A handful of property owners in the East Bay has been publicizing a torrent of data arguing against offshore wind projects, causing alarm and anger from oceanographers, environmental regulators, and climate activists who say the group’s arguments are wrong, misleading, and tainted with negative innuendo, false linkages, and guilt by association.

The group, called Green Oceans and organized last December as a nonprofit, believes offshore wind projects are the “industrialization of the ocean” and “100% destructive,” said one member, Bill Thompson, who owns a house in Tiverton.

Since January, Green Oceans has had at least four opinion pieces and one letter to the editor published in EastBayRI, a group of community newspapers based in Bristol. A few readers have counter-attacked with angry letters, accusing Green Oceans of both factual errors and a communication method that blasts out a tsunami of data points and arguments, mixing fact and innuendo, and overwhelming anyone arguing against its claims.

Thompson said his group is concerned about climate change, but its members fear offshore wind facilities may threaten biodiversity and cause other serious and unforeseen problems. “We tell people these wind farms will kill whales and harm codfish stocks” — assertions not supported by marine scientists — “and people are willing to give all that up because they are panicking about the state of the planet” because of the climate crisis.

Thompson called offshore wind power “a crapshoot, but the majority of what the turbines do is destructive.” He added, “There is no way [wind farms] will supply enough electricity to get us to shut down other sources” — a claim that is not being made.

Revolution Wind proposes to build up to 100 wind turbines on the outer continental shelf about 18 miles southeast of Point Judith. The project is currently moving through the permitting process by the federal Bureau of Ocean Energy Management (BOEM), NOAA Fisheries, and other regulators. A draft environmental impact statement for Revolution Wind was published last fall. Ten dozen comments from the public included one from Green Oceans member Elizabeth Quattrocki Knight and one from a law firm speaking for Green Oceans, Eubanks & Associates PLLC of Washington, D.C.

Members of Green Oceans say they are environmentalists and that they became deeply alarmed by the prospect of wind facilities on the outer continental shelf when they began to learn more about the scope of the projects, including Revolution Wind.

“We did not set out to find fault with offshore wind,” Thompson said. “We were shocked by this giant industrialization of the outer continental shelf; the scale is mind-numbing. We thought: this cannot be good.”

Green Oceans has produced a white paper against offshore wind, presenting 31 objections: the projects’ alleged harms in the form of carbon dioxide emissions, air and water pollution, and biodiversity destruction; unsightliness from the shore; toxic algae; disruption of national defense; damage to tourism; distrust of foreign-based wind companies; disruption of bird migration; food insecurity; and damage to Rhode Islanders’ mental health. (These claims are discussed in more detail below.)

The white paper, with 89 endnotes, also offers 10 alternatives to offshore wind facilities, including the immediate conversion of all coal-burning plants in the United States to natural gas. Alternatives proposed by the group also include solar, nuclear, fission, and geothermal.

One expert who read the white paper called it “total horseshit” and “shoddy scholarship.”

Michael Healey, spokesperson for the Rhode Island Department of Environmental Management, said, “Any organization that trashes offshore wind and says the best alternative to it is ‘immediately converting coal plants in the U.S. to natural gas’ doesn’t deserve a serious response. It deserves mockery. The climate crisis is blinking ‘code red,’ we’re going to have another foot of sea level rise by 2050, according to NOAA, and Green Oceans wants to burn more gas to fight it? That’s like putting out the fire with gasoline.”

Conversion of power plants to natural gas is irrational, Healey added. “Research has determined the entire life cycle carbon footprint of wind turbines is much less than natural gas power plants. … The crucial difference between fossil fuels and wind turbines [is that] a power plant releases CO2 every second it runs, whereas most of the CO2 generated during the wind turbine’s life occurs during manufacturing.

“Also, for Green Oceans to profess to care about climate change but not to mention anything about public health is repulsive. Power plants, which Green Oceans offers as the No. 1 cure to cut GHGs [greenhouse gases], are this country’s No. 1 source of deadly air pollution, contributing to tens of thousands of deaths and hundreds of thousands of illnesses every year.”

Persuasion tactics criticized

Dwight McNeill, in a letter to the East Bay newspapers, wrote that in its opinion pieces, Green Oceans is “using the special interest group playbook to stall or kill … Revolution Wind: a) Express great support for the goals of the project, but stand firm that it should not be done here, not now, and not by ‘them’; b) Emphasize emotion-laden and polarizing issues such as whale deaths, foreigners ripping off U.S. taxpayers, and the dangerous depletion of oxygen in the oceans to get citizens’ attention and scare them into their position; c) Call for confirmatory data, but in the meantime, elevate their hypotheses to ‘facts’ through constant repetition and/or ask for ‘more time for more study.’”

