Responsible Offshore Development Alliance Calls for Correction on Coast Guard Study; Cites ‘Serious’ Errors

WASHINGTON, DC / ACCESSWIRE / July 1, 2020 / The Responsible Offshore Development Alliance (RODA) has officially requested that the U.S. Coast Guard revise and correct its Massachusetts and Rhode Island Port Access Route Study (MARIPARS), citing “serious foundational and analytical errors that merit correction.” On June 29th, it filed a formal Request for Correction under the Information Quality Act in order to improve the objectivity and utility of the disseminated information.

The Coast Guard MARIPARS study examined current waterway uses in the areas off the coast of Massachusetts and Rhode Island, which are sites of proposed offshore wind energy development. Understanding these ocean use patterns is critical for successfully designing any offshore development, and for minimizing interactions between the proposed developments and existing activity.

Unfortunately, the Coast Guard’s final report, issued on May 27th, contained several key errors, and the process “failed to address nearly all of the substantive comments from fisheries professionals.” These include dozens of comments from vessel operators, fishing companies, and fishing associations, as well as independent experts including the New England Fishery Management Council, the New Bedford Port Authority, the Rhode Island Fisheries Advisory Board, and Dr. Thomas Sproul.

One key error involved the Coast Guard’s reliance on “inappropriate data sources.” RODA previously warned the Coast Guard that most fishing vessels in Massachusetts and Rhode Island do not use Automatic Identification System (AIS) technology onboard, and that any analysis of fishing vessel activity and movement should not rely on AIS data. Despite this warning, the Coast Guard cited only AIS data in its study. Additionally, while the MARIPARS contains a list of nearly 900 contacts in its “stakeholder outreach” section, only two are active commercial fishermen – hardly sufficient to inform a study primarily focused on fishing vessels.

Despite drawing conclusions about the amount of space necessary to conduct fishing operations, the study similarly did not include important information on the nature of fishing activity in the region, including the spatial requirements of vessels and their gear, and the changes in vessel traffic patterns that are likely to result from wind turbine construction.

The study’s flaws were not limited to its analysis of fishing activity. The Coast Guard also failed to properly analyze a range of alternative spacing proposals for wind turbines that included dedicated transit lanes for fishing vessels. Rather than provide an analysis of the impacts transit lanes would have, the Coast Guard simply asserted “project developers have made clear that larger corridors … would result in reduced [turbine] spacing.” RODA asserts in its appeal that the Coast Guard should have conducted a full, independent evaluation of this claim. Instead, “it relied on developers’ attestations that there are a predetermined number of turbines that will be placed in the wind energy areas,” which is at odds with the public record and how the development process is supposed to work.

RODA’s Request for Correction raises further issues, including unsubstantiated claims made by the Coast Guard about the nature of potential radar interference from wind turbines as well as simple calculation errors included in the study.

In light of these numerous errors, RODA considers the conclusions of the study “wholly unsupported and unsubstantiated by the record” and is requesting that the Coast Guard address and correct these errors. It is specifically asking for relief in the form of: (1) revising the analysis using appropriate data and calculations; (2) clear documentation of the MARIPARS’ limitations; (3) a formal, independent peer review; and (4) not using the MARIPARS as a basis for regulatory decisions pending these corrections.

Since the publication of the final MARIPARS, the Bureau of Ocean Energy Management released the Supplemental Environmental Impact Statement for the Vineyard Wind I project to analyze cumulative impacts of offshore wind energy development off of New England. That document relies heavily on the MARIPARS in assessing the navigational safety impacts of the project’s preferred layout.

Read RODA’s Full Request for Correction here

Press Contact
Bob Vanasse
(202) 333-2628

SOURCE: Responsible Offshore Development Alliance

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