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Virginia’s offshore wind proposal threatens endangered whales

The massive offshore wind (OSW) project proposed by Dominion Energy may pose a serious threat to the endangered North Atlantic Right Whale population. A comprehensive environmental impact assessment is required to determine the extent of this threat and the mitigation it might require. The same is true for the other proposed Mid-Atlantic OSW projects.

The North Atlantic Right Whale is reported to be the world’s most endangered large whale, with an estimated population of just a few hundred critters. They winter off of Florida and Georgia, but summer off New England. So they migrate through the coastal waters off of Virginia twice a year, including that year’s baby whales. They can grow to over 50 feet in length and weigh more than 70 tons. Protecting them is a major challenge.

For background see https://www.fisheries.noaa.gov/species/north-atlantic-right-whale.

Phase one of the huge proposed Virginia/Dominion OSW project looks to occupy something like 400 square miles. Pause two might bump that up to 800 or 1,000 square miles and the proposed federal lease area for OSW is even greater, much greater in fact.

The obvious monster question is how will all this development affect the severely endangered Right Whale population? Answering this question must be central to the project’s required Environmental Impact Assessment (EIA) under NEPA. This is Federal land.

For example, will the whales enter the resulting maze of giant towers and whirling overhead blades? If not then OSW might well be a significant obstacle to the migration. So we first need to know just how these migrations work, in both directions. Is there a single path or many highly distributed paths? Are they taken by single whales or large groups? Do they quickly go straight through or is there a lot of wandering and feeding?

Then too, there is a great deal of northbound and southbound shipping in this area. The Northeast US and Canada supply, and are supplied by, many places and countries to the South. Being struck by ships is the leading cause of whale death. If the OSW arrays force the whales into the shipping lanes the impact could be devastating. Note that these huge OSW arrays are also an obstacle to commercial shipping, which might tend to concentrate the shipping, thereby increasing the threat of killing whales.

Then there is the noise issue. Whales communicate acoustically and there is an extensive literature on how human noise adversely impacts them. That wind arrays create a lot of noise is well established, with many states having noise limits for onshore wind.

So we need to know things like

How noisy will this Virginia/Dominion array be under water?
What are the likely frequencies and how are they related to whale communication?
Will the noise make it harder for whales to hear approaching ships?
If a problem, how far will it extend?

It is conceivable that the noise might cause confusion, distress or even act like a great wall to the whales trying to migrate. Confusion alone could be dangerous to the baby whales. So the impact of noise should be a central part of the EIA.

There are other potential issues as well. For example, how might the huge OSW array affect the local food supply for the whales? What about the impact of construction, as compared to operation.

In addition to building and operating the huge OSW array itself, there may be issues with the power lines use to bring the juice ashore. These lines are collectively gigantic compared to even our biggest onshore power lines.

Phase one has a generating capacity of about 2,600 MW, with phase two boosting that to 5,200 MW. To my knowledge the biggest AC power line in America is just around 750 MW, and up to 1,000 MW for DC. Thus the OSW lines dwarf these land lines.

The whales are thought to actually dig into the ocean floor, which is an obvious problem with these monster power lines. But there is also the question of how the strong EMF of these lines might affect them?

In some cases, not building or operating during migration might be a viable mitigation action. Depending on how long a period that is, it might significantly change the economics of OSW.

In addition to NEPA, these whales are supposedly protected by the Endangered Species Act and the Marine Mammal Protection Act. I say supposedly because it appears that the proper analyses are not being done. There is already litigation along these lines for a smaller OSW array in New England. See https://www.texaspolicy.com/wp-content/uploads/2021/12/001-Complaint-without-Exhibits.pdf.

The responsible agency is the Bureau of Ocean Energy Management and you can see from the name that they might not want to inhibit ocean energy development on environmental grounds. Their middle name is Ocean Energy.

The lawsuit says that BOEM’s EIS for this New England project is cursory at best. Apparently the other agencies charged with enforcing these whale protection laws were also feeble. Given that the Biden Administration is hell bent on OSW development, this neglect may be predictable.

Likewise, I have heard nothing about whales from Dominion or Virginia. They both love OSW, just as BOEM does.

Litigation in Virginia may be the only real protection the whales have.

Note that in addition to this Virginia case, a whole series of huge OSW arrays are proposed along the East Coast. North Carolina has one just south of Virginia’s, Maryland just a bit north, and so on. These successive arrays add up to a formidable gauntlet that the migrating whales will have to run twice a year. Surely this endangers the whales.

The adverse impact of massive offshore wind development on the highly endangered North Atlantic Right Whale has yet to be properly assessed. It must be done.