One instance of misdirection occurs in Green Oceans’ Jan. 27 piece, which opens, “On April 20, 2010, the oil rig, Deepwater Horizon, exploded in the Gulf of Mexico, releasing millions of barrels of oil into pristine ocean waters. … the U.S. government applied unprecedented amounts of chemical dispersants. While the dispersants helped diffuse the petroleum, they significantly magnified (52x) the toxicity of the spill … Such is the law of unintended consequences.”

The next paragraph moves into offshore wind, an activity with no chance of massive oil spills: “After years of inaction, the U.S. is now aggressively intervening in another crisis: global warming. … Extensive offshore wind arrays may seem like a promising solution; yet no country has industrialized the ocean to this extent.” (The world’s largest-capacity offshore wind energy project is operating about 56 miles off the United Kingdom’s east coast. The Hornsea 2 project includes 165 wind turbines spread over 178 square miles.)

Asked about the paragraph about Deepwater Horizon that opened the opinion piece, Thompson said, “It was a literary device as a way of opening the essay and make the statement that there are unintended consequences” to big environmental projects.

A Feb. 7 opinion piece by Green Oceans states that “Oxygen production doesn’t occur in the open ocean, it happens along the outer continental shelf, in the very location now designated for utility scale offshore wind. No right-minded environmentalist would advocate clear-cutting a forest to install a solar array.”

That seems to indicate that Green Oceans expects offshore wind facilities to reduce oxygen production in the oceans. Thompson offered a clarification, saying that paragraph refers to a potential loss of plankton production because of wind farms. “If you reduce plankton production, that affects the whole food chain.” Without evidence, Thompson said, “Plankton production will be diminished, affected by wind farms.”

Knight, another member of Green Oceans, said scientists are just starting to recognize the amount of oxygen produced by phytoplankton in the oceans. Now, they realize phytoplankton likely produces a majority of the planet’s oxygen. Phytoplankton, Knight continued, quoting a study, “thrive along coastlines and continental shelves” and “any change in their productivity could have a significant influence on biodiversity, fisheries and the human food supply, and the pace of global warming.”

Timmons Roberts is a professor of environmental studies and sociology at Brown University and executive director of the Climate Social Science Network, a global group of scientists who study the politics of climate change, particularly organizations that are trying to block the transition away from fossil fuels.

Roberts said Green Oceans is very typical of small groups that block renewable energy efforts by effectively working “veto gates” at which projects can be strangled. Large national groups that oppose renewable energy, such as the Texas Public Policy Foundation and the Caesar Rodney Institute, lay down the model and sometimes provide support for local anti-renewables groups.

“These are usually people with a lot of social capital,” he said. “On issue after issue, many have no scientific background whatsoever. They are raising fear and hysteria.”

Green Oceans members say they have no affiliation with any like-minded regional or national groups.

Roberts continued, “They cast aspersions without support. They are throwing up as many things as they can to see what sticks. It is hard to refute every argument; they just make more new ones. This quite small group of people is endangering our effort to address climate change in any kind of time frame that is adequate. It is crazy to say that [the group’s influence] is not going to make any difference to the future of offshore wind.”

Speaking of Green Oceans’ disregard for scientific studies and conclusions that differ from its position, Roberts said, “It is quite disrespectful of the people who have spent their lifetimes studying the oceans by saying, ‘We know better.’”

Concerning views

Rep. Michelle McGaw, a Democrat who represents Portsmouth, Tiverton, and Little Compton, said she is a strong supporter of renewable energy, provided it is done carefully and responsibly. She said she first met with Green Oceans’ Knight and Thompson last November.

Knight in particular, McGaw said, “was concerned about how close [Revolution Wind] was to Little Compton and concerned about views.” Knight owns property in Little Compton.

Knight, in fact, was one of 123 people or groups that submitted comments to BOEM after the Revolution Wind draft environmental impact statement came out last year. Her two-page letter said, “the project as planned will destroy Rhode Island’s best and most treasure resource, the vitality and beauty of its coastline and coastal habitats. Boating, fishing and beach-going … will be indescribably negatively impacted. The value of every coastline town will be grossly diminished. … The wind farm will dominate our landscape in an unexpected and unwanted manner.”

