Ms. Amanda Lefton
Director, Bureau of Ocean Energy Management
45600 Woodland Road
Sterling, VA 20166
Re: Notice of Intent to Prepare an Environmental Impact Statement for Ocean Wind, LLC’s Proposed Wind Energy Facility Offshore New Jersey
On behalf of the undersigned individuals, businesses, organizations and the thousands of recreational anglers we represent across the northeast region, we submit the following comments on the Bureau of Ocean Energy Management’s (BOEM) Notice of Intent (NOI) to prepare an Environmental Impact Statement (EIS) regarding the Ocean Wind 1,100-megawatt offshore wind energy project that is a joint venture between Ørsted and PSEG.
Governor Murphy has made New Jersey a national leader in offshore wind with a goal of deploying 7,500 megawatts of responsibly developed offshore wind by 2035, enough to power 3.75 million homes. New Jersey’s offshore wind strategic plan states, “New Jersey must develop offshore wind in a manner that maintains and protects robust commercial and recreational fishing, while recognizing that the environmental benefits of offshore wind and new economic opportunities it brings also have the potential to support these industries.” The EIS is a critical step to achieve this goal, and we support projects moving through a robust environmental review process that ensures responsible development is achieved every step of the way.
As recreational anglers, we recognize the potential benefits of offshore wind power and believe it is possible for turbine development to peacefully coexist with and even improve fishing in the Atlantic, provided project developers and government agencies abide by three clear principles as articulated by Anglers for Offshore Wind Power, listed below.
Anglers Principles for Responsible Offshore Wind Power Development:
Access: Recreational anglers must be able to fish up to the base of the turbine foundations to take advantage of the new habitat that will be created by offshore wind power development. We understand that access may be limited during construction.
Public Input: Recreational anglers must be engaged early in the planning process for offshore wind power development. Clearly communicated opportunities to provide input on siting, permitting, access, and other issues can avoid future conflicts.
Science: Fisheries research before, during, and after wind turbine construction is essential for monitoring impacts to species of interest to recreational anglers. Study results should be publicly available and regularly communicated to our community.
Upon review of the Construction and Operations Plan, and guided by the principles listed above, we have prepared the following recommendations for inclusion in the Draft Environmental Impact Statement, guided by each of our principles.
By far, the number one issue of concern to the recreational fishing community is the potential loss of access to the very productive offshore fisheries that occupy this area at certain times of the year, mostly summer and fall. Besides the unique and irreplaceable social value of these fisheries, any loss of access in the Ocean Wind project site would result in significant impact to the local fishing and boating economy. This is a high-dollar fishery utilized by vessels accounting for hundreds of thousands of dollars of economic activity in electronics, gear, and tackle alone. For BOEM to gain a thorough understanding of potential impacts to recreational offshore fishing, we recommend consultation with the American Sportfishing Association and the NOAA Northeast Fishery Science Center.
Throughout this process many individual anglers and recreational fishing organizations have requested formal confirmation that after construction, access in lease areas and around turbines and other structures would be treated in the same manner as oil rigs in the Gulf of Mexico. In the decommissioning phase, we suggest that turbine structures be cut down to a safe height off the sea floor and the foundation and the reef that has been established as marine habitat remain intact. GPS positions of each of these reefs should be distributed to the fishing community as a “fishing hotspot reef chart.”
We also request BOEM include firm language in the Draft EIS clarifying that the entire impact analysis is based on an expectation of total access to the wind farm area after construction. Our ideal approach to this issue would be for BOEM to make post-construction access a permit condition for all offshore wind-related structures. We feel offshore wind structures should fall under the existing US Coast Guard regulations regarding “aids to navigation.” This is established language that is well understood by both mariners and enforcement.
We acknowledge and applaud the efforts of Ørsted and other developers to build relationships and learn about potential impacts to both commercial and recreational fishing. While we encourage each developer to continue their individual outreach, we do feel that a more formal and enduring forum for gathering input from the recreational fishing community is needed.
We agree that developing offshore wind energy is essential to protecting our nation and planet from the impacts of climate change and ocean acidification, and feel that all parties need a clearly defined seat at the table to ensure that such potentially massive development is undertaken as responsibly as possible. The opportunity for fisheries experts and the general public to provide input must be hardwired into the system.
We suggest each region establish a fisheries advisory body made up of various stakeholder groups that must be consulted on a regular basis. We feel the Federal Advisory Committee Act lays out a potential model for the type of formal process we are proposing.
Fisheries management needs are specific and often hard to understand. Some combination of staff from the NOAA Northeast Fisheries Science Center, The New England and Mid-Atlantic Fisheries Management Councils, and the Atlantic States Marine Fisheries Commission must be involved in determining what types of monitoring should be required of the Ocean Wind proposal. In addition, we suggest a mechanism be created where these same fisheries management agencies have opportunities to review results and make further recommendations.
We further request that the Draft EIS reflect consideration of fisheries science data from the Virginia Institute of Marine Science’s Northeast Area Monitoring and Assessment Program and the National Oceanic and Atmospheric Administration’s Northeast Fisheries Science Center Bottom Trawl Survey.
Finally, we request a more comprehensive discussion of cumulative impacts on fisheries from continued offshore wind power development. It is essential we have a well-established framework for monitoring cumulative impacts now to avoid consequences for fisheries down the line.
We thank you for the opportunity to provide comment. By following our principles listed above, this new and important energy source can provide multiple benefits to recreational angling. Our community looks forward to continued engagement as the Ocean Wind project advances, and surrounding all future proposed offshore wind development.
Here is the link to sign the above letter: https://docs.google.com/forms/d/e/1FAIpQLSdfXxkdgZuY6EkmS5zIBpxD_p7B2hRT3bktiMMpIPqdqynnuw/viewform