Help Ensure Offshore Wind is Done in Compliance with Oregon Law

It’s critical that all offshore wind development be done in accordance with Oregon state laws — specifically, our laws that protect wildlife and habitat. Right now, we’re seeing major gaps in the Bureau of Ocean Energy Management’s (BOEM) proposal for offshore wind development. We need you to take a moment to urge the Department of Land Conservation and Development (DLCD) to ensure BOEM adheres to our state laws that protect seabirds, fish, marine mammals, and all marine life.

BOEM, the federal agency in charge of the offshore wind process, has provided the state with a “consistency determination” report explaining how its proposed action of leasing Oregon’s offshore waters for energy development aligns with State laws and enforceable policies. However we see real problems with BOEM’s consistency determination that must be rectified. Please see talking points and a sample letter below with specifics for emailing or sending comments.

This comment period is particularly important because right now Oregon’s agencies may be in the best position to shape and influence BOEM’s plans.

Take Action

Three ways to submit your comments (due Friday June 14th!). Talking points and sample letter below.

  1. Email your comments: coast.permits@dlcd.oregon.gov
  2. Fill out the form at the website.
  3. By mail: 
    OCMP-DLCD
    635 Capitol St. NE, Suite 150
    Salem, OR 97301-2540
Humpback Whales, photo by Ashala Tylor

Key Talking Points

  • Require BOEM to prepare a west-coast-wide programmatic environmental impact statement with a comprehensive cumulative impacts analysis as a condition for lease approval in accordance with Territorial Sea Plan Part 2.
    BOEM must require developers follow best management practices to avoid harm to wildlife, fish and habitats in accordance with Statewide Goals and the Territorial Sea Plan by requiring:
  • Robust baseline surveys for wildlife so that—should construction someday proceed— will be able to monitor and understand changes. Attention should be given to endangered species as well as Oregon Conservation Strategy Species.
      • Assign qualified wildlife observers to vessels to record critical wildlife impact data.
      • Limit vessel travel to speeds not exceeding 10 knots to minimize the risk of collisions with wildlife.
      • Use low-energy acoustic testing methods for surveys to reduce noise impacts
      • Avoid bottom contact with hard substrate, rocky reefs, seamounts, deep-sea coral, sponge aggregations, and other sensitive habitats.
      • Coordinate and plan for a single onshoring cable from each Wind Energy Areas to minimize impacts from cables.
      • Add conservation bid credits to the Proposed Sale Auction, to help fund an independent science entity that can provide independent review of the wildlife science to be generated by development companies.
      • Engage in meaningful consultation with Tribes; Oregon natural resource agencies and commissions; and local communities.

Sample Letter with Key Recommendations

(Please personalize):

Dear Mr. Burright and Mr. Lanier,

I’m writing to express my deep concern about the wind energy leasing occurring at such a fast pace off our coast. The health of our coastal and marine ecosystems and wildlife is very important to me and I worry about development happening too fast without a plan to minimize impacts as best as we can. Although this current consistency review is focused on pre-development activities, it is a reasonable and foreseeable consequence that energy companies may ultimately construct energy developments. For that reason, I am counting on DLCD to take a hard look now at the possibility of industrial energy development and do its best to minimize impacts to Oregon’s world-class marine ecosystems, wildlife, and fisheries. I support the need to move away from fossil fuels to address the climate crisis but it needs to be done right.
  
I urge DLCD to set firm conditions before giving concurrence to BOEM for its proposed leasing and associated activities off of Oregon’s Coast. 

Please require that BOEM prepare a west-coast-wide programmatic environmental impact statement with a comprehensive cumulative impacts analysis as a condition for lease approval. The Territorial Sea Plan Part 2 requires an effects evaluation that should include analysis of cumulative effects of the proposed action in combination with probable future projects.

Please ensure BOEM requires developers follow best management practices to avoid harm to wildlife in accordance with Statewide Goal 19 and the Territorial Sea Plan by requiring: 

  • a qualified wildlife observer be onboard any vessels to record critical data to travel at speeds not exceeding 10 knots to minimize the risk of collisions.
  • Use low-energy acoustic testing methods on surveys to reduce noise impacts
  • Avoid bottom contact with hard substrate, rock outcroppings, seamounts, deep-sea coral, sponge habitats, and other sensitive habitats.
  • Coordinate and plan for a single onshoring cable from each Wind Energy Areas to minimize impacts from cables.
  • Conduct robust baseline surveys for wildlife so that—should construction someday proceed— will be able to monitor and understand changes. Attention should be given to endangered species as well as Oregon Conservation Strategy Species.
  • Engage in meaningful consultation with Tribes; Oregon natural resource agencies and commissions; and local communities.
  • Add conservation bid credits to the Proposed Sale Auction, to help fund an independent science entity that can provide independent review of the wildlife science to be generated by development companies. 

Thank you for considering my comment.


For more information about the Federal Consistency Review for Offshore Wind Energy leasing, visit here.

For more information about the State’s enforceable policies, check out this page.