CRMC, Seeking More Time to Review Revolution Wind Project, Moves Hearing to March 14
Meeting expected to focus on the export cable and the turbines, both of which are proposed for federal waters
February 9, 2023
Editor’s note: This story was updated at 5 p.m. on Feb. 9 and at 9 a.m. on Feb. 10 to reflect new information.
WAKEFIELD, R.I. — The Coastal Resources Management Council (CRMC) has rescheduled a Feb. 14 hearing on the Revolution Wind project to March 14.
The hearing was rescheduled under a third stay agreement between the CRMC and Revolution Wind because, according to the agreement, the CRMC believes “the Revolution Wind project has undergone refinement in recent months which require additional State agency time and resources to analyze.”
The Feb. 14 CRMC hearing was to be attended by the project developers and several regulating agencies, and would have been the federal consistency review for the offshore wind project, which was due by Feb. 24. Attention was expected to be focused on the export cable, which will bring power onshore, and the turbines, both of which are proposed for federal waters.
The new stay agreement makes the CRMC’s federal consistency decision due on or before March 31.
The council’s last major action on the wind project was unanimous approval in mid-December to allow the developer to install export cables and other infrastructure through the West Passage of Narragansett Bay and into Quonset Business Park in North Kingstown. The December vote also included the creation of a compensation fund of more than $3 million for commercial fishermen.
The federal Bureau of Ocean Energy Management (BOEM) is in charge of studying and permitting the wind facility, with input from federal and state environmental agencies, such as CRMC, along with citizen groups and individuals.
The project still needs more approvals from state and federal regulators, including the CRMC, which is charged with making sure Revolution Wind or any offshore project conforms to the state’s Ocean Special Area Management Plan (Ocean SAMP).
Support for and opposition to the project continues, much of it expressed in 123 online comments posted last fall, following the publication in September of the draft Environmental Impact Statement for Revolution Wind.
The Biden-Harris administration has set a target of 30 gigawatts (GW) of installed offshore wind energy by 2030, which it posits will create nearly 80,000 jobs.
Revolution Wind seeks approval to build and operate up to 100 wind turbine generators on the Outer Continental Shelf (OCS) about 18 miles southeast of Point Judith. The offshore export cables would be buried below the seabed in the Continental Shelf and Rhode Island submerged lands. The onshore export cables, substations, and grid connections would be in North Kingstown.
The project would have a maximum capacity of 704 to 880 megawatts (MW). In addition to the turbines, the project would include up to two offshore substations, cables linking the turbines to the offshore substations, one interconnector cable linking the substations to each other, an onshore export cable system, one onshore substation, and connection to the existing electrical grid at Rhode Island Energy’s Davisville substation in North Kingstown.
The draft Environmental Impact Statement (DEIS) that BOEM released last September is an eye-glazing 2,386 pages, including a 14-page table of contents, appendices, figures, and tables. BOEM considered 18 alternatives when preparing the DEIS and carried forward six alternatives for further analysis in the DEIS, including one alternative of no action. A final Environmental Impact Statement (FEIS) is expected to be released in June.
A brief summary of the alternatives, expressed in a letter to BOEM by the New England and Mid-Atlantic Fishery Management Councils after release of the DEIS last fall, stated:
The DEIS includes six alternatives, some of which include sub-alternatives. Alternative A is the no action alternative. Alternatives B-F would all use a uniform east-west and north-south facing grid of 1 x 1 nautical miles (nm) between wind turbines.
Alternative B includes up to 100 wind turbine generators with a nameplate capacity of 8-12 MW, up to two offshore substations, and up to two export cables co-located in a single corridor.
Alternative C includes two mutually exclusive and mostly overlapping sub-alternatives to reduce impacts to habitat. Alternative C1 would remove turbine positions that are in or adjacent to … areas of contiguous complex benthic [seafloor] habitat, while C2 would remove turbine positions that are in or adjacent to … areas of Atlantic cod spawning.
Alternative D includes three sub-alternatives that would remove certain turbine locations to reduce space-use conflicts, including with fisheries. When combined, Alternatives D1-D3 would remove the outermost portions of the project area that would then allow for either 4-nm transit lanes or additional space for the Buzzards Bay Traffic Lane.
Alternative E includes two sub-alternatives to reduce visual impacts. Alternative E1 would allow up to 64 turbines and Alternative E2 would allow up to 81 turbines.
