From CFACT

CFACT Comments on the California Offshore Wind Draft Programmatic Environmental Impact Statement (PEIS)

By Craig Rucker, President

CFACT

https://www.cfact.org

Submitted to https://www.regulations.gov/document/BOEM-2023-0061-0189

February 12, 2025

Overview of our concerns

BOEM is taking comments on a draft Programmatic Environmental Impact Statement (PEIS) for its five floating wind offshore leases off the California coast. This is BOEM’s second offshore wind PEIS. The first was for a set of leases off New York which featured fixed bottom turbines. This is the first PEIS for floating wind turbines which are very different from the fixed turbines being built along the Atlantic coast.

Floating wind is still an immature technology with a large number of proposed designs none of which has been tested at commercial utility scale. There are just a handful of small demonstration scale projects in the world.

There are at least two useful things about this PEIS. First is a pretty good tutorial on floating wind with a focus on the California case. This is Appendix A, done by the National Renewable Energy Laboratory. They rule out a number of design options including the most popular that has been demonstrated, the spar floater. The huge range of options they present shows the immaturity of the technology

Second the PEIS includes an encyclopedic discussion of numerous potential adverse impacts of a generic floating wind project. These impacts are limited to just what is contemplated for each of the five leases so when combined for all five leases it is clear that this Program will be environmentally destructive. These adverse impacts cannot be mitigated so the correct decision is that the Program should not proceed. The No Action Alternative is the proper choice.

Here is just a short list of some of the major flaws in the PEIS

1. By far the biggest flaw is that there is no cumulative multi-lease impact assessment. The whole point of a PEIS is to do such an assessment for the entire Program. Cumulative impact can be much greater than the sum of individual project impacts especially where two or more projects are closely clustered as in this case. Thus merely listing individual project impacts is completely inadequate.

2. In many cases an adverse impact is merely mentioned with no assessment of the potential harm. This is supposed to be an impact assessment not just a list of impacts.

3. The systematic harassment of large numbers of endangered and protected species of whales and other animals is certain to occur but it is not discussed. In fact the term “harassment” only occurs twice in the entire main report. Death due to noise harassment causing deadly behavior is one of the top adverse impacts of offshore wind.

4. Moreover floating wind introduces a major non-acoustic form of harassment. This is the 3D web of potentially thousands of mooring cables each of which could be on the order of a mile long. We are talking about hundreds of square miles of deep ocean literally filled with webs of cables. Harassment is defined by the Marine Mammal Protection Act as causing behavioral change on a protected animal’s part and these monstrous webs will certainly do that. This very large scale continuous harassment should be carefully assessed.

5. The PEIS does briefly mention the threat of “secondary entanglement” in the nets, lines and other debris that are caught on the cables over time. The potential adverse effects of this deadly accumulation needs to be assessed in detail.

6. Lastly there is an extensive economics section but no mention of cost. Development of these five leases will likely cost ratepayers and taxpayers tens of billions of dollars, possibly hundreds of billions. The entire Program should cost over a trillion dollars but these staggering sums are never quantified. Job creation is treated in detail as a benefit when jobs are in fact a cost. The total cost needs to be estimated.

It is clear that this PEIS is woefully inadequate. In fact it specifically avoids those issues that justify cancelling the Program. The cumulative impact threat is treated in more detail below.

The entire Western Offshore Wind Energy Program must be assessed

A new federal report shows that these five leases are tiny compared to the yawning Programmatic EIS gap created by the Federal Action Plan for West Coast offshore wind development. To begin with the full California Program is huge compared to the measly five leases covered by the so-called California PEIS. The present PEIS document would be better called the Starter Kit EIS. Plus there is a lot of development off of Oregon and Washington.

As pointed out above the PEIS document does not address the cumulative impact of those five leases; it just looks at the generic impact of one lease. But what is really Missing In Action is an environmental impact assessment for the entire West Coast Program.

The new report bears the long title: “AN ACTION PLAN FOR Offshore Wind Transmission Development in the U.S. West Coast Region” (all caps in the original). The Action Plan is a conceptual design for transmission of offshore generation but in order to do that design you have to know where the generation is so that is included in considerable detail.

Instead of the just five leases considered in the present draft PEIS the Action Plan includes about one hundred leases by 2035. These typically occur in clusters of from 5 to 20 leases. Moreover while the total generating capacity for 2035 is 15,000 MW this grows to a massive 33,000 MW in 2050.

Each lease contains numerous huge floating turbines each anchored to the sea floor thousands of feet below with multiple mooring lines. So the environmental impact of each cluster is potentially enormous.

Even worse a series of these clusters basically line the coast especially in Northern California and Southern Oregon. Migrating species might encounter and be adversely affected by this entire series.

