Program Manager
Office of Renewable Energy
Bureau of Ocean Energy Management
45600 Woodland Road (VAM-OREP)
Sterling, Virginia 20166

RENEW Northeast, Inc. (RENEW) (1) submits these comments on the U.S. Bureau of Ocean Energy Management’s (BOEM) Supplement to the Draft Environmental Impact Statement (SEIS) for the Vineyard Wind 1 Offshore Wind Energy Project (Vineyard Wind 1) and its analysis of the foreseeable effects of cumulative activities from offshore wind projects on the Atlantic Outer Continental Shelf. On behalf of RENEW, I offer my appreciation to BOEM for its work in considering different viewpoints and creating this comprehensive supplement. RENEW supports BOEM issuing a final Environmental Impact Statement by November 13, 2020, and a Record of Decision by December 18, 2020, approving Vineyard Wind 1, consistent with the revised One Federal Decision Permitting Timeline issued earlier this year. (2)

Approval of the project is pivotal for states on the Atlantic Coast to realize their renewable energy development and carbon reduction legal requirements. In Massachusetts, whose utilities have contracted for the output of Vineyard Wind I, these objectives are codified in its Renewable Portfolio Standard (“RPS”), G.L. c.25A, §11F, and the Global Warming Solutions Act (“GWSA”), G.L. c. 21N.

The 800-megawatt Vineyard Wind I and the several other projects in adjacent lease areas that are now under contract will also provide significant economic development benefits for Atlantic Coast states. At sites located on the Outer Continental Shelf, the Department of Energy estimates offshore wind’s technical potential at over 2,000 gigawatts (or double the amount of all existing installed U.S. electricity), 86 gigawatts of which could be developed by 2050. Atlantic Coast states, recognizing the economic and environmental opportunities afforded by the technology, have collectively issued procurement targets for 29 gigawatts of offshore wind. A recent economic development study from the American Wind Energy Association (AWEA) reported that offshore wind development off the Atlantic Coast could translate into $57 billion in direct investment, add $25 billion in annual economic output and create 83,000 well-paying jobs by 2030, all while stabilizing retail electricity rates and emitting no climate-altering greenhouse
gases.

One of the pivotal outstanding items being reviewed by BOEM is that of navigational lanes. RENEW supports the Alternative D2 uniform 1 x 1 nautical mile layout. The U.S. Coast Guard with its mission to ensure our nation’s maritime safety, security, and stewardship determined the layout, which will provide more than 200 transit lanes in all directions, will “maximize safe navigation”. (3) It concluded in its final report, The Areas Offshore of Massachusetts and Rhode Island Port Access Route Study (MARIPARS), that the 1 x 1 layout, which was agreed to by all New England offshore wind leaseholders, will provide ample and uniform navigation channels and is significantly larger than routes provided in the more mature European offshore wind industry.

The MARIPARS report concluded that the 1×1 nautical mile pattern, orientation and spacing will safely accommodate vessel transits, traditional fishing operations and search and rescue operations. The recommendations on navigation safety in the MARIPARS report show how offshore wind development is compatible with existing commercial and recreational activity in the Wind Energy Area.

The Alternative F proposal to insert unnecessary wider transit lanes would, according to the MARIPARS report, increase risks to navigation safety. (4) That report found that the transit corridors in Alternative F would make “navigation more challenging, [as] most traffic would then be funneled into the corridors thereby increasing traffic density and risks for vessel interaction.” (5) RENEW acknowledges the significantly more extensive comments concerning the transit lane issue in the SEIS submitted by AWEA and stands in agreement with AWEA’s analysis in support of Alternative D2 and in opposition to Alternative F.

In conclusion, RENEW respectfully requests BOEM expeditiously approve the project consistent with the Alternative D2 1×1 nautical mile turbine layout to enable the states in region to meet their schedules for renewable energy deployment and carbon reduction. Thank you for the opportunity to provide these comments.

Sincerely,
Francis Pullaro
Executive Director
RENEW Northeast

(1) The comments expressed herein represent the views of RENEW and not necessarily those of any particular member of RENEW. RENEW is a non-profit association uniting environmental advocates and the renewable energy industry whose mission involves coordinating the ideas and resources of its members with the goal of increasing environmentally sustainable energy generation in the Northeast from the region’s abundant, indigenous renewable resources. RENEW members own and/or are developing large-scale renewable energy projects, energy storage resources and high-voltage transmission facilities across the Northeast. They are supported by members providing engineering, procurement and construction services in the development of these projects and members that supply them with multi-megawatt class wind turbines.

(2) Vineyard Wind Offshore Wind Facility One Federal Decision Permitting Timeline, BUREAU OF OCEAN ENERGY MGMT. (last updated Feb. 7, 2020), https://www.boem.gov/sites/default/files/documents/renewable-energy/state-activities/Vineyard-Wind-SEIS-Permitting-Timetable.pdf.

(3) U.S. Coast Guard, The Areas Offshore Massachusetts and Rhode Island Port Access Route Study (May 14, 2020), https://www.navcen.uscg.gov/pdf/PARS/FINAL_REPORT_PARS_May_14_2020.pdf.

(4) U.S. Coast Guard, The Areas Offshore Massachusetts and Rhode Island Port Access Route Study, 85 Fed. Reg. 31792, 31795 (May 27, 2020).

(5) Id.