McGaw said, “We have good processes in place to review” offshore wind projects. “People who I trust the most have concerns about information [from Green Oceans] misleading people in a direction that is not accurate. My concern about the approach they are taking is that it is going to make people less comfortable with the transition to renewable energy. The more misinformation people hear the more ire we are going to get from leaders who are trying to steer us in the right direction.”

Green Oceans’ techniques are relentless, McGaw said. “As soon as you start researching one point they throw 10 more ‘facts’ at you.”

Her point was echoed by Andrew Morley, a Little Compton resident who wrote to the East Bay newspapers to object to Green Oceans’ claims. He wrote the group uses “a debate technique where you attempt to overwhelm your opponent with an unrelenting barrage of arguments, with little regard for the truth. Using quantity over quality to blindside your unprepared opponent with an endless list of half-truths and utter nonsense is the name of the game.”

McGaw noted Green Oceans members “are distrustful of information that is not supportive of their point of view. Lisa [Knight] is under the impression that everyone is bought and sold.”

Data dump

The white paper and Green Oceans’ published opinion pieces often open with a calm, rationale tone, agreeing that climate change is real and solutions are needed quickly. After the opening, the content does a quick about-face and argues against offshore wind projects, throwing out a huge and unwieldy variety of data points.

The organization urges distrust of offshore wind developers, such as Ørsted and Eversource, co-developers of Revolution Wind. Thompson said he would not characterize the group’s view of wind developers as “mistrustful.”

“They are out to make money and their judgement is informed by that,” he said. “There is nothing wrong with that.”

Green Oceans’ objections, particularly in reference to offshore wind’s impact on whales, also follows a pattern of skipping over established science.

Barbara Sullivan-Watts, a senior marine scientist emerita at the University of Rhode Island’s Graduate School of Oceanography, is equally offended by what she calls Green Oceans’ method of distorting scientific reports and also by its actual wrong information about the impact of offshore wind projects on ocean currents and on whales.

Sullivan-Watts referred to a bullet point in the Green Oceans white paper stating wind turbines reduce downstream wind and can reduce prevailing currents. The bullet point continued, “Any further slowing of the Gulf Stream and the Atlantic Meridional Overturning Circulation could send the planet beyond the tipping point into catastrophic sea level rises and mass extinction.” The paragraph had six endnotes.

“That’s ridiculous,” Sullivan-Watts said. “The studies they were citing had nothing to do with offshore wind. The article was about planning the location of wind turbines so that they don’t influence each other.”

Sullivan-Watts said Green Oceans’ method of presenting data was biased and devious. “It took me and my husband [also an oceanographer] two hours to pick apart those few sentences [from the white paper] … and to ask, ‘What are these people saying?’

“Their logic is twisted and contorted. They are implying in clever ways that wind turbines will be placed in these currents — but they are not even going to be in these currents. It is hard to make it clear when someone puts a fog over the actual facts.”

Sullivan-Watts said it was personally upsetting to see Green Oceans claiming NOAA scientists “don’t want to know the answers to these questions” about offshore wind’s impact on sea life. A Feb. 1 opinion piece by Green Oceans claimed neither NOAA nor the offshore wind companies or their supporters “want to examine whether underwater surveys have contributed to the high whale mortality.”

“NOAA scientists have spent their entire lives trying to prevent harm to these endangered species,” Sullivan-Watts said.

Disagreements over threats to whales

A large part of Green Oceans’ arguments against wind projects pertain to their impact on whales, which is discussed in the group’s opinions, white paper, and its lawyer’s 13-page response to the draft environmental impact statement for Revolution Wind.

The statement by Eubanks & Associates claimed offshore wind facilities “will have serious adverse impacts on the North Atlantic right whale and threatens to tip the species from a state of, at best, precarious survival into a state of likely extinction.

“We must be careful to avoid simply trading the climate crisis for a biodiversity crisis, as the erosion of biodiversity will only exacerbate climate change and its effects. … Accordingly, … the Agencies must adopt a strong protective stance and advance programmatic regulations that require the avoidance of North Atlantic right whale habitat areas and ensure the survival and recovery of this iconic keystone species.”

The Feb. 1 opinion by Green Oceans made several statements that implied — without actually stating — causation between offshore wind sonic surveys of the ocean floor and whale deaths. The piece noted that nine humpback whales have died along the coast of New York and New Jersey since December 2022 and added, “During this same period, offshore wind companies have been conducting underwater surveys along the Atlantic coast.”

