Penobscot Bay Watch
POB 1871, Rockland ME 04841
People who care about Maine's biggest bay

August 23, 2012

Bureau of Ocean Energy Management, 
Office of RenewableEnergy
381 Elden Street, HM 1328,
Herndon, Virginia 20170–4817.

Re: [Docket No. BOEM–2012–0049]
Intent To Prepare Environmental Impact Statements: 
Potential Commercial Wind Lease Issuance and Decision Regarding Approval of Construction and Operations Plan onthe Atlantic Outer Continental Shelf (OCS) Offshore Maine

Dear BOEM

Penobscot Bay Watch (PBW) is a citizens association dedicated since 1993 to protecting and restoring the living marine resources of Penobscot Bay and the greater Gulf of Maine. PBW's oversight includes participation in state and federal permitting and licensing processes discharge licenses and major development initiatives  potentially affecting Penobscot Bay and surrounding waters, from petroleum tank farms and port plans in upper Penobscot Bay to the University of Maine's DeecCwindConsortium

We are writing in response to Bureau of Ocean Energy (BOEM) Notice of Intent To Prepare Environmental Impact Statements: Potential Commercial Wind Lease Issuance and Decision Regarding Approval of Construction and Operations Plan on the Atlantic Outer Continental Shelf (OCS) Offshore Maine.  Docket No. BOEM–2012–0049]

We thank you for the opportunity to comment on the scope of the Hywind Maine deepwater floating windpower project's Environmental Impact Study.

 We strongly believe that serious unertainaties  uncertainties exist, both
onsite and offsite, to warrant preparation of an environmental impact statement
prior to the BOEM making a final decision as to whether the
Monhegan site if the most appropriate of the alternatives. Given the facts, we do
not believe that it remotely possible for the Department to decide otherwise
without making a mockery of NEPA.

SCOPE OF REVIEW
We ask that the BOEM consider as broad a geographic scope as possible.

1. Impacts to living natural resources in the air, sea surface and water column footprint of the demonstration test site

2. Impacts to the dynamics of the Eastern Maine Coastal Current, the Western Maine Coastal Current and other existing oceanographic structures of the Gulf of Maine that may be impacted by deployment of the four full sized floating turbines in stgratified deepwater area off Maine.

3. Impacts to Gulf of Maine lobster larvae migration from alterations in existing
Gulf of Maine current dynamics caused by deployment of floating deepwater
wind turbines in hydrodynamically sensitive areas.

4 Impacts to Gulf of Maine nutrient flows and to overall seasonally significant
geographic concentrations of finfisheries, due to alterations in existing Gulf of
Maine current dynamics and alterations in thermal structure of the water column
of the footpring of floating deepwater turbines.

5. Impacts to irreplaceable scenic resources of state and national significance
from deploying this test project as opposed far lesser in more distant yet feasible locations 

6. Impacts to Atlantic puffins and other seabirds known and documented to
overfly the area of the proposed wind test site 

7. Impacts to land birds known and documented as seasonally migrating through
the location off Monhegan proposed for the University of Maine's deepwater
wind site

AT ISSUE
Below we will describe general and site specific issues of unavoidable adverse
impacts, followed by citations and excerpts or complete copies of relevant peer
reviewed research, followed by information gathered by competent bird
naturalists, that is worthy of consideration in the Department's Environmental
Assessment.

1. Unavoidable adverse impacts of artificially modified ocean wind on oceanic processes. Winds play a key role in many natural marine circulation processes, including the natural Ekman Transport of energy from air to water; ocean surface circulation (particularly at gyres); vertical water motion; mixing of upper ocean layers; upwelling of deep, often nutrient-rich, anoxic waters to the surface, and downwelling of oxygen rich waters to the lower water column.

The operation of an ocean windfarm's turbines creates an in-situ forced 1
meter/day upwelling process in the water column beneath that facility. (1)
Brostrom 2008  They artificially and continuously impact the natural Ekman Transport within the windturbine complex's energy footprint. Deepwater  ocean windfarms, by their very nature, as moored or  in-place energy sinks, can act as
anthropogenically generated  perturbations of the water column and nearby water currents. 

Gulf of Maine's marine ecosystem has evolved and adapted to seasonally
predictable gyres and eddies. The addition of year-round in-place artificial gyres
to the hydrodynamics of the Gulf of Maine is highly likely to have discernable
impacts on its surface water characteristics and currents, with consequences for
transport of lobster larvae and those of other animal species, as well as for the
timing of Gulf of Maine phytoplankton blooms.

It is the duty of the BOEM to determine the significance of those
impacts and those consequences before setting out any locations for
development of offshore renewable energy .

