CFACT Comments on the California Offshore Wind Draft Programmatic Environmental Impact Statement (PEIS)
By Craig Rucker, President
CFACT
Submitted to https://www.regulations.gov/document/BOEM-2023-0061-0189
February 12, 2025
Overview of our concerns
BOEM is taking comments on a draft Programmatic Environmental Impact Statement (PEIS) for its five floating wind offshore leases off the California coast. This is BOEM’s second offshore wind PEIS. The first was for a set of leases off New York which featured fixed bottom turbines. This is the first PEIS for floating wind turbines which are very different from the fixed turbines being built along the Atlantic coast.
Floating wind is still an immature technology with a large number of proposed designs none of which has been tested at commercial utility scale. There are just a handful of small demonstration scale projects in the world.
There are at least two useful things about this PEIS. First is a pretty good tutorial on floating wind with a focus on the California case. This is Appendix A, done by the National Renewable Energy Laboratory. They rule out a number of design options including the most popular that has been demonstrated, the spar floater. The huge range of options they present shows the immaturity of the technology
Second the PEIS includes an encyclopedic discussion of numerous potential adverse impacts of a generic floating wind project. These impacts are limited to just what is contemplated for each of the five leases so when combined for all five leases it is clear that this Program will be environmentally destructive. These adverse impacts cannot be mitigated so the correct decision is that the Program should not proceed. The No Action Alternative is the proper choice.
Here is just a short list of some of the major flaws in the PEIS
1. By far the biggest flaw is that there is no cumulative multi-lease impact assessment. The whole point of a PEIS is to do such an assessment for the entire Program. Cumulative impact can be much greater than the sum of individual project impacts especially where two or more projects are closely clustered as in this case. Thus merely listing individual project impacts is completely inadequate.
2. In many cases an adverse impact is merely mentioned with no assessment of the potential harm. This is supposed to be an impact assessment not just a list of impacts.
3. The systematic harassment of large numbers of endangered and protected species of whales and other animals is certain to occur but it is not discussed. In fact the term “harassment” only occurs twice in the entire main report. Death due to noise harassment causing deadly behavior is one of the top adverse impacts of offshore wind.
4. Moreover floating wind introduces a major non-acoustic form of harassment. This is the 3D web of potentially thousands of mooring cables each of which could be on the order of a mile long. We are talking about hundreds of square miles of deep ocean literally filled with webs of cables. Harassment is defined by the Marine Mammal Protection Act as causing behavioral change on a protected animal’s part and these monstrous webs will certainly do that. This very large scale continuous harassment should be carefully assessed.
5. The PEIS does briefly mention the threat of “secondary entanglement” in the nets, lines and other debris that are caught on the cables over time. The potential adverse effects of this deadly accumulation needs to be assessed in detail.
6. Lastly there is an extensive economics section but no mention of cost. Development of these five leases will likely cost ratepayers and taxpayers tens of billions of dollars, possibly hundreds of billions. The entire Program should cost over a trillion dollars but these staggering sums are never quantified. Job creation is treated in detail as a benefit when jobs are in fact a cost. The total cost needs to be estimated.
It is clear that this PEIS is woefully inadequate. In fact it specifically avoids those issues that justify cancelling the Program. The cumulative impact threat is treated in more detail below.
The entire Western Offshore Wind Energy Program must be assessed
A new federal report shows that these five leases are tiny compared to the yawning Programmatic EIS gap created by the Federal Action Plan for West Coast offshore wind development. To begin with the full California Program is huge compared to the measly five leases covered by the so-called California PEIS. The present PEIS document would be better called the Starter Kit EIS. Plus there is a lot of development off of Oregon and Washington.
As pointed out above the PEIS document does not address the cumulative impact of those five leases; it just looks at the generic impact of one lease. But what is really Missing In Action is an environmental impact assessment for the entire West Coast Program.
