SEWC Submits Comments to BOEM in Support of Kitty Hawk Offshore Wind Project
August 30, 2021
Bureau of Ocean Energy Management
Office of Renewable Energy Programs
45600 Woodland Road
Sterling, Virginia 20166
RE: Comments on Notice of Intent To Prepare an Environmental Impact Statement for the Proposed Kitty Hawk Offshore Wind Project Offshore North Carolina (Docket ID: BOEM-2021-0050)
Dear Mr. Reeves,
The Southeastern Wind Coalition ("SEWC") appreciates the opportunity to provide comments to the Bureau of Ocean Energy Management ("BOEM") concerning the Notice of Intent ("NOI") to prepare a Draft Environmental Impact Statement ("EIS") for the review of a construction and operations plan ("COP") submitted by Kitty Hawk, LLC ("Kitty Hawk") for the Kitty Hawk Offshore Wind Project.
SEWC is a 501(c)(3) non-profit organization that works to advance the wind industry in ways that result in net economic benefits to utilities, residents, and ratepayers. The Coalition takes an objective, data-driven, and economic development-focused approach to ensure the Southeast can take advantage of this clean, abundant generation source. Our members include industry (e.g., manufacturers, utilities, suppliers, developers, consultants, service providers), appropriate government bodies (economic developers, commerce departments, energy offices), academic and research institutions, and other non-profit organizations.
We are at a pivotal moment in our country’s efforts to both combat the effects of climate change, and to support the burgeoning offshore wind industry - a technology that will play an integral role in that fight. The Biden Administration’s ambitious goal of achieving 30-gigawatts (GW) by 2030 will unlock the economic and environmental benefits offshore wind stands to provide - more than 44,000 well-paying jobs, nearly $12 billion per year in capital investment, and eliminating 78 million metric tons of CO2 emissions from the atmosphere. The responsible development of Kitty Hawk is the next step towards realizing this goal, as well as making progress towards respective offshore wind goals set by both North Carolina through Governor Cooper’s Executive Order 218, or Virginia’s Clean Economy Act. We support the responsible advancement of Avangrid’s Kitty Hawk project, and the unparalleled benefit it will provide to our economy, environment, and communities.
SEWC provides the following comments regarding the potential effects that the proposed action could have on socioeconomic and cultural resources, including commercial fisheries and for-hire recreational fishing, demographics, employment, economics, environmental justice, land use and coastal infrastructure, navigation and vessel traffic, other uses (marine minerals, military use, aviation), recreation and tourism, and scenic and visual resources (FR Doc. 2021-16282-P50).
Commercial Fisheries & For-Hire Recreational Fishing
Because of the project's location, fishers from both North Carolina and Virginia may conduct operations within the lease area. Both states have major commercial fisheries, with Virginia producing the most seafood on the East Coast and North Carolina producing the most on the South Atlantic Coast. Because of the importance of the fishing industry, as well as the nascency of offshore wind in the United States, coastal towns have expressed concern about their ability to continue commercial fishing throughout the building and operation of offshore wind farms. Given the economic benefits of both industries, we urge the Kitty Hawk Draft EIS to conduct additional research into potential consequences and to help guide any necessary monitoring and mitigation.
While individual fish injury and/or mortality may be unavoidable during initial construction, current studies demonstrate that offshore wind and fisheries can coexist without inflicting population-scale problems. Offshore wind contributes to the growth of habitat for undersea populations by creating an artificial reef, which promotes biodiversity. Wind turbines can provide a safe haven for new creatures and provide habitat for benthic organisms such as commercially significant fish and invertebrates. Fishing trawls at Block Island Wind Farm discovered a higher variance in species surrounding the wind farm as compared to pre-construction investigations. Similarly, in Europe, fisheries and wind farms have been effectively co-located, with considerable impacts reduced by investigation, planning, and assessment.
Recreation and Tourism
Offshore wind’s impacts on recreation and tourism are becoming better understood as more projects are constructed in areas with important tourism economies. In the U.S., the Block Island project has shown that not only can tourism exist within view of offshore wind, but it can thrive. In the first year after the turbines were constructed only three miles from shore, both revenues and occupancy increased for Airbnb vacation rentals.
Given Kitty Hawk’s distance from the coast is unlikely to create viewshed impacts, we would similarly not expect noticeable impacts to tourism and recreation. Additionally, offshore wind creates a new coastal employment sector, allowing coastal residents to work outside of the seasonal confines of the tourism industry.
