Stacking the deck 

Last of two parts:

The U.S. Fish & Wildlife Service has exposed the federal government’s review of Cape Wind’s alternative sites for what it is: a sham.

When the Minerals Management Service, which is reviewing the proposal to build 130 wind turbines in Nantucket Sound, defined the purpose of the process, it stacked the deck in favor of the developer.

The “purpose and need statement” developed by MMS describes “a facility that utilizes the unique wind resources in the waters offshore of New England using a technology that is currently available, technically feasible, and economically viable, that can interconnect” with the New England power pool.

“As described, the purpose and need statement appears to be a virtual prescription for the proposed (facility),” said Michael Bartlett of Fish & Wildlife. “The use of special qualifiers in this section (of the draft environmental impact statement) has a dramatic effect on the range of reasonable alternatives…because they constrain the size, location, and energy source to specific parameters.”

Bartlett said the underlying public purpose should be stated more broadly as to meet the public’s need for electrical energy. “A broadly-worded purpose…allows for a full range of reasonable alternatives to be considered without having the effect of or appearing to predetermine the outcome,” he said.

For example, the geographic scope of the alternatives analysis was limited to New England offshore areas.

“This special qualifier was also used as a screening criterion to eliminate project alternatives,” Bartlett said. “As a result, market-based wind farms…and an array of other generating facilities, which are found elsewhere in New England, were eliminated from consideration by the combination of qualifiers in the purpose and need statement and screening criteria.”

Another criterion identified in the purpose and need statement requires alternatives to interconnect with the New England power grid.

“It seems unreasonable to us to require interconnection with and delivery to the New England pool system and, at the same time, require the electricity to be generated in a geographically specific area by a special fuel source…,” Bartlett said.

In addition, several alternative sites were accepted or rejected based on screening criteria or other factors that, at times, seem inconsistent.

For instance, a site east of Block Island was rejected because storm waves were estimated to be 50 feet and seabed geology likely consists of boulder outcrops. On the other hand, the south of Tuckernuck Island site was retained for detailed analysis despite having a storm wave height of 52.5 feet. No issues are raised about seabed geology.

“It is not clear why east of Block Island was discarded with two fatal flaws, while south of Tuckernuck was retained with a single fatal flaw,” Bartlett said.

For these and many other reasons, the Minerals Management Service should prepare a supplemental draft environmental impact statement that broadens the scope of renewable energy projects to be considered and then seriously considers alternatives.

The Cape Cod Times

8 May 2008