Revolution Wind’s Final Proposal Cuts Some Turbines, Adds Mitigation and Safety Measures
Final decision on wind project off coast of Point Judith expected this summer
July 20, 2023
The federal government released this week the final environmental impact statement (EIS) for the Revolution Wind project, the last major step before the final decision to approve, approve with changes, or reject the proposal. The final decision is expected later this summer. If it is approved, construction work could begin in 2024 and operations could begin in 2025.
At 2,800 pages, the final EIS presents seven alternative scenarios for the project, including Alternative G, called the “preferred” alternative. The proposed wind facility would be on the Outer Continental Shelf, about 15 nautical miles southeast of Point Judith.
Alternative G — the only one discussed in detail in this story — attempts to reduce the project’s impact on seafloor life, fisheries, and views of the wind turbines from land, primarily the shores of Rhode Island and the Aquinnah Cliffs of Martha’s Vineyard. Alternative G includes 79 potential locations for 65 turbines, thereby allowing flexibility in situating them to avoid seafloor disturbance and problems with viewscapes. The original plan called for a total of 100 turbines.
“The Bureau of Ocean Energy Management developed a preferred alternative that includes fewer turbines to reduce potential impacts to visual resources and benthic habitat, allows for ocean co-use, and meets the energy needs of Rhode Island,” said Lissa Eng, a BOEM spokesperson.
The Revolution Wind project is expected to deliver 704 megawatts (MW) of power, including 400 MW delivered to Rhode Island and 304 MW to Connecticut. The project would have two offshore substations. Export cables on the seafloor would bring power to the land-based grid at Quonset Point.
BOEM, the federal agency with final authority on the project, estimates that Revolution Wind could “power more than 300,000 homes with clean renewable energy,” thereby supporting “the Biden-Harris administration’s goal of deploying 30 gigawatts of offshore wind energy capacity by 2030.” The New England seaboard is considered a prime location for offshore wind production because the shelf is not too deep — in contrast to the steep seafloor dropoff, for instance, in California — and winds are powerful, especially in the winter.
Rhode Island commercial and recreational for-hire fishers have fought the project strenuously at almost every stage of the planning process over a period of years, saying it threatens the health of offshore fisheries and their livelihoods. In particular, fishers are incensed that the project, on a tract in a federally approved wind-energy area, is partly on Coxes Ledge, a rich fishing ground and a habitat and spawning area for cod. Other opponents of the project have expressed concern about its possible impact on whales, other marine mammals, birds, plankton, currents, and pollution. A major contingent of opponents lives in or near Little Compton, the nearest place on land to the turbines in Rhode Island.
The EIS defends the plan and says Alternative G, along with many mitigation actions, reduces perceived problems. “By omitting certain [turbine] positions, Alternative G would reduce the adverse impact of … structures on commercial fisheries and for-hire recreational fishing during project construction. In comparison to the Proposed Action [the original plan with 100 turbines], fishing access would be improved, and the risk of fishing gear loss/damage would be reduced.”
The EIS says climate change — the emergency renewable energy attempts to ease — bears some responsibility for the project’s impacts. “The overall impacts of Alternative G when combined with past, present, and reasonably foreseeable activities would be … long term major adverse as a result of climate change. These major adverse impacts from climate change are driven by cumulative activities and trends and not by emissions from the project.”
Referring specifically to impacts on fishing, the EIS states, “The impact level from the presence of structures would be … short term negligible to moderate adverse for the majority of commercial fishing vessels but short term major adverse for a small number of vessels.”
BOEM noted Alternative G “could include long-term minor beneficial impacts for some for-hire recreational fishing operations due to the artificial reef effect,” which has been observed at the five-turbine Block Island Wind Farm.
The original plan for 100 turbines would increase the commercial fishing revenue at risk by $1.42 million, according to the EIS. Alternative G, with 65 turbines, would increase the commercial fishing revenue at risk by $1.14 million. The largest impacts in terms of exposed revenue would be in the spiny dogfish, Atlantic herring, and American lobster fisheries. Midwater trawl and sink gillnet gear would be the gear types most affected. In terms of ports, the largest impacts in terms of exposed revenue as a percentage of total commercial fishing revenue in the regional fisheries area would be in Little Compton (6.4%), Westport, Mass. (5.1%), and Chilmark/Menemsha, Mass. (3.6%).
