Save Right Whales Open Letter to the Public

Dear Fellow Concerned Members of the Public, 

We are writing as citizens, scientists, and conservationists who are concerned that offshore wind projects may have adverse impacts on marine wildlife. We are particularly troubled by projects slated for areas known to be frequented by the critically-endangered North Atlantic Right Whale, of which there are less than 350 still living. 

On Thursday, November 18 we will launch the Save Right Whales Coalition (SRWC) by participating in a public comment meeting held by the Bureau of Ocean Energy Management (BOEM) where we will challenge the bureau’s failure to fully assess the danger offshore wind energy poses to right whales and other wildlife. On Friday, November 19 at 1 p.m. Eastern Time we will hold a press conference announcing the creation of our group. SRWC is strictly non-partisan. Our intent is to secure a moratorium on offshore wind energy development in right whale habitat until further scientific research can be conducted about the environmental impacts of offshore wind plants. 

Environmental NGOs including the Natural Resources Defense Council, National Wildlife Federation, and Conservation Law Foundation claim that offshore wind can be built and operated without significant harm to wildlife and right whales. They believe that offshore wind power is needed to fight climate change, which is affecting ocean ecosystems through ocean acidification, loss of sea ice, sea level rise, and other climate damages. 

 In January of 2019 these environmental groups entered into an historic agreement with the proposed Vineyard Wind offshore facility which they say will protect right whales by restricting vessel speeds, requiring whale detection measures, and limiting pile driving activity to periods when right whales are likely not present in the project area.

This agreement paved the way for Vineyard Wind to receive an incidental take permit under the Marine Mammal Protection Act, which allows them to harass marine mammals, including the right whale. Such an action involving a critically endangered species is highly concerning, especially given the sharp increase in mortality of right whales since 2019 alone. Vineyard Wind, which will site 62 turbines in waters just 15 miles south of Martha’s Vineyard, is the first project to receive federal approval.

While we agree with the requirement that vessel speeds be reduced, the agreement  falls far short of its promise to protect the North Atlantic right whale. The agreement relies on certified “protected species observers” and passive acoustic monitoring to detect the presence of right whales which will, in turn, signal the need for mitigation measures. Neither of these methods are foolproof. Right whales are black and have no dorsal fin, making them hard to spot. They also can call quietly, making audio detection of the whales difficult. Right whale mothers don’t vocalize loudly when traveling with their young calves, so attempts to hear them in an offshore wind construction zone may be missed until it is too late. Studies show that 60-minutes of acoustic listening, which is the period cited in the agreement, can miss the presence of a right whale 60% of the time during the summer months. 

Even if a right whale is spotted in the project area, the lead engineer for Vineyard Wind will ultimately decide if construction activity will stop. The agreement, which expires after 5 years unless amended or renewed, provides little direction on how to protect right whales during the operational phase. And should a dispute arise over the terms of the agreement, the parties can decide unilaterally to withdraw with no penalty or other recourse. 

In July of this year, the Northeast Fisheries Science Center of NOAA’s National Marine Fisheries Service, the New England Aquarium, and the Center for Coastal Studies released a report that revealed information about right whale behavior off the Massachusetts coastline that was not previously known. According to the authors, “Since 2017, whales have been sighted in the [project] area nearly every month,” and, “[m]ovement models showed that southern New England is an important destination for right whales, including conceptive and reproductive females, and qualitative observations included animals feeding and socializing.” 

This finding is in direct contrast with information Vineyard Wind supplied in its 2019 “Incidental Harassment Application” which reported no right whale sightings for 6 months of the year and most sightings occurring in just two months, March and April. The new study suggests that limiting pile driving to just a few months will still expose the whales to the harmful construction practice. Fifty percent of reproductive right whale females spend time in southern New England, which is worrisome because they are now giving birth two to three times less frequently than in the past. Any additional stressors on female right whales could be devastating. 

The new report raised serious questions regarding the impact of operating wind projects on right whales for which we have no answers. These include: What will be the effect of acoustic exposure on animal behavior and how far will that impact extend? Will the presence of the operating facility alter the physical and oceanographic characteristics of the right whale habitat? How will the turbines and the increase in maintenance vessels affect migration patterns?

Obviously more research is needed. Considering that the right whale is facing extinction, the planned offshore wind installations are tantamount to an irreversible experiment that could have deadly consequences. 

It is well documented that industrial human activities can affect right whales. Oceanic noise pollution generated by construction harms whales in a number of ways. It can hinder whale calls used to maintain contact, gather to feed, and find mates. The anthropogenic sounds also result in habitat displacement, hearing loss, and increased stress levels. 

The expansion of renewable energy development in our eastern coastal waters will add to the stresses already impacting the right whale and other marine animals. Vineyard Wind is the first of many proposed projects off the coasts of Massachusetts and Rhode Island. Wind energy companies are planning to build 1,400 turbines covering 1,400 square miles, an area roughly the size of Rhode Island. As these wind projects are erected, the turbines will concentrate the space available for other commercial and recreational marine activity thereby further displacing the right whale from its natural habitat.  

As such, there is a good chance that offshore wind developments in right whale habitat will drive them closer to extinction, and their population is already declining even without offshore wind turbine construction.

As for climate change, we can’t save whales and other species by destroying their habitats in the name of fighting climate change. 

Given the possibility of habitat destruction and other deleterious effects of offshore wind energy development on right whales, we are calling for a moratorium on such projects in right whale habitat including Vineyard Wind. We look forward to engaging our fellow citizens about the potential threat of offshore wind development, and we hope that lawmakers, regulators, and citizens who love nature will step up and halt offshore wind development off the coast of Martha’s Vineyard, Nantucket, and all locations bordering the East Coast. 

Sincerely,

Nantucket Residents Against Turbines

Wildlife Energy and Conservation Coalition

Environmental Progress