Comments on Notice of Intent to develop a Draft Environmental Impact Statement (EIS) on US Wind Marwin and Momentum offshore wind Construction & Operations Plan, BOEM 2022-0025
US Wind’s proposed offshore wind projects off the coast of Maryland will have direct impacts on Delaware as power is to be brought on shore, and turbines will be visible in Delaware. We represent over 1,400 individuals who have expressed concerns about offshore wind development to the Caesar Rodney Institute, and through the website Save Our Beach View. BOEM has stated they are accepting the Construction & Operations Plan (COP) as complete. We beg to differ and highlight below issues that need to be addressed before the COP is considered complete and before BOEM begins the EIS process.
David T. Stevenson
Director, Center for Energy & Environment
Caesar Rodney Institute
June 22, 2022
1. US Wind mistakenly claims emissions savings from the project, and emission savings are the core reason to build the project.
2. BOEM has no suitable study to determine the cost impact of viewshed loss.
3. Maryland shifts costs to, and interferes with interstate tourism in Delaware in violation of Interstate Commerce provisions of the US Constitution.
4. US Wind left several mitigation plans undefined and incomplete.
5. Cumulative impacts are missing from the COP.
6. Discussions of impacts on marine life are incomplete.
7. Commercial fishing will be abandoned in the lease area.
BOEM has a clear duty to protect historic and future users of the lease area from interference from industrial-sized wind turbines. Major negative impacts will be inflicted especially on commercial and for-hire fisheries, tourist viewshed enjoyment, vessel traffic, Coast Guard search and rescue operations, scientific research, and the endangered Northern Right Whale and other marine mammals. Fisheries face not only a direct loss of gear, but also increased risk of collision damage to their vessels, loss of life from hampered search and rescue operations, and loss of the scientific data needed to protect fisheries. Potential loses in tourism will exacerbate social injustice as losses will disproportionately impact lower-wage service workers in restaurants, hotels, and fishing tourism. The COP is missing key information and requires serious modification before BOEM can begin an Environmental Impact Statement.
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