Research
People on Cape Cod have recently discovered the Bureau of Ocean Energy Management (BOEM) has determined approximately one million acres of ocean off the coast of Cape Cod National Seashore should be developed with 1,000 skyscraper size wind turbines (84 stories high) with most visible from our ocean beaches. The people of Maine have been involved in the process with BOEM since 2019. The people on Cape Cod, including our elected officials who are members of the BOEM Task Force are just finding out about this plan. The Cape Cod elected officials should have been informed and involved since 2019. They were not. They should have been invited to BOEM Task Force meetings, consulted and advised BOEM since 2019, commented during comment periods and made the public aware of the process. They had no opportunity to do so since they were not informed. BOEM said during the 5/31/24 Task Force meeting they “took the lead from the state”.
Below please find some preliminary research.
BACKGROUND INFORMATION:
1. CAPE COD NATIONAL SEASHORE AND HOW THIS PROPOSAL VIOLATES THE FOUNDING DOCUMENTS OF THIS NATIONAL PARK
The National Park Service was created in 1916 with the Organic Act: (16 U.S.C. l 2 3, and 4), as set forth herein, and consists of the Act of Aug. 25 1916 (39 Stat. 535) and amendments thereto. The agency’s mission as managers of national parks and monuments is “to conserve the scenery and
the natural and historic objects and the wild life therein and to provide for the enjoyment of the same in such manner and by such means as will leave them unimpaired for the enjoyment of future generations.”
https://www.nps.gov/grba/learn/management/organic-act-of-1916.htm
Cape Cod National Seashore was signed into law by President John F. Kennedy on August 7, 1961 with S. 857 Public Law 87-126, Cape Cod National Seashore Act. The Foundation Document of Cod National Seashore states “the purposes of Cape Cod National Seashore are to preserve the nationally significant and special cultural and natural features, distinctive patterns of human activity, and ambience that characterize the Outer Cape, along with the associated scenic, cultural, historic, scientific, and recreational values, and to provide opportunities for current and future generations to experience, enjoy, and understand these features and values.”
https://www.jfklibrary.org/asset-viewer/archives/jfkwhp-1961-08-07-a#?image_identifier=JFKWHP-AR6733-B
Included in the CCNS Purpose is: “Cape Cod’s beauty, solitude, and aesthetic values have offered inspiration and renewal for more than 100 years and contributed to a rich artistic and architectural heritage. Proximity to densely populated areas of the Northeast makes the Cape accessible to millions.”
Also in the Foundation Document of CCNS it states: “Cape Cod continues to be recognized for its special charm and unique ambience, and its proximity to densely populated and developed areas makes its special character all the more important to preserve.”
http://npshistory.com/publications/foundation-documents/caco-fd-overview.pdf
The ocean beaches of CCNS are some of the most pristine beaches in the world designated as a National Seashore in 1961 by President Kennedy. “Miles of Paradise [in which one can] step into the serenity of the Outer Cape [and] Listen to the crashing waves and be at one with Mother Nature” according to the National Park foundation.
Red flashing lights of wind turbines:
Typically wind turbines each have a red light that flashes continuously one hour prior to sunset, all night long and until one hour after sunrise. This means that the perhaps 1,000 wind turbines in the lease areas OCS-A 0564, OCS-A 0567, OCS-A 0568, OCS-A 0565, OCS-A 0569 and perhaps OCS-A 0566 would be visible from our ocean beaches with pulsing red flashing lights. This would drastically change the dark night sky that is currently found at CCNS.
According to material on the NPS website: “The Organic Act of 1916 directs the National Park Service to—”conserve the scenery and the natural and historic objects and the wildlife therein and to provide for the enjoyment of the same in such manner and by such means as will leave them unimpaired for the enjoyment of future generations.” While scenery has been traditionally thought of as being geologic curiosities, distant vistas, and sublime landscapes, it also includes the night sky.”
https://www.nps.gov/subjects/nightskies/resources.htm
Additionally, “The night sky is a natural resource. Naturally dark skies provide refuge for wildlife, and allow natural processes and rhythms to evolve unimpeded. They yield scientific insights into our complex natural world, and allow natural physical processes to churn unabated. In such a landscape, artificial light is inappropriate and potentially harmful.
