SEWC Submits Comments to BOEM in Support of Wilmington East WEA

September 12, 2021

Casey Reeves
Program Manager
Bureau of Ocean Energy Management
Office of Renewable Energy Programs
45600 Woodland Road
Sterling, Virginia 20166
casey.reeves@boem.gov

RE: Comments on Notice of Intent To Prepare a Supplemental Environmental Assessment Environmental for the Wilmington East Wind Energy Area (Docket ID: BOEM-2021-0055)

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 Supplemental Environmental Assessment (“EA”) for the Wilmington East Wind Energy Area ("WEA").

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.

SEWC commends BOEM’s decision to move forward with preparing a supplemental EA for the Wilmington East WEA and supports the intent of this process to take into consideration the most recent and relevant environmental, wildlife, and ocean use data. We urge BOEM to move expeditiously through this process, and to ultimately hold a lease sale for the greatest acreage possible of the Wilmington East WEA ahead of the impending leasing moratorium set to take effect on July 1st, 2022.  

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[1].

Investments of more than $2.9 billion[2] have already been made in the U.S. to support the offshore wind industry, primarily through port upgrades and manufacturing. These investments have largely taken place in states that have made strong offshore wind development commitments, and have a significant pipeline of projects and lease areas off their coasts. The Carolinas have an important role to play in this industry.

North Carolina has shown significant leadership through Governor Cooper’s Executive Order 218, which aims to develop 2800 MW of wind off the coast by 2030 with a goal of 8000 MW by 2040. Duke Energy, which serves around 4 million customers across the Carolinas, has a goal of net zero emissions by 2050, which almost certainly requires offshore wind to meet that goal. The state is home to over 30 land-based wind manufacturers that are well-positioned and excited to expand into the offshore industry. South Carolina is home to the world’s most advanced wind turbine drive-train testing facility, and known for their top tier manufacturing capabilities, including the only two subsea cable manufacturers in the country. The port of Charleston is a premiere deep water port with limitless opportunities to support the industry.  In order to realize the tens of thousands of jobs, billions in new economic development, and to reach the goals set by EO 218 and Duke Energy, the Carolinas require BOEM to advance leasing in the Carolina Long Bay.

SEWC respectfully provides the following comments to inform BOEM’s efforts in preparing this supplemental EA for the Wilmington East WEA, and for advancing the offshore wind industry in the Carolinas and the Southeast:

Continue to engage in regular and proactive stakeholder engagement across the Carolinas

Significant amounts of abundant, reliable, cost-effective offshore wind will need to be deployed in the coming years in order to reach the decarbonization goals set forth by the Biden Administration, the state of North Carolina, and the utilities that operate across our region. To ensure that the regulatory process continues to move forward in a transparent, inclusive, and time-sensitive manner, and remains informed by the latest science and data, SEWC encourages BOEM to engage in regular communication with and solicit feedback from various stakeholders that may be impacted by offshore wind development. As has been the case with the lease areas off the coast of the Carolinas, there may be periods of time with little regulatory progress and the existence of continued engagement, both led by or in concert with BOEM, can help to maintain a steady stream of information-sharing and awareness to expedite the regulatory progress as it arises. Additionally, these stakeholder forums will prove essential as the industry begins to contemplate novel matters such as offshore transmission expansion.

Clarify BOEM’s intent with regard to existing WEAs and future WEA identification off the coast of the Carolinas

