From CFACT

“In light of various alleged legal deficiencies underlying the federal government’s leasing and permitting of onshore and offshore wind projects, the consequences of which may lead to grave harm…” is the conclusion that guided President Trump’s Executive Order suspending wind project permitting.

CFACT has already criticized several offshore wind permitting cases for being inadequate due to the omission of important issues, making them incomplete. Some of the worst cases are listed below. Although Dominion was not the subject of all of these criticisms, they are undoubtedly affected by them. Plus Dominion permits were the focus of many of these criticisms going back more than two years.

These characteristics apply to every instance of a permit deficiency. A substantial approval is supported by a formal document. These include the authorized COP, the Final NEPA EIS, the ESA Biological Opinion, and the MMPA Incidental Take Authorization. In each case a critical issue is overlooked in one or more of these permitting documents, making them incomplete.

The relevant federal agency disregarded these deficiencies in each instance. However, the Trump administration is currently looking at the history and procedure of offshore wind permits. In each of the circumstances stated below, if the investigation is done correctly, they should discover incomplete approval paperwork, halt the approval until it is finished, and then reissue it.

The following are some of the worst permitting flaws that CFACT has found so far:

1. The NMFS Incidental Take Authorization has no EIS

The absence of an EIS for the NMFS harassment-taking permission is arguably the most obvious shortcoming. For Dominion, this is a huge takeover. Just about 60,000 mammal takings are permitted due to noise harassment during the Dominion project.

According to the authorization document, this authorization action requires an EIS in accordance with NEPA. The permission document then makes it clear that the harassment EIS is included in the Dominion project EIS as a whole. However, the taking is never mentioned in the project EIS. Therefore, until the necessary EIS is finished, we shouldn’t start construction. The authorization paperwork that is currently in place is lacking.

2. The impact of harassment is not considered in the Biological Opinion

The same argument—albeit one that is more complex—applies in the Biological Opinion. The BiOp gave the harassment authority a small section 3.8, but the project EIS does not even address it. The BiOp only lists the number of endangered whale species that are being harassed and claim to have prepared every feasible mitigation strategy.

There is no evaluation of the detrimental impacts of harassment, which is the problem of whale death. The BiOp does not state that such impacts exist, but other NMFS assessments do. This important problem of harassment-induced death is never discussed in the permit documentation.

Although it is now known that harassment kills whales, CFACT warned NMFS of this possibility long ago, especially for the Dominion project.

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 It is important to carefully assess the potentially fatal consequences of harassment.

 3. The turbine installation ship is not authorized to harass

 Another instance of harassment is the deployment of several thrusters to maintain position by the pile driving ship Orion, which has been laying Dominion’s monopile foundations.

 The thruster noise is above the harassment level, according to Rand Acoustics’ measurements. However, such noise has not been approved because it was not mentioned in the harassment application. It appears that Orion is unable to lawfully work on the project. This will probably apply to tower, turbine, and blade installations as well as any monopile installation ship.

 Before construction can continue, the Dominion project harassment authorization must be updated to account for all anticipated installation vessel noise.

 4. The use of suction caissons rather than pile driving is not considered

 One solution for wind turbine foundations that does away with the requirement for those tremendously noisy gigantic monopiles is the suction caisson. Monopiles pose the greatest damage to whales from offshore wind, but suction caissons pose minimal harm. For many years, offshore oil rigs have been anchored using the suction caisson technology. Although it is relatively new, offshore wind is obviously viable at the size of US offshore projects, as seen by the 900 MW project currently under construction off Taiwan by Ørsted, the largest developer in the world.

 In terms of minor mitigation measures to lessen the threat of construction to endangered whales, the Dominion COP, the BOEM EIS, and the NMFS harassment permission all go to considerable lengths. The use of suction caissons as an alternative to pile driving, which may greatly lessen the hazard to endangered whales, is not considered by any of them, though.

 These three permission documents need to be revised to account for suction caissons instead of pile driving.

 5. Breaking the “small numbers” requirement of the MMPA

 Only a limited number of each species of protected mammal are eligible for incidental take authorizations under the Marine Mammal Protection Act. More than 50,000 dolphins are covered by Dominion’s acoustic harassment permission, which is obviously a significant amount.

 Also 5% of the whole population of the critically endangered right whale is legally taken, which is by no means a tiny number. The overall quantity of taking would be many times the population if every leased project permitted this level of taking per MW.

 The Dominion COP must be redesigned in order to adhere to the MMPA small numbers requirement.