The opinion piece added, “if an association between the surveys and whale deaths exists, the public deserves to know.” Green Oceans implied NOAA was hiding the reasons for the unexplained 60% of whale deaths not attributed to human interaction. NOAA has said that cause of death can be hard to determine, even after a necropsy, for these large animals because of fast degradation of their corpses.

Green Oceans stated, “Despite these claims, a logical, indirect link exists between underwater surveys and baleen whale deaths.” In a phone interview, Knight said, “There is a correlation; we are not saying causation. We are not trying to deceive anybody.”

Knight said scientists are not trying to find links between whale deaths and offshore wind site exploration, including such things as sonar soundings. “Absence of evidence does not mean evidence of absence,” she said, or more plainly, “If you have looked and don’t find anything it does not mean there is nothing there.”

Knight claimed marine scientists’ evidence is faulty. “They are making claims without the scientific evidence to back it up. They are saying, ‘We don’t know the causes of death of these whales,’ but then they say, ‘We definitely know [deaths] are not because of [wind farm] surveys.’”

In fact, NOAA and organizations, such as the Sierra Club of New Jersey, where many recent whale strandings have happened, are studying the problem intensively. Across the board, marine scientists say whale deaths are mostly caused by vessel strikes and entanglements with fishing gear. Also, as climate change causes ocean warming, whales and other species may be moving toward cooler waters, sometimes following prey, and thereby putting them in places with heavier boat traffic.

In 2017, NOAA Fisheries declared an unusual mortality event (UME) for humpback whales along the East Coast from Maine to Florida. The UME includes whales stranded since 2016. As of this month, 181 humpback deaths are included in the UME. Necropsies — difficult to do on these animals for many reasons, including access — have been done on half the dead whales in the UME. Of the animals necropsied, 40% showed evidence of human interaction, by vessel strike or fishing-gear entanglement.

NOAA Fisheries and many other experts have stated repeatedly that there is no known connection between surveys for offshore wind sites and whale deaths. Anjuli Ramos, the New Jersey director of the Sierra Club, has written, “Blaming offshore wind projects on whale mortality without evidence is not only irresponsible but overshadows the very real threats of climate, change, plastic pollution, and unsustainable fishery management practices to these animals.”

Another point of dispute about marine mammals also arose between Green Oceans and URI’s Sullivan-Watts, along with her colleague and co-author, Robert Kenney, also a marine scientist emeritus from the URI School of Oceanography. This dispute pertained to “incidental takes.”

A take is defined under the Marine Mammal Protection Act as “to harass, hunt, capture, or kill, or attempt to harass, hunt, capture, or kill any marine mammal.” Level A harassment is essentially an injury, like some form of auditory injury resulting from noise exposure. Level B harassment is a behavioral disturbance.

Incidental take requests and authorizations refer to harm done to animals as an unintended side effect of an activity. Incidental takes may be requested by offshore wind energy developers and approved or denied by NOAA Fisheries after a review.

An opinion piece by Green Oceans stated, “If granted, these authorizations will permit the legal harassment of marine mammals, even to the point of death.” In an interview, Knight added, “If you ask for a Level A [incidental take request] you know you are doing something that has the risk of death.” She said the phrase “permanent injury” implies death to a whale because “a deaf whale is a dead whale.”

NOAA Fisheries has stated, “NOAA Fisheries has not authorized — or proposed to authorize — mortality or serious injury for any wind-related action. Offshore wind developers have not applied for, and NOAA Fisheries has not approved, authorization to kill any marine mammals incidental to any offshore wind activities.”

Sullivan-Watts and Kenney called the Green Oceans statements on takes “entirely misleading. … ‘Taking’ under federal law is not the same a killing or even injuring,” the scientists wrote.

Amanda Barker of the Green Energy Consumers Alliance voiced the view of many offshore wind supporters, saying, “Offshore wind is the single biggest lever that we can pull to reduce our emissions and address the climate crisis, and it can be developed in a responsible way that respects our environment and our wildlife. We don’t need to choose between clean energy development and wildlife protection; we can do both, and in doing both we’re protecting wildlife from the greatest threat of all: climate change.”

