RE: DOE/EA 1792 University of Maine’s Deepwater Offshore Floating Wind Turbine Testing and Demonstration Project, Gulf of Maine (108 page PDF)
Dear Ms. Margason,
We are writing in response to the draft Environmental Assessment for Project DOE/EA 1792, released by the Department of Energy.
Penobscot Bay Watch sent scoping comments to the DOE in October 2010, noting concerns over the limited scope of review proposed, which excluded the reasonably foreseeable offsite indirect and secondary impacts that would flow out from the University's proposed activity, if the impacts to larger oceanic processes of the Gulf of Maine did occur as a result of development and deployment of the planned sequence of full scale floating wind turbines - the entire raison d'etre for the University's project.
The University seems content to hold that there is no necessity to consider any impacts beyond such immediate and short term impacts to resources they have identified as being within the footprint and viewshed of the proposed marine windpower research center.
However this causes the Environmental assessment to be inadequate because it fails to address the most important , most fundamental questions raised by the proposal: what are the likely climate changing effects of interfering with the Eastern Maine Coastal Current's flow and flow rate by positioning windmills, as planned, within its pathway in the Gulf of Maine?
The state has identified as appropriate several locations in the Gulf of Maine for utility scale wind development. The preferred alternative lies within the EMCC just prior to where bathymetric conditions stimulate a segment of it to break off (and deliver lobster larvae to Penobscot Bay).
It does not pass the straight face test for the University of Maine to pretend that the completely predictable impacts of the utility scale ocean windfarms it proposes to build following and based on preparation of these prototypes need not be considered at this stage. It is to feign that there is no possible connection between the prototype and the full scale device that is the reason for building the prototype.
This is untenable. The Department of Energy need to work with the University of Maine to develop either a supplemental Environmental Assessment or an Environmental Impact Statement to deal with the predictable and connected offsite and indirect and cumulative impacts stemming from the proposed DeepCwind project that is requesting funding from the Department of Energy. Anything else is a mockery of the NEPA process and serves only political haste, not scientific certainty
In conclusion we continue to find the scope of review of a number of critical issues to be seriously inadequate. Therefore we believe that the University of Maine should be required to prepare a supplemental Environmental Assessment to address those issues, as cited below. Please note that these issues and the University of Maine's state permit to operate its wind testing area off Monhegan are presently subject of litigation in Maine Superior Court.
Ron Huber, for
Penobscot Bay Watch