While NRDC has long been a strong supporter of increased use of wind energy, we have moved cautiously when it came to the Cape Wind project. This has been out of respect for the environmental review process—a corner stone of modern environmental policy—and wanting to make sure that the first offshore wind project in the US gets it right. The results of the DEIS and the other studies we have reviewed make it clear to us that the Cape Wind project will be a big win for the environment and is urgently needed. However, no energy project is without its potential environmental impacts and, to address these, NRDC strongly recommends that the Final Environmental Impact Statement (“FEIS”) and any lease, easement, and right-of-way for the Project include specific monitoring and mitigation conditions to protect the coastal and marine environments.

The technology for producing electricity from wind energy has improved greatly over the past twenty years, and wind—on and offshore—now represents one of the most promising sources of emissions free electricity. Indeed, offshore wind power is probably the New England’s largest untapped renewable energy resource and a vital resource for the entire country.

The potential benefits of the project are undeniable. The project would produce a maximum electric output of 468 MW and an average daily output of 182.6 MW free of air and water pollution. In addition to the local and regional air pollutants, such as NOx and SOx that the project would avoid, the project would reduce emissions of carbon dioxide—the pollutant most responsible for global warming by 0.88 million tons per year. As UCS calculated as part of their comments, this means that Cape Wind will reduce expected growth in CO2 emissions from the power sector in 2014 by about 9%.

This would be an important contribution to fighting global warming for two reasons: 1) it would do more than any other renewable energy source of electricity in New England to avoid global warming pollution and 2) it is by far the largest single contribution that Cape and Islands—a region that is exceptionally vulnerable to global warming—can make to reducing greenhouse gas emissions.

To address the environmental impacts of the project, NRDC recommends that the FEIS and lease, right-of way or easement for the project include the following: 1) a requirement for a comprehensive underwater acoustic monitoring system that not only measures the levels of underwater noise but that detects the approach of marine species into the safety zone around the turbines, 2) a requirement that construction activity be scheduled so as to avoid periods of peak abundance of threatened or endangered species, 3) a requirement that additional surveys be conducted to reduce remaining uncertainty regarding the threat of impacts to the federally endangered Roseate Tern, and 4) a requirement—detailed below—for a comprehensive Environmental Management, or adaptive management, system.

Given the relative lack of experience with offshore wind projects in this country, there is the possibility that the scale of certain impacts will only become clear overtime. It is important to the future not only of this project but to offshore wind generally, that there be an effective system be in place to monitor and adjust operations to avoid such impacts.

To that end, we call on MMS to include in the FEIS and as a condition of any lease, easement or right-of-way, a detailed and comprehensive Environmental Management System for monitoring and mitigating potential impacts associated with project construction and operation. MMS’s interim policies and Best Management Practices, issued as part of its Alternative Energy and Alternate Use (AEAU) Program, require MMS and lessees and grantees to adopt adaptive management that will include monitoring of activities to ensure that potential adverse impacts of OCS alternative energy development are avoided (if possible), minimized, or mitigated.

The Environmental Management System should achieve the following goals:

• · be guided by a panel of government and academic scientists,
• · include specific adaptive responses for environment impacts judged to be reasonable possibilities at the chosen site,
• · include a framework that prevents abuse of the program and which also protects the economic interest of Cape Wind by establishing a reasonable budget for implementation costs and mitigation measures including possible short-term shutdowns,
• · require monitoring during both construction and operation, and
• · require that all data collected be made available to the public, in electronic form, in real-time when possible.

The urgency of stopping global warming increases regularly as the drumbeat of scientific studies about the quickening pace of climate change continues. Cape Wind will make an important contribution to the fight against global warming both through its immediate displacement of fossil fuels and by paving the way for greater use of offshore wind.

MMS should adopt our recommendations, finalize the EIS, and expeditiously permit the project with the recommended monitoring and mitigation measures.