White paper statements and responses

Below are bullet items from the Green Oceans (GO) white paper, followed by observations from Ørsted, co-developer of Revolution Wind (RW):

GO: RW’s CO2 emissions during the construction phase counteracts any possible returns until 2031 and potentially, until 2035. The project’s initial CO2 emissions will drive climate change forward during a critical window of time. Ørsted: The carbon saved throughout a wind turbine’s lifespan is up to 50 times greater than the emissions from its manufacture, construction, operation, and decommissioning. CO2 and other emissions are reviewed in great detail as part of the federal permitting process.

GO: During operations, wind turbines release sulfur hexafluoride (SF6), the most potent greenhouse gas in the world. Ørsted: Revolution Wind turbine generators will not contain SF6; however, SF6 would be present in the offshore substation. In a worst-case scenario, SF6 could have a leakage rate of 0.5%, an estimated 18.9 pounds per year.

GO: The mortality risk to endangered species, the introduction of invasive organisms, and the decrement of the coastal habitat will all contribute to a reduction of biodiversity. Ørsted: Studies of the Block Island Wind Farm have shown no measurable impact on fish species and in fact an increase in abundance for certain species due to an artificial reef effect. NOAA has said offshore wind has no proven tie to whale strandings. Introduction of hard habitat from wind farm construction locally increases biodiversity.

GO: The hundreds of miles of high-voltage cables will heat the proximate area by as much as 36 degrees Fahrenheit and radiate electromagnetic fields (EMFs) that can interfere with fish larvae viability and disorient migratory species. Ørsted: The buried cables will not emit heat or radiate EMF into the overlying water column beyond barely detectable levels. Animals with the ability to detect an EMF does not mean they will respond to, or be affected by, new EMF sources in their environment.

GO: Wind farms can increase water and air temperatures, redistribute humidity, and alter atmospheric flow, thereby modifying local weather patterns and regional climate. Ørsted: The most significant threat to the local climate is the impact of global climate change, including warming waters, severe weather, and changing ecosystems. Ocean warming from climate change is a documented driver of measurable changes in water and air temperatures, local weather patterns, and regional climate.

GO: The anti-corrosive coating on the wind turbines leaches significant levels of toxic heavy metals (lead and cadmium) and harmful organic compounds into the water that will contaminate the food chain. Toxic coolants (1.8 million gallons), fuel, oil, and lubricants from the planned developments could significantly contaminate the water and threaten both vulnerable species and the marine ecosystem.  Ørsted: Regarding anti-corrosive coatings, Ørsted referred to the project’s construction and operations plan, which makes no mention of toxic heavy metals in coatings. Regarding toxic coolants, DEM stated: “Over half of all water withdrawn in the United States each year is for cooling purposes, with power plants being the largest user of cooling water. According to BOEM, “The withdrawal of cooling water by existing power facilities removes and kills billions of aquatic organisms from waters of the U.S. each year. … In addition, waste heat is discharged in the form of heated cooling water, which decreases oxygen supply and affects the ecosystem composition. In many cases, biocides are added to the cooling water to prevent fouling of the cooling water system.”

GO: The tidal and estuary currents flowing across the underwater portion of the wind turbines will induce sediment plumes, decrease stratification, and increase turbidity. Sediment plumes can resuspend toxic heavy metals, reintroducing them into the food supply chain, and threaten marine mammals. Ørsted: There are no estuarine currents present nor is there any evidence of induced sediment plumes from the proposed project.

GO: Introducing artificial reefs will allow invasive filter feeders to alter the ecosystem. Invasive filter feeders increase the risk of harmful algal blooms that deplete oxygen in the water, causing fish die-offs and can release harmful toxins. Ørsted: There is no evidence that turbine foundations in the Northeast Atlantic are colonized by large number of invasive filter feeders, nor any link with harmful algal blooms. Studies of the Block Island and European wind farms suggest that each foundation functions as an artificial reef, increasing diversity and production in the immediate area.

GO: Wind turbines reduce downstream (leeward) wind by over 40% for a 40-60 mile expanse and can reduce prevailing currents by 15%. Any further slowing of the Gulf Stream and the Atlantic Meridional Overturning Circulation (AMOC) could send the planet beyond the tipping point into catastrophic sea-level rises and mass extinction. Ørsted: Predicted effects on the AMOC and changes in the Gulf Stream are due to climate change and have never been considered a reasonable consequence of offshore wind development since these currents are driven by hemispheric climate conditions not local currents.

GO: Meeting quotas is not the equivalent of combating climate change. The wind farms will not necessarily help climate change, they will merely allow states to meet their renewable energy quotas. Ørsted: Renewable energy contributes to state, regional, and federal decarbonization goals, which will combat climate change.

