by David Wojick
Prior to approving offshore wind development NOAA routinely authorized the loud noise harassment of large numbers of whales under the Marine Mammal Protection Act (MMPA). New research by Professor Apostolos Gerasoulis shows that this harassment is causing a lot of whale deaths.
For example, it is known to cause deafness which can easily be deadly. But harassment need not cause deafness to cause death. Offshore wind arrays that occupy a hundred square miles or more are typically built in low ship traffic areas with high traffic nearby. Harassment can simply cause the whales to avoid the low traffic area and spend more time in heavy ship traffic leading to an increase in deadly collisions.
The same is true for lightly versus heavily used fishing areas where avoidance leads to increased entanglement. Ship strikes and entanglement are the two leading causes of whale deaths. Ironically the wind defenders say that increased ship strikes and entanglements show that wind is not causing increased death rates when they are actually strong evidence against wind.
The clear solution to this killing of whales is to severely constrain the number of harassment authorizations. With these very limited authorizations very few new offshore wind projects can be built. Nor should they be since they are killing whales. Each project requires a large number of authorizations so drastically reducing their number drastically reduces the number of offshore wind projects and the number of whale deaths.
The simplest way to do this is to cap the total number of wind authorizations that will be issued for a given exposed population. This is analogous to capping the emission of dangerous pollutants. One could even have a cap-and-trade program where developers bid for authorizations just as they now bid for leases. The 1990 cap-and-trade program for power plant sulfur dioxide emissions is an obvious analog.
If the cumulative harassment were limited to say 10% of the exposed population of a given species of whale this would severely constrain offshore wind development. As it is now the cumulative authorized harassments of multiple projects often add up to many times the exposed population. This is a striking example of BOEM and NOAA’s stubborn refusal to do cumulative environmental impact analysis.
This is especially true of the severely endangered North Atlantic Right Whale which has an estimated population of just 340, all of which are exposed to all of the Atlantic offshore wind development because they migrate along the entire coast. Ten percent of this population is 34 harassments and some projects approach this number individually.
As part of this harassment capping program the numerous existing authorizations for projects that are not yet under construction should be revoked and made subject to the cap. The cap could also apply to projects under construction that have yet to exhaust their authorizations.
The cap should also apply to all endangered and protected species not just whales. These authorization numbers can be much higher than those for whales. For example Dominion’s huge project off Virginia is authorized to harass over 50,000 dolphins and is two years from completion.
There are a couple of other harassment points of interest here. First, all of the authorizations to date are for harassment during construction. No grid scale project has become operational at this point and NOAA claims that there will be no operational harassment. Others have argued that there will be operational harassment and if there is then the cap will constrain operation.
Second the floating turbine wind array development sites that have now been leased off California, Maine and Massachusetts create a new form of deadly harassment that needs to be either drastically constrained or simply prohibited. This is the incredible 3D web of hundreds to thousands of mooring lines that fill the ocean to keep the hundreds of giant turbine floaters in place. The MMPA defines harassment as anything that causes a behavior change in protected mammals and these mooring line webs certainly do that. They also pose an entanglement threat.
In summary the solution to wind project harassment killing endangered whales is simple. Cap the allowable harassment.
David Wojick is an independent policy analyst and senior advisor to CFACT (Committee for a Constructive Tomorrow). This column is republished with permission from the CFACT website.
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