Leveraging federal law permitting the suspension of a renewable energy lease, the Long Beach Island Coalition for Wind Without Impact on June 5 submitted a request to the secretary of the Department of Interior to squelch the forward momentum of the proposed Atlantic Shores Wind project off the coast of LBI.
In its missive to Secretary Deb Haaland, the group cites Title 30, Chapter V, Subchapter B, Part 585 in its request, which states “when continued activities pose an imminent threat of serious or irreparable harm or damage to resources; life (including human and wildlife); property; the marine, coastal, or human environment; or sites, structures, or objects of historical or archaeological significance” as the primary reason for its request that the federal agency suspend activities at the proposed Atlantic Shores Wind lease area.
“It’s a pretty dramatic thing to do,” Bob Stern, a founding member of the LBI Coalition for Wind Without Impact, said of requesting a suspension at the lease area. “We’re not happy with the lease area (site).”
The Atlantic Shores project calls for nearly 183,353 acres of leased sea area on the Outer Continental Shelf, located within the New Jersey Wind Energy Area, to be developed. The site lease has the potential to generate 3 gigawatts of offshore wind energy. Atlantic Shores plans to start onshore construction of substations in 2024 and offshore construction by 2025.
Later this month, the New Jersey Board of Public Utilities will make a decision on the power level, effectively setting the number of turbines that would be constructed at the site.
“We are a growing group of several hundred residents, visitors and business interests generally supportive of offshore wind energy as long as it is done sensibly and with genuine consideration of its impact on those most directly affected by it,” states the letter authored by Stern, the former director of environmental compliance for the U.S. Department of Energy, with Wendy Kouba, Dawn Hall and Lindsay Ehlert on behalf of the coalition.
“In our case, we are being faced with the most visible modern wind turbine complex in the world and the threat of serious impacts on endangered species, and merely seek consideration of some common-sense alternatives to avoid both of those impacts,” the letter continues.
For Stern, the most common-sense approach to concerns raised by the coalition is for Hudson South Call Area to be included as an alternative site in the environmental impact study. The site is located 30 to 57 miles off the coast.
“The Hudson South area has substantially more wind energy than the current project area,” according to the letter to Haaland. “The Bureau of Ocean Energy Management has recently identified that area as highly suitable for wind energy development and is proceeding with leases there. Any option that can provide more comparable or more wind energy with substantially less environmental impact should be fully analyzed in the EIS (environmental impact statement).”
Stern said he’s doubtful the appropriate authorities will agree to consider an alternative site.
If Hudson South was given serious consideration as an alternative site, it would help alleviate concerns of the turbines being in the migratory path of piping plovers and the North Atlantic right whale.
As the proposal stands now for the lease area, piping plovers would have to cross the lease area to gain access to their nesting area in Holgate, and they fly at about the same height as the turbines, Stern said.
More than 6,000 acres of the Edwin B. Forsythe National Wildlife Refuge are designated a National Wilderness Area, including the southern tip of Long Beach Island, which is one of the few undeveloped barrier beaches in the state – and a vital habitat for shorebirds such as piping plovers, least terns, black skimmers and American oystercatchers.
Every year, access to the Holgate Unit of the refuge is closed to the public from April 1 to Sept. 1 to protect beach-nesting birds. There’s another area near the lighthouse in Barnegat Light for beach-nesting birds such as plovers.
Like the piping plovers, the North Atlantic right whale’s migratory pattern goes to the outer edge of the proposed Atlantic Shores lease area, according to Stern. The project calls for nearly 183,353 acres of leased sea area on the Outer Continental Shelf, located within the New Jersey Wind Energy Area, to be developed.
The North Atlantic right whale is one of the most endangered large whale species, with less than 400 remaining, according to the National Oceanic and Atmospheric Administration. The species has been on the endangered list since 1970 and researchers estimate there are fewer than 100 breeding females, NOAA said.
