Dominion’s Planned Offshore Wind Farm Need Not – and Must Not – Be Built Where Planned

by James C. Sherlock

I am referring in the title, of course, to Dominion Power’s Coastal Virginia Offshore Wind (CVOW) project to be located in the hatched area below.

It is planned for one of the U.S. Department of the Interior’s (DI) Bureau of Ocean Energy Management (BOEM) offshore wind farm lease areas. Lease areas that have been rendered obsolete by operational modern floating turbine technology.

The area for which CVOW construction is proposed is overlaid below on an operational graphic of Atlantic international maritime vessel density. Red indicates highest density.

There are only a half dozen expanses of water that reach that international vessel density on the entire U.S. Atlantic coast. They are, of course, the approaches to the East Coast’s major ports.

See the Atlantic Coast Port Access Route Study Final Report Appendix III Fig. 18 below for an operational rendering of international shipping flow at the location proposed for CVOW.


See the coastal shipping traffic chart below.

The nearest point is 27 miles off the coast of Virginia Beach and the furthest 42 miles offshore. The lease area occupies 112,800 acres. One seventh the size of Rhode Island.

Undersea noise propagation characteristics will not be known unless and until it is built.

CVOW, if built, will threaten:

  • the entrance to the Chesapeake Bay;
  • the point at which international maritime traffic funnels to and from the ports of Norfolk and Baltimore;
  • the point at which coastal maritime traffic on the east coast is most dense; and
  • the point at which Navy warships and logistics vessels enter and depart the world’s largest naval base.

You might reasonably ask “Of the entire Atlantic Coast, why there?” Or you might put it somewhat less gently. Net of all the risks and rewards, there is no reasonable answer to that question. Never was.

But the facts have also changed.

At this point Dominion can testify that it must have offshore wind power under Virginia law that itself can be changed.

But, because of the deployment of operational floating turbines, it can no longer testify that it must source that power from that singular spot at the entrance to the Chesapeake Bay.

CVOW, in a class of risk that we used to call a “grenade with the pin pulled,” has yet to receive final construction approval from the federal government. But the time is late.

We can ask questions of BOEM in three online public meetings in January and February. You can mail in your questions to BOEM to their office in Sterling listed at the link ahead of those meetings. I will submit this column.

The SCC, in an order a couple of weeks ago, wrote:

The magnitude of this project is so great that it will likely be the costliest project being undertaken by any regulated utility in the United States. And the electricity produced by this Project will be among the most expensive sources of power — on both a per kilowatt of firm capacity and a per megawatt-hour basis — in the entire United States.

So project risk — project magnitude plus inexperience in offshore wind project management at Dominion – is enormous. It is so big a project that they don’t and won’t hire a prime contractor.

So Dominion is the prime. This is the project they start with?

That SCC action was celebrated as final. It is not. Construction cannot begin until the federal approval is granted.

Whatever approvals have been granted by the SCC will be withdrawn if the General Assembly revises Virginia law to ban energy from that specific place in the ocean.

As it should.

The magnitude and utilization of CVOW. CVOW, scheduled pending federal and state approval to begin offshore construction in 2024 in an immense span of ocean leased from the federal government, is planned to be a 2.6-gigawatt wind farm.

In the totality of Virginia’s energy needs, that is not a lot of energy.

If built, it will consist of 176 wind turbines standing slightly more than 800 feet tall, three offshore substations to collect and bundle the energy, undersea cables to get it ashore, and new onshore transmission infrastructure to deliver the energy onto the broader electric grid. At night.

To replace solar energy dormant at night that we have at utility scale because we fund it with federal dollars in foregone tax credits and rebates. Tax dollars that are spent in the name of clean energy.

Those tax credits and rebates are, with CVOW, about to threaten maritime safety, the reliability of the grid, and national security.