The night sky is a cultural resource. First-hand observations of the heavens were critical to the Age of Enlightenment, allowing Newton to write the laws of gravity, Galileo to place our sun at the center of the solar system, and Einstein to imagine the fabric of the universe. These discoveries, in turn, had a palpable influence on culture, religion, and art. Today, space is still the frontier of science, enticing children’s interest in science and concealing some of the greatest questions humans have ever asked.
With the popularity of stargazing program, night walks, full moon hikes, and other nighttime activities in parks, natural lightscapes have become an economic resource as well. Visitor facilities in communities surrounding national parks are finding that stargazing activities draw more tourists and tend to increase the length of stay and corresponding economic benefit to those communities.
Everyone has a right to starlight—whether a turtle making its way to the sea or a curious child asking questions about the cosmos or an adult following in the footsteps of great scientists.”
https://www.nps.gov/subjects/nightskies/resources.htm
It is quite evident that from Provincetown to Chatham and over 40 miles of ocean beaches, all along the ocean beaches of CCNS, many hundreds and potentially approximately 1,000 wind turbines would be noticeable and quite visible from our currently “pristine” ocean beaches day and/or night. We have numerous concerns about the wind turbines in the following lease areas where all would be visible from our CCNS ocean beaches in a National Seashore: OCS- A 0564, OCS-A 0567 and OCS-A 0568. We also have serious concerns about the wind turbines in the following lease areas where many would be visible from our ocean beaches in a National Seashore: OCS-A 0565 and OCS-A 0569. We have concerns about the lease area OCS-A 0566 as well as the previously mentioned lease areas should the wind turbines become taller. This is a clear reason why none of these wind turbines should be constructed.
2. SIGNIFICANT HISTORICAL SITES THAT ARE MANDATED TO BE PROTECTED FOR FUTURE GENERATIONS
Indigenous people and National Historic Landmarks:
The Nauset Archaeological District, within the southern portion of Cape Cod National Seashore was one focus of substantial ancient settlement since at least 4,000 BC…The area can be visited via the Fort Hill area, off Route 6, Eastham, where the Fort Hill and Red Maple Swamp trails wind from the top of the hill to the marsh and beyond. Visitors can view interpretive displays of the area at the Salt Pond Visitor Center at the corner of Route 6 and Nauset Road, Eastham. Additional trails from the visitor center to Coast Guard Beach pass by other ancient archaeological sites. The sites around Nauset Marsh, like most archaeological sites in the eastern part of the country, are hidden from view by soil and vegetation. This protects the sites, but it also makes it difficult for visitors to envision ancient settlements. At Nauset, the Champlain map (Figure 1) suggests how houses and cultivated fields must have filled the margins of land around the marsh in pre-European times. The view from the top of Fort Hill overlooking the modern marsh takes in all of Nauset Harbor, with its steep shorelines and extensive marsh divided by natural channels. Beyond the harbor are the breakers of the Atlantic Ocean. Nauset Beach, a barrier beach with a narrow entrance, protects the tidal lagoon.”
https://www.nps.gov/caco/learn/historyculture/the-nauset-archaeological-district-eastham.htm
National Register of Historic Places:
There are 25 National Register of Historic Places listings in Cape Cod National Seashore.
The Highland Light: (previously known as Cape Cod Light) is an active lighthouse on the Cape Cod National Seashore in North Truro, Massachusetts. The current tower was erected in 1857, replacing two earlier towers that had been built in 1797 and 1831. It is the oldest and tallest lighthouse on Cape Cod.
The grounds are open year-round, while the light is open to the public from May until late October, with guided tours available. Highland Light is owned by the National Park Service, and was cared for by the Highland Museum and Lighthouse, Inc. until 2014 when Eastern National, another non-profit group, took over the contract to operate the facility as a tourist attraction. The United States Coast Guard operates the light as an aid to navigation. The United States Navy ship USS Highland Light (IX-48) was named after the light. It is listed on the National Register of Historic Places as Highland Light Station.
Nauset Light, officially Nauset Beach Light: is a restored lighthouse on the Cape Cod National Seashore near Eastham, Massachusetts, erected in 1923 using the 1877 tower that was moved here from the Chatham Light.[2][3][4] It is listed on the National Register of Historic Places. The tower is a cast-iron plate shell lined with brick and stands 48 feet (15 m) high. The adjacent oil house (where fuel was stored in the early days) is made of brick and has also been restored. Fully automated, the beacon is a private aid to navigation. Tours of the tower and oil house are available in summer from the Nauset Light Preservation Society which operates, maintains and interprets the site. The tower is located adjacent to Nauset Light Beach.
