Cape Wind Project
Comments of the Union of Concerned Scientists on the Cape Wind Project Final Environmental Impact Report, EOEA #12643
March 22, 2007
Secretary Ian A. Bowles
Executive Office of Environmental Affairs
Attn: MEPA Office
Anne Canaday, EOEA No. 12643
100 Cambridge Street, Suite 900
Boston, MA 02114
Regarding: Comments of the Union of Concerned Scientists on the Cape Wind Project Final Environmental Impact Report, EOEA #12643
Dear Secretary Bowles,
On behalf of the Union of Concerned Scientists, I am writing in response to the request for comments on the Final Environmental Impact Report (FEIR, or The Report) for the project proposal of Cape Wind Associates (The Proponent).
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.
UCS's position is 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.
With regard to the Cape Wind project (The Project), we appreciate the extensive effort that the cooperating state and federal agencies have made to ensure that the Environmental Impact process (both the EIR and the federal Environmental Impact Statement, or EIS) has followed a thorough and sound review of the Project's permit application.
We limit the scope of our comments here to matters under the state's jurisdiction in this matter, and therefore likewise reserve for later our comments regarding matters under federal jurisdiction and still being assessed through the federal EIS process.
The Context
Since the release of the draft EIR and EIS in 2005, 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. Efforts such as the Northeast Climate Impacts Assessment (www.climatechoices.org/ne), a collaboration between UCS and more than 40 independent experts, show even more clearly the impact that global warming will have in this region specifically.
UCS strongly believes that in order to avoid the worst outcomes posed by climate change, we must begin implementing a broad array of solutions immediately, including offshore wind power. The carbon emissions coming from electric generators make up a significant share of this region's and the U.S.'s contributions to heat-trapping gasses. These emissions threaten the stability of the earth's climate and, if not addressed, will push ecosystems and economies here and around the world to their limits. Delaying action in addressing carbon emissions only increases the eventual severity, expense, and likelihood of irreversible and frightening losses.
By developing our region's renewable resources, we can begin to free ourselves from the risks and damage caused by coal, oil, natural gas, and nuclear power. Renewable energy is the only source of indigenous power available in New England. Offshore wind may offer the greatest potential for renewable energy development in the region. Every kilowatt that we produce from our local resources, including our significant offshore wind resources, keeps money and jobs in our region.
No single technology, or even a single renewable project, 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 the current unsustainable energy path we are on, 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 FEIR
The findings of the FEIR show that the Cape Wind project could be a significant step in addressing the many negative impacts of our electricity system. We appreciate the Proponent's responsiveness to the concerns and issues addressed in comments from the wide variety of parties in response to the Draft Environmental Impact Report/Statement, and in the Certificate on the Draft EIR issued by the Massachusetts Secretary of Environmental Affairs. We also appreciate the 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 are quite encouraged by the FEIR's findings regarding the Project's benefits and potential impacts, the significant positive socioeconomic, public health, and environmental benefits.
While we have not reviewed the entire FEIR, and do not have the in-house expertise to comment on many of the specific potential impacts examined, we are also encouraged by the limited or transitory nature of the majority of the other potential impacts examined, which are expected to be minor, temporary, localized, or mitigated or wholly removed through the project design or construction.
While the FEIR contains a significant body of data and promising conclusions, the federal 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 the Cape Wind project to be designed and implemented in a way that allows the development of an environmentally sound wind project.
With regard to the state's jurisdiction, we believe that the FEIR is responsive to the issues raised by the Office of Environmental Affairs, along with those of UCS and many others. We also believe that the Project is potentially very important for Massachusetts and the region in terms of the benefits outlined above.
Given those factors, we strongly encourage you to issue a Certificate finding the Project's FEIR adequately and properly complies with the Massachusetts Environmental Policy Act.
Thank you very much for your consideration.
Sincerely,
John H. Rogers
Northeast Clean Energy Project Manager
