I am still digging into the Construction and Operations Plan (COP) for its monster offshore wind project that Dominion Energy filed with the federal Bureau of Ocean Energy Management. My focus is on adverse environmental impacts, especially on the severely endangered North Atlantic Right Whales that migrate through the proposed project area twice a year.

My last article pointed out that the crucial technical Appendix R on Endangered and Threatened Species was being kept secret by Dominion and BOEM. You can read that here: https://www.cfact.org/2022/09/15/dominion-hides-osw-threat-to-whales/

It turns out that this is not the only secret stuff in the COP. In addition there is a lot of hand-waving wishing when environmental impacts are addressed where you can actually read. Here is a quick look at just some of the worst of the secrets and wishes.

First some more big secrets, that is important technical appendices that are listed but not accessible by the public.

Appendix C: Marine Site Investigation Report

Appendix K: Conceptual Project Design Drawings

Appendix M: Certified Verification Agency Nomination

(I have no idea what this even means.)

Appendix W: Preliminary Cable Burial Risk Assessment (Confidential and Proprietary)

Appendix X: Metocean Assessment (Confidential and Proprietary)

(In offshore engineering, “metocean” refers to meteorology and oceanography. How can this be proprietary?)

This is a lot not to know, much of which is directly related to analyzing the potential adverse environmental impacts on endangered whales.

The wishes come in when we look at the several-hundred page main Plan, which is readable by the public. Each wish takes the form “We will do whatever it takes to avoid or mitigate this adverse environmental impact”. What it might take and whether it is even possible is not discussed.

There is no way to assess such wishful statements. But at least they tell us what some of the impact issues are, those that happen to get listed in the COP. Some threats are not mentioned, for example forcing the migrating whales into the nearby heavy traffic shipping lanes where they can be struck and killed.

The COP does discuss several major areas of concern, under the strange heading of “Biological Resources”. See The COP is at https://www.boem.gov/sites/default/files/documents/renewable-energy/state-activities/Public_Sec-4-2-Biological-Resources.pdf

This discussion include whales under the heading Marine Mammals.

Interestingly they list six different whale species that are listed as Endangered under the Endangered Species Act. Three of these are said to be commonly occurring, including the severely endangered North Atlantic Right Whale. The COP estimates these Right Whales to have a total population of 412 critters but I have seen estimates as low as 320. Clearly whales are a serious issue.

They discuss various threats, especially construction noise, which I discuss in my third article. See https://www.cfact.org/2022/07/26/threat-to-endangered-whales-gets-louder/.

This discussion is followed by a very brief listing labeled “Avoidance, Minimization and Mitigation”. Here is what they say about noise reduction:

“Dominion Energy would use commercially and technically available noise-reducing technologies as appropriate and will provide marine mammal sighting and reporting training for each specific stage of construction to emphasize individual responsibility for marine mammal awareness and protection“.

That is all there is! They will do what they can and hope it helps. In my noise article I quote a federal OSW website saying that with today’s technology the noise of driving the huge monopiles holding up the towers is still “incredibly loud”. And what does “as appropriate” mean? If they feel like it?

On the operations side they specifically list the impact of “Project-related underwater noise”. But under Avoidance, Minimization and Mitigation there is nothing on this topic. Nothing! It is this endless noise that might push the migrating whales into the deadly nearby shipping lanes. There might be some discussion in Appendix R but it is all secret.

In short this so-called Plan is all description with no action when it comes to protecting the endangered whales from OSW. More broadly even a lot of project description is being kept secret.

Wishes and secrets are not a plan. When it comes to protecting the whales there is no plan.

We must save the whales from OSW.