Race Point Light: is a historic lighthouse on Cape Cod, in Provincetown, Massachusetts; it is on the National Register of Historic Places. The original tower, first illuminated in 1816, was replaced in 1876 with the current 45-foot tall iron-plated tower and a new keeper’s dwelling. The American Lighthouse Foundation operates the property and rents out two buildings for overnight stays. The actual light is maintained by the Coast Guard. The site is reached by walking about 45 minutes over sand; with a National Park Service Oversand Permit, a four-wheel-drive vehicle can be used.
The Old Harbor U.S. Life Saving Station: is a historic maritime rescue station and museum, located at Race Point Beach in Provincetown, Massachusetts. Built in 1897, it was originally located at Nauset Beach near the entrance to Chatham Harbor in Chatham, Massachusetts. It was used by the United States Life-Saving Service (USLSS), and then by its successor, the United States Coast Guard (USCG), as the Old Harbor Coast Guard Station. The station was decommissioned in 1944, abandoned and sold as surplus in 1947, and was used as a private residence for the next twenty-six years.
The property returned to Federal ownership in 1973, acquired by the National Park Service as part of the Cape Cod National Seashore. The building was added to the National Register of Historic Places in 1975. Two years later, facing the threat of imminent destruction from extreme beach erosion, it was removed, cut in half, and floated by barge to Provincetown. The Park Service rehabilitated it and furnished it as it would have existed during its original use as a turn-of-the-century life-saving station. The Old Harbor U.S. Life Saving Station Museum opened at its new location in 1978.
The Marconi Wireless Station Site: in South Wellfleet, Massachusetts, USA is the site of the first transatlantic wireless communication between the United States of America and Europe, on January 18, 1903. At this location, now part of the Cape Cod National Seashore (though no admission is charged if not visiting Marconi Beach), inventor Guglielmo Marconi erected a large antenna array on four 210-foot (64 m) wooden towers, and established a transmitting station powered by kerosene engines that produced the 25,000 volts of electricity needed to send signals to a similar station in Poldhu, Cornwall, United Kingdom. The first transmission received on the continent of North America by Marconi was at Signal Hill, St. John’s, Newfoundland and Labrador in 1901; Glace Bay, Nova Scotia was the site of the first such two-way transmission, in 1902.
One of the station’s most notable roles occurred with the sinking of the RMS Titanic in April 1912. Operators at the station were able to alert the RMS Carpathia so that the rescue of some of the Titanic’s passengers could be effected. The station was shut down in 1917 in part over concerns about its use in World War I, but also because its towers were threatened with erosion. In 1920, usable materials and equipment were removed from the site, and it was abandoned. Erosion has taken its toll over the years since then, and there was little left as of the date of the National Park Service brochure.[2] No trace of the site remains as of September 2014; the sea has claimed it all.
The site was listed on the National Register of Historic Places in 1975.
The French Cable Hut: is a historic building in Cape Cod National Seashore, near the Nauset Beach Light in Eastham, Massachusetts. Built in 1891, the hut formed a linkage point in the transatlantic telegraph cable of the French Cable Company connecting the cable, where it came ashore near the present site to its main station in Orleans. After the cable was abandoned in 1932, the hut was adapted for residential use. It has since been restored to its turn-of-the-century appearance by the National Park Service. The building was listed on the National Register of Historic Places in 1976.
The Highland House: is a historic hotel building, now serving as a museum, located at 6 Highland Light Road within the Cape Cod National Seashore in Truro, Massachusetts. It is located in the Cape Cod National Seashore near the Highland Light in the Truro Highlands Historic District. The present two story wood-frame building was constructed in 1907 by Isaac Small, whose family had been serving tourists in the area (among them Henry David Thoreau) since 1835.
The building was listed on the National Register of Historic Places in 1975. It is now known as Highland House Museum and is operated by the Truro Historical Society as a museum of local history.
The Edward Penniman House and Barn: is a historic site in Eastham, Massachusetts, on Fort Hill, which is currently protected by the Cape Cod National Seashore and home to Indian Rock.
The house was built in 1868 and added to the National Register of Historic Places in 1976.