The new report bears the long title: “AN ACTION PLAN FOR Offshore Wind Transmission Development in the U.S. West Coast Region” (all caps in the original). The Action Plan is a conceptual design for transmission of offshore generation but in order to do that design you have to know where the generation is so that is included in considerable detail.
Instead of the just five leases considered in the present draft PEIS the Action Plan includes about one hundred leases by 2035. These typically occur in clusters of from 5 to 20 leases. Moreover while the total generating capacity for 2035 is 15,000 MW this grows to a massive 33,000 MW in 2050.
Each lease contains numerous huge floating turbines each anchored to the sea floor thousands of feet below with multiple mooring lines. So the environmental impact of each cluster is potentially enormous.
Even worse a series of these clusters basically line the coast especially in Northern California and Southern Oregon. Migrating species might encounter and be adversely affected by this entire series.
The list of endangered or protected species that are threatened is quite long. As pointed out above these massive 3D cable arrays are a new form of harassment under the Marine Mammal Protection Act. There are also endangered sea turtles, giant rays, etc., in jeopardy.
The PEIS Appendix A says a single turbine floater can require up to 12 mooring lines to keep it stable and in place in heavy weather. Assuming 15 MW turbines with a dozen lines each the 15,000 MW development would have 12,000 mooring lines. The 33,000 MW case would have a staggering 26,400 mooring lines, many over 4,000 feet long.
We are talking about thousands of square miles of deep ocean literally filled with webs of cables. Harassment is defined by the Marine Mammal Protection Act as causing behavioral change on a protected animal’s part and these monstrous webs will certainly do that. This very large scale continuous harassment should be carefully assessed.
The PEIS also describes the threat of “secondary entanglement” in the nets, lines and other debris that are caught on these cables over time. The potential adverse effects of this deadly accumulation needs to be assessed in detail before any offshore projects are approved. Note that this threat accumulates over time, throughout the entire life cycle of a project.
Capping harassment diminishes the adverse impact of this offshore wind development
The clear solution to these mooring line threats is to severely constrain the number of harassment authorizations. With these very limited authorizations very few new offshore wind projects can be built. Nor should they be since they are environmentally destructive. Each project requires a large number of authorizations so drastically reducing their number drastically reduces the number of offshore wind projects.
The simplest way to do this is to cap the total number of wind authorizations that will be issued throughout the Program for a given exposed population. This is analogous to capping the emission of dangerous pollutants. One could even have a cap and trade program where developers bid for authorizations just as they now bid for leases. The 1990 cap and trade program for power plant sulfur dioxide emissions is an obvious analog.
If the cumulative harassment were limited to say 10% of the exposed population of each threatened species this would severely constrain offshore wind development.
In summary the so-called California Programmatic Environmental Impact Statement is nothing of the kind. The full Offshore Wind Program needs to be assessed for the entire West Coast before any project is approved for construction. This required assessment is Missing in Action.
Based on this assessment the cumulative impacts then have to be minimized. Capping the authorized harassment of each threatened species may be the best way to avoid destructive impacts.
Respectfully submitted,
Craig Rucker
President
CFACT
Washington, D.C.
“hundreds of square miles of deep ocean literally filled with webs of cables”
“We are talking about thousands of square miles of deep ocean literally filled with webs of cables.”
Well, no, not “literally”. I do not think you know what that word means.
The web goes from sea surface to sea floor for the entire volume under the array of floaters. Would you prefer “completely filling”?
It’s still 99.99% water. It’s not completely filling. Literally, it isn’t.
“cluttered by”
“littered with”
“infested with”
“obstacle course”
Any number of ways to say too damned many cables without abusing “literally”.
People literally don’t know what ‘literally’ means
A web does not have to fill every cubic unit to fill a space. A spider web can fill a window. The floater webs fill the sea.
So you are invoking an overly narrow concept of fill.
No. I’m invoking a literal concept of literal.
No it does literally fill the ocean under the array in the sense that webs fill spaces.