Ørsted and Eversource, developers of Revolution Wind, have promised dozens of techniques to mitigate the impact of the turbines, from careful movement and repositioning of boulders on the seafloor to work stoppages during the months in which marine mammals are most active in the area.
Ørsted has promised to set up a fund of $12.9 million to compensate fishers for losses during the project’s construction. That amount could rise by $5 million if losses turn out to be larger than estimated. The $12.9 million includes $300,000 for a Coastal Community Fund, $333,333 for a voucher program to provide radar systems, and $300,000 for a project effects study.
Some fishers are appeased, and some are not.
Richard Hittinger, first vice president of the Rhode Island Saltwater Anglers Association, which represents recreational anglers and for-hire charter boats, said the payments and mitigation measures offered by Ørsted have “done nothing at all for recreational fishing.” He complained that the EIS does not include maps showing areas popular for recreational fishing, so it is difficult to determine where the proposed wind facility and recreational fishing spots might overlap. (The EIS does, however, have a table showing latitude and longitude of every turbine location.)
Hittinger said the EIS states the project will avoid terminal moraine — piles of rocks where the greatest diversity of fish larvae and invertebrates exist — but in the absence of standard mariner charts like the Captain Seagull brand, he cannot verify the developer’s claim of avoidance.
In contrast, Rhode Island fishing boat captain David Monti was upbeat about the concessions and mitigating measures contained in the EIS, along with the financial compensation for fishers. Monti praised the reduction of turbines to 65 from 100, saying the move eased some peoples’ concerns about views from Martha’s Vineyard.
Monti also said the project’s footprint absolutely avoids sensitive fishery habitats. Referring to the footprint’s shape, which some people have described as looking like a pirate ship, Monti said, “The whole map looks like Battlestar Galactica. That’s because they removed [from the lease area] sensitive areas of Coxes Ledge. People say [the turbines] are being built on Coxes Ledge. They are not. The whole lease area was designed by BOEM and approved by the [Rhode Island Coastal Resources Management Council] to avoid sensitive fishing areas on Coxes Ledge.”
Responding to public comments, the final EIS states, “BOEM excluded 70 miles of Cox Ledge from offshore wind energy development because of the importance of the area to for-hire recreational fishing and commercial fisheries.”
A multitude of rules and conditions in the EIS are intended to protect the ocean environment and its inhabitants. Some examples of rules in the EIS:
BOEM would restrict bottom-disturbing activities from January through April, with the addition of December with contingencies as described in the [Marine Mammal Protection Act] final rule. Revolution Wind would be required to develop an adaptive acoustic monitoring plan for spawning Atlantic cod from November through March, including restrictions on project activities if Atlantic cod spawning is detected.
Between Nov. 1 and April 30, all vessels, regardless of size, must operate at 10 knots or less when traveling between the lease area and ports; all vessels must immediately reduce speed to 10 knots or less when any large whale, mother/calf pairs, or large assemblages of cetaceans are observed (within 500 meters) of an underway vessel.
For in-water construction, heavy machinery activities other than impact or vibratory pile driving, if a marine mammal is on a path toward or comes within 10 meters of equipment, the lessee must cease operations until the marine mammal has moved more than 10 meters on a path away from the activity.
Between June 1 and Nov. 30, Revolution Wind must have a trained lookout posted on all vessel transits during all phases of the project to look for sea turtles.
To minimize adverse effects to Atlantic cod, no pile driving or seafloor disturbing activities, or removal or detonation of unexploded ordinance, should occur between Nov. 1 and March 31.
No in-water work should occur between April 1 to June 30 to avoid and minimize potential impacts to horseshoe crabs spawning along the beaches of the Western Passage of Narragansett Bay.
To minimize impacts to Atlantic cod sensitive life stages and complex habitats on Coxes Ledge, no more than the minimum number of turbines required to meet the power-purchase agreement should be permitted.
To minimize impacts from boulder/cobble removal/relocation activities, relocate boulders and cobbles as close to the impact area as practicable, in areas immediately adjacent to existing similar complex bottom, placed in a manner that does not hinder navigation or impede commercial fishing, and avoids impacts to existing complex habitats.
Require the use of noise-mitigating measures during pile driving construction, including the use of soft start procedures and the deployment of noise dampening equipment such as bubble curtains.
Cable protection measures should reflect the preexisting conditions at the site. This mitigation measure chiefly ensures that seafloor cable protection does not introduce new hangs for mobile fishing gear.
Reroute the current export cable alignment at the exit of the lease area to avoid impacts to complex habitats.