Zachary Jylkka
Bureau of Ocean Energy Management
Office of Renewable Energy Programs
45600 Woodland Road, Mailstop: VAM-OREP
Sterling, VA 20166
re: Draft Wind Energy Area (WEA) in the Gulf of Maine
Penobscot Bay Watch is a citizens association dedicated since 1993 to protecting and restoring the living marine resources of Penobscot Bay and the greater natural Gulf of Maine it adjoins and serves.
Our relevant oversight efforts over that time have included
(1) Communications, then administrative appeals and litigation over the University of Maine's DeepCwind project's Monhegan site selection. This continues since its inception and through its morphing into Maine Aquaventus Project leaving us today with their presently stalled increasingly outdated floating wind turbines proposal there.
(2) Frequent dialog with the Norwegian Statoil company's staff as it proposed but ultimately dropped a proposal for a floating wind array off midcoast Maine.
We likely have the best archive around of audio and documents of those early years of BOEMRE and DeepCwind.
Comments on Impacts of Offshore Wind Energy Development on Currents and Fishing Grounds in the Gulf of Maine
Background:
BOEM is requesting input on offshore wind planning in the Gulf of Maine, which contains numerous interconnected currents critical for ecosystems and fisheries. These comments from Penobscot Bay Watch (PBW) outline concerns regarding disruption of these complex flows that sustain marine life.
Major Currents and Fishing Grounds at Risk:
Labrador Current - This cold water influx already weakened by climate change
may be further altered by Canadian wind projects, disrupting the Gulf’s circulation.
Nova Scotia Current - Flows past productive grounds like Laurentian Channel and Banquereau Bank. Changes could impact larvae supplies for lobster, crab, and other fisheries.
Northeast Channel Current - Anything slowing this current could lessen influx of nutrients that increase productivity on western Gulf banks.
Eastern Maine Coastal Current - This major southwest flow passes valuable scallop and urchin grounds on Petit Manan and Dirt Hills. Anchor scour or current shifts threaten these species.
Downeast Coastal Current - Flows towards lucrative urchin and sea cucumber grounds off Grand Manan Island that rely on this current’s nutrient transport.
Jordan Basin Circulation - This internal cyclonic gyre concentrates particles to feed scallop and worm grounds in the Basin. Slowing this gyre may lower productivity.
Western Maine Coastal Current - Change to this flow passing through lobster grounds like Small Point could impact larval supply and dispersal.
Georges Basin Gyres - These gyres entrain larvae of clams, scallops, lobster and other invertebrates harvested here. Disrupting circulation may lower settlement.
Gulf of Maine-wide Concerns:
Right whale migratory routes, feeding habits, and population distribution depend on currents and gyres that concentrate their zooplankton prey. Any disruption threatens this endangered species.
Herring spawning grounds rely on currents to transport eggs and larvae. Altering flows during critical stages may jeopardize stocks.
Overall lowered productivity that could ripple through all trophic levels, worsening with climate change pressures.
Recommendations:
Site-specific current studies using ADCPs and drifters should occur before siting decisions, with attention to variations over time.
Ecosystem impacts must be projected using coupled biophysical models accounting for cumulative effects.
Seasonal restrictions may be needed during critical life history events dependent on stable currents and gyres.
Gulf of Maine-wide Concerns:
Independent review is essential to ensure adequate data collection, model projections, and ecosystem-based planning.
PBW believes the scale of floating offshore wind development proposed for the Gulf of Maine warrants a precautionary approach to safeguard the region's interconnected ecosystems, fisheries, and maritime communities.
These comments outline risks to major currents, fishing grounds, endangered whales, critical bird habitats, lobster larvae flows, scenic areas, and more. BOEM must fully assess array effects on currents and marine life before approving projects that could inflict irreversible damage. The Gulf's biodiversity, ecology, subcultures and sustainability must take priority over energy production targets.
Right whale migratory routes, feeding habits, and population distribution depend on currents and gyres that concentrate their zooplankton prey. Any disruption threatens this endangered species.
Herring spawning grounds rely on currents to transport eggs and larvae. Altering flows during critical stages may jeopardize stocks.
Overall lowered productivity that could ripple through all trophic levels, worsening with climate change pressures.
Recommendations:
* Site-specific current studies using ADCPs and drifters should occur before siting decisions, with attention to variations over time.
* Ecosystem impacts must be projected using coupled biophysical models accounting for cumulative effects.