The house was built by Edward Penniman (1831–1913). When Edward Penniman was growing up, it was possible to catch whales directly from the seashore, a practice the Indians perfected using the shallow marsh waters to scare herds of blackfish onto the beaches. Attracted by the profits to be made as a whaler, he ran to sea at age eleven and at 29 he was master of his own whaling ship. He took his wife with him on his travels, and the addition of 3 children to his household did not deter him from trips lasting up to four years. His youngest daughter suffered from seasickness and was sent to live with an aunt. It is the family correspondence with this daughter that makes the Penniman house so interesting, as it brings the daily life of a whaling captain into perspective.
On retirement in 1868, Captain Penniman built this unusual house with plans he designed himself, including a modern toilet and bath with hot running water. From the cupola he would watch his extended family play in the surrounding fields, while on the lookout for ships. His daughter took many pictures of impromptu family gatherings, including a picture of her mother in pants.
The Fort Hill Rural Historic District: is a historic district encompassing two farmsteads with more than 200 years of history in Eastham, Massachusetts. The district is a 100-acre (40 ha) area of forest, fields, and salt marshes that was owned by the Knowles and Penninman families from 1742 to 1941. It has been part of the Cape Cod National Seashore since 1961. The area is dominated by the rise called “Fort Hill”, which provides extensive views of the area and has its own rich history. The district includes the Edward Penniman House and Barn, previously listed on the National Register of Historic Places, and the Nauset Archeological District, a National Historic Landmark.
The district was listed on the National Register of Historic Places in 2001.
The Truro Highlands Historic District: encompasses an area of North Truro, Massachusetts, within the Cape Cod National Seashore, that has served as a recreational destination for more than 175 years. The major features of the district, which is centered on Highland Road east of US Route 6, are the Highland Light Station, the Highland House (now a museum), and the Highland Golf Links, one of the oldest golf courses on Cape Cod.[2]
The district was added to the National Register of Historic Places in 2011.
The Dune Shacks of Peaked Hill Bars Historic District: occupies approximately 1,960 acres within Cape Cod National Seashore at the northern end of the park. The historic district includes both historic buildings, known as dune shacks, and the dune landscape. According to the 2011 National Register of Historic Places documentation, the historic district is significant for its role in the development of American art, literature and recreation; for its association with the life of American poet, Harry Kemp; for its collection of dune shacks which represent a regional waterfront expression of a rare and fragile architectural type of shelters; and for its potential to yield further archeological information about prehistory or history…The shacks themselves have their roots in the lifesaving huts of the maritime era in the mid-19th century. The first lifesaving station in the area was built in 1872 and was known as the Peaked Hill Bars Lifesaving Station. In 1914, the first recorded transition from a lifesaving structure to a private residence took place…In 1961, when Cape Cod National Seashore was created, dune dwellers continued to live in the shacks.” This historic and cultural landmark will be adversely impacted by any proposed wind turbines off the ocean beaches of CCNS.”
https://www.nps.gov/caco/learn/historyculture/dune-shacks-of-peaked-hill-bars-historic-district.htm
3. COST
Tourism and the economy of Cape Cod:
According to the CC Chamber of Commerce, “Tourism creates $1.3 billion in spending by domestic travelers, supporting 12,000 jobs and generating more than $89 million in state and local tax receipts.” A “National Park Service (NPS) report shows that 4 million visitors to Cape Cod National Seashore in 2022 spent $548 million dollars in communities near the park. That spending supported 6,680 jobs in the local area and had a cumulative benefit to the local economy of $750 million dollars.”
https://www.capecodchamber.org/your-chamber/public-policy/policy-priorities/sustainable-tourism/
A vast majority of people who live on Cape Cod derive their income from the tourist industry either directly or indirectly. If wind turbines are constructed off of CCNS, the entire economy of Cape Cod could collapse, people could lose their livelihood and the cost to society would be immeasurable.
Transmission and power cables brought onshore:
During a BOEM meeting on May 31, 2024 it was stated that transmission cable bundling was the most efficient method of transmission of offshore wind to the shore. The other method is known as a spaghetti method bringing more cables and transmission lines onshore. It was also stated that transmission would cost upwards of one and a half billion dollars, or eight billion dollars. These costs would be paid by the consumers of electricity in Massachusetts.
Any transmission of power and cables from the proposed wind turbines need to be brought through a marine sanctuary in order to reach land. There are major concerns.
Astronomical Cost to consumers:
On Cape Cod we currently pay some of the highest electric rates in the nation. Although other wind turbine installations initially promised low rates, the final cost to the Massachusetts consumer will not be what was initially promised. It is not acceptable to raise the rates to consumers of electricity to the people and businesses in Massachusetts with this technology both with the wind turbine generated power and the transmission infrastructure and cables.