BOEM. BOEM is given authority and responsibility for granting of leases under
section 388(a) of the Energy Policy Act of 2005 (EPAct) (Pub. L. 109-58)

Requirements under that act are specific. They include:

(4) REQUIREMENTS- The Secretary shall ensure that any activity under this subsection is carried out in a manner that provides for–
(A) safety;
(B) protection of the environment;
(E) coordination with relevant Federal agencies;
(F) protection of national security interests of the United States;
(G) protection of correlative rights in the outer Continental Shelf;
(I) prevention of interference with reasonable uses (as determined by the Secretary) of the exclusive economic zone, the high seas, and the territorial seas;
(J) consideration of–

(i) the location of, and any schedule relating to, a lease, easement, or right-of-way for an area of the outer Continental Shelf; and
(ii) any other use of the sea or seabed, including use for a fishery, a sea lane, a potential site of a deepwater port, or navigation;

And with that charter they came up with, among others, the grid on which CVOW is to be built?

In practice that agency considers commercial fishing industry and environmental impacts and picks locations that offer the right wind and bottom conditions.

“Relevant” federal agencies are supposed to provide the rest of the inputs.

BOEM in 2020 released a supplement to its draft environmental impact statement (EIS). That statement found major adverse impacts to commercial fishing and scientific research, moderate impacts to marine life, and minor impacts to air quality.

Impacts, but apparently not obstacles now.

And now the federal map of approved locations similar to that where Dominion hopes to build CVOW has been disrupted by a new technology, floating turbines, that allows offshore wind farms nearly anywhere. They are proven successful and undergoing accelerated deployment in waters off of the U.K.

But that BOEM map, given some combination of bureaucratic inertia and forward-leaning administration ideology, persists.

Coastal traffic. The Coast Guard published in 2015 a draft study of the effects of offshore wind farms on maritime traffic on the Atlantic Coast, with an utterly negative opinion of the idea. You see the international traffic above. Below is an illustration of the coastal traffic.

Map of ocean off of the entrance to the Chesapeake Bay overlaid with coastal traffic routes and density.

The Coast guard objection was beaten back to the point that you cannot find that draft report on the Coast Guard website any more, nor can you find there the final study linked above.

The Navy. The CVOW location certainly wasn’t the Navy’s idea.

The Department of the Navy was reportedly consulted in the Obama administration when the lease areas were set, but I don’t know whether the operational navy was asked its opinion.

I sincerely doubt it was asked whether it thought that location a good idea.

The Navy, if it has to, will work to deal with potential enemy submarine threats made more challenging by the physical obstacles in that location and the noise that massive field will put in the water. And with the physical restrictions on ingress and egress routes for the naval bases in South Hampton Roads.

Engineers, having never built either a field or wind turbines this size, much less in a location like this, reportedly have no real idea how that noise will propagate.

If it is built, the Navy will measure the noise and its propagation and spend a great deal of money over time to overcome the challenges it will present to defense of the national assets within the Chesapeake Bay.

Marine mammals will either deal with it. Or not.

Money for Navy efforts will be hidden in the defense budget, not included in the advertised costs of the project. A hundred studies will be dedicated to technical and operational approaches to dealing with the massive field of towers.

Exercises will be held. The exercises should require shutting down the field, as would happen in wartime.  Operational commanders will, in time of conflict, shut CVOW down to eliminate the undersea noise it generates. For the duration of the threat.

But because of floating turbine technology, such zones no longer have to hover over the Navy’s bases or major international sea lanes.

But bureaucratic inertia will cause policy to trail transformational change for years. Always does.

CVOW is just the first project at such a strategic location facing a federal construction permit action.

Then there are freedom of navigation operations (FONOPS), arguably the Navy’s most successful mission since WWII.  It has kept open sea lanes all over the world to support the international trade that has enriched the world.

We are now doing what we have spent 75 years protecting against, extending national interests into international waters.  We will have no basis to complain when Russian warships, including submarines, get very close to CVOW, just as we sail into the Black Sea and the new”islands that the Chinese have built near the Philippines.

Perhaps retired admiral submariners, not subject to silencing by the Secretary of the Navy, will make their voices heard on the national defense matter.

Perhaps the new Republican-led House will hold hearings.

The Greens. The interesting thing is that the Greens don’t care where such generators are located. In their own Sophie’s choice, they have long made their peace with killing raptor birds ashore and marine mammals in the ocean in a trade for wind power.

They don’t care whether there is ever a CVOW at that spot in the ocean. They just want offshore wind power. With floating turbine technology now available, the options for locating such turbines have expanded immensely.

So CVOW does not have to present an obstacle to international shipping or commercial fishing. It does not, ever, have to represent a complication to the defense of the entrance to the Chesapeake Bay.

