URGENT: Public Comment Requested on Two BOEM Wind Energy Projects Off the Coast of Southern Oregon
Leave a comment on the Commercial Leasing for Wind Power Development on the Oregon Outer Continental Shelf the federal government wants to install off the coast of Coos Bay.
BOEM will accept comments through 11:59 p.m. ET on October 16, 2023.
Click here to leave a comment:
https://www.regulations.gov/document/BOEM-2023-0033-0001
TWO SAMPLE COMMENTS:
“Concerning BOEM-2023-0033-0001:
HELL NO to the scam. I am opposed to the Bureau of Ocean Energy Management granting a lease for the wind power development on the Oregon outer continental shelf, especially off the coast of Coos Bay .”
Or,
“Concerning BOEM-2023-0033-0001:
It is not possible to have an accurate environmental risk assessment or estimated production output of these wind farms due to the lack of long-term studies on floating wind farms.
There have only been a handful of 5-year studies using prototypes and some of those prototypes were disassembled and recycled after 5 years of use. All prototypes are estimated to have a life span of only 15 years. When considering the breakdowns, failures, and fluid leaks that occur within the lifespan of a wind turbine, there is a high probability of environmental damage. The open ocean is the most destructive and powerful thing on earth and the Pacific Ocean is the most powerful. The amount of time these turbines will be inoperable due to maintenance, failures, and leaks will be significant if there is a viable turbine able to withstand the Pacific Ocean for any period.
Some studies show wind turbines in the summer only produce 17% of what they produce in the winter. That means Oregon can only rely on 17% of the actual maximum output of this wind farm unless we want to have rolling blackouts every summer.
All of the obstacles mentioned are only related to the wind turbines themselves. This does not include the equipment, cables, and infrastructure needed to move the electricity from the farm to land, all of which are also new technology and untested in the Pacific Ocean. Nobody can promise a productive, cost-effective floating wind farm.
If history shows us anything, it shows us that wind turbines are unreliable sources of energy that require lots of maintenance and lots of oil and grease. The combination of all of those factors makes floating turbines in the Pacific Ocean a waste of space, time, and money. The only advantage of having these wind farms is purely political because there is no functional or environmental advantage.
The state and federal governments need to stop this project immediately if they have any shred of honesty left. The true lifetime output of these wind farms will probably be only 25% of what the farm is intended to produce and that is assuming the turbines survive their first winter. The Oregon coast is not the place to have a very risky experiment using untested technologies in an environment that will not allow for maintenance many months out of the year.
I am opposed to the Bureau of Ocean Energy Management granting a lease for the wind power development on the Oregon outer continental shelf, especially off the coast of Coos Bay”
Click here to leave a comment:
https://www.regulations.gov/document/BOEM-2023-0033-0001
Click here for the Bureau of Ocean Energy Management:
Additional information on the webinars will be available on the BOEM Oregon state activities page.
BOEM will accept comments through 11:59 pm ET on October 16, 2023.
Link to news on the project:
Coastal communities voice concerns as Oregon offshore wind energy projects move forward | kgw.com
Link to more info on opposing the wind energy ocean project:
Public Meetings and Comments
During the 60-day public comment period starting on August 15, 2023, BOEM will hold public meetings to outline data and information used to inform the draft WEAs and to discuss next steps. The meetings will be open to the public, with one specifically designed for engaging the fishing community. BOEM will also convene an Oregon Intergovernmental Renewable Energy Task Force meeting to discuss the draft WEAs and next steps in offshore wind energy planning in Oregon. Additional information on the webinars will be available on the BOEM Oregon state activities page.
To comment on the draft WEAs please go to regulations.gov and search for docket number BOEM-2023-0033. BOEM will accept comments through 11:59 pm ET on October 16, 2023.
Commenter's Checklist
Tips for Submitting Effective Comments*
Overview
A comment can express simple support or dissent for a regulatory action. However, a constructive, information-rich comment that clearly communicates and supports its claims is more likely to have an impact on regulatory decision making.
These tips are meant to help the public submit comments that have an impact and help agency policy makers improve federal regulations.