The list of endangered or protected species that are threatened is quite long. As pointed out above these massive 3D cable arrays are a new form of harassment under the Marine Mammal Protection Act. There are also endangered sea turtles, giant rays, etc., in jeopardy.

The PEIS Appendix A says a single turbine floater can require up to 12 mooring lines to keep it stable and in place in heavy weather. Assuming 15 MW turbines with a dozen lines each the 15,000 MW development would have 12,000 mooring lines. The 33,000 MW case would have a staggering 26,400 mooring lines, many over 4,000 feet long.

We are talking about thousands of square miles of deep ocean literally filled with webs of cables. Harassment is defined by the Marine Mammal Protection Act as causing behavioral change on a protected animal’s part and these monstrous webs will certainly do that. This very large scale continuous harassment should be carefully assessed.

The PEIS also describes the threat of “secondary entanglement” in the nets, lines and other debris that are caught on these cables over time. The potential adverse effects of this deadly accumulation needs to be assessed in detail before any offshore projects are approved. Note that this threat accumulates over time, throughout the entire life cycle of a project.

Capping harassment diminishes the adverse impact of this offshore wind development

The clear solution to these mooring line threats is to severely constrain the number of harassment authorizations. With these very limited authorizations very few new offshore wind projects can be built. Nor should they be since they are environmentally destructive. Each project requires a large number of authorizations so drastically reducing their number drastically reduces the number of offshore wind projects.

The simplest way to do this is to cap the total number of wind authorizations that will be issued throughout the Program for a given exposed population. This is analogous to capping the emission of dangerous pollutants. One could even have a cap and trade program where developers bid for authorizations just as they now bid for leases. The 1990 cap and trade program for power plant sulfur dioxide emissions is an obvious analog.

If the cumulative harassment were limited to say 10% of the exposed population of each threatened species this would severely constrain offshore wind development.

In summary the so-called California Programmatic Environmental Impact Statement is nothing of the kind. The full Offshore Wind Program needs to be assessed for the entire West Coast before any project is approved for construction. This required assessment is Missing in Action.

Based on this assessment the cumulative impacts then have to be minimized. Capping the authorized harassment of each threatened species may be the best way to avoid destructive impacts.

Respectfully submitted,

Craig Rucker

President

CFACT

Washington, D.C.

From MasterResource

By Robert Bradley Jr. — February 14, 2025

Ed. Note: Four years ago, Storm Uri caused Texas’s centrally planned wholesale electricity market (ERCOT) to buckle, vindicating warnings about the state’s wind/solar reliance. The mainstream media implicated natural gas instead, failing to explore the why behind the why. Rather than deregulation, Texas has chosen to add wind, solar, and batteries, while subsidizing natural gas plants to counter intermittency. This duplicated grid is now driving rates up in a state that could have relied on surplus natural gas instead.

It was not so much the story of freak weather triggering a market failure writ large. It was a classic application of the political economy of government intervention: the seen and the unseen, expert/regulatory failure, and unintended consequences.

Don Lavoie, a preeminent thinker in the field of market-versus-government planning, once warned:

If the guiding agency is less knowledgeable than the system it is trying to guide—and even worse, if its actions necessarily result in further undesired consequences in the working of that system—then what is going on is not planning at all but, rather, blind interference by some agents with the plans of others.” [1]

Planned chaos, in other words.

The failure of governmental electricity in Texas humbled many electricity design experts (including technocrat Lynne Kiesling); the Public Utility Commission of Texas (PUCT); the Electric Reliability Council of Texas (ERCOT); and the Texas Legislature. Other players at a distance were the Federal Energy Regulatory Commission (FERC), North American Electric Reliability Corporation [né Council] (NERC); and National Association of Regulatory Utility Commissioners (NARUC).

Classical liberals can tie experience to theory to identify expert/regulatory failure. This should not be surprising given that electricity is the most regulated industry in the United States next to money & banking and the national-defense contracting.

Superficial View

The ‘mainstream’ view is that an “extreme tail event” caught the private-sector firms, most in natural gas, unprepared. The regulators, in the middle for the most part, did their job. I have challenged this interpretation in detail here and here. “Renewables, representing more than one-fourth of Texas’s generating capacity,” I argued, “all but disappeared at the peak.

But there is a very important second part of the story: the tax-break-driven pricing of wind severely compromised the economics of existing and new natural gas and coal plants.

But the rare event was not a market situation begging for market reform. It was a governmental situation where the inertia of intervention resulted in more intervention: continued wind/solar, battery storage, and even talk about demand-side responses (meter technology and incentives). The experts can solve this, in other words, with a lot of studies and planning.

Enron Analogy

This reminds me of the (superficial) Enron interpretation. Enron made bad investments, tried to cover them up, and lost the confidence of the market. They went bankrupt and ‘the market worked.’ Why the massive failure? Fish rot at the head, one book concluded. But why?

