The Bureau of Ocean Energy Management, Regulation and Enforcement (BOEMRE), part of the Interior Department, in early November formally solicited industry to gauge interest in leasing part of the Outer Continental Shelf to develop wind energy in an area starting 10 nautical miles from the beach at Ocean City, Md., and extending about 27 nautical miles to the east. The development could include more than 2,500 wind structures.
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'Safety of navigation dictates that there should be no circumstances where a lease should be invited in or near the approaches to a commercial shipping channel' that has an established, internationally approved routing system for separating traffic, said the trade association, which represents container lines engaged in international trade with the United States.
The proposed site would primarily affect traffic entering and exiting the Delaware Bay, which is the route to the Port of Philadelphia.
The transition zones between open ocean and travel lanes close to shore already present significant navigational challenges for large commercial vessels, 'which would be made much more dangerous by the presence of wind turbines,' the WSC said.
President Obama has made renewable energy development and reduction of greenhouse gas emissions a top priority of his administration.
In late November, Interior Secretary Ken Salazar launched a program to speed up site selection, leasing and construction of offshore wind farms along the Atlantic Coast.
The 'Smart from the Start' initiative is designed to identify suitable areas for potential wind energy development and cut red tape to speed up the leasing process. BOEMRE said at the time that it wants to avoid developers proposing wind farms in high vessel traffic areas along the coast, and has indicated that just because an area is part of a proposal does not mean leases will be approved in that area.
The WSC said a better approach would be to not include navigational safety exclusion zones in the request for information to begin with.
'Dealing with navigational safety issues at the beginning of the process, rather than after seeking the level of interest in lease bids in an area, would be more logical and would also simplify and streamline the required environmental impact statement process. Finally, an added benefit of this approach ' is that potential lease bidders will not waste their time considering bids for lease areas that will later be excluded for navigational safety reasons.'
The group said BOEMRE should rely on the U.S. Coast Guard to thoroughly study appropriate wind farm locations that don't pose a safety threat to vessels. BOEMRE plans to collect Automated Identification System data transmitted by vessels to track movement patterns in the proposed development area. The WSC requested that the Coast Guard be allowed to conduct the primary analysis of the AIS information because it already manages the U.S. AIS system, has additional information on ship movements and is responsible for safety in U.S. waters.
BOEMRE and the Coast Guard should use the information to develop guidelines for determining whether offshore blocks should be excluded from leasing activity based on traffic density or navigational safety reasons, the WSC said.
On Dec. 28, BOEMRE initiated a similar leasing process for commercial wind development off the southern coast off Massachusetts. The proposal, formed with state support, calls for the installation of up to 4,000 megawatts of wind energy, which could power about 1.7 million households.
The WSC also questioned whether BOEMRE's effort to move ahead with offshore leases aligns with the Obama administration's ocean stewardship policy, released last July, which identifies coastal and marine spatial planning as a priority and calls for federal coordination in ocean management.
'It is not clear how BOEMRE's wind farm planning process is integrated into the administration's new ocean policy governance structure, as any proposal by the Department of Interior to consider placing wind farms in known high-density navigational areas, overseen and regulated by the U.S. Coast Guard, appears to be hurried, rather than an integrated and coordinated, proposal,' it said. ' Eric Kulisch
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