mother and child communications are a particular concern.
5. Presumably a 14-15 MW turbine is significantly louder, how much worse we do not know. This is a central research question.
6. Research also suggests that seven 10 MW turbines together raises the sound level to 188 dB, which is a lot. It is close to the pain threshold for human hearing.
7. This multi-turbine increase should also significantly increases the above 120 dB loudness area. How much is a major research question.
8. The loudness and the above 120 dB loudness area of a hundred or more turbines should be much greater than these numbers. For example the Virginia project phases 1 & 2 combined has about 350 turbines of 15 MW each, a huge noisy array.
9. We have no idea what the loudness and above 120 dB areas are for the numerous proposed offshore wind farms. Clearly in each case there will be a wide wall of extreme noise, potentially pushing the whales into nearby ship traffic.
10. How loud and how big these various wind farm noise walls will be are research questions that must be answered before environmental impact can be properly assessed. A great deal of modeling will be required.
Case study: Coastal Virginia Offshore Wind
The Virginia project is one we have looked at carefully. Let’s focus on the huge 2,600 MW Virginia phase 1 OSW project, even though the other East Coast projects multiply the threat. Note that if each proposed OSW project kills just one whale a year, then extinction of the 300 or so remaining North Atlantic Right Whales is assured.
Dominion’s Construction and Operation Plan (COP) provides the necessary navigation data in Appendix S: Navigation Risk Assessment. Ironically this assessment is all about the risk to ships, not to whales.
The project creates what amounts to an intense noise wall that the whales will undoubtedly go around, either to the East or to the West. To the East lies the westernmost lane of the very busy coastal ship traffic. To the West lies the equally busy coastal barge traffic. Both are deadly.
It seems the project was deliberately located where there is the least shipping traffic. This would make sense if it were not for displacing the whales. As it is the project closes the low shipping corridor, which the whales probably use. Being hit by ships is the leading cause of death to the whales.
Just to be clear the noise is extreme. As explained above, new research suggests that a mere 10 MW turbine creates a great deal more noise than the relevant NOAA standard says is safe for marine life. But the Dominion COP calls for 15 MW turbines, which are clearly much noisier than 10 MW units. Moreover there are almost 200 of these monster 15 MW turbines. (Land turbines typically run just 2-3 MW.) We have no idea how much louder 200 or so of these 15 MW turbines are than one or seven 10 MW turbines are. Enormously louder is a good bet.
So the existence of the huge noise wall looks incontestable. Stretching many miles across the continental shelf, blocking the twice annual whale migration. Forcing the migrating whales into heavy traffic, to be killed.
Conclusion and recommendations
This now obvious extreme threat to the severely endangered North Atlantic Right Whales does not even show up in the draft BOEM/NOAA NARW Strategy.
A reasonable mitigation strategy would be to have an OSW Noise Exclusion Zone. This might be a coastal migration zone, say 30 miles wide, where offshore wind facility noise did not exceed 120 dB. Where each proposed wind farm would need to be located to meet this noise standard is part of the research need outlined above.
Speaking of research, the Strategy seems to regard adverse impact research as something to do during construction and operation. This is unacceptable as it treats the whales as laboratory animals. We cannot first build these potentially fatal facilities then study how much damage they do.
The severe threat hypotheses must be resolved before construction can begin. The necessary research is in fact an integral part of the required environmental impact assessment. A number of state of the art 15 MW test turbines need to be built to determine their noise levels under various wind conditions.
Thus in addition to the predicted loudness and spatial extent of the excessive operational noise, research needs to consider the likely impacts on the whales. As with construction noise, these potentially adverse impacts include stress, confusion, loss of communication, and dangerous behavioral changes. Given the whales extreme endangerment there is little room for error.
The whales must be made safe before construction begins, including an appropriate OSW Noise Exclusion Zone.
Respectfully submitted,
David Wojick, Ph.D.
Senior Analyst and Advisor
CFACT
H. Sterling Burnett, Ph.D.
Director of the Arthur B. Robinson Center on Climate and Environmental Policy
The Heartland Institute
David T. Stevenson
Director of the Center for Energy & Environment
Caesar Rodney Institute