Power generation does not ever have to occur in that spot. Virginians who support clean energy don’t care if it comes from there.

If CVOW winds up being built, it will be there because it was available, Dominion leased it, and is using the Virginia Clean Energy Act and that Act’s Mandatory Renewable Energy Portfolio Standard Program to get SCC permits to bring the power ashore.

For that the entire federal government, the fishing and maritime industries, the national defense and the Virginia State Corporation Commission are lashed to the helm.

Wind industry and the Greens vs. the Coast Guard — no contest. The Coast Guard conducted a study into broader issues with wind farms offshore of the U.S. coasts; particularly how wind projects are sited within shipping lanes and safe operating clearances for vessels traveling past turbine towers.

The Coast Guard’s Atlantic Coast Port Access Route Study (ACPARS), as reported by the Checks and Balances Project, a not-for-profit transformed into a spokesperson for the wind industry, concluded that:

After five years of delay, the U.S. Coast Guard finally released a study that concludes commercial shipping off the Eastern Seaboard is incompatible with a proposed offshore wind energy industry – despite the fact that Europe has successfully integrated the two for more than a decade.

The Obama Administration has promoted the development of offshore wind energy since 2009. In September 2015, the Administration held a Summit on Offshore Wind with federal agencies. Yet though the Dept. of Homeland Security participated, the U.S. Coast Guard, of which it is a part, has sailed in a different direction.

The Atlantic Coast Port Access Route Study (ACPARS), released on March 14, 2016, focuses on what its authors assert are dangers from offshore wind farms to shipping, even going so far as to say that offshore wind energy could be an impediment to American energy independence. The study calls for dramatically limiting space for wind energy installations on the Outer Continental Shelf, and even recommends removal of blocks from currently leased areas.

The attacks were swift, brutal, and effective, a testimony to the political clout of the Greens.

ACPARS, which in an act of contrition has disappeared from the Coast Guard’s web site, showed that only one of the BOEM lease areas in 2015 was squarely in the middle of a high-density shipping lane. If you have not already guessed which one, see the first map above.

The Greens, through the Obama Administration, beat the Coast Guard into submission because of ACPARS broader findings. They don’t care about CVOW per se.

But it is the one Dominion wants.

The shore transmission system. Another concern is the substantial increase in energy to the coastal transmission system. Offshore wind will add an enormous amount of power to the existing grid, and the current grid must be modified to handle the influx.

When it comes to integrating the resulting influx into the power grid, Dominion will need to construct new facilities to handle what the industry calls euphemistically “the uptick in load.”

The power will come ashore at the state military reservation on the coast and be transported to Naval Air Station Oceana and finally terminate at Dominion’s existing substation at Naval Auxiliary Landing Field Fentress in Chesapeake.

One wonders it there are to be complications or risks in that plan.

Game changer – floating turbines. The U.K. earlier this year, in partnership with industry, increased funding to its Floating Offshore Wind Demonstration Programme to accelerate deployment, not R&D, into such sources. The UK already has eleven projects it has deemed successful.

The UK is already home to the world’s largest deployment of offshore wind, however floating turbines, which can be deployed in deeper waters than conventional turbines, will boost energy capacity even further by allowing wind farms to be situated in new areas around the UK coastline where wind strengths are at their highest and most productive.

It is the near-term availability of that technology that is driving lobstermen from the Gulf of Maine.

Floating turbines make the East Coast BOEM lease areas map obsolete.

That map was limited to wind areas that were of the right bottom depth to support towers. Like the ones that Dominion plans to build. At the entrance to the Chesapeake Bay.

Dominion asserts to the State Corporation Commission that it must have CVOW power ashore to supply power at night when the solar farms are impotent. That it must under the Act and can under its assumptions use it to provide power to the 600,000 customers they estimate it will serve at peak power generation, presumably including Hampton Roads military installations.

It can provide that power when the wind does not blow. Or when it blows too hard in a Nor’easter. When maintenance and repair are necessary. When, ultimately, replacement is necessary after what Dominion hopes will be 30 years. These are not perpetual motion machines.

Dominion testifies that batteries will store energy for those contingencies.