With Enron (as with the Blackout), I argue that something greater was at work. It was ‘contra-capitalism,’ the pursuit of the unearned, in the form of pervasive rent-seeking, strategic deceit (’philosophical fraud,’ short of prosecutable fraud), and imprudence that Adam Smith, Samuel Smiles, Ayn Rand, and Charles Koch, among others, have warned against.

For me, at least, getting to the ‘why behind the why’ to explain a ‘systemic failure’ like Enron opened up a lot of deep thinking that tested and expanded my theory. Capitalism was not to blame for Enron considering all the warnings from our side on bad commercial behaviors, and same for electricity in Texas in February 2021.

Reinterpreting the Backout

With Texas, the surface explanation of wind and solar all but disappearing at the peak is just the beginning. (‘This was expected by planners—can’t blame them.’)  It was a pervasive lack of weatherization among natural gas companies from the wellhead to the power plant. But why? Reliability is JOB 1 with electricity, and this job was outsourced to regulators working with a very (regulatory) weakened/fragmented industry. Coordination issues aplenty!

The ‘why behind the why’ gets to a lot of regulation and political/social pressure that brought the worst out of private sector parties. Think about the intended and unintended consequences of government forcing of wind power in particular. Wind’s intermittency and negative pricing (from the federal tax credit) ruined the economics of conventional power plants.

Regarding (mal)coordination, federal and state regulation has disaggregated the natural gas industry in three phases, and the same for electricity in three/four phases. There are no ‘electricity majors’ or ‘natural gas majors’ that are vertically and horizontally integrated (regulation forced the disaggregation of the industry). We needed Majors, in fact…. (The business strategy of integration (“oil majors”), by the way, was part of the answer to the “commons problem” of oil and gas production under the ‘rule of capture.’ another story.)

Electricity is different, they say. Need large control areas because of the nature of electrons. A ‘commons problem’ says Lynne Kiesling.  Okay, then who do you trust? Markets or experts/regulators? And no, there is no Hayekian/ central planning solution of private resources in the electricity ‘commons’.

The experts have been working hard on market design to find that right balance between reliability and price. Texas went virtually all price (thinking that peak pricing for several weeks of the year would compensate for not having ‘capacity payments’ for standing ready to meet peak demand). But the shortage during Storm Uri sent prices to astronomical levels, which now will result in a bunch of nonpayment, lawsuits, and probably socialistic cost-spreading among all customers. Total mess—and most all of the involved regulators have resigned and have court dates.

———————

On Facebook, Lynne had a revealing exchange with economist Steve Postrel:

Postrel: According to the data I’ve seen, ERCOT consistently plans for lower reserve margins than other grids. ERCOT now planning for 15-20%, but that’s still lower than surrounding grids.

Kiesling: Reserve margin: In contrast to your interpretation, I would argue that other RTOs (PJM in particular) have excessive reserve margins relative to supply requirements and relative to the ability of demand to respond to higher prices. Other RTOs (PJM in particular) are governed by generators, who clearly have an incentive to have higher than needed reserve margins. Again I say to you: what do you think the cost is of a reserve margin to achieve 100% reliability during a 1-in-20-year extreme tail event??????

Postrel: As I noted on your other post, the decision to just accept blackouts like these (in extreme freezes) as the cost of doing business cannot be ruled out as the optimal policy, given the cost of incremental reliability. Presumably, this would be a good subject for cost-benefit analysis with reference to the degree of public risk-aversion. But the “excess” reserves in other places, if adequate to mitigate the consequences currently being felt in Texas, don’t seem so burdensome as to be obviously superoptimal.

It is a huge planning issue: reliability vs. price. Experts (like Kiesling) must tell the regulators what to do. NO, we cannot let the market decide because it is a “commons problem.”  But I say: deregulate to let the electricity majors into the market … And short of this, at least understand the ‘coordination problem’ as an expert/regulatory failure, not market failure.

It is time for an entrepreneurial discovery process in a true market, not a contrived market under mandatory open access. Firms must be allowed to internalize the reliability function with their Grade A corporate guarantee. Lots of laws must be repealed, another story.

———————

[1] Don Lavoie, National Economic Planning: What is Left? (Cambridge: Ballinger Publishing Company, 1985), p. 95.  

