By Committee For A Constructive Tomorrow
“Damn the whales, full speed ahead” seems to be the offshore wind policy of Biden’s NOAA. They now propose to approve yet another site survey, just 10 miles off Atlantic City. These surveys are the top suspect for the recent wave of dead whales, centered on New Jersey.
The site is a big one because the offshore wind project is huge. Phase 1 is a whopping 1,500 MW, which means over 100 monster turbine towers. The survey area is around 1,500,000 acres or an incredible 2,300 square miles.
Ironically the project is called Atlantic Shores, which is where all the dead whales are washing up. In fact this is basically a renewal of a prior permit. NOAA acts as though nothing has changed, ignoring the horrible New Jersey whale deaths.
NOAA’s National Marine Fisheries Service (NMFS) is taking public comments on this preposterous proposal, details below.
The proposal’s cursory environmental impact assessment is ridiculously simple minded. NMFS itself predicts that a great many (supposedly protected by them) marine mammals will be subjected to unsafe levels of survey noise. See https://www.fisheries.noaa.gov/s3/2023-03/AtlanticShoresHRG_2023_Proposed_IHA_OPR1.pdf
NOAA predicts the number of adverse impacts by species, but here are the staggering numbers by category:
Total = 4,190 adversely impacted marine mammals
Here is NOAA’s basic argument:
“….only Level B harassment is proposed for authorization, which NMFS expects would be of a lower severity, predominately in the form of avoidance of the sound sources that may cause a temporary abandonment of the location during active source use that may result in a temporary interruption of foraging activities for some species. NMFS does not expect that the proposed activity will have long-term or permanent impacts as the acoustic source would be mobile and would leave the area within a specific amount of time for which the animals could return to the area.”
In short these thousands of large animals will get the hell out of the way and come home when the survey is over, in a year or so. Apparently NMFS thinks this massive forced relocation is harmless. Despite having hundreds of scientists on staff they cannot think of how it might be harmful.
Here are two obviously harmful possibilities, among many.
First, the site is deliberately in a relatively low ship traffic area, surrounded by high traffic zones. This is one of the busiest ship traffic areas in the world. Being forced to relocate into higher traffic areas is virtually certain to increase the incidence of fatal ship strikes.
Second, moving this many animals into territory already occupied by similar animals should greatly increase the population densities for each species. But the food supply remains the same, which could lead to food scarcity.
The treatment of the severely endangered North Atlantic Right Whale is especially egregious. NOAA says this:
“…the size of the survey area (5,868 km2) in comparison with the entire migratory habitat for the North Atlantic right whale (BIA of 269,448 km2) is small, representing 2.11 percent of the entire migratory corridor.”
Right Whales migrate through the area twice a year, going between offshore Georgia and New England so the “corridor” is indeed large, but this is irrelevant. What is crucial is that the survey area is about 35 miles wide East to West and almost all of the migrating whales presently pass through this space. Thus the survey has the potential effect of blocking the migration, or at least seriously disrupting it, taking nearly 100% of the needed space not 2.11%.
Despite all of the above predicted and potential impacts, NOAA maintains that this proposed authorization is exempt from the environmental impact assessment requirements of NEPA. They specifically claim there is “no anticipated serious injury or mortality”.
They should anticipate a little harder. NEPA requires assessment if injury is reasonably likely. Injury and death certainly are reasonably likely here, to thousands of supposedly protected marine mammals, including the severely endangered Right Whales.
More deeply, the Atlantic Shores Wind Project has yet to be approved and may never be. Hugely disruptive site surveys should not be authorized until the Project is approved.
Here is the basic comment statement: “Comments should be addressed to Jolie Harrison, Chief, Permits and Conservation Division, Office of Protected Resources, National Marine Fisheries Service. Written comments should be submitted via email to ITP.Potlock@noaa.gov “
I suggest as an email subject line: “Comment on proposed Atlantic Shores IHA”. Simple objection is sufficient but specific arguments are always useful. Anyone can comment.
In the offshore wind stampede Biden’s National Marine Fisheries Service has lost sight of its mission to protect marine mammals.
Just say no to NOAA.
David Wojick, Ph.D. is an independent analyst working at the intersection of science, technology and policy. For origins see http://www.stemed.info/engineer_tackles_confusion.html For over 100 prior articles for CFACT see http://www.cfact.org/author/david-wojick-ph-d/ Available for confidential research and consulting.
— Mike Dean (@mikerdean22) March 21, 2023
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