Abstract
SouthCoast Wind Energy LLC (SouthCoast Wind), a 50/50 joint venture between Shell New Energies US LLC (Shell New Energies) and OW North America LLC (Ocean Winds), is working to develop an offshore wind renewable energy generation project (the Project) located in federal waters off the southern coast of Massachusetts in the Outer Continental Shelf (OCS) Lease Area OCS-A 0521 (Lease Area). This North Atlantic Right Whale (NARW) Monitoring and Mitigation Plan for Pile Driving describes the methods that will be used to monitor the pre-start clearance and shutdown zones as well as the Level B harassment zones during installation of Project foundations that occur within an area of concern initially defined by NMFS as waters within 20 km of the 30 m isobath on the west side of Nantucket Shoals (Figure 1). SouthCoast Wind is initially proposing this supplemental monitoring based on input from NMFS, which may be revised based on the best scientific and commercial data available upon approval from NMFS, consistent with the adaptive management approach incorporated into this plan.
This supplemental monitoring is included in the Mitigation and Monitoring Plan at NMFS' request. SouthCoast Wind believes that supplemental monitoring in the NMFS defined area of concern is not supported by the best available scientific evidence, and we continue to request from NMFS evidence on the necessity of this supplemental zone. Some of the topics raised by SouthCoast Wind were discussed in general terms during phone conversations with NMFS, but to date, no written responses directly addressing our specific questions have been received. Achieving a more complete understanding of the scientific basis for NMFS’s concerns with the pile driving planned in the specific location would allow SouthCoast Wind to create a monitoring and mitigation plan tailored to addressing the concerns. Once SouthCoast Wind finalizes this Mitigation and Monitoring Plan and its associated measures, those measures will be subject to an adaptive management approach pursuant to which SouthCoast Wind may propose for NMFS' approval, revisions to the supplemental monitoring and/or the zone in which it is required based on the best available scientific evidence in order to ensure the practicability of monitoring measures while minimizing adverse impacts to NARW.
This monitoring plan for pile driving is meant to supplement the existing monitoring and mitigation measures currently described in the request for Incidental Take Regulations (ITRs), which was deemed Adequate and Complete by NMFS on September 19, 2022. This includes the “Standard” measures that are applicable to all aspects of the proposed activity (see Section 11.1 in the ITR Application), such as PSO and PAM operator qualifications, training requirements and responsibilities, data recording protocols and software, reporting procedures, and noise attenuation systems for foundation installations. The standard conditions will remain applicable to the additional monitoring described in this plan, so they are not repeated here. Additionally, no vibratory pile driving will be used during the installation of the first 72 foundation positions in the northern portion of the Lease Area (Project 1), which includes all locations within the NMFS area of concern.
The monitoring methods and technologies described in this plan are based on what is currently available. Ongoing efforts by various academic, government, non-government and industry entities, from the time of submission of this document to initiation of construction by SouthCoast Wind are likely to produce improved detection methods for NARW. Advances made between now and the anticipated construction of the Project may also reduce uncertainties around current best practices as well as a better understanding of the abundance, presence and habitat use by NARW in this region. This Mitigation and Monitoring Plan adopts an adaptive management approach pursuant to which SouthCoast Wind may propose for NMFS' approval revisions to the monitoring and mitigation methods and technologies described in this plan. Such modifications would be based on the best available scientific evidence in order to ensure the practicability of monitoring and mitigation methods and technologies while minimizing adverse impacts to NARW, reducing risk to human safety, and maintaining consistency with the latest best practices and mitigation requirements from regulatory agencies to deliver the Project in the safest and most efficient way to meet State and Federal targets.
The methods described in this plan are primarily focused on times with sufficient daylight to conduct observations. If pile driving at night is determined to be feasible, a separate Nighttime Monitoring Plan that builds off this plan and describes the additional monitoring tools and methods to be implemented at night will be submitted to NMFS for review and approval.