As the new home of MASSPIRG's environmental work, Environment Massachusetts can be contacted regarding this news release.
Karen Kirk Adams
Cape Wind Energy Project
EIS Project Manager
Army Corps of Engineers
New England District
696 Virginia Rd.
Concord, MA 01742-2751
wind.energy@usace.army.mil
Secretary Ellen Roy Herzfelder
Executive Office of Environmental Affairs
Attn: MEPA Office, Anne Canady
EOEA No. 12643
100 Cambridge Street, Suite 900
Boston, MA 02114
mepa@state.ma.us
Cape Cod Commission
3225 Main St.
PO Box 226
Barnstable, MA 02630-0226
Attn: Phil Dascombe/Cape Wind
pdascombe@capecodcommission.org
February 24, 2005
Re: US ARMY CORPS OF ENGINEERS
REFERENCE FILE NAE-2004-338-1
Dear Ms. Adams, Secretary
Roy Herzfelder, and Members of the Cape Cod Commission,
I am writing to provide
the following comments to aid your review of the Cape Wind power project proposed
for Nantucket Sound.
I. Introduction
I appreciate the opportunity
to submit these comments. Members and staff of the Massachusetts Public Interest
Research Group (MASSPIRG) have commented at various times on the Cape Wind proposal
during prior stages of the review process. These comments represent our updated
and formal position on the project and the review process.
MASSPIRG is a member-supported
non-partisan not-for-profit environmental and consumer advocacy organization
with approximately 45,000 citizen members throughout the Commonwealth of Massachusetts,
permanent offices in Boston, Amherst and on 23 college and university campuses,
and seasonal offices in Somerville and Hyannis. We work on a range of energy
issues, including clean air, electricity markets, energy efficiency and renewable
power.
II. Summary
Given all that we know about
the dire need to shift to cleaner energy sources in order to adequately protect
public health, consumers, and the environment, the default position on this
project should be to allow it to move forward. The Cape Wind project should
be built, as long as important concerns about the potential negative impacts
of the project on wildlife are addressed. Rigorous monitoring and adaptive management
plans should be included in the Final Environmental Impact Statement and, if
necessary, mitigation plans should be required as a condition for approving
the project.
III. Comments
MASSPIRG has long supported
renewable energy and wind power. We were active in the effort to establish the
Commonwealth's Renewable Portfolio Standard (RPS), and are strong supporters
of the federal wind power production tax credit, both of which have helped to
enable proposals such as Cape Wind. We are active in working for policies that
achieve reductions in global warming, mercury, smog and soot pollution from
the electricity sector. And we serve our members by advocating for policies
that will protect small electricity customers from risk and volatility in electricity
markets.
We also work in multiple
forums to preserve natural areas and species habitat, and to protect endangered
species. In light of concerns that have been raised about the potential for
the project to negatively impact marine and avian wildlife in Nantucket Sound
and the surrounding area, we urge you to proceed cautiously in preparing the
Final Environmental Impact Statement, and to work with scientific experts in
the relevant fields to ensure that these concerns are adequately addressed.
Given all that we know about
the dire need to shift to cleaner energy sources in order to adequately protect
public health, consumers, and the environment, the default position on this
project should be to allow it to move forward. The Cape Wind project should
be built, as long as important concerns about the potential negative impacts
of the project on wildlife are addressed. Rigorous monitoring and adaptive management
plans should be included in the Final Environmental Impact Statement and, if
necessary, mitigation plans should be required as a condition for approving
the project.
It is critical in reviewing
this project proposal to keep the broad context in mind. We face a global environmental
crisis because of our dependence on polluting fossil fuels; global warming is
going to have severe impacts on public health, the economy, and the environment
on Cape Cod and throughout the region. We have long dealt with devastating local
impacts from coal and oil burning power plants, as our children miss school
because of asthma attacks and have trouble in school because of learning disabilities
linked to mercury pollution. We face the threat of a lethal accident or attack
at the Pilgrim nuclear power plant in Plymouth that could render huge swaths
of the region uninhabitable for generations. And we face terrible military and
geo-political consequences as a result of our dependence on foreign oil.