2. Unavoidable adverse impacts to a nationally significant scenic Monhegan
viewshed.
Lobster Cove on the southern tip of Monhegan, possesses nationally significant
scenic resources. It is reachable only by pedestrian footpath and is one of the
most popular destinations for day tripping tourists visiting the island,. It is also a
place of pilgrimage for generations of fine artists, who annually in their hundreds
paint the views of and from Lobster Cove, where the deep waters of the Gulf of
Maine are cut by the granite shieldwall of the continent, and by barely glimpsed
archipelagoes far to south'ard. The deep dark of the Atlantic ocean, and the clear
starfields, presentlyclaim the night here.
The proposed deployment of prototype small and full sized wind turbines at this
site for an indefinite number of years and renewals will unavoidably adversely
impact this nationally significant viewshed:
During the daytime, the turning blades will modify the optical experience of
dawn, from numerous places on the island, and throughout the day will
command the visual attention of all who gaze to the south upon the Gulf of Maine
viewscape, including those visiting publicly-accessible Lobster Cove, artist and
casual tourist alike.
At night the safety lights atop the turbines, blinking and occasionally flared by the
passing blades, will similarly command the attention of those viewing the evening
skies and starshed south of Monhegan.
It is not known what the sonic impact of the prototype turbines will be on the
public and the artists enjoying Lobster Cove, however, sonic pollution both in the
audible spectrum and "infrasound" are problems that challenge people living
similar distances from landbased wind.
3. Unavoidable adverse impacts to a unique island bird population and to an
internationally nationally significant migratory bird route along the Atlantic
Seaboard.
Birds living on or transiting Monhegan - and the site where the full scale 5
megawatt ocean wind turbine will be deployed, if outside the Monhegan test
center's waters - will be adversely impacted if the project's wind turbines are
funded, built, deployed and operated. Birds have been counted off Monhegan
and other outer Penobscot Bay islands since the 1940s
Lobster Cove, the public beach on Monhegan whose nationally significant scenic
viewshed is reachable only by pedestrian footpath, is also very popular as a
location for ornithologists desiring to count migrating birds heading north or
south in great numbers during the same times of year that the prototype
windturbines would be deployed - summer and autumn.
Maine Bureau of Parks and Lands erroneously concluded in its decision approving
the Monhegan Deepwater Test Area that little impact was likely to birds from
development and operation of this project. That decision is under review by
Maine Superior Court
To the contrary, however, the records of recent and historic professional and
amateur ornithologists experienced with the bird life of Monhegan and the
waters south of the island show a very heavy use of the island and those waters
by a large number of residential and migratory bird species.
* Bird sitings on Monhegan. September 14 to September 28, 2010 . Bryan Pfeiffer
professional bird naturalist, author and consultant, identified 122 bird species
during a visit to Monhegan from September 14th to September 28, 2010. (List
below)
* Maine eBird, sponsored by Audubon and Cornell Laboratory of Ornithology,
recorded 202 bird species during 2009 & 2010. (List below.)
* Bird sitings on Monhegan, July2 2010 to October 16, 2010 These are primarily
from Lobster Cove, the public beach on Monhegan whose nationally significant
scenic viewshed includes the location slated for the proposed Monhegan
Deepwater Wind Test Area. Migrating birds heading south along the atlantic
flyway pass over Penobscot Bay then stop at Monhegan in great numbers during
the times of year that the prototype windturbines would be deployed - summer
and autumn.
They were made by ornithologist Tom Magarian and submitted by him to the
Maine-Bird online forum & archive. (List below) Magarian is a professional
ornithologist who works with New Jersey Audubon. He has been tasked to carry
out radar sitings of birds off Lobster Cove, Monhegan. The visual observations he
recorded (see below) are a supplement to those readings, by this highly qualified
individual. His email address: tmagarian@alumni.unity.edu
Because the funds being released by Department of Energy will be used to build,
deploy and test both one or more 1/3 scale test prototypes, and "a full-scale
prototype of a 5 megawatt floating wind turbine", according to Elizabeth Viselli
of the University of Maine-led DeepCwind Consortium, the environmental
assessment needs to acknowledge the potential impacts of both size turbines on
birds.
Nothing is known about the proposed location for deploying the full scale 5
megawatt floating turbine. Neither the Bureau of Parks and Lands designation
of the deepwater wind test area off Monhegan, nor the enabling law MRSA 12
§1868. Identification of offshore wind energy test areas" limit the size of
prototypes that may be deployed in the test center's waters. However, the
expectation among Monhegan residents is that deployment will be limited there
to 1/3 sized prototypes, not full sized ones.
Unless the University proposes to renege on its informal agreement with the
Monhegan community to limit deployments off their island to 1/3 sized
prototypes, it will have to either choose one of the other two wind test areas, or
consider some hitherto undisclosed location elsewhere. If so, then a range of
alternative locations needs to be selected, examined and ranked, prior to final
determination and the releasing of funds to the University of Maine, as
construction and deployment of this full size windturbine will take place only
with the authorization of the DOE funds under present consideration.
4. Unavoidable adverse impacts to Fisheries