Alternative F would require a 14-MW wind turbine generator, which is higher than the range proposed (8-12 MW) in the Construction and Operation Plan (COP). This would reduce the number of wind turbines necessary to meet the existing power-purchase agreements (i.e., 704 MW) to 56.
Careful support; clear opposition
The Rhode Island Department of Environmental Management was among the many sources of comments on the proposal. DEM emphasized the importance of studying the undersea impact of offshore wind, but it concluded with support for Revolution Wind “and its contribution to mitigating the impacts of climate change.”
Rules and guidelines for the permitting process place heavy emphasis on seeking input from groups affected by the project.
Commercial and recreational fishermen are wary, mostly because of the unknown impacts, both during construction and operation. They are particularly worried because part of the project area overlaps part of Coxes Ledge, an upwelling of seafloor that is a rich habitat for cod and other species and a fruitful area for commercial fishing.
Richard Hittinger, an officer of the Rhode Island Saltwater Anglers Association and a member of the state’s Fisheries Advisory Board, said fishermen are worried about lots of aspects of the project, starting with the loud pounding needed to drive the turbine foundations into the seabed. The Revolution Wind turbines are expected to be monopiles, which are single large posts driven into the seafloor. (By contrast, the five wind turbines of the pilot project off Block Island are “jacketed” style. These have four legs in the seafloor supporting the turbine, in a shape that somewhat resembles the base of the Eiffel Tower.)
Hittinger said a single monopile shaft may be 30-40 feet in diameter and may be pounded more than 100 feet into the seabed. “Drilling could be catastrophic for a certain number of fish in the immediate area,” Hittinger said, adding that the zone of negative impacts from the turbines could extend a couple of nautical miles in each direction.
“We don’t know the answer to whether the fish will recover,” Hittinger said. He said it could take years of electricity production by Revolution Wind simply to offset the energy output needed to build the project, “and that is not very reassuring.”
Like some other critics of offshore wind, Hittinger said it is problematic to fight renewable energy, given the perils of global warming and the need to end the use of fossil fuels. “I would like to see humans do whatever we can to stop our input into global climate change. If these things were really going to reduce our impact on climate change, that could be good.”
A small group of homeowners in the East Bay has banded together to protest Revolution Wind because they believe the overall impact on the environment would be damaging. Bill Thompson of Little Compton said opponents of offshore wind are quickly labeled NIMBYs, or stooges of the fossil fuel industry.
Thompson said the wholesale embrace of offshore wind as a solution to climate change overlooks the dangers of wind turbines in the ocean, including threats to many forms of sea life.
“Am I opposed to all offshore wind? Not at all,” Thompson said. “I am opposed to it at this scale. They are building cities of these turbines in the oceans; it is staggering.”
Thompson said he believes offshore wind projects are almost 100% destructive. “I tell people, these wind farms will kill whales and harm codfish stocks. But people are willing to give all that up because they are panicking about the state of the planet. This is the industrialization of the ocean. Haven’t we done enough damage?”
Comments seek refinement of plans
Reaction to the DEIS includes 123 posted online comments from organizations and individuals.
The New England and Mid-Atlantic Fishery Management Councils, two of the eight regional fishery management councils in the United States, raised many questions about the DEIS, but concluded by supporting two of the six alternatives, with considerably fewer than the maximum proposed 100 turbines.
The councils’ letter opened by noting that Alternative F calls for 14-MW turbines, which are not part of the project design. The councils wrote that they “support consideration of higher MW turbines as this can reduce the footprint of the project while still generating the same amount of power as a project with lower MW turbines and a larger footprint.”
The councils’ letter discussed matters like: changing the configuration of cables and substations if fewer than 100 turbines are erected; requiring a minimum depth of 6 feet for burial of cables under the seafloor; requiring developers to dispose of unexploded ordinance that is uncovered during site work; expanding time-of-year restrictions during construction to reduce disruptions of cod spawning; and using grab technology rather than seafloor plowing to move boulders when preparing the seabed.
The councils expressed concern that the maximum capacity of the project has been described as 704MW to 880MW, the latter a full 25% higher than the former. “Some alternatives can only meet the 704MW target at larger turbine capabilities,” the councils wrote. “The large range in potential total operating capacity make it difficult to estimate … impacts effectively.”
The councils implored BOEM to revise the DEIS so the document would include clearer descriptions and maps when alternatives or sub-alternatives are re-combined in different ways, saying, “the FEIS should specify the number of turbines and their locations for each alternative and turbine capacity combination.”