4. ENVIRONMENTAL IMPACTS
According to BOEM material, potentially each of these wind turbines would have the power of 13 MW to 16 MW at this point in time. Wind turbines emit audible noise as well as low frequency noise and infrasound.
Noise and marine mammals, fish, birds, other mammals, other forms of life including endangered species:
According to NOAA fisheries: “Sound is essential to many types of marine animals and is one of the main tools they use to survive in the ocean…[marine mammals] rely on sound to communicate with each other, navigate, find mates and food, defend their territories and resources, and avoid predators. Fish and invertebrates also use sound for basic life functions…Because water is denser than air, sound travels faster and farther in the ocean…Some sounds, particularly low-frequency ones, can cover vast distances, even across ocean basins…Depending on the sound source, duration, and location, human-caused sound has the potential to affect animals by: Causing temporary or permanent hearing loss. Causing a stress response. Forcing animals to move from their preferred habitat. Disrupting feeding, breeding/spawning, nursing, and communication behaviors. The impacts may be immediate and severe, or they may accumulate over time.”
https://www.fisheries.noaa.gov/insight/understanding-sound-ocean
BOEM material contains maps showing all of the proposed lease areas also have high density of whale activity. BOEM has sited wind turbines in areas where there is known high density of whale activity. There are other places where there is little or no whale activity.
This area is part of where the critically endangered North Atlantic Right Whale spends the entire year and the only place in the world where there are year round feeding grounds for these whales.
The Department of Marine Fisheries map depicts several areas areas of concern for birds. Seabird risk and vulnerability assessment is high within the proposed lease area OCS-A 0566. Also within OCS-A 0566 and in within each of the other lease areas of OCS-A 0569, OCS-A 0568, OCS-A 0564,OCS-A 0567 there are areas identified as core use areas for diving birds.
There is a grave concern about bats since it is common knowledge that bats drop out of the sky dead near wind turbines.
13 MW wind turbines offshore have only been installed fairly recently. We want to review scientific studies conducted by independent scientists published in reputable scientific journals showing conclusively that 16 MW wind turbines and at what distance, do no harm to mammals, fish, birds, bats and other life. If there is 10GW of wind power sited starting at only 24 miles off of our National Seashore beaches, point us to documents that guarantee there would be no harm.
On Cape Cod we are familiar with a legal determination that stated irreparable damage to the health of citizens in Falmouth, MA was done by 2 wind turbines of 1.65 MW each.
Ecosystems and biodiversity:
The draft of floating offshore wind foundations will penetrate the thermocline could potentially result in the mixing of stratified waters as a result of wake effects. “Enhanced mixing may lead to profound impacts on shelf sea dynamics and thus marine ecosystem functioning,” and “it is concluded that offshore wind farm infrastructure may have significant, and long lasting, effects on fragile shelf sea ecosystems”
https://www.frontiersin.org/articles/10.3389/fmars.2022.830927/full
The cool pool:
Significant concerns of the potential impacts wind turbines have to the cool pool have been raised. The cool pool is essential to many of the high value fisheries present such as lobsters and scallops and many ground fish species.
Other living creatures in the ocean, some we are just learning about, example:
It is important to understand the interdependence of nature in an area we intend to change before we do so. Diatoms are present in the ocean and are essential to life because they convert CO2 to oxygen. “Every other breath you take comes from these forms of life. This is the ocean breathing… our breath of life. It is wise to pay attention to the light we cannot see, to the sounds we cannot hear & to the life we know is there; on which our lives, all our lives depend.” This statement is according to a leading scientist and expert on noise and its impact on whales, Christopher Clark.
Https://www.youtube.com/watch?v=HdHW77blug
5. OTHER
Unexploded ordinances:
OCS-A 0567 (western most lease area), could be impacted by the Camp Wellfleet FUDS. Camp Wellfleet was located at what is now Marconi Beach and was used as an artillery and anti aircraft firing range and missile testing range from 1942 until 1961. Fire was directed into the Ocean due East of Camp Wellfleet. The finalized FUDs report was issued in 2022.
Commercial and recreational fishing in this area
Some stories about fishers and wind turbines are already alarming. There is a fishing industry off of the ocean beaches on Cape Cod. They are an economic driver for this region. If they are adversely impacted, this is a problem of magnitude and should not be allowed to happen. Here are a few stories that forecast a bleak picture.