* Seasonal restrictions may be needed during critical life history events dependent on stable currents and gyres.
Appendix A
Proposal for Eastern Maine Coastal Current Habitat Area of Particular Concern Designation
The Eastern Maine Coastal Current (EMCC) warrants designation as a National Marine Fisheries Service Habitat Area of Particular Concern (HAPC) due to its ecological significance for fisheries and protected species, vulnerability to disruption, and increasing threats from expanding human uses like offshore wind development. But also legacy pollution wastes
We call on BOEM and NOAA to work with the New England Fishery Management Council, Wabanaki Nation and other indigenous and historic stakeholders to initiate this process.
An EMCC HAPC would highlight the current's vital role as a migratory conduit, larval transport pathway, and nutrient aggregation zone supporting Gulf of Maine ecosystems and economies. It would facilitate tracking and assessment of cumulative impacts while prompting comprehensive review of proposed projects like floating wind arrays that could degrade essential habitat conditions.
While not imposing direct regulations, EMCC HAPC status would compel managers and developers to account for the risks posed to the current's ecological functions and productivity. It would incentivize careful siting of new infrastructure and thoughtful mitigation of unavoidable impacts. Seasonal restrictions could safeguard critical life stages of vulnerable species like right whales.
The EMCC meets the key criteria for an HAPC based on its importance for ecological functions, sensitivity to human impacts, foreseeable development pressures, and singular nature as the Gulf's dominant coastal current system. An HAPC would provide no new restrictions but highlight the EMCC as a flowing habitat requiring stewardship. Responsible planning mandates recognizing the current's significance before permits are issued in the region.
In closing, we urge BOEM to embrace a vision of the Gulf of Maine as a living entity nourished by interconnected currents that flow through it like arteries and veins. These currents pulse with the kinetic energy of winds, tides, and celestial cycles, while drinking sustenance from the outflow of rivers and streams along the coast. Their rhythms enable the Gulf’s bountiful ecology, from microscopic plankton to great whales.
As you evaluate the risks posed by floating offshore wind turbine arrays, consider the perspective of this watershed as a nurturing habitat animated by currents that are vital to sustain. New development must respect the Gulf’s own currents of life if it is to find an enduring place within this ecologically and culturally rich seascape.
Please don't hesitate to contact us if you would like additional inforimation our email is coastwatch@gmail.com tel and text 207-691-4634
Sincerely
Ronald Huber
Ron Huber
Penobscot Bay Watch
cc Media
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REFERENCES
•Atlantic Salmon Federation. "Species Profile: Atlantic Salmon." https://www.asf.ca/species-profile-atlantic-salmon.html
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•BOEM. "Commercial Wind Leasing Offshore Massachusetts." https://www.boem.gov/commercial-wind-leasing-offshore-massachusetts
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•Davies, K.T.A, Taggart, C.T. "Measuring the influence of wind-driven advection on the recruitment ecology of Gulf of Maine Atlantic cod." Fisheries Oceanography. 2007.
•Harrison, Autumn-Lynn. “Migratory Birds of the Gulf of Maine.” Gulf of Maine Council on the Marine Environment. http://www.gulfofmaine.org/2/wp-content/uploads/2014/03/migratory-birds-web.pdf
•Johnson et al. "Entanglements of baleen whales in fishing gear and marine debris in the Gulf of Maine and Scotian Shelf." Endangered Species Research. 2021.
•Kenney, Robert D. “Right Whales: Eubalaena glacialis, Eubalaena japonica, and Eubalaena australis.” In Encyclopedia of Marine Mammals. 2018.
•NOAA Fisheries. "Atlantic Salmon." https://www.fisheries.noaa.gov/species/atlantic-salmon-protected#conservation-management
•NOAA Fisheries. “Shortnose Sturgeon.” https://www.fisheries.noaa.gov/species/shortnose-sturgeon#conservation-management
•Saba et al. "The Past, Present and Future of the Atlantic Meridional Overturning Circulation." Nature. 2021.
•Burgund THE CURRENTS OF PENOBSCOT BAY, MAINE:Observations and a Numerical Model by Halsey R. Burgund Advisor: Philip Bogden 2nd Reader: George Veronis April 21, 1995
* Conlon 2018 Circulation, Cross-Shelf Exchange, and Blue Mussel (Mytilus edulis) Population Connectivity in a Complex, Tidally Driven System. Summer 7-27-2018 A thesis by LeAnn M. Conlon