We wonder what they will testify in response to a question about what will happen when a military commander in time of conflict orders CVOW shut down to silence it. For the duration of the threat. However long that may be.

Has anyone ever told a broad swath of Virginians that, entirely because of Northam’s Act, even CVOW won’t provide nearly enough power? Below is what Dominion showed the SCC about capacity.









Alternatives. Since wind turbines are freed from their dependence on depths for the towers, Dominion can either find a place less threatening for its own floating turbines or buy wind power from those that can.

Virginia is also blessed to sit adjacent to by far the largest proven natural gas reserves in the nation, and some of the largest in the world — those in West Virginia.

Virginia can join the natural gas pipeline wars in favor of those pipelines.

With the looming Dominion power gap, national defense and reliable power as front-line issues, and floating turbine technologies to satisfy their green base’s desire for offshore wind power, Virginia’s two senators can join with West Virginia Senator Joe Manchin to block further related appropriations until:

  1. Gas pipelines to Virginia’s Atlantic Coast and Southern Virginia are mandated in federal law; or
  2. CVOW is eliminated from the list of available offshore wind turbine areas; or
  3. Both.

Or they can tell us why they will not.

Such a move will fill not only the nighttime need here, but also fill the capacity gap that Dominion so clearly describes.

Observations and Recommendations for Approaching Federal Milestone. CVOW construction start awaits the BOEM Record of Decision for the Construction and Operations Plan (COP) in Q2-2023.

This article is filled with information and unanswered questions that argue for a no on that decision.

The development and operational success of floating wind turbines has made the current map of government-approved locations for offshore wind turbines obsolete.

But make no mistake.  I argue that the location proposed for CVOW violates current law regardless of floating wind turbine technology.

Section 8 of the Outer Continental Shelf Lands Act (43 U.S.C. 1337) as amended by SEC. 388. requires:

“(F) protection of national security interests of the United States; and

(J) consideration of–
(i) the location of, and any schedule relating to, a lease, easement, or right-of-way for an area of the outer Continental Shelf; and
(ii) any other use of the sea or seabed, including use for a fishery, a sea lane, a potential site of a deepwater port, or navigation;”

Three observations:

  1. If the lease location at the entrance to the Chesapeake Bay through which the warships and logistical vessels of Atlantic Fleet pass does not qualify as a threat to the national security interests of the United States, then the words in the law are meaningless.  The fact that the wind farm in that location, with the noise it puts in the water and the proximity of sea lanes and the world’s largest naval base will attract both potentially hostile and hostile naval vessels, including submarines, is unchallenged.  The open question is whether we can defend against them, the level of effort it will take to do so and how Dominion will deal with the prolonged shutdown that such operations would require.  The unanswerable question, already asked in the law, is why BOEM would complicate the defense of that strategic location in the first place.
  2. That site will be identified and published as a hazard to navigation.
  3. Finally, BOEM need not consider the effects of this and some other identified locations on “potential” deepwater ports. Consider the ports that already exist on both coasts.

A federal judge, and the appropriate committee of the new House of Representatives, will ask three questions of BEOM.  So I will:

  1. Is this specific location critical for the energy security of the United States?
  2. Are there viable alternatives?
  3. Does this specific location compromise the national security interests of the United States by requiring dedicated military effort to account for its strategic location?

If the answer to the first question is “no” and the second and third are “yes”, BOEM must withdraw and update the current lease area maps to make the changes required by existing  law.

The first step will be to deny the construction permit, cancel the lease currently held by Dominion and remove that location from the map.

The Virginia General Assembly. Construction, awaiting federal permission, and with it the biggest costs to Virginia rate payers, has not begun in earnest.

But Ralph Northam’s Virginia Clean Economy Act (VCEA) (the Act) represents Dominion’s entire justification before the State Corporation Commission for this abomination.

That is vulnerable to General Assembly action. And should be foreclosed by such action.

Bottom line. Others will do what they can to prevent federal approval.

Virginia’s General Assembly can amend the Virginia Clean Energy Act to make illegal the bringing ashore in Virginia of power from the CVOW.

That will end the madness of CVOW.

And must.

Update Dec 27 at 12:20 AM.  Updated “Approaching Federal Milestone” with arguments I will use in a letter to BOEM in conjunction with its review of the final approval of construction of CVOW.