GUEST SPEAKER: I convened this meeting
because I believe that the review is limited
as it stands now.
And in order for the Environmental Impact Assessment
to be effective, it needs to consider
a number of other alternatives in order
to provide a larger scope for the project impacts,
both positive and negative.
The draft Environmental Impact Assessment, as it stands now,
considers the number of turbines,
the location of the turbines, and a very limited
no-build option.
This alternatives analysis fails to create
a clear vision of the situational context
of the project.
In this presentation, I will be discussing
ways in which we can revise the Environmental Impact
Assessment so that it better evaluates all alternatives
and I will provide arguments for why it is necessary to spend
the time and money to do so.
First, we need to define the goal of the project
if we are to effectively evaluate
alternative approaches.
Alternatives analysis should paint
a picture of the multitude of options
available to reach this goal.
So I believe that the goal of the project
is to provide energy for the growing electricity
demand in the region.
And studies have shown that new energy facilities will
need to be built within the next 15 years
to meet this growing demand.
So we should use this goal to frame to project evaluation.
And sending a clear goal at the beginning
helps to consider better alternatives.
And it's necessary to take a step back
and to see the project and its impacts in the larger context.
So if we all agree to this, that the goal is to meet the growing
electricity demand, we must determine that this product
is the best option.
And the Environmental Impact Assessment
is the way that we'll do that.
So to do this, we need to make three major revisions
to the Environmental Impact Assessment.
One, we need to consider alternative forms
of energy production and their environmental,
economic, and social impacts if this plant is not to be build.
So if we do not build offshore wind,
we would build wind farms on land.
And what will the land use impacts of that be?
Will we need to build a natural gas plant to meet demand,
or is solar an option?
So we need to really consider the greater alternatives.
It will be difficult to do a full Environmental Impact
Assessment of all of these theoretical alternatives.
We can pick a few items to focus on, for instance, carbon
emissions or land use.
Second, we need to consider the impacts of wildlife
and coastal communities based on cumulative impacts,
if this project isn't built and other clean energy products are
not built and we're not meeting our greenhouse gas emission
targets.
Third, if this project is perhaps
the best way to meet our energy needs,
then we need to consider alternative ways
to mitigate the impacts from this project on wildlife
and navigation.
Some mitigation efforts could include
moving the wind farm further offshore or presenting--
providing better long term monitoring.
So including all of these alternatives
in the more comprehensive alternatives
analysis will lead to two major benefits.
One, it will increase the opportunity for public buy-in
by making a more transparent process.
This is really important for complex problems
like energy development.
And by including a more comprehensive analysis,
or alternatives analysis, the project
will be less likely to be fought later on.
Because the public will be better able to use
this document to see the decision-making process.
The public will see that the Environmental Impact Assessment
did not just consider the impacts of the proposed
pre-design project that was already going to happen
but will see it in a greater context
of the different alternatives that
were considered along the way.
This will, while spending this money upfront,
it will be expensive to do all of these extra studies,
it will be important in saving money down the pipeline
in delays and litigation.
And second, because there is not much precedent
for Environmental Impact Assessments of offshore wind
in the United States, we have the opportunity
to set the standards for evaluation.
This project will set best practices,
so let's make them best practices
and establish mitigation and monitoring practices as well as
the robust alternatives analysis that I proposed.
Again, we should, we should be sure to engage
the public around this alternatives
analysis during the review of this draft, the comments
on this draft Environmental Impact Assessment,
so that there's public buy-in and support of the project
and that the public understands what alternative options would
look like.
So finally, we need to recognize that, internally as the EPA,
that Environmental Impact Assessments are not
unbiased and purely scientific, but that they operate
within a political framework.
So because of this and because of our recent decision
to limit greenhouse gas emissions in power plants,
we need to create a better framework
for analyzing alternative energy projects
and present a better framework for analyzing
all of those impacts and risks.
We cannot encourage clean energy development at a great cost
to local ecosystems.
But we must create a system in which
a sound case for wind generation can be made, including--
So this, by doing this, we need to examine,
have an assessment that examines all other options,
including meeting energy needs from less clean sources.
So for these reasons, I recommend
revising the draft Environment Impact Assessment
to include these comments.
Thank you.