No it literally does not. There is something literally contradictory about using “literally” non-literally.
In almost everything else, my attitude is that if something said is understandable, it is good grammar, regardless of what the grammar nazis say. I do understand your meaning. But using “literally” non-literally is literally self-contradictory. It robs the word of any meaning, and makes the sentence look like just so much hyperbole, worthy of any politician or alarmunist.
Maybe you should use “figuratively” as less abusive.
Or here’s a more practical description of why “literally” was wrong.
Throw some clothes in a suitcase until it is “full”. Is it literally full? Not if you can push them down to squeeze out the air and get another shirt in there. Eventually it will be literally full of shirts, even if there is room for air, or socks at each end.
Is that ocean literally full of cables? Not if you can add more cables. Think of that suitcase of clothes. Suppose you cut cable into lengths to fit. You can fill it such that no more cables can fit. Their round shape means there are gaps for air or water, or even cables with sufficiently smaller diameter. I’m willing to go along with the statement that the suitcase is literally full of 1″ cables, when no more 1″ cables can fit. But if you could work in 1/16″ cables, then no, it is not literally “full of cables of any size”.
Literal has a specific meaning.
Or the article could have said “The ocean would be literally too full of cables for whales to enter.” I don’t believe that would truly be the case, as far apart as those things are, but it would not literally abuse the word “literal”,
Well, we have literally wasted half a morning discussing the use of literally.
Agreed.
Question for you, David:
“This is BOEM’s second offshore wind PEIS. The first was for a set of leases off New York….”
What about the CVOW project off of Virginia? Did it have a PEIS? Just asking for accuracy, not making a point.
CVOW has a singe project EIS as do all the approved projects but the NY Bight 5 project PEIS was the first multi-project EIS.
CFACT is suing BOEM and Dominion for failing to consider CVOW’s contribution to the cumulative impact of the entire East Coast OSW Program. That point is made in these comments for the West Coast as well.
These anchoring cables, plus electrical cables dangling down from each 850 ft tall, floating windmill, and the electrical cables running to numerous AC to DC conversion stations on land, and from there, long distances, to users, is a super-expensive nightmare, the extent of which is just now becoming clear in Germany and the UK, both of which have the highest electric rates in Europe and near-zero, real-growth economies, and declining living standards, and populations, that are already totally upset, due to the Euro elites encouraging, coddling, catering to the uninvited folks coming from all over by the tens of millions.
The in-grown, self-serving, political Euro elites, in censoring, obfuscation, finger-pointing mode, are trying to save their demise, especially after being ignored by Trump & Co.
Lots of dumb phrases in modern English that chap my hide:
“moving forward”
“the narrative” (always singular?)
“like”
The use of one here (“literally”) should not detract from the importance of illustrating the stupidity of ocean wind turbines.
A sh!tload of cables? A fu@kton of cables? Too f@cking many cables? A rats nest of cables?
The US and Canadian Pacific coast is a major migratory path for both marine mammals and birds, both of which would be adversely affected by offshore windmills. Playing word games does not change that.
Story tip
https://7news.com.au/news/scientists-say-ai-could-help-save-struggling-great-barrier-reef–c-17707295
Scientists say AI could help save struggling Great Barrier Reef
😅
So in 10 years, when nothing continues to happen, they’ll be able to claim that they saved the Reef!
Interesting how the reporter doesn’t bother to check the current status of the GBR, which is super healthy right now. Shows they don’t really care.
There’s a word I can’t think of, for when you cover over something that’s ugly and you don’t want to look at with white paint. Brain fog, I guess.
Whitewash? Certainly true here.
Hey, as long as there is no harassment to the delta smelt then full steam ahead.
What idiot actually thinks wind farms in Pacific off US west coast is a good idea? And further, why has that idiot not been locked up and forcibly medicated? Just stand on the shore and watch one moderately severe storm system come ashore. That alone should put an end to this stupidity.
Don’t wait for a hurricane. That would be a long wait.