Despite the number of queries raised by the councils’ letter, the letter said the groups support Alternative C, the “habitat impact minimization alternative, with up to 65 turbines, and Alternative D, with no surface occupancy in the outermost portion of the project area to allow a transit lane of four nautical miles.”
Comments from DEM strongly urged the developers to reduce impact of the project on fisheries to the greatest degree possible, and to seek input through the project from fishing professionals, like the Fishermen’s Advisory Board.
DEM urged developers to avoid placing turbines near Coxes Ledge, “and any areas of complex benthic [seafloor] habitat in general in an effort to best maintain current complex habitat structures that species such as Atlantic cod rely on.” Renowned for its marine biodiversity and its cod habitats, Coxes Ledge partly intersects with the wind farm lease area.
DEM urged the developers to use large turbines. The project’s Construction and Operating Plan (COP) now includes turbines of 8MW to 12MW, but one of the DEIS alternatives mentions 14MW turbines. “If turbines larger than 12MW are available by the time of construction, the developer should aim to use larger turbines to reduce the number of foundations within the wind farm. This will reduce the area of benthic disturbance and the amount of pile driving,” DEM wrote.
DEM comments encouraged burial of cables at the proposed 4-6 feet below the seafloor and also recommended use of horizontal directional drilling of the cable at Quonset landfall over more-intrusive installation techniques like open cut or jet plowing.
Some comments referred to the much smaller, five-turbine Block Island Wind Farm, and lessons learned so far from that project. The DEM wrote, “… habitat changes at the BIWF documented heavy colonization of the turbine structures by blue mussels three years post-construction. … Black sea bass were found in large numbers and appeared to benefit from added structure.” But DEM said three years of observation of the Block Island installation may not be enough to observe longer-term trends, and that assessments there should continue.
After repeated warnings to the developers to take great care at studying the affected undersea area and its plant and animal populations, DEM concluded by supporting the intent of the offshore wind project, writing, “The localized impacts from the construction and operation of the Revolution Wind Farm to marine and avian organisms may be significant; however, this project will result in substantial reduction of regional fossil fuel generation and lower emissions of nitrogen oxides and carbon dioxide. Therefore, on balance, the RIDEM is supportive of the Revolution Wind Farm and its contribution to mitigating the impacts of climate change.”
Also among the parties that commented on the DEIS was NOAA Fisheries. In an Oct. 17, 2022 letter, NOAA Fisheries found much to dislike about the DEIS. Mostly, NOAA Fisheries said the DEIS’s descriptions of impacts of the wind project were incomplete, dependent on outdated information, or that they relied on untested assumptions.
“The DEIS does not fully evaluate each alternative and, in many cases, the analysis does not provide any meaningful distinctions between the impacts of the … alternatives,” wrote regional administrator Michael Pentony.
He also wrote about the impact of the project on Coxes Ledge, an important cod habitat. “[NOAA Fisheries] consider the proposed action to have unmitigated major adverse impacts to [essential fish habitats] and Atlantic cod as the proposed action includes full build out of the lease area.”
NOAA Fisheries faulted what it called the DEIS’s reliance on untested strategies intended to ease the environmental impact of offshore construction. “The [DEIS] unreasonably relied on the anticipated success of fisheries mitigation guidance that has not been finalized or implemented by BOEM.” The letter added, “The DEIS fails to incorporate and consider the best available scientific information to support impact determinations.”
The letter found fault with time-of-year restrictions on pile driving for the turbines, stating, “… the time of year that cod spawning occurs on Coxes Ledge (November-April) does not entirely overlap with the January-April right whale pile driving restriction.”
Pentony wrote, “The mitigation and monitoring measures for the [project] … are only briefly referenced in the document with little analysis of their effectiveness.”
NOAA Fisheries did not endorse any of the DEIS’s proposed alternatives but did note that “Alternative C (habitat impact minimization alternative) in combination with Alternative F (larger turbine size) could avoid most impacts to complex habitat and avoid areas of known Atlantic cod spawning activity.”
Under federal law, NOAA Fisheries will be responsible, during this permitting process, to produce a biological opinion describing how a project such as a wind facility could affect a threatened or endangered species, like the North Atlantic right whale. If NOAA Fisheries issues a “jeopardy” conclusion, the opinion would include reasonable alternatives. If NOAA Fisheries issues a “no jeopardy” opinion, it may issue an Incidental Take Statement, allowing the project to harass or kill a limited number of animals during the normal course of the project. If NOAA Fisheries allows an incidental take, it must propose measures to mitigate the harm.
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