Summary
· Read and understand the regulatory document you are commenting on
· Feel free to reach out to the agency with questions
· Be concise but support your claims
· Base your justification on sound reasoning, scientific evidence, and/or how you will be impacted
· Address trade-offs and opposing views in your comment
· There is no minimum or maximum length for an effective comment
· The comment process is not a vote – one well supported comment is often more influential than a thousand form letters
Detailed Recommendations
Comment periods close at 11:59 eastern time on the date comments are due - begin work well before the deadline.
Attempt to fully understand each issue; if you have questions or do not understand a part of the regulatory document, you may ask for help from the agency contact listed in the document.
Note: Although the agency contact can answer your questions about the document's meaning, official comments must be submitted through the comment form.Clearly identify the issues within the regulatory action on which you are commenting. If you are commenting on a particular word, phrase or sentence, provide the page number, column, and paragraph citation from the federal register document.
If a rule raises many issues, do not feel obligated to comment on every one – select those issues that concern and affect you the most and/or you understand the best.
Agencies often ask specific questions or raise issues in rulemaking proposals on subjects where they are actively looking for more information. While the agency will still accept comments on any part of the proposed regulation, please keep these questions and issues in mind while formulating your comment.
Although agencies receive and appreciate all comments, constructive comments (either positive or negative) are the most likely to have an influence.
If you disagree with a proposed action, suggest an alternative (including not regulating at all) and include an explanation and/or analysis of how the alternative might meet the same objective or be more effective.
The comment process is not a vote. The government is attempting to formulate the best policy, so when crafting a comment it is important that you adequately explain the reasoning behind your position.
Identify credentials and experience that may distinguish your comments from others. If you are commenting in an area in which you have relevant personal or professional experience (i.e., scientist, attorney, fisherman, businessman, etc.) say so.
Agency reviewers look for sound science and reasoning in the comments they receive. When possible, support your comment with substantive data, facts, and/or expert opinions. You may also provide personal experience in your comment, as may be appropriate. By supporting your arguments well you are more likely to influence the agency decision making.
Consider including examples of how the proposed rule would impact you negatively or positively.
Comments on the economic effects of rules that include quantitative and qualitative data are especially helpful.
Include the pros and cons and trade-offs of your position and explain them. Your position could consider other points of view, and respond to them with facts and sound reasoning.
If you are uploading more than one attachment to the comment web form, it is recommend that you use the following file titles:
Attachment1_<insert title of document>
Attachment2_<insert title of document>
Attachment3_<insert title of document>
This standardized file naming convention will help agency reviewers distinguish your submitted attachments and aid in the comment review process.
Keep a copy of your comment in a separate file – this practice helps ensure that you will not lose your comment if you have a problem submitting it using the Regulations.gov web form.
Posted Comments
After submission, your comment will be processed by the agency and posted to Regulations.gov. At times, an agency may choose not to post a submitted comment. Reasons for not posting the comment can include:
The comment is part of a mass submission campaign or is a duplicate.
The comment is incomplete.
The comment is not related to the regulation.
The comment has been identified as spam.
The comment contains Personally Identifiable Information (PII) data.
The comment contains profanity or other inappropriate language.
The submitter requested the comment not be posted.
Form Letters
Organizations often encourage their members to submit form letters designed to address issues common to their membership. Organizations including industry associations, labor unions, and conservation groups sometimes use form letters to voice their opposition or support of a proposed rulemaking. Many in the public mistakenly believe that their submitted form letter constitutes a "vote" regarding the issues concerning them. Although public support or opposition may help guide important public policies, agencies make determinations for a proposed action based on sound reasoning and scientific evidence rather than a majority of votes. A single, well-supported comment may carry more weight than a thousand form letters.
* Throughout this document, the term "Comment" is used in place of the more technically accurate term "Public Submission" in order to make the recommendations easier to read and understand.
Disclaimer: This document is intended to serve as a guide; it is not intended and should not be considered as legal advice. Please seek counsel from a lawyer if you have legal questions or concerns.