In this light, it is absurd
to hold a clean energy project hostage to an impossible zero-impact standard.
Moreover, the choice we face is not between building a wind farm and not building
a wind farm. The choice is between this particular wind farm, and a new energy
facility being built on or near Cape Cod, or the Brayton Point or Canal plants
running more. In other words there is no such thing as a "no action alternative."
There are clear, known risks from doing "nothing." And because of
this project, they are avoidable risks.
So where your review considers
the specific impacts of the Cape Wind project, it should weigh them against
the specific impacts of not building the Cape Wind project. For example, the
number of bird deaths caused by turbine collisions should be compared to the
number of bird deaths caused by the relevant amount of oil and gas drilling,
coal mining, uranium enrichment, fuel combustion and disposal, and related oil
shipping and other accidents.
But where it is impossible
or infeasible to gather all the information that would provide certainty with
regard to impacts of the proposed project, we have to face the question: how
large an uncertain negative impact can we tolerate, when weighing it against
known benefits?
In answering this question,
one might conclude that prior policy and practice in permitting energy facilities
should provide some guidance. In our view there has been an unfortunate lack
of rigor in reviewing proposals to build coal, oil, natural gas and nuclear
energy facilities. Indeed, most of the coal plants that provide a significant
share of the nation's energy were built well before scientists told us that
the pollution from those coal plants triggers hundreds of thousands of asthma
attacks and shortens the lives of tens of thousands of citizens across the country
each year. Every one of the nation's nuclear plants was built despite a glaring
lack of certainty regarding storage plans for the lethal radioactive waste generated
by those facilities-and after five decades of studying the problem, we are still
unsure what to do with it. And many of the natural gas plants built in the Northeast
region since the mid-1990s were built despite the fact that we were far more
certain about the benefits of energy conservation than about the benefits of
new power plants. (And, it is worth noting, many of these gas plants were built
despite strong local opposition.) The record clearly shows that policy-makers
at multiple levels are willing to tolerate significant uncertainty about the
impacts of energy facilities (and unfortunately all too often they are willing
to tolerate even severe known negative environmental impacts).
While we need to guard against
setting the bar for wind power impossibly high, this unfortunate lack of rigor
obviously should not inform the review process for the Cape Wind proposal.
You should pursue all reasonably
available data to inform your decision regarding Cape Wind. Important concerns
have been raised by experts on various matters, especially the impact of the
proposal on roseate terns and other birds, that must be adequately addressed
in the Final Environmental Impact Statement. We do not, however, believe that
a Supplemental Environmental Impact Statement is necessary to permit construction
of the project. Where there are concerns about specific impacts, you should
address them in the Final EIS through consultation with a science advisory board,
aggressive monitoring, adaptive management, and mitigation requirements if necessary.
Where the academic and policy-making communities have not yet developed practices
that will achieve this goal, we now must work together to craft the tools that
will enable us to safely build and operate offshore wind power projects.
I also hope you thoroughly
treat in the Final EIS the important consumer benefits of wind power and specifically
this project. Right now, we are over-dependent on a narrow range of fuel sources.
A huge portion of every energy dollar spent by a Massachusetts resident is sent
out of the region and out of the country. We are captive to high and volatile
costs of natural gas and oil, which causes instability and rising utility bills
for Massachusetts residents and businesses. Introducing renewable power like
the Cape Wind project will boost our local economy and provide direct consumer
benefits by under-bidding the most expensive existing fossil fuel plants, applying
downward pressure on fossil fuel prices, and keeping energy dollars in the region.
IV. Conclusion
Thank you for your careful
attention to this matter and our comments. I look forward to continuing to work
with you during the remaining stages of the review process.
Respectfully,
Frank Gorke
Energy Advocate
617.747.4316
frank@masspirg.org
