Program Manager
Office of Renewable Energy
45600 Woodland Road
Sterling, Virgina 20166
Re: Comments on SFWF Draft EIS January 2021
Dear Program Manager:
With a project as significant as this Proposed Action it is necessary to have a good understanding of potential impacts and approaches to minimize those impacts early in the planning process. This Draft Environmental Impact Statement (DEIS) is an attempt to identify those impacts and how the Proposed Action will minimize them to the extent possible. There seem to be several instances where this document fails to provide sufficient detail or simply fails to assess certain potential impacts. These comments are provided as input to the decision making process relative to the DEIS but should not be taken as exhaustive in nature. These comments are based on examination of sections of the DEIS; additional issues may be discussed at a future date after further examination of this document that is approximately 600 pages in length.
First, the DEIS fails to even consider impacts to private recreational fishing. The only recreational fishing
mentioned in the DEIS is for hire, Charter and Party boat fishing, while in fact, private recreational fishing on
Cox Ledge in the area of the SFWF is the most economically important fishery for that area when impacts are estimated using NOAA’s report of “Fisheries Economics of the United States, 2016”. Simply because there is little data available for Private Recreational Fishing is not a reason that it should not be considered. The DEIS is flawed by not including an analysis of potential impacts to Private Recreational Fishing and therefore needs to be rewritten.
BOEM, NOAA, OWE Developers and angler groups need to immediately launch a study to determine the level of recreational fishing in each of the OWE areas including SFWF. This study would give an indication of the number and type of fishing trips to each OWE area so that NOAA economic data can be used to estimate the value of that activity. The American Saltwater Guides Association, the Rhode Island Saltwater Anglers Association and other industry groups would be willing to participate in and contribute to this type of study.
Second, the summary tables Table ES-1. Key Environmental Impact Statement Findings for the Proposed Action and Table 2.3.1-1. Comparison of Impacts by Alternative are misleading when they characterize impacts of the proposed action. For example, Table ES-1 lists impacts of the proposed action on benthic habitat, essential fish habitat, invertebrates and finfish during construction and installation as “a negligible to minor adverse effect on for benthic resources, minor for EFH (essential fish habitat), and negligible to minor for invertebrates and finfish” while the detailed analysis of Biological Resources on page 3-23 includes a table of expected impacts to finfish (Table 3.4.2-3.). This table lists likely injury to finfish greater than 2 grams in size out to a radius of 39,265 feet from each monopile during installation. This is a diameter of 12.9 NM. In no way could this be construed as “a negligible to minor adverse effect”.
This section should indicate the level of “harm” that may be inflicted on fish close to the source compared to the level at a greater distance and also include a discussion of the radius around active pile driving wherein fish mortality may occur. Since many readers depend on reading the summary tables without diving into the full document, these types of misleading statements are very important and need to be corrected.
Installation of monopile foundations not only produces significantly more sound energy compared to jacketed
foundations, but the resulting in-water structure is monolithic with far less area for marine growth and less
habitat in comparison to jacketed foundations such as those used for the Block Island Wind Farm. The third
bullet in the next section refers to a potential improvement to aid development of new complex bottom habitat
at the base of each turbine.
Not only are monopiles less beneficial for marine growth, but they also are far more dangerous during
installation. A monopile foundation must not only support the weight of the full turbine system, but it must
resist the twisting and turning stresses caused by the wind acting on the long arm of this single shaft from the height of the hub to the bottom of the ocean. This is much different than the jacketed foundation which relies on four legs nailed into the seafloor at an outward angle with cross bracing between the legs for additional support.
For this reason, the BIWF needed roughly three-foot diameter piles driven down through the hollow legs, but
the new turbines will require 36-foot diameter monopiles driven straight down through the sea floor. We do not know the energy requirements for each because they depend on many design factors, but the energy required for pile driving is dependent on 2 primary factors: pile end resistance and pile side surface resistance. A 36-foot pile has a cross section that is 230 times as great as a 3-foot pile and a surface area per foot of length that is 10 times as great. This means that energy requirements are hundreds of times as great for driving these monopiles compared to the piles needed for the jacketed foundations used at BIWF. Even with 4 piles per foundation the impact of underwater sound energy would be much less during installation of jacketed foundations and a comparison of sound impacts using the two basic designs should be included in the DEIS.
Next, in Appendix G, Table G-2 Potential Additional Mitigation and Monitoring Measures appears to contain
measures that were considered but not included as a part of the Proposed Action Alternative. There are several measures listed there that could contribute to significantly reducing potential impacts and therefore should be included as part of the Proposed Action Alternative and included as requirements for the proposed project.
These include the following:
An anchoring plan – Due to the importance of Cox Ledge as an area of Essential Fish Habitat (EFH) it is very important to minimize disturbance to the complex bottom structure to the fullest extent possible. Requiring an Anchoring Plan for any vessel associated with the construction of these platforms which need to anchor would help control additional and unnecessary destruction of EFH.
Post installation cable monitoring plan – Considering the issues that have already become evident with the BIWF cable becoming exposed and considering the shifting nature of bottom sediments in areas where the cable for SFWF will be installed, it is very important that the developer include a robust plan to monitor the cable and include actions that will be necessary if the cable becomes exposed.
Monitoring and minimizing scour protection – With the EFH present in the area of the SFWF installation of scour pads must be minimized so that alteration of this EFH is no greater than necessary. Rather than simply placing engineered rip-rap in a circle up to 112 feet out from turbine bases, complex scour
protection needs to be employed. This should include 3 dimensional structures such as large reef balls that will both reduce the need for large scour pads by dispersing currents near the sediment surface and make up for some of the complex bottom habitat that is lost during installation of the monopiles and scour protection required (for reference see p.31 of our January 2021 newsletter). This step could contribute to a positive effect on fish habitat at the base of the OWE platforms and could add to the reef effect that has been discussed in the DEIS.