“Where offshore wind advocates see one of the best options for curbing climate change, fishers see a maze of obstacles that will make their jobs tougher and more dangerous.
““Wind farms are getting a tremendous political push, whereas the people who fish are being crushed,” said Greg Matarones, president of the Rhode Island Lobstermen’s Association…[Fisher Robert Ballinger stated] Where they want to put those turbines is right where all these are during the summer,” he said, grabbing a squid from the deck and giving its slimy, silvery body a frustrated squeeze. “And the amount they want to put in — it’s mind-boggling. It will change the entire squid season.” But there’ve been plenty of problems with the transmission line that carries electricity from the turbines to the mainland. Despite promises it would be buried, large sections sit exposed on the seafloor. Orsted, the Danish energy company that owns the farm, has placed blocks and mats on the exposed sections, but these protections pose snag hazards for drag netters in what Ballinger said was a “sweet spot” for squid. “I’ve wrecked two nets on it, and various other guys have wrecked nets on it,” he said.”
“The future of wind power and the plight of fishermen are colliding in New Bedford. The components to build turbines for Vineyard Wind, which started offshore construction last November, will be shipped from the Port of New Bedford, which is also the top-earning commercial fishing port in the nation. It supports almost 15,000 jobs and moves between 390 and 544 million pounds of seafood a year from its waterfront to consumers around the world.
“The great majority of the people who rely on going out to fish will be squeezed out of the industry,” said Scott Lang, a former mayor of New Bedford and an attorney who for four decades has represented many of the city’s commercial fishermen. “This is going to be the final nail.””
Shipping lanes
There are major shipping lanes going east to west and north to south in the area. “The maritime community has expressed concern that wind turbine generators could interfere with radar, complicating navigation for both large vessels passing through shipping channels near offshore wind farms, and smaller vessels navigating through or adjacent to the structures, the report said. Previous studies that examined this question relied on data from European wind farms — however, wind turbines in offshore wind farms located in or planned for the U.S. Outer Continental Shelf are larger, and spaced farther apart than those included in past studies.
The report concludes wind turbine generators have significant electromagnetic reflectivity, and therefore can interfere with radar systems operating nearby. The rotating blades can also create reflections in Doppler radar systems. In particular, these forms of interference could obfuscate smaller vessels and stationary objects such as buoys on radar, complicating navigation decisions and increasing the risk of collision with larger vessels. Maritime search and rescue teams also rely on radar to find smaller boats — their primary targets — and interference could therefore also complicate rescue operations near wind farms.”
Furthermore any loss of power to a ship like a big tanker could cause widespread damage as in the recent Baltimore bridge disaster.
Quality of Life:
Simply put, if any wind turbines are visible from our ocean beaches within CCNS, or there are any red lights visible at night or if there is any damage to the health of people or other life, the quality of life will be severely adversely impacted. This is simply unacceptable.
BOEM statement in documents of the two approved offshore wind project in MA regarding the minimal impact to climate change:
BOEM General statement in assessing the Vineyard Wind project: Climate change: Construction and operation of offshore wind projects would produce greenhouse emissions(GHG) (nearly all CO2) that contribute to climate change…U.S. offshore wind projects would by themselves probably have a limited impact on global emissions and climate change, but they may be significant and beneficial as a component of many actions addressing climate change, and integral for fulfilling state plans regarding climate change.”
BOEM Environmental Impact Statement in assessing the Revolution Wind project under many categories, the impact to greenhouse gas emissions is minimal:
Environmental Justice: given the global scale of GHG emissions, the reduction in GHG emissions resulting from the Project would have a long term negligible beneficial impact on the health and safety of environmental justice populations.
Commercial Fisheries and For-Hire Recreational Fishing:
As they become operational, future offshore wind facilities would produce fewer GHG emissions than fossil fuel– powered generating facilities with similar capacities. However, given the global scale of GHG emissions, the benefits would be negligible. The cumulative impacts to commercial fisheries and for-hire recreational fishing in the GAA would be similar to those under the Proposed Action: long term negligible beneficial.
Given the minimal impacts to climate change overall, it is important to receive justification for a technology that has the potential for large scale damage, especially when there are other responsible solutions.