Sorry, I don’t understand your comment.
The West Coast doesn’t need hurricanes. A couple winter storms out of the Gulf of Alaska will do the job.
Good point. California is the first idiot with a target of 25,000 MW of floating wind likely to cost over a trillion dollars. The Bidenistas were the second.
Didn’t Trump ban or delay any offshore development of wind power for the East and West coasts of the the United States just like Biden did with oil and gas?
Yes no new permits but the five CA lease projects are far from the permitting stage at this point. Here’s hoping for a permanent ban which is under study per the Trump Executive order.
This strong article should reach the hands of new EPA Director, Lee Zeldin or, perhaps better yet, the hands of Energy Minister Chris Wright. It would be an instant ‘game over’ for all that useless, needless, bird – whale killers, most expensive and intermittent ‘unsustainable’ renewable nonsense, parasites of every grid and every economy,
Well said Doug. However OSW is all under BOEM in the Interior Dept under Burgum so EPA and DOE have little to do with it. We just sent Burgum a letter hoping to kill the existing permits for all permitted projects.
See https://www.cfact.org/2025/02/14/coalition-to-burgum-stop-offshore-wind/.
Hopefully killing the leases comes next. Permits are easier and that buys lots of time.
Steel cables?…..in salt water? Scotty, I think we have a problem.
Well, semisubmersible drilling rigs have been using steel anchor chains and wires for decades and they sill seem to work.
The Golden Gate bridge has huge cables that are not submersed but the cables are constantly being painted….is it for nothing?
Those cables are not underwater, they are in maritime air which is very corrosive. You need salt water and lots of oxygen for abundant rust.
On the outside of a ship the most rust tends to be on the area which is often in the air, i.e. the area between loaded trim and ballast trim. The area which is always underwater doesn’t rust much, it is painted with antifouling paint to stop barnacles etc, and barnacles won’t bother mooring chains or wires.
“The entire Western Offshore Wind Energy Program must be
assessedSCRAPPED.”Agreed and we sort of say that. In NEPA-speak the no action alternative is the correct one. DON’T DO IT.
President Trump is spoken ill of wind turbines, and I will be waiting patiently for him and Congress to pull the funding and political support for these contraptions.
HIGH COST/kWh OF WIND AND SOLAR FOISTED ONTO A BRAINWASHED PUBLIC
What is generally not known, the more weather-dependent W/S sources, the less efficient the other, traditional generators They have a hell-of-a-time to counteract the ups and downs of W/S output.
https://www.windtaskforce.org/profiles/blogs/fuel-and-co2-reductions-due-to-wind-energy-less-than-claimed
.
At about 30% W/S, the entire system hits an increasingly thicker concrete wall, operationally and cost wise.
Germany and the UK are hitting that wall more and more hours each day
.
Base-load nuclear, gas and coal plants are the only rational way forward, plus the additional CO2 is very beneficial for additional flora and fauna growth
https://www.windtaskforce.org/profiles/blogs/we-are-in-a-co2-famine
.
US gravy-train subsidies are:
1) Federal and state tax credits, up to 50%
– Community tax credit of 10 percent
– Base tax credit of 30 percent
– State tax credit and other incentives of up to 10%
2) 5-y Accelerated Depreciation write off of the entire project
3) Deduction of interest of borrowed money
.
The subsidies reduce the owning and operating cost of a project by 50%, which means electricity can be sold at 50% less than it costs to produce.
Utilities pay 15 c/kWh, wholesale, after 50% subsidies, for electricity from fixedoffshore wind systems
Utilities pay 18 c/kWh, wholesale, after 50% subsidies, for electricity from floating offshore wind
Utilities pay 12 c/kWh, wholesale, after 50% subsidies, for electricity from larger solar systems
.
