Save Right Whales Coalition Year to Date Summary

Dear Save Right Whales Coalition members, friends, and followers,

I hope this email finds you well. Our collective network of people and groups continues to grow, and I’m pleased to report our work is getting important attention! 

SRWC has conducted detailed investigations into the offshore wind developments, and we’ve been very proactive in getting the message out to the right people. A SRWC whitepaper is in the works that consolidates our findings. Meanwhile, please take a moment to review this 2024 Year to Date summary.

Status of Offshore Wind Construction

·         Offshore wind approvals and construction gust ahead

It’s now apparent that the objective for this White House is to get as many projects approved as possible before the November election. Nine applications have moved into the construction phase with 4 that are completed or under active construction. Expect more approvals to follow. (see table below)

·         Increased whale deaths

Whale deaths continue to pile up while NOAA ignores our requests for updates. Meanwhile, the agency has removed easy access to what little information we could access about the 3 UMEs. This is an unacceptable situation.

·         All eyes on the Vineyard Wind failure

The blade failure at Vineyard Wind 1 may prove an inflection point in this debate.

The shattered blade did more than strew fiberglass shards and blade chunks in the ocean and along pristine New England beaches forcing closures. The event also shattered the fantastical aura many in the public have created around wind energy. It forced the reality that turbines are not benign, mystical, planet-saving giants, but imposing industrial machines that can, and likely will again, splinter into a million pieces. Turbines also catch fire, spill oil, fall down, and throw blades long distances! We will get GE’s root cause analysis sometime in the next year but no matter what it says, the industry and its boosters cannot un-ring the bell. Wind turbines fail and they fail in big ways!

The Vineyard Wind 1 blade failure raises new concerns regarding how BOEM is managing the financial security behind decommissioning. Needless to say, the security must be rock solid and must have some government entity monitoring the security to be sure it’s in place when needed. Otherwise, the decommissioning obligation is meaningless.

Under their lease, developers are required to post decommissioning costs before construction is initiated. Decommissioning was a known project cost at the time developers negotiated their power contracts. But when presented with the bill, they complained to BOEM calling the requirement an “unnecessary and unreasonable financial burden.” BOEM caved and granted “departure” requests allowing decommissioning costs to be deferred until the 15th year of operation.

This is an absurd concession.

One turbine has already failed and created public distrust. The prospect of whole wind projects falling into disrepair and hundreds of blades deteriorating demands that decommissioning be paid in advance.

Prior SRWC Research

·         SWRC’s Whale Death Correlation Report

Many of you are aware of SWRC’s report released last January which established a strong correlation between the increase in whale deaths and offshore wind activity. Our data focused on the dramatic increase in vessel traffic within the wind lease areas beginning in 2016 as developers conducted sonar surveys of the seabed.

·         Our letters to NOAA Fisheries

We also filed several letters with NOAA Fisheries (NMFS) detailing a regular pattern of developers understating the loudness of the ‘sparker’ sonar devices used during their surveys. The only mitigation for harmful impulsive noise is distance. The distances NMFS defines to ensure marine life is protected are derived directly from the sonar noise levels. Inaccurate sonar levels would result in protective distances that are too short.

We informed NMFS that this was likely a contributing factor behind the spate of whale deaths in the Atlantic Ocean since December 1, 2022 and the ongoing Unusual Mortality Events (UMEs) dating back to 2016.  The shortened Level B distances enforced by NMFS under the IHAs , in effect, rendered any expected mitigations useless. NMFS dismissed our finding with this non-answer:

“Based on the best scientific information available there is no evidence that noise resulting from offshore wind site characterization surveys could potentially cause whale deaths. There are no known links between large whale deaths and ongoing offshore wind activities.”

SRWC Current Findings

SRWC’s current investigations add to the concern that NMFS is not properly mitigating offshore wind development noise. Our key findings are listed below. They suggest NMFS is increasingly more interested in facilitating offshore wind development than in protecting wildlife. For more detail on each of the below topics, see the comments we filed with NMFS related to the Atlantic Shores South and SouthCoast Wind ‘take’ applications.

·         Flawed predictive noise modeling

Impact pile-driving at Vineyard Wind 1 produced noise levels in the water that were materially louder than predictive models claimed. NMFS relied on the models when determining the protective distances around the work. As pile-driving proceeded, NMFS had to extend the safety distance by an additional 1 mile (from 4121 meters to 5720 meters). This 1 mile increase meant that the area exposed to harmful noise levels doubled from 20 sq. mi. to 40 sq. mi. The only evidence of this change could be found in the PSO report that was released months after the work was completed. These protective distances are a key factor in determining animal take levels. There is no information to suggest NMFS updated the Vineyard Wind 1 take levels to match the larger impacted area.

·         Inadequate observation and monitoring

NMFS mitigations largely rely on Protective Species Observers (PSO) observations. However, SRWC’s examination of the PSO post-monitoring reports suggests this method of mitigation is not reliable at the scale that offshore wind projects are being built. Animal detection levels by the PSOs are dramatically lower than modeled density levels. Yet, Revolution Wind and Vineyard Wind 1 have each insisted that PSO detection levels from prior sonar surveys at wind lease areas represent a better metric for determining wildlife densities. NMFS has indicated it’s inclined to agree. SRWC research shows this would be a mistake. These reports offer no assurance that the number of recorded detections represents a reliable count of animals in the area. The PSO reports show material limitations in the ability of PSOs to see and machine-hear wildlife. Given these limitations, PSO data should not be used to inform species density or take levels.

·         Insufficient oversight

NMFS has removed regulatory oversight for continuous noise levels produced by dynamic positioning thrusters on offshore wind vessels. In the latest SouthCoast application related to construction, it’s apparent that NMFS is also not enforcing protective mitigations for continuous noise produced by vibratory pile-driving. According to the application, vibratory pile-driving at SouthCoast will produce harmful continuous sound levels (over 120 dB) that extend 26 miles from the work. This would create high noise levels well within the important North Atlantic right whale habitat surrounding the Nantucket Shoals, an area deemed by NMFS scientists as off-limits for wind energy development.

·         Developer misrepresentation

Developers have repeatedly misrepresented to NMFS the effectiveness of technologies used for nighttime detection by PSO. These include infrared and thermal cameras, night vision goggles and machine hearing. Post-monitoring reports clearly show PSOs are unable to detect wildlife at night beyond 100-200 meters of the operating offshore wind vessel, and these detections are typically made with the naked eye. Yet, NMFS continues to approve nighttime sonar surveys and is considering allowing for nighttime pile-driving work.

Staying in touch

One of our best opportunities for success is to continue communicating and sharing what we’re learning with others. SRWC’s WhatsApp chat offers immediate access to many great people who have good information at their fingertips. In addition, our monthly zoom calls for members are back! These calls provide everyone with a chance to be heard and to share what you or your groups are doing. If you are not on our chat or zoom call invitation list, please contact me to be added.

Thanks so much for all your work and for all your support! If you have questions, feel free to email me at lisa@linowes.com or lisa@saverightwhales.org      

--Lisa