GO: Revolution Wind will occupy a site within the migratory Atlantic flyway region and will thereby add additional stress to three bird species already on the endangered list. Ørsted: As part of the construction and operations plan we commissioned a study on potential bird and bat impacts. Overall, the assessment found that project construction, operation, and decommissioning are not expected to affect the populations of any migratory, coastal or marine birds, including federally listed species or bats. In general, exposure of bird populations has been avoided by siting the project offshore in a wind energy area designated by BOEM.

GO: Wind farms increase environmentally significant ocean noise, both during construction and operation. Seismic surveys, pile driving, increased vessel traffic, and operations all contribute to underwater noise pollution that harms marine animals and drives them to abandon habitats. Recent marine mammal strandings have been associated with impaired hearing. Ørsted: NOAA has stated that vessel strikes and entanglements in fishing gear — not offshore wind — are the greatest human threats to whales. Every aspect of surveys, construction, and operations are reviewed by multiple agencies and subject to protective conditions, including vessel speeds, time of year restrictions, and mandatory observers aboard vessels.

GO: The power purchase agreement (PPA) insists on little accountability. The agreement allows RW to deliver less than one-quarter (94 megawatts) of the total capacity (440 MW) before incurring any liability for damages. Ørsted: Green energy is a critical component to reduce CO2 emissions and Rhode Island and the region’s decarbonization goals. Revolution Wind will reduce CO2 contributions by producing cleaner energy.

GO: Large wind turbines in the inhospitable offshore environment frequently fail and have a finite lifespan due to metal fatigue. Taxpayers may be responsible for paying the millions (to billions) of dollars required for decommissioning. Ørsted: None of the turbines will be located in Rhode Island state waters, so they are the ultimate responsibility of the federal government. Federal law and the terms of the offshore wind leases require that offshore wind developers decommission all facilities at the end of the project lifetime (25-30 years). This is reinforced by additional requirements which use bonding or other financial assurance to ensure that sufficient funding is available for project decommissioning.

GO: After construction, Ørsted will no longer be responsible for maintaining the Revolution Wind farm. Ørsted will pass off the legal and financial liability to the shell company, Revolution Wind LLC. Ørsted: Revolution Wind will maintain responsibility and liability for wind farm operations and maintenance.

GO: Offshore wind electricity will cost more than any other form generated, three times more than solar by 2027. A greater reliance on offshore wind will most likely result in higher rates. Ørsted: Benefits of the project were thoroughly reviewed by the Rhode Island Public Utilities Commission when they approved the power purchase agreement, which found that the project is “expected to transmit energy from the offshore generating source of the project to the mainland at the lowest reasonable cost to the consumer.” Revolution Wind has responsibility for all costs embedded in the PPA to develop the project and there will be no additional costs to Rhode Island ratepayers.

GO: Rhode Island hosts 21 million tourists every year. Revolution Wind turbines will dominate the horizon from nearly every public beach in the state and will be visible from a distance of 40 miles. Ørsted: A study of the Block Island Wind Farm, which is significantly closer to shore than Revolution Wind, found no “significant negative impact of prior knowledge or views of the turbines on the average number of trips or ‘willingness to pay.’”

GO: The press inflates the number of jobs that the offshore wind farm will generate. Ørsted does not promise to source these employees from Rhode Island and may import a specialized workforce. Ørsted: The offshore wind industry is already creating hundreds of jobs in Rhode Island, and development of Revolution Wind and future projects will continue to support those jobs, as will the ongoing operations and maintenance of wind farms.

GO: Tax benefits will provide the companies 30% of the investment costs. Ørsted: Federal investment and production tax credits for green energy are well established and the recent passage of the Inflation Reduction Act reaffirms the national importance of these tax credits to accelerate the deployment of cleaner energy.

GO: The planned 873-foot turbines will tower over any other ocean structure in the world. These compromise the FFA safety regulations on height and proximity to heavily traveled air routes. Ørsted: Height and potential impact on air traffic are addressed in our construction and operations plan. According to a commissioned study, historical air traffic data indicates that 873-foot ASL wind turbines would not affect any regularly-used visual flight rules routes.

GO: The 873-foot wind turbines will be much more visible than the company’s simulations imply and will flash red lights during the night. Ørsted: Visual impacts of turbines are assessed as part of the federal review process.