Economics and Employment
Offshore wind is a once-in-a-generation opportunity for Virginia and North Carolina, bringing thousands of jobs and economic benefits. Kitty Hawk, the region's second offshore wind project, is expected to support over 900 jobs and generate over $2 billion in economic impact over the next decade. Offshore wind jobs are well-paying, with onsite employees earning an average annual income of $141,000. (including employer-provided benefits such as retirement and health care contributions). Earnings in the supply chain are expected to be approximately $78,000, while earnings in induced jobs are expected to be around $57,000. The project will raise total net household incomes in Virginia by $390 million, $273 million of which will be in Hampton Roads.
Virginia is already reaping the benefits of the $100 billion offshore wind supply chain, as corporations consider the state as a potential hub for business development. Partnerships with industry giants such as Ørsted have resulted in a six-year lease to Portsmouth Marine Terminal, which in full could be worth approximately $13 million to the port, and could come with more than $20 million in site upgrades. Virginia's progress in offshore wind has also prompted Siemens Gamesa, a world leader in renewable technology, to actively explore locating a $200 million blade facility in Hampton Roads, which would create approximately 750 jobs. Furthermore, North Carolina has the greatest manufacturing workforce in the Southeast. In order to attract future development and avoid supply chain interruptions, both states must continue to demonstrate their commitment to offshore wind development and understand the need for forwarding momentum. The draft Kitty Hawk EIS is the next stage in maintaining momentum and ensuring that development on offshore wind in the United States does not stall.
Low-income Black and Brown communities are disproportionately affected by the effects of climate change and the adverse repercussions of fossil fuel generation. Wind, solar, and geothermal energy have all helped to reduce pollutant emissions over the last decade, resulting in health benefits such as fewer premature deaths, respiratory and cardiovascular ailments, and lost work and school days; nevertheless, more progress is needed.
The Virginia Environmental Justice Act (VEJA) was enacted by the Commonwealth in 2020 to assure the equitable treatment and meaningful participation of historically underserved populations in decision-making processes affecting their health and environment. The Virginia Clean Economy Act (VCEA) of the same year mandated that offshore wind projects prioritize marginalized populations in community involvement, employment training, and job recruitment. In North Carolina, the Environmental Justice and Equity Advisory Board of the Department of Environmental Quality Secretary “advises the Secretary on the consistent implementation of fair treatment and meaningful involvement of North Carolina citizens across the Department” . President Biden recently echoed environmental justice concerns by calling for action through Executive Orders 12898 and 1400811, which are aimed at addressing the federal environmental impact on minority communities and prioritizing investments in environmental justice through federal infrastructure proposals.
Offshore wind is a clean energy alternative that places a premium on conservation and environmental stewardship. A typical wind turbine will pay off its carbon footprint in less than six months and continue to provide emission-free electricity for the remainder of its 20 to 30-year lifespan. This means that offshore wind can assist to displace pollution-emitting fossil fuel generation sources, which are often located in underserved communities. Furthermore, the prioritization of underserved populations in both VEJA and VCEA helps to ensure that low-income and communities of color can reap the benefits of economic development, job creation, and additional tax revenue from offshore wind development.
The COP for Kitty Hawk demonstrates that no potential operations will overlap with any designated environmental justice area. SEWC recommends further engagement by Avangrid Renewables and the Kitty Hawk team with minority communities and detailed tracking of that engagement. SEWC would also recommend that the company define the measures it intends to use to track diversity, equity, and inclusion in its hiring practices.
We urge BOEM to do additional research into these and other possible economic and environmental implications of Kitty Hawk on environmental justice communities. While historically disadvantaged communities are expected to benefit from millions of dollars in state and local tax income, more guidance on how to reduce other potential socioeconomic impacts, such as the short and long-term effects on affordable housing, is needed.
We encourage BOEM to move forward with drafting the EIS, advancing the offshore wind industry and the Southeast’s clean energy future. Offshore wind provides an opportunity that goes beyond just one region but has a national impact. Because of this, we urge BOEM to consider the broader suggestions outlined in these comments to ensure that Kitty Hawk is developed sustainably and responsibly, enabling the project to serve as a model for future offshore wind development. We appreciate the opportunity to weigh in on this matter and look forward to engaging in productive efforts and discussions with BOEM regarding Kitty Hawk and the Southeast's advancement of clean energy projects.
