Cape Wind Comments
Comments of the Union of Concerned Scientists at the Cape Cod Commission Hearing on the Cape Wind Project
September 6, 2007
Thank you for the opportunity to provide comments to the Commission on the Cape Wind Project. My name is John Rogers, and I am the Northeast Clean Energy Project Manager for the Union of Concerned Scientists.
The Union of Concerned Scientists (UCS) is the leading science-based nonprofit working for a healthy environment and a safer world. UCS combines independent scientific research and citizen action to develop innovative, practical solutions and secure responsible changes in government policy, corporate practices, and consumer choices. UCS’s Clean Energy Program focuses on encouraging the development of clean and renewable energy resources, such as solar, wind, geothermal, and biomass energy, and on improving energy efficiency. Participating in the design and implementation of state renewable energy policies is one way UCS actively works toward these ends. UCS is interested in promoting the public interest, which is served by a reliable and efficient regional electricity market broadly defined.
The Context for Decision-Making: Cape Cod and Climate Change
Since the Cape Wind Project was first considered by this commission, in 2001, the importance of addressing global warming, and the importance of significantly increasing the use of renewable energy toward that end, have become even more apparent. Confronting Climate Change in the U.S. Northeast, a report issued in July by more than 50 scientists and economists and UCS, details how global warming could seriously harm the northeastern United States. It looks at temperature and precipitation under two different carbon emissions scenarios: one that assumes a continuing increase in global warming emissions from ongoing heavy reliance on fossil fuels, and another that assumes substantially lower emissions by making changes like increasing our reliance on clean energy sources.
The report spells out clearly the consequences for our region and our state if we do not responsibly address climate change. “[I]f global warming emissions continue to grow unabated,” the report concluded, “Massachusetts can expect dramatic changes in climate over the course of this century, with substantial impacts on vital aspects of the state’s economy and character.” [1] Cape Cod would be hit in many sectors:
- Like other parts of the state, it would suffer from extreme heat and air quality impacts, with many more days of excessive heat and expected acceleration of seasonal pollen production, possibly extending allergy seasons and increasing asthma risks.
- It would feel the effects in its agriculture: “If higher emissions prevail, increasing summer temperatures and heat stress are expected to depress the yields of a number of… economically important crops by mid-century, while rising winter temperatures are expected to further the northward expansion of agricultural pests and weeds… [C]hilling requirements for cranberries are unlikely to be met by mid-century in the state’s key cranberry-producing region (the southeast).”
- The local fishing industry would feel the increasing pressures on the historically important Atlantic cod and other species, as water temperatures “become too warm to support the growth and survival of young cod by late this century”—and even adult cod under the higher-emissions scenario.
- And rising sea levels caused by global warming “are projected to increase the frequency and severity of damaging storm surges and coastal flooding” and “permanently inundate certain low-lying coastal areas and dramatically accelerate erosion, particularly on important barrier beaches such as…Nauset Beach.”
Implementing Solutions
The report also shows that the majority of the consequences are avoidable; we have a choice in the emissions path we take, and in the extent and effect of climate change. In order to avoid the worst outcomes, we must begin immediately implementing a broad array of solutions—in transportation, in our buildings, in the agriculture sector, and in our use of energy—to reduce our global warming pollution on the order of 80 percent by mid-century.
Because carbon emissions from electric generators make up a significant share of this region’s and the U.S.’s contributions to heat-trapping gasses, they must be a key target of our efforts. Energy efficiency is a key tool, but we will also need to substantially reduce the carbon intensity of the remaining power generation. By developing our region’s renewable energy resources, we can begin to free ourselves from the climate change risks and damage caused by coal, oil, and natural gas. Renewable energy is the only source of indigenous power available in New England, and offshore wind may offer the greatest potential for renewable energy development in the state.
No single project or single technology can meet our society's future energy needs by itself. The solution instead will come from a family of diverse energy technologies that share a common thread—they do not deplete our natural resources or destroy our environment. We must look to safe, clean, reliable wind power as a key component of the solution to our energy problems.
As a society, we must accept that no energy source available has zero impact. When weighed against the very real threats of climate change to coastal property and many risks of continuing on our current unsustainable energy path, the benefits of well-sited offshore wind power are starkly apparent. Pursuing every environmentally responsible opportunity to move our energy system to more sustainable sources—offshore wind power included—is essential.
The Cape Wind Project
UCS believes that Cape Wind and other wind projects should be built unless rigorous review and study shows significant environmental impacts that cannot be mitigated and that outweigh project benefits. We believe that with proper siting, careful design, comprehensive study, monitoring, and mitigation, wind power can and should play a significant role in this region’s electricity system.
The findings of the extensive Cape Wind review process to date, including the state’s review and approval of the Final Environmental Impact Report (FEIR), show that the project could be a significant step in addressing the many negative impacts of our electricity system, with regard to climate change and many other issues. In developing the FEIR, Cape Wind responded to the concerns and issues addressed in comments from the wide variety of parties on the Draft Environmental Impact Report (DEIR)/Statement, and in the Certificate on the DEIR issued by the Massachusetts Secretary of Environmental Affairs. We particularly appreciated the project proponent’s responses to UCS’s comments (Feb. 24, 2005) about further quantifying the project’s likely impacts on the state’s/region’s electricity generation system, the economic benefits of increased fuel diversity, and the consumer benefits associated with reduced natural gas use in New England. We found quite encouraging the FEIR’s findings regarding the project’s significant positive socioeconomic, public health, and environmental benefits.
While we did not review the entire FEIR, and did not have the in-house expertise to comment on many of the specific potential impacts examined, we were also encouraged by the limited or transitory nature of the majority of the other potential impacts examined in the FEIR, which were expected to be minor, temporary, localized, or mitigated or wholly removed through the project design or construction.
The FEIR contains a significant body of data and promising conclusions, but the federal Environmental Impact Statement (EIS) process under the Minerals Management Service should and will continue to examine the potential impacts of areas of the Project under federal jurisdiction, particularly related to wildlife. UCS supports that process and looks forward to reviewing the draft EIS. Proper execution of that process will enable Cape Wind to be designed and implemented in a way that allows the development of an environmentally sound wind project.
Cape Wind is potentially very important for Massachusetts and the region, including in terms of moving forward now on addressing the various serious challenge of climate change. As the Commission makes its decisions about the project, we would strongly urge you to consider what is now known about climate change, and consider the conclusions of the Northeast Climate Impacts Assessment:
“Global warming represents an enormous challenge, but we can meet this challenge if we act swiftly. The emissions choices we make today in Massachusetts, the Northeast, and globally will shape the climate our children and grandchildren inherit. The time to act is now.”
Thank you very much for your consideration.
Sincerely,
John H. Rogers
Northeast Clean Energy Project Manager
