The federal Bureau of Ocean Energy Management (BOEM) recently released its assessment of the environmental impacts of leasing sites for offshore wind development in an area of Rhode Island Sound offshore Massachusetts and Rhode Island. The document, Commercial Wind Lease Issuance and Site Assessment Activities on the Atlantic Outer Continental Shelf Offshore Rhode Island and Massachusetts (379-page PDF), plays an important role in the federal leasing process for offshore wind sites, but it is far from the last step in the process.
The National Environmental Policy Act (NEPA) requires federal agencies to evaluate the reasonably foreseeable impacts of proposed agency actions on the environment. Agencies perform this evaluation by preparing an environmental assessment (EA), a document describing the proposed action, its purpose and need, environmental impacts, and alternatives that might reduce these impacts. If the EA reveals that the action would lead to reasonably foreseeable significant impacts on the environment, the agency must prepare an environmental impact statement (EIS) before taking the action. If, on the other hand, the EA reveals that the proposed action would have no significant impact on the environment, the agency may proceed with its proposed action without further environmental analysis.
BOEM’s ”Smart from the Start” offshore wind leasing process includes a series of notices, requests for public comment, and requests for indications of commercial interest in leasing sites for offshore wind development. Before issuing leases in a given region, NEPA requires BOEM to develop an EA evaluating the impacts of lease issuance and site evaluation.
The area covered by the EA covers an area offshore Rhode Island and Massachusetts, generally east of Block Island and southwest of Martha’s Vineyard. This area was selected through a process dating back as far as July 2010, when the governors of Rhode Island and Massachusetts entered into a Memorandum of Understanding identifying an “Area of Mutual Interest” (AMI) in federal waters offshore both states. Later that year, BOEM received two geographically overlapping, unsolicited requests for commercial wind energy leases within the AMI from Deepwater Wind New England, LLC, and Neptune Wind, LLC. Anticipating further competitive interest for sites within the AMI, in August 2011, BOEM published a Notice of Intent to prepare an EA and a Call for Information and Nominations (Call) in the Federal Register. In response to the Call, BOEM received eight overlapping nominations of interest ranging from 350 megawatts (MW) to 2,000 MW.
The Call area was then refined through consultation with other federal and state agencies, resulting in BOEM’s February 2012 identification of the Wind Energy Area (WEA) in question. Compared to the Call area, the WEA excluded “high value” fishing grounds that BOEM said “would likely cause substantial conflict with existing fishing uses” if ultimately developed with commercial wind energy facilities.
The EA presents BOEM’s assessment of the environmental impacts of the reasonably foreseeable consequences of two BOEM actions: issuing leases to developers and approving developers’ plans to assess sites. Based on the expressions of commercial wind energy interest received by BOEM in response to the Call, BOEM assumed that the entire WEA would be leased. BOEM considered both routine activities stemming from issuing leases and approving site assessment plans, such as site characterization surveys and the installation of meteorological towers and buoys, as well as “non-routine” events such as storms, collisions, and fuel spills.