Katharine Kollins, President, Southeastern Wind Coalition
 The White House (2021, March 29) Biden Administration Jumpstarts Offshore Wind Energy Projects to Create Jobs. https://www.whitehouse.gov/briefing-room/statements-releases/2021/03/29/fact-sheet-biden-administration-jumpstarts-offshore-wind-energy-projects-to-create-jobs/
 Cody, R. (2021). (rep.). Fisheries of the United States. NOAA Fisheries. Retrieved from https://media.fisheries.noaa.gov/2021-05/FUS2019-FINAL-webready-2.3.pdf?null=
 Degraer, S., Carey, D., Coolen, J., Hutchison, Z., Kerckhof, F., Rumes, B., & Vanaverbeke, J. (2020). Offshore Wind Farm Artificial Reefs Affect Ecosystem Structure and Functioning: A Synthesis. Oceanography, 33(4), 48-57. doi: 10.5670/oceanog.2020.405
 Offshore Wind and Fisheries: The Science Behind Coexistence. (2021). Retrieved 2 August 2021, from https://cleanpower.org/wp-content/uploads/2021/06/OSW-Factsheet-Fisheries-Science-Behind-Coexistence.pdf
 Wilber, D., Carey, D., & Griffin, M. (2018). Flatfish habitat use near North America's first offshore wind farm. Journal Of Sea Research, 139, 24-32. doi: 10.1016/j.seares.2018.06.004
 Offshore Wind and Fisheries, 2021
 Andrew Carr-Harris, Corey Lang. Sustainability and Tourism: The Effect of the United States’ First Offshore Wind Farm on the Vacation Rental Market. Resource and Energy Economics, 2019; DOI: 10.1016/j.reseneeco.2019.04.003
 (2021). (rep.). Economic Impact of Kitty Hawk Offshore Wind. Retrieved from https://www.kittyhawkoffshore.com/wps/wcm/connect/www.kittyhawkoffshore.com6868/948731ee-8a59-4336-b6d7-5c7374ca0f03/Economic_Impact_KHOW_Report_MFINAL_v1.pdf?MOD=AJPERES&CACHEID=ROOTWORKSPACE.Z18_NIL40101P8T300QULESL022GJ4-948731ee-8a59-4336-b6d7-5c7374ca0f03-npnwe26
 U.S. Department of Energy. (2014, January). Economic Impacts of Offshore Wind. https://www.nrel.gov/docs/fy14osti/60445.pdf.
 Economic Impact of Kitty Hawk Offshore Wind, 2021
 Hampton Roads Alliance. (2020). (publication). Potential Impact of the Development of the Offshore Wind Energy Industry on Hampton Roads and Virginia. Retrieved from Potential Impact Of The Development Of The Offshore Wind Energy Industry On Hampton Roads And Virginia
 Hampton Roads Alliance, 2020.
 North Carolina Department of Commerce. (2021). (publication). Building North Carolina's Offshore Wind Supply Chain: The Roadmap for Leveraging Manufacturing and Infrastructure Advantages. Retrieved from https://files.nc.gov/nccommerce/documents/Policymaker-Reports/Report_North-Carolina-OSW-Supply-Chain-Assessment_BVGAssociates_asPublished-Mar3-2021.pdf
 U.S. EPA. (2018). (publication). Quantifying the Multiple Benefits of Energy Efficiency and Renewable Energy: A Guide for State and Local Governments. Retrieved from https://www.epa.gov/sites/default/files/2018-07/documents/epa_slb_multiple_benefits_508.pdf
 Secretary's Environmental Justice and Equity Board. North Carolina Department of Environmental Quality. (n.d.). https://deq.nc.gov/outreach-education/environmental-justice/secretarys-environmental-justice-and-equity-board.
 Global Wind Energy Council. (n.d.). Wind Power Works. https://gwec.net/wp-content/uploads/2012/06/Wind-climate-fact-sheet-low-res.pdf.
 See AVANGRID RENEWABLES, KITTY HAWK OFFSHORE: CONSTRUCTION AND OPERATIONS PLAN (26 July, 2021), available at https://www.boem.gov/renewable-energy/state-activities/kitty-hawk-wind-construction-and-operation-plan-commercial-lease [hereinafter Kitty Hawk COP”] at 7.9.1
 Kitty Hawk COP, at 126.96.36.199