Excluded costs, at a future 30% W/S annual penetration on the grid, based on UK and German experience:
– Onshore grid expansion/reinforcement to connect distributed W/S systems, about 2 c/kWh
– A fleet of traditional power plants to quickly counteract W/S variable output, on a less than minute-by-minute basis, 24/7/365, which leads to more Btu/kWh, more CO2/kWh, more cost of about 2 c/kWh
– A fleet of traditional power plants to provide electricity during 1) low-wind periods, 2) high-wind periods, when rotors are locked in place, and 3) low solar periods during mornings, evenings, at night, snow/ice on panels, which leads to more Btu/kWh, more CO2/kWh, more cost of about 2 c/kWh
– Pay W/S system Owners for electricity they could have produced, if not curtailed, about 1 c/kWh
– Importing electricity at high prices, when W/S output is low, 1 c/kWh
– Exporting electricity at low prices, when W/S output is high, 1 c/kWh
– Disassembly on land and at sea, reprocessing and storing at hazardous waste sites, about 2 c/kWh
Some of these values exponentially increase as more W/S systems are added to the grid
.
The economic/financial insanity and environmental damage of it all is off the charts.
No wonder Europe’s near-zero, real-growth economy is in such big do-do
That economy has been tied into knots by inane people.
YOUR tax dollars are building these projects so YOU will have much higher electric bills.
Remove YOUR tax dollars using your vote, and none of these projects would be built, and YOUR electric bills would be lower
How close to these cables do whales and dolphins have to be, before they can detect them?
Would it be possible for a whale to not be able to detect this web of cables before it becomes entangled in the web of cables?
A very good question that shoukd be answered before proceeding. In addition there is “secondary entanglement” because the cable web will collect lost nets, lines and other debris that critters can get tangled in. And not just whales as there are lots of marine mammals in these waters. Elephant seals dive thousands of feet.
I don’t have the references handy, but bottlenose dolphins can detect a thin piano wire and I recall that a more pelagic one is not as capable which makes sense. However, there is along history of animals biting and disturbing cables and I have an example of a fish biting a seismic cable off the Mississippi delta laid in the mud. It’s been quite awhile but had to research fish biting cables in water and sediment which is a difficult subject. Question is whether it is an electrical attraction or accident while feeding. Gray whales feed on the bottom and the subject should have been researched for all this.
Anderson, E. M. and J. R. Lovvorn. 2008. Gray whales may increase feeding opportunities for avian benthivores. Marine Ecology Progress Series. 360:291-296. https://doi.org/10.3354/meps07359.
Haedrich, R. L. 1965. Identification of a deep-sea mooring cable biter. Deep-Sea Research. 12:773-776. https://doi.org/10.1016/0011-7471(65)90798-9
Sudis, called barracudinas, with knife-like, serrated teeth, 600-800 meters, not very big and often found in stomachs of larger fish.
How about this one, sperm whales.
Heezen, B.C. 1957-1958. Whales entangled in deep sea cables. Deep Sea Research. 4:105-114.
https://doi.org/10.1016/0146-6313(56)90040-5
There is no good reason to consider offshore or onshore wind farms. Fossil fuel and nuclear are far superior.
The more we spend the less we get.
https://cei.org/blog/wind-subsidies-are-rising-but-wind-power-production-isnt/
Government subsidized projects have yet to produce Environmental Impact Reports. To date, all wind and solar generation of electricity has been funded by government subsidies as NONE have been financed by private entrepreneurial investor funds.
All those subsidized renewable projects have yet to be accountable for Environmental Impact Reports (EIR’s) that details the life cycle for renewables that runs from design, procurement, and construction through operations, maintenance, and repair, as well as the life ending decommissioning and disposal or recycling and restoration of the landscaping back to its original pristine condition, so the question for our conversation is:
· Why are government subsidized renewable projects toward wind, solar, and electric vehicles EXEMPT from the same Environmental Impact Reports that extensively discuss decommissioning, recycling, and restoration of the landscaping back to its original pristine condition for wind, solar, and EV battery materials, when they are required when those projects are funded with private money?