6. BOEM RENEWABLE ENERGY AUTHORIZATION PROCESS IS NOT BEING FOLLOWED BY BOEM:
It is requested BOEM follow its mandated timeline and process as published in a number of locations online. This calls for BOEM to first evaluate the public comments from the Proposed Lease Sale Notice comment period that just ended in July 1, 2024; change the Proposed Lease Areas based upon the public comments received; review the Draft Environmental Assessment relative to these changes; convene a series of well publicized Task Force Meetings, including one in Barnstable County and invite all elected officials in Barnstable County, MA, NH and ME to attend so the public, public officials and others who have an interest in this topic may be informed and have the opportunity to comment, and advise BOEM; then reissue the Draft Environmental Assessment with a comment period. Given the current document is 259 pages long, it makes good common sense to issue a comment period of 60 days following the process BOEM defines and which has not been followed.
BOEM FY 2023 Budget Justification
Page 34: Timeline clearly shows the process outline is NOT being followed
“Conduct Area Identification and Determine Wind Energy Areas” Prior to and not concurrent with: “Conduct Environmental Review and Prepare Environmental Assessment”
Page 35: Once again clearly states the Assembly of Delegates should have been part of the process beginning in 2019.
Question: Isn’t it incumbent upon the public comments to insist the process restart and all elected officials in Barnstable County as well as the public informed and notified about opportunities to be engaged in the process?
“The Planning and Analysis phase seeks to identify suitable areas for wind energy leasing consideration through collaborative, consultative, and analytical processes that engage ocean users, stakeholders, Tribal governments, and State and Federal agencies. In this phase, BOEM coordinates with stakeholders and ocean users to deconflict potential renewable energy lease areas with existing uses on the OCS. After identifying Wind Energy Areas, BOEM conducts environmental reviews and consultations with Tribes, States, and natural resource agencies to consider reasonably foreseeable impacts associated with leasing (e.g., site characterization surveys and site assessment activities). Once the environmental review and consultations are completed for a Wind Energy Area, BOEM may proceed to the leasing phase.”
https://www.doi.gov/sites/doi.gov/files/fy2023-boem-greenbook.pdf
Wind Energy Commercial Leasing Process
Once again see that the process is NOT being followed:
First “BOEM identifies priority Wind Energy Areas (WEAs) offshore…”
Two steps later it talks about BOEM preparing an Environment Assessment
7. PHOTO SIMULATION AND GULF OF MAINE LEASE AREA VISIBILITY – BOEM:
Please see below a graphic of the wind turbines from Highland Light when it is zoomed from 19% that is shown on the BOEM website to 100% in a graphics program as is necessary to see. (Most people will NOT know this.)
(However, the 500′ smoke stack in Sandwich is about the same distance away [23 miles] from Wellfleet as the projected wind turbines are from shore. It looked about the same size from the beach as these 1,171′ wind turbines in the BOEM photo simulation from the top of Highland Light.)
The BOEM expert at the 5/31/24 Task Force meeting stated that all of the following wind turbines would be visible from our Cape Cod National Seashore ocean beaches and uplands in a National Seashore in the following proposed lease areas: OCS-A 0564, OCS-A 0567 and OCS-A 0568. Furthermore many in the following proposed lease areas would be visible from our ocean beaches and uplands day and/or at night in a National Seashore: OCS-A 0565 and OCS- A 0569. ALL OF THE WIND TURBINES IN THESE PROPOSED LEASE AREAS SHOULD NEVER BE CONSTRUCTED BECAUSE THEY VIOLATE THE 1916 ORGANIC ACT AND THE FOUNDATION DOCUMENT OF THE CAPE COD NATIONAL SEASHORE. There are concerns about the lease area OCS-A 0566 as well as the previously mentioned lease areas should the wind turbines become taller.
Question: If the wind turbines are constructed, should we use good common sense and question will they look twice as tall as the ones in the BOEM photo simulation from the ocean beaches of Cape Cod National Seashore?
Question: If the BOEM visibility map is accurate, does that mean the wind turbines could be seen in Dennis?
Question: Do we want the advertisement for Cape Cod and Cape Cod National Seashore to change to the following: Visit Cape Cod when it’s fogged in, misty or raining…when it is clear and beautiful, you will see a wall of approximately 1,000 wind turbines from Provincetown to Chatham 40 miles long off of our National Seashore ocean beaches day and/or night?
WE DON’T NEED TO DESTROY OUR ENVIRONMENT IN ORDER TO SAVE IT. LET’S WORK TOGETHER AND IMPLEMENT ACTUAL RESPONSIBLE SOLUTIONS TO STOP AND REVERSE CLIMATE CHANGE.