North Atlantic right whales are primarily found in Atlantic waters on the continental shelf, though they do travel offshore and into deep water, according to National Oceanic and Atmospheric Administration. They migrate seasonally, traveling alone or in small groups.
Threats to the North Atlantic right whale include climate change and vessel strikes as well as ocean noise, according to NOAA. Activities, such as shipping, boating, construction, and energy exploration and development can interrupt the normal behavior of right whales and interfere with their ability to communicate, NOAA said. Noises can also decrease the right whale’s instinct to detect and avoid predators and human hazards as well as navigate, identify physical surroundings, find food and find mates.
“Right whales feed primarily on copepods, which are abundant off the New Jersey shore, and it is likely they supplement their diet as they migrate. They are already experiencing significant food-stress, and any disruption to their foraging opportunities could jeopardize their population further and is of critical concern,” according to the coalition’s letter.
Additionally, the level of underwater noise at the site of the proposed turbine is expected to exceed the 120-decibel limit before the right whale’s behavior is impacted, according to Stern.
“It’s a critical situation for the right whale,” he said, acknowledging he doesn’t know how the endangered species would react to the disturbance. “It (the turbines) creates all kinds of problems.”
Initial discussions of offshore wind farms took smaller turbines into account, ones that could generate 5 to 6 megawatts of electricity. The turbines being proposed almost double that output, Stern said.
“The current Atlantic Shores proposal would place 100 to 200 12 megawatt or higher power turbines, 10-20 miles offshore of Long Beach Island,” according to the coalition’s letter. “The tower or hub height of such turbines is 502 feet and blade tip height 853 feet.”
As a result, the turbines would dominate shoreline visibility and would “in fact pose the most visible modern wind turbine complex in the entire world,” the letter continued.
The BOEM’s decision to adopt a 17.3-mile turbine exclusion distance from the shore for New York wind energy projects supports the impact of turbines on visibility, according to the coalition. The decision was largely based on an analysis of the New York Outer Continental Shelf Area, the letter reads.
“That study simulated the visual impact of 152 6.2 mw turbines from 16 observation points in New York and New Jersey,” according to the coalition’s letter. “The simulation most reflective of the LBI project is from the Jones Beach observation point because the turbine array was parallel to that shore. The closest point of the turbine array to Jones Beach was 15 miles.”
The study ranked the visual impact on a scale from 1 to 6, with 6 being the highest. Six is defined as “dominates the view because the study subject fills most of the field for views in its general direction. Strong contrast in form, line, color, texture, luminance, or motion may contribute to view dominance,” according to the coalition letter.
Shoreline visibility from Jones Beach ranked at the highest end of impact, the coalition noted in its letter.
“Consequently, under the current state of affairs, the project poses an inevitable threat of serious, irreparable harm to the human environment,” according to the coalition’s letter.
“Atlantic Shores is committed to lead with science and aims to design, build and operate our wind farm in the most environmentally responsible way,” Jennifer Daniels, development director at Atlantic Shores, said in response to the coalition’s requests for suspension of activities at the lease area. “We are partnering with leading scientists and research institutions both within the state of New Jersey and around the world to evaluate and support our project efforts. We understand that the development of offshore wind must be a collaborative process, and that’s why we have proactively worked to engage coastal and fishing communities to answer their questions and hear their feedback and input through public forums and our community and fishery liaisons.
“The years-long process of determining lease areas, companies submitting a bid and developing a wind farm are incredibly thorough and highly regulated, overseen by both state and federal agencies with multiple opportunities for public comment from community members and other stakeholders throughout. We will continue to provide and participate in opportunities to speak directly with the communities we hope to deliver clean, renewable energy to, including during virtual open houses later this summer.”
On June 23, the coalition is hosting an online forum to further discuss the proposed offshore wind farm. Visit savelbi.org for additional information and to donate to the nonprofit.
“We will play the cards we’re dealt,” Stern said of what comes next.
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