By David Wojick
You would think that with all the uproar over whale deaths, NOAA and the offshore wind industry would be more careful about harassing huge numbers of marine mammals. On the contrary, NOAA’s latest proposal sets a new record for needless cruelty.
NOAA’s National Marine Fisheries Service (NMFS) is taking comments on an outrageously destructive harassment proposal from Invenergy Wind off the coast of New Jersey, where whale deaths have been greatest. Here is the proposal: https://www.fisheries.noaa.gov/action/incidental-take-authorization-invenergy-wind-offshore-llcs-site-characterization-surveys-new
It is called a “site characterization survey,” and it does include a new offshore wind development site that Invenergy picked up last year with a whopping bid of $645 million. That apparently buys a lot of Federal cooperation because this is nothing like a site survey.
You see, the site is a mere 131 square miles, while the proposed sonar blasting survey area is over 6,000 square miles. In other words, the site is a mere 2% of the survey area, so it is clearly not a site survey.
What is the 98% non-site survey for? There is no actual explanation, but it is labeled the Export Cable Route (ECR) area. There is no actual export cable route, so they are surveying every place it might conceivably go. Some of the ECR area is absurd as a potential cable location, especially that which is as far out to sea as the project or further.
This possible-cable area is enormous. It runs from New York City to south of Atlantic City and from the Jersey Shore to over 50 miles out to sea. The front page of the NMFS proposal linked above has a map, conveniently showing both the tiny site area and the huge ECR area.
Not surprisingly, given this huge area, the predicted marine mammal harassment numbers are appalling:
Total = 4,730 or just under 5,000 supposedly protected marine mammals
This is needless cruelty personified. They clearly have no idea where the cables will go. That will be determined by who takes the Power Purchase Agreement, if anybody, and where they can come ashore to deliver the juice.
The results of this incredibly destructive 6,000-square-mile survey will be almost entirely irrelevant when that happens. All that will matter is what lies between the project site and the landing point. Obviously, the cable route survey should wait until that location is known, thus saving thousands of protected critters from harmful harassment.
That NMFS should propose this huge amount of needless harassment is an issue in itself. NMFS, known simply as NOAA Fisheries, seems to have abandoned its mission to protect marine mammals in favor of reckless offshore wind industrialization.
Here is their mission statement: “NOAA Fisheries is responsible for the stewardship of the nation’s ocean resources and their habitat.” These are living resources to be cared for, not industrial wind facilities.
In particular, NMFS is supposed to enforce the Marine Mammals Protection Act. Allowing the pointless harassment of thousands of marine mammals is the opposite of protection.
They cannot have failed to notice that this is not a site characterization survey. NMFS should have rejected the Invenergy proposal as absurdly overreaching and cruel.
Even worse, NMFS claims that this mass harassment of thousands of protected critters is not an environmental impact, so it does not fall under NEPA. Harassment is clearly an adverse impact, plus it can easily lead to deadly behavior. For example, it includes causing deafness which in one of the world’s busiest shipping areas is obviously life-threatening.
Given this absurdly cruel proposal, NOAA Fisheries needs to be redirected back to its mission. To begin with, the Invenergy proposal must be rejected.
David Wojick, Ph.D. is an independent analyst working at the intersection of science, technology and policy. For origins see
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