Re: Draft Environmental Impact Statement for Deepwater Wind South Fork, LLC Proposed Wind Energy Facility Offshore Long Island and Public Meetings (Docket ID BOEM-2020-0066)
February 22, 2021
Program Manager
Office of Renewable Energy
Bureau of Ocean Energy Management 45600 Woodland Road, VAM-OREP Sterling, VA 20166
Re: Draft Environmental Impact Statement for Deepwater Wind South Fork, LLC Proposed Wind Energy Facility Offshore Long Island and Public Meetings (Docket ID BOEM-2020-0066)
To Director Amanda Lefton:
My name is Mariah Dignan and I am the Long Island Organizer for Climate Jobs NY. We are a growing coalition of labor unions representing 2.6 million working New Yorkers united to combat climate change and reverse inequality. We are educating our fellow workers, building alliances, and advocating for policy solutions - demonstrating that we do not have to choose between a healthy planet and good jobs. I am a Long Islander acutely aware of the impacts climate change has and continues to have globally and here in my community, so I enthusiastically support the South Fork Wind Project, which clearly demonstrates responsible offshore wind development.
I commend the Bureau of Ocean Energy Management (BOEM) for completing the Draft Environmental Impact Statement (DEIS) during the COVID-19 pandemic. As we fight to address this public health crisis, BOEM is doing the necessary work to move offshore wind forward. We are undeniably addressing intersectional crises - public health, the economy, environmental justice, and climate change are interwoven with offshore wind development. At a moment when we must make large-scale investments to restart our economy, we should take action on clean energy at the level we know we need to to take on climate change. We have a once-in-a-generation opportunity to put ourselves on the path to a low-carbon future while creating new quality careers that provide family-sustaining wages and benefits for communities across the nation.
South Fork Wind is slated to be New York’s inaugural offshore wind project. This is a 15 turbine, 132MW, project contracted by the Long Island Power Authority (LIPA) to serve a local demand for energy on the South Fork that will be located 35 miles east of Montauk Point, New York. The project will power 70,000 homes, create hundreds of family-sustaining union jobs, and help the state and Town of East Hampton meet their 100% renewable energy goal.
As noted in the DEIS, the majority of the impacts for the South Fork project are negligible to moderate, and the higher-rated impacts can and must be addressed by mitigation through ongoing stakeholder discussion and outreach. In the following paragraphs, I will detail the developers' engagement and outreach with local labor and the local community as well as the importance of the Beach Lane cable route and the 1X1 nautical mile compromise signed off by the Coast Guard.
Ørsted/Eversource and Long Island Labor Outreach and Engagement
Deepwater Wind South Fork, LLC, also referred to as Ørsted/Eversource, has committed to working with Long Island Labor by using contractors who have Project Labor Agreements with the Building and Construction Trades Council of Nassau and Suffolk Counties and investing in our local workforce with a $10 million Offshore Wind Training Center. In addition, Ørsted/Eversource is investing in Port Jefferson and East Setauket with operations and maintenance facilities that will create hundreds of long-term jobs for Long Islanders.
This project has set the stage for offshore wind developers to work in conjunction with organized labor. Labor unions offer world-class training programs through apprenticeships. By coordinating with industry, we will continue to lead and train the offshore wind workforce of the very near future.
Ørsted/Eversource and Local Community Outreach and Engagement
In addition to working with Long Island labor, the developers have listened, engaged, and altered construction plans based on local community and environmental feedback. This is something we need to replicate in other offshore wind projects. Ørsted/Eversource has worked hand-in-hand over the past few years with the Town of East Hampton to realize additional mitigation efforts that include construction, environmental, and fishery concerns of local residents, businesses, and mariners. To highlight a few of the provisions, there is a commitment to maintain access to Wainscott Beach during construction for pedestrians, emergency vehicles, etc.; a commitment to limit construction activities to the off-season months; a comprehensive fisheries compensation plan; and town and community notice and construction monitoring requirements.
It is worth highlighting that the East Hampton Trustees have unanimously approved the Joint Proposal (JP), and five NYS agencies have invested extensive time and expertise in this process and have also signed onto this proposal. The Town of East Hampton Board and Trustees voted overwhelmingly to support the Host Community Agreement and the easement/lease agreements for the Beach Lane route. Overall, the JP and related agreements clearly demonstrate a methodical and thoughtful approach to working with the community to actualize New York’s first offshore wind project.
The Beach Lane Route is the Best Onshore Cable Route
Not only has the project developer worked with local stakeholders on construction-related and community-benefit agreements, but Ørsted/Eversource has thoroughly vetted and studied cable-landing options which has resulted in the best onshore cable route.
The Beach Lane route for the South Fork export cable mitigates community and environmental impacts as demonstrated in numerous geotechnical field surveys, samplings, and studies both on land and in the water. As noted in the DEIS, the Beach Lane route onshore construction activities would “result in localized, short-term, minor incremental impacts on land use and coastal infrastructure” (BOEM DEIS, 3-154). However, the alternative Hither Hills route would result in construction activities that “could coincide with the projected East Hampton Railroad Station improvements and could increase traffic delays; result in additional traffic rerouting; and increase short-term, construction-related vehicular and equipment emissions that would impact area residents” (BOEM DEIS, 3-154).
The Beach Lane route is the clear option to responsibly construct the onshore activities and would be the least impactful to local residents. This route and related infrastructure upgrades will increase the resilience of Long Island’s transmission infrastructure and inject clean, renewable energy into the grid. The 1X1 nautical mile Compromise
CJNY supports the 1X1 nautical mile turbine layout compromise that responds to commercial fisheries' concerns in the Areas Offshore of Massachusetts and Rhode Island Port Access Route Study. Not only does the Coast Guard approve of this mitigation effort, but adding additional mileage to the layout would only take away from the efficiency and carbon reduction potential the project is meant to address (MARIPARS, 32). We ask BOEM to reject the transit lane alternative which threatens the overall success and viability of not only this project, but future offshore wind projects.
The Importance of South Fork Wind to U.S. Offshore Wind Development
To maximize the economic development and job opportunities in offshore wind, the industry and its potential workforce needs confidence that demand in the U.S. offshore wind market is real. This means we need to move forward promptly in the permitting process to set the stage for this nascent industry. By launching this industry now, the potential for additional jobs multiplies exponentially, with the potential for hundreds of thousands of good-paying jobs across the United States. For example, the American Wind Energy Association’s U.S. Offshore Wind Power Economic Impact Assessment Report finds that the United States offshore wind industry will invest $28 to $57 billion into the nation’s economy by 2030 depending on the scale of installations and supply chain growth. In addition, the study concludes that “offshore wind project development, construction, and operations will support 19,000 to 45,000 jobs by 2025 and 45,000 to 83,000 jobs by 2030” (U.S. Offshore Wind Power Economic Impact Assessment Report, 1). This potential all starts now with South Fork.
I urge BOEM to follow the current permitting schedule for this project and to move forward expeditiously on this and other offshore wind projects. The only way to achieve 9GW of offshore wind energy by 2035 -- New York State's goal, enshrined last year in legislation -- is to advance permitting in a timely manner and develop safe and fair conditions with community stakeholders, as was done with South Fork Wind.
We can provide long-term sustainability, economic development, and create a skilled green-economy workforce for a consequential new industry. In this time of bold transformation, smart investments in a clean-energy future can simultaneously put people back to work, build infrastructure to address climate change, and spur economic development in our communities. Thank you for your consideration.
Respectfully submitted,
Mariah Dignan
Long Island Organizer, Climate Jobs NY