Pile driving sound source verification – It is well understood that driving monopiles greater than 30 feet in
diameter will require a huge amount of energy. How that energy is created and how it propagates through the
water and seafloor must be well understood if there is any chance of verifying that the required maximum noise levels and minimum attenuation are achieved. Remedies such as bubble curtains and containment sleeves may not achieve the anticipated level of sound reduction due to transmission of sound and shock movement through the seafloor. Sound source verification will help assure that the required 10dB reduction in sound is achieved.
Pile driving monitoring plan – As the previous comment, since pile driving has the potential to harm fish for miles around the active area a robust monitoring plan is critical to assuring that impacts are identified and
minimized to the extent possible. Agree with monitoring.
PSO training – Since protected species observers (PSOs) will be tasked with determining when protected
species are in the area and therefore the operation is required to be modified or stopped, a rigorous training of PSOs is necessary. This training may necessitate use of technology to enhance siting and identification of
particular species.
Geophysical survey vessel collision avoidance – Geophysical survey vessels are already operating in the area of SFWF and the proposed cable route. These vessels are already impacting the EFH of Cox Ledge with loud sounds and repeated passes through an area. There should be PSOs on every geophysical survey vessel to help avoid strikes of turtles and marine mammals and these PSOs should be using this time during ocean operation of geophysical survey vessels to begin collecting data on biological resources in the SFWF area.
Offshore wind energy (OWE) developers to fill scientific survey needs – NOAA fisheries conducts regular
biological surveys in the OWE area. NOAA has already indicated that they will not be able to conduct some of these surveys after construction of OWE projects. This will leave a data gap that will increase the percent error of the data set and therefore reduce allowable landings due to uncertainty. If such an impact is seen due to placement of OWE structures then Orsted and other OWE developers should have a plan agreed to by NOAA fisheries whereby they provide funding to NOAA fisheries to supplement fisheries data collection to an extent that at least makes up for any losses of data collection due to OWE installation and operation.
Section 3.4 Biological Resources identifies the area of Cox Ledge where SFWF is to be located as Essential
Fish Habitat (EFH) for more than 25 marine species, many of which are very significant species for commercial or recreational fishing or both. In consideration of this fact and the statement that this project will impact up to 354.8 acres of seafloor, the DEIS should include at a minimum how the Proposed Action will include construction of new fish habitat that exceeds the 354.8 acres that will be impacted, where and how this new habitat will be constructed, and how this new habitat will be monitored to assure that it develops into a high quality habitat that will make some accommodation for impacts to 354.8 acres of EFH. In addition, considering that the Proposed Action has such significant impacts to fish (as referenced above, injury to finfish greater than
2 grams in size out to a radius of 39,265 feet shown on p. 3-23) and is located in an area of EFH with major
concentration of existing fishing, the Proposed Action should include an analysis of alternatives that do not
require the enormous energy necessary to drive monopiles into the seafloor. Those alternatives that should be considered include gravity foundations, helical piles, floating platforms, jacketed foundations which require much lower energy levels for pile driving, or other alternatives that do not result in the level of impact that would result from the Proposed Action.
Section 3.5 Socioeconomic and Cultural Resources includes a lengthy discussion of Commercial Fisheries in the general area and the potential for impacts to commercial fisheries operations by the Proposed Action. It even includes a brief discussion of For Hire recreational fishing in the form of Charter and Party boat operations, but does not even mention Private Recreational Fishing or the impacts that the Proposed Action will have on this sector. Cox Ledge is an area that is of critical importance to recreational fishing for boats from RI, MA, CT and NY. The failure to even consider the extreme harm that the Proposed Action may have on this major fishing industry is a flaw that requires rewriting of the DEIS.
Even though the DEIS includes significant characterization of the geology of the area, information collected
through extensive geophysical surveys of the area over the last 2 years, it contains no new information about the biological resources that are key to the existing fishing interests in the area. This is because while developers have been devoting significant resources to geophysical surveys they have spent very little time or money surveying existing fish resources and recreational or commercial fishing activities in the area. This failure to collect necessary data on fish and fisheries including recreational fishing leads to insufficient ability of the DEIS to predict impacts of the Proposed Action to existing fish resources.
Although there are many species which are important to recreational anglers in the SFWF area, the key species of interest in this area is the Atlantic Cod, Gadus morhua. Cod in the Cox Ledge area are considered part of the George’s Bank stock and this stock is listed as “Overfished” by NOAA Fisheries. Rebuilding plans have required allowable catch to be drastically reduced in recent years in an attempt to end overfishing of this stock and area closures have been implemented to protect areas of critical habitat. Cox Ledge has been shown to be an area of Essential Fish Habitat (EFH) in the DEIS and so will play an important part in rebuilding this stock of cod.
NOAA Fisheries states that Complex Habitat such as that in moraines, including Cox Ledge is critical to
survival of juvenile cod. In 2015 the New England Fisheries Management Council even proposed Cox Ledge as a Habitat Management Area (HMA) because of the importance of this area in rebuilding the George’s Bank Cod stock. Nevertheless, the DEIS does not consider the impact that the Proposed Action may have on the cod stock or the ability of the cod stock in Southern New England to rebuild.
In light of the importance of cod in the area of the SFWF the DEIS needs to include more consideration of
potential impacts to cod and more consideration of design changes, location changes, and operational changes both during and after construction that may reduce impacts on critical fish stocks such as cod. This is especially important since they are currently in a rebuilding phase according to NOAA Fisheries.
Thank you for the opportunity to provide these comments.