On behalf of the Natural Resources Defense Council (NRDC), Environmental Defense Center (EDC), National Audubon Society (Audubon), California Coastal Protection Network, Defenders of Wildlife (Defenders), Surfrider Foundation, Sierra Club, and our millions of members, we submit these comments on the Bureau of Ocean Energy Management’s (BOEM’s) Call for Information and Nominations (Call) for Commercial Leasing for Wind Power Development on the Outer Continental Shelf (OCS) Offshore California. Our organizations are united in support of responsibly-developed offshore wind energy as a critically-needed climate change solution, and our organizations have long advocated for policies and actions needed to bring it to scale in an environmentally protective manner.
We applaud BOEM’s substantial progress in advancing offshore wind energy development along the Atlantic Coast and are supportive of California also potentially benefitting from this innovative renewable energy opportunity. Advancing offshore wind to fight climate change, reduce local and regional air pollution, and grow a new industry that supports thousands of well-paying jobs is critical to our future, but we must also ensure offshore wind is developed responsibly and in a manner that protects our valuable marine life. Offshore wind development advances must include strong protections for valuable and vulnerable coastal and marine habitat and wildlife every step of the way. We urge BOEM to adopt an approach which engages stakeholders early and often in discussions on efforts to avoid, minimize, and mitigate any potential impacts to California’s beloved ocean life.
In this letter, we address several central issues: 1.) we offer recommendations for how BOEM should proceed on offshore wind by working in partnership with the state of California, and other key stakeholders (See Section II below); 2.) we respond to BOEM’s request for relevant “socioeconomic, biological, and environmental information” on the three Call Areas, sharing our initial review of relevant data for benthic habitat, fish, seabird, marine mammal, and sea turtle data (See Sections III through V below); and, 3.) we summarize several potential mitigation measures that could be used to help advance offshore wind (See Section VI and Appendix below).