  6. Sediment plumes from ocean currents passing across wind facilities are not considered

 The notion that ocean current flow via a standing wind array will produce a continuing sediment plume, which could have a serious environmental impact, is now the subject of a substantial body of scientific literature. Only the temporary sediment plumes produced by cable trenching are considered in the Dominion Biological Opinion. The operational sediment plume, which can persist for as long as the project is in the ocean, is not taken into account. Here, the Clean Water Act might be relevant.

7. Failure to take into account the project’s contribution to the overall effects of several projects

Compared to the simpler aggregate of the individual initiatives, the cumulative impact can be far larger. Avoiding project combinations, for example, can greatly lengthen the amount of time spent in regions with a lot of ship activity or fishing. The right whale’s migratory path will be doubled by Dominion’s proposed second CVOW project.

Cumulative impact should be covered in all the key Dominion project evaluation documents, but none are.

 8. Operating noise is not considered

According to several studies, the massive turbine array’s operating noise will be higher than the acoustic harassment threshold. This noise is not covered by the Dominion harassment authority. The project cannot move further with the current construction and operation permit if it achieves this noise level. This impact must be included in the project assessment. Another potential problem is infrasound.

9. Physical presence-based harassment is not considered

Only acoustic harassment is covered by the Dominion harassment authorization. Harassment is defined by the MMPA as altering behavior. Avoiding the 150 square mile array of turbines is a significant behavioral shift that could have negative effects. As a result, the project’s physical presence—which is unapproved and has to be properly evaluated—is harassment.

Ah, the Atlantic Meridional Overturning Circulation (AMOC) collapse—our old friend. Like a horror movie franchise that refuses to die, the idea that the Gulf Stream is about to shut down and plunge Europe into an icy apocalypse has returned. This time, the BBC is breathlessly warning that “the chance of it happening is growing”​. But before you start knitting survivalist-grade wool socks, let’s take a moment to review how many times we’ve heard this story before—and why it never seems to pan out.

A Climate Catastrophe… Someday, Maybe, Possibly

According to the BBC, AMOC is supposedly “getting weaker,” but they immediately admit that direct measurements have only been taken since 2004—meaning we have barely two decades of actual data​. Now, call me old-fashioned, but when you’re talking about an ocean system that has been operating for millions of years, 20 years of data is like trying to predict a person’s entire life based on a single Tuesday morning.

And what’s their big evidence? Ocean floor sediments and a “cold blob” in the Atlantic. That’s right, they’re looking at dirt samples and a patch of water that isn’t warming like the rest of the ocean, and somehow, this is supposed to spell doom for civilization​.

This wouldn’t be so bad if they admitted the uncertainty. Instead, the article plays a game of “it’s probably not happening, but it totally could!” For instance, the IPCC says they have “medium confidence” that AMOC will not collapse this century. But some other scientists say, well, maybe it could! As one of them warns, we “maybe need to be worried”​.

What kind of science is this? It sounds more like a horoscope than a serious climate analysis.

Fear-Mongering 101: Every Climate Scare is the Last One

Here’s where it gets really interesting. The article includes dire warnings that “even the most likely scenario” could lead to disastrous storms and colder European winters​. But haven’t we been told for decades that global warming was supposed to make winters warmer? How many times have we heard that skiing in the Alps would be a thing of the past? Now, suddenly, the UK is going to be plunged into Arctic conditions.

It’s the ultimate climate fear two-for-one special: No matter what happens—hotter, colder, wetter, drier—it’s all climate change, and it’s all your fault.

Of course, this isn’t the first time we’ve heard these predictions. The same scare popped up in The Day After Tomorrow (2004), based on theories that had been bouncing around for decades before that. In 2015, similar claims made headlines, only for scientists later to admit that “the jury is still out” on whether AMOC is actually slowing down​.

Then, just last month, a new study showed that—wait for it—the North Atlantic Current is actually stable​. So, despite all the apocalyptic speculation, the real-world evidence just isn’t there.

The Real Agenda: Cut Emissions, No Matter the Cost

At the end of the article, we get to the real point. The only way to “reduce these risks,” scientists insist, is to cut greenhouse gas emissions​. That’s right—whether the planet is warming or cooling, whether AMOC is speeding up or slowing down, the answer is always the same: more regulations, more taxes, more restrictions on energy use.

It’s almost as if the climate narrative isn’t really about science at all, but about controlling human activity.

Conclusion: No, the UK Won’t Freeze Over Anytime Soon

If history is any guide, this latest AMOC scare will soon fade away, just like all the previous ones. Then, in a few years, another set of scientists will “discover” the same threat all over again, and the cycle will repeat.

So, before you panic-buy thermal underwear and start hoarding firewood, remember: Climate doom predictions are like bad fashion trends—they always come back, but they never quite deliver on their promises.

HT/Darren K