On September 17, 2015, BOEM published the Commercial Wind Lease Issuance and Site Assessment Activities on the Atlantic Outer Continental Shelf Offshore North Carolina - Revised Environmental Assessment, which considered the lease sale of the Kitty Hawk WEA, as well as the Wilmington East and Wilmington West WEAs. BOEM’s announcement on August 12, 2021 states that BOEM is now looking to hold a lease sale for the Wilmington East WEA, and is therefore only preparing a supplemental EA for the Wilmington East WEA. SEWC recognizes the time challenges associated with the impending offshore leasing moratorium and understands the decision made by BOEM to solely advance the review of the Wilmington East WEA. However, in order for developers and original equipment manufacturers (OEMs) to have confidence in the progression of the regulatory process to support the decision to locate facilities in the Carolinas region, a proactive plan and timeline for evaluating the additional existing Wilmington and Grand Strand WEAs as well as the identification of new WEAs is critical and should be developed and published in a timely manner. SEWC encourages BOEM to work with other federal agencies, the states of North and South Carolina, and the necessary state agencies to determine and publicize an anticipated leasing timeline that incorporates state goals and maximizes economic development opportunities. 

Preserve existing Wilmington East WEA coordinates to the greatest extent possible

Cost-effective deployment of offshore wind relies on, in part, reaching economies of scale both industry-wide and on a project-specific basis. While offshore wind development off the coast of the Carolinas will reap the cost efficiencies gained from technological advancements, first-wave development in the Northeast Atlantic, and a growing domestic supply chain, further savings can be achieved through both market competition and component sourcing efficiencies within a project. SEWC recommends for this reason that BOEM prioritize preserving the existing Wilmington East WEA coordinates to the greatest extent possible. Further, SEWC only supports the removal of OCS blocks or aliquots from the Wilmington East coordinates should BOEM find, through the collection of sound science, a negative impact to the environment, wildlife, or existing ocean users can be anticipated during site assessment activities. Conflicts with the development of a wind energy facility will be identified by either a lessee through its stakeholder engagement activities or by BOEM through later phases of the regulatory process. To fully recognize the benefits of this industry, it is important to ensure that wind energy areas are maximized and analysis of potential conflicts are thoroughly conducted with individual mitigation solutions identified, before removing areas of potential development on account of potential or perceived conflicts.

Determine and implement best management practices throughout the regulatory process

The offshore wind industry has put forth tremendous effort to collaborate with stakeholders early and often to ensure responsible coexistence with the people and wildlife that inhabit, migrate through, navigate, and make a living within the offshore lease areas. Through cooperative science, research partnerships, and co-developed mitigation plans, impacts from existing projects and those under development are becoming increasingly clear. This information should be used by BOEM to develop tools and processes that will streamline the site identification and leasing process, minimizing the regulatory timeline for future projects. SEWC recommends that BOEM openly incorporate applicable information generated from previous EA’s, leasing actions, and developer activities in this supplemental EA and in all regulatory progress in the Carolinas going forward.

Encourage site assessment practices that enhance data collection for future offshore wind energy facility siting

As the Carolinas continue to make progress towards developing an offshore wind industry, the consistent gathering of relevant science and data will be critical towards a streamlined, timely, and transparent regulatory process. SEWC recommends BOEM make a  concerted effort to compile and share marine data submitted by leasees of all Carolina WEAs to create a more robust and efficient leasing and development program in the Carolinas.

Conclusion

We appreciate BOEM’s initiative to prepare a supplemental EA for the Wilmington East WEA, and for prioritizing the advancement of offshore wind leasing ahead of the decade-long moratorium. SEWC and its members reiterate the need to expand offshore wind’s benefit to coasts outside of the Northeast, as the Southeast and the Carolinas stand ready to manufacture, construct, and operate the next wave of offshore wind projects that will provide family-sustaining wages to our communities and carbon-free energy to our region. We urge BOEM to consider the broader suggestions outlined in these comments to ensure that the Wilmington WEA is advanced responsibly, provides maximum benefit to the Carolinas, and sets the stage for continued growth across the Southeast.

Sincerely,

 

Katharine Kollins
President, Southeastern Wind Coalition

 

[1] 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/

[2] American Clean Power (2021). Interactive Map: The Economic Benefits of Offshore Wind. https://cleanpower.org/resources/interactive-map-the-economic-benefits-of-offshore-wind/