Comments to BOEM are due by 11:59 p.m. on October 31. Follow these instructions to submit your comment (talking points below):
Please click on “comment” type in your comment or attach a file and hit “submit comment.”Submit Comments
Key Talking Points
Please urge BOEM to minimize impacts to ocean and coastal wildlife and habitats and to responsibly site offshore wind development by doing the following:
- BOEM must conduct a West Coast-wide Programmatic Environmental Impact Statement (PEIS) or an analogous robust cumulative impacts before the siting process is finalized. Seabirds, whales and fish range widely across multiple areas now under consideration for wind development. A PEIS or cumulative impacts analysis will provide a transparent consideration of larger, ecosystem wide issues and it can be done in a way that does not delay the process and could lead to better outcomes.
- For the Draft Coos WEA: Remove the northwestern portion that overlaps the NMFS-recommended protected species leatherback turtle exclusion area. This corresponds with the NMFS’ recommended exclusion areas for habitats and NMFS’s recommended scenario.
- For the Brookings WEA: Remove NMFS-recommended protected species Blue/Humpback foraging exclusion area, which will also reduce incursions into high value coral habitats and minimize potential Short-tailed Albatross conflicts. This corresponds with the NMFS-recommended scenario.
- BOEM has not provided sufficient analysis of how wind energy arrays in the proposed WEAs could impact upwelling that is the very basis for the productivity of our region’s highly productive marine ecosystems. Previous research has indicated upwelling could be disrupted by wind turbine arrays and thus potentially have ecosystem-wide impacts. BOEM needs to include an upwelling analysis in their modeling efforts to inform siting recommendations.
- BOEM has not sufficiently considered impacts to Leach’s Storm Petrels, an Oregon Conservation Strategy Species of Concern. The proposed Brookings WEA is located right between where the West Coast’s largest population of Leach’s Storm Petrel (an estimated 480,000 birds) nests and where they feed.
- BOEM needs to provide a sufficient analysis of how electromagnetic fields (EMF) created by transmission cables may impact invertebrates and fish, especially the small forage fish that birds and wildlife depend upon.
- I am concerned that BOEM has given insufficient consideration to how and where wind energy installations will come ashore and then connect with major transmission lines that have a high risk for wildfires and high values for tourism, especially the Samuel Boardman Corridor and Cape Sebastian State Park that run parallel to the Brookings WEA. I urge BOEM to consider realistic onshoring scenarios in the NCCOS spatial analysis so that the public can know what is likely to actually be proposed.
For further background information:
- Click here for a link to BOEM’s official notice.
- Click here for the joint BOEM-NCCOS analysis that was used to inform how WEAs were selected.
- Presentation hosted by Oregon Shores Conservation Coalition in March 2022 with panel presentations (including Joe Liebezeit) and discussion on the issue.
You can also thank BOEM for excluding some areas of high ecological value in a previous decision.
Thank you for taking action to protect our ocean habitats and limit harm to marine wildlife.