Direct impacts upon commercial and recreational fisheries and pleasure sailors
include the exclusion zone directly around each windturbine, as well as, for fishers
with bottom tending gear, cable areas and other seafloor installations of the
wind project.
Direct impacts to important fishing feeding and breeding and nursery areas, if
turbines are deployed there. Indirect impacts by deploying windturbines in
migratory pathways of fish, shellfish or prey species, due to the upwelling and
thermal modification of ocean hydrology per Brostrom 2008 and other
researchers cited in above.
In summary, because deployment of a full scale 5 megawatt floating turbine is a
reasonably anticipated outcome of the DOE releasing these funds, the adverse
impacts that it could likely have on birds and fish inside and outside the
immediate footprint of the offshore test area needs to be considered. The
Environmental Assessment will be deficient if it does not acknowledge and
include the reasonably foreseeable impacts to managed and protected resources.
Viable alternatives to the proposed project.
The state of Maine identified eight sites in Maine state waters as potentially
appropriate for hosting Maine's Offshore Wind Energy Test Areas. These sites
were winnowed down to three locations in 2009; of those three, the easternmost
site, two miles south of Monhegan, was chosen on December 14, 2009 to host the
Maine Offshore Wind Research Center.
The state's decision to locate the Offshore Wind Research Center off Monhegan is
being contested in Maine Superior Court as of October 18, 2010. The petitioner
suggests that the Bureau of Parks and Lands has underemphasized likely impacts
to Monhegan scenic and bird resources, due to a pre-made decision to locate the
University of Maine deepwater test site off Monhegan Island for logistical
reasons.
The Department of Energy has an opportunity to reexamine the record of the
BPL's decision, coupled with and tempered by additional information that
extends the Bureau's overly narrow definition of scenic , fishery and avian
resources at risk to one more consistent with natural resource conservation and
scenic resource preservation standards under federal law.
Irreversible and irretrievable commitments of resources.
Because the project being considered for funding by the Department of Energy
would build and deploy floating renewable energy facilities that would be
anchored or moored in place, irreversible and irretrievable commitments of
resources will be far fewer than those of fixed monopile wind turbines, such as
those approved off southern Massachusetts.
Should the site prove unsuitable due to unacceptable adverse impacts to living
and/or non living marine resources. the floating facilities can be towed to
different locations or returned to shore, for, maintenance, modification or
recycling.
Conclusion. We strongly believe that sufficient uncertainties exist, both onsite
and offsite, of the nature and extent of the adverse impacts of this project to
warrant preparation of an environmental impact statement prior to the
Department of Energy making a final decision as to whether the Monhegan site is
the most appropriate of the alternatives. Given the facts, we do not believe it
possible for the Department to decide otherwise.
We ask that the DOE consider as broad a geographic scope as possible. that it
consider:
1. Impacts to both the two square mile footprint of the demonstration test site
and to the ill-defined but foreseeable footprint of the site farther offshore where
the full-sized floating wind turbine will be deployed as part of this expenditure of
DOE funds.
2. Impacts to the Eastern Maine Coastal Current, the Western Maine Coastal
Current and other existing oceanographic structure of the Gulf of Maine that will
be impacted by deployment of the test and full sized floating turbines.
3. Impacts to Gulf of Maine lobster larvae migration from alterations in existing
Gulf of Maine current dynamics caused by deployment of floating deepwater
wind turbines in hydrodynamically sensitive areas.
4 Impacts to Gulf of Maine nutrient flows and to overall seasonally significant
geographic concentrations of finfisheries, due to alterations in existing Gulf of
Maine current dynamics and alterations in thermal structure of the water column
of the footpring of floating deepwater turbines.
5. Impacts to irreplaceable scenic resources of state and national significance
from deploying this test project off of Monhegan Island, as opposed far lesser
impacts from deploying in one of the other two locations chosen by the state of
Maine as deepwater test areas, but relegated to later development, if at all.
6. Impacts to Atlantic puffins and other seabirds known and documented to
overfly the area of the proposed wind test site off Monhegan.
7. Impacts to land birds known and documented as serasonally migrating through
the location off Monhegan proposed for the University of Maine's deepwater
wind site
See attachments, below.
Sincerely
Ron Huber
Ron Huber
Penobscot Bay Watch
Attachments (pdf files)
* On the influence of large wind farms on the upper ocean circulation by Goram
Brostrom, Norwegian Meteorology Institute. 2008
* Goram Brostrom. August 2010 . Personal communication
* Weather response to a large wind turbine array D. B. Barrie and D. B. Kirk-
Davidoff University of Maryland Department of Atmospheric and Oceanic Science,
Atmos. Chem. Phys. Discuss.: 29 January 2009
* Potential climatic impacts and reliability of very large-scale wind farms 2009”
by C. Wang and R. G. Prinn
* Bird sitings off Monhegan's Lobster Cove, July 2, to October 16, 2010,
_by Audubon ornithologist Tom Magarian
* Maine eBird Monhegan listings 2009-2010. Cornell Laboratory & Audubon
* Bird Observations, Monhegan, September 2010 Bird naturalist Bryan Pfeiffer
* Notes on a Fall Migration at Matinicus Rock, 1949 Rosario Mazzeo
* Gulf of Maine Circulation
* Gulf of Maine Fishing Grounds