———————

Appendix: Storm Uri Blackout Reinterpretation

My posts on the Great Texas Blackout:

Wind, Solar, and the Great Texas Blackout: Guilty as Charged

Renewables “Market-Failed” Natural Gas in Texas

Electricity Planning: Physical vs. Economic (an exchange with Eric Schubert)  

ERCOT “worked as planned” (architect Hogan gives no quarter)

Civil Society and Natural Gas during the Great Texas Blackout

For other posts:

“U.S. Winter Outlook: Cooler North, Warmer South” (NOAA’s prediction bust)

Numbers and the Great Texas Blackout (Bill Peacock: March 4, 2021 )

ERCOT: A Central Planning Government Agency

ERCOT: A Government Agency

Texas’ Renewable Fail: Remember Georgetown’s Green New Deal Too

Oklahoma’s Rolling Blackouts: Remembering Audrey McClendon’s War on Coal (Charlie Meadows: February 23, 2021)

Wind Subsidies Help Freeze Texans (Bill Peacock: February 18, 2021)

Texas Windpower: Will Negative Pricing Blow Out the Lights? (PTC vs. reliable new capacity) (Josiah Neeley: February 17, 2021)

From ClimateREALISM

By Linnea Lueken

A recent CNN article, “How a ‘cow fart’ vaccine could help tackle climate change,” discusses a vaccine under development to be given to cows to reduce the amount of methane their digestive processes produce. The hope is that the vaccine will significantly reduce livestock emissions, thereby slowing down climate change. It won’t. Methane from livestock contributes little, if anything, to global warming. As a result, attempting to change these animals’ biological processes seems to carry risks far exceeding any possible benefits.

CNN explains that methane is produced as grass ferments in the rumen, and claims that it is more “potent” than carbon dioxide, but does admit that it is comparatively very short-lived in the atmosphere. The author, Jacapo Prisco, goes on to claim that “livestock accounts for about a third of human-related methane emissions, which are collectively responsible for about 30% of global warming.”

Here the CNN author either misunderstands claims made about methane, or is intentionally misleading readers. The author cites the International Energy Agency (IEA) as the source of his claim concerning livestock methane emissions. The IEA does say methane is estimated to be responsible for 30 percent of global warming, a point it admits is open to debate. What it does not say, however, is that livestock emissions of methane are responsible for 30 percent of warming, which is what Prisco’s claim implies. Livestock emissions are only a small part of methane emissions attributable to human causes, much less global methane emissions as a whole. It is also important to note that the IEA’s estimates of anthropogenic (human-caused) methane emissions are much higher than most official government assessments calculate. To be clear, the IEA is not a scientific organization but rather an institution created to assess global energy supplies, stocks, and future needs – in recent years, it has strayed from its mission to become an advocate for climate activism and legislation.

Data from the EPA show that beef production only accounts for 2 percent of all greenhouse gas emissions in the U.S., with only part of that coming from methane from cows’ digestive processes. This is notable, especially since the United States produces more beef and veal than any other country. Agricultural crop production, in contrast, produces 10 percent of all U.S. greenhouse gas emissions. It is not unreasonable to assume the same is true for the rest of the world.

A recent paper written by physicists William Happer, Ph.D., of Princeton University and W. A. van Wijngaarden, Ph.D., of Toronto’s York University, explains that contrary to claims methane is some super-warmer in the atmosphere, “the contribution of methane to the annual increase in forcing is one tenth (30/300) that of carbon dioxide.” Based on that fact, the scientists conclude that “[p]roposals to place harsh restrictions on methane emissions because of warming fears are not justified by facts.”

As Climate Realism has discussed on other occasions, here, here, and here, for example, methane has a limited ability to meaningfully contribute to warming by the fact that much of the energy absorption bands affected by the gas are already covered by water vapor, which makes up a massive proportion of the greenhouse gases in the atmosphere.

As a result, methane is virtually inconsequential with regards to global warming. Current concentrations are around 1.9 parts per million (ppm). For comparison, the atmosphere contains 18 ppm of Neon, and 426 ppm CO₂.

The vaccine discussed in the story does not exist yet, it is being researched by the UK’s Pirbright Institute, and has been a decade-plus effort from various research organizations, with no “tangible results as of yet,” CNN reports.

Side effects for the animal have already been hypothesized, such as “a reduction in the amount of feed that the rumen can absorb, meaning cattle might require more food, increasing costs to farmers.” Making livestock less efficient at processing food into energy and mass is a poor idea in a world where hunger is still all too common.

It seems that livestock’s digestive processes, and methane production’s role in it, is still poorly understood. Considering the fact that methane production is possibly a fundamental step in the digestive processes of rumen animals, including livestock such as cattle, sheep, and goats, it is critical to understand methane’s importance in the digestive process before tampering with it in the vain effort to mitigate climate change. This is especially true considering that the effort to control livestock emissions is a solution in search of a problem, with no tangible benefit to the world, and unknown consequences for the animals involved.

CNN misleads readers by hyping the influence methane emissions have on global temperatures, as well as the amount that animal husbandry contributes. Data show that agriculture as whole, and livestock production more particularly, have little if any impact on global climate.