Wind Energy in Louisiana
PLEASE COMMENT!
LOUISIANA’S BIRDS AND OTHER WILDLIFE NEED YOU!
Wind Energy in Louisiana Territorial Waters with NO environmental assessments!
The State of Louisiana is fast-tracking the development of near shore wind farms in its territorial waters within three miles of the coast. While our Nation and our State welcome renewable energy including wind, unfortunately, the proposed new process the State has adopted to speed up the construction of these projects will not allow for adequate risk assessment for birds and other animals using Louisiana’s coastal zone.
While the federal government undertakes detailed environmental studies before choosing wind energy sites further offshore as do other States for their near shore wind projects, Louisiana has decided to pursue its own near shore efforts in reverse: let developers choose locations based solely on economic considerations and then try to mitigate the disastrous environmental consequences afterward. This is a major concern because migratory flyways through Louisiana are some of the largest in North America.
Louisiana’s backwards approach is also not good for the wind developers who risk investing significant funds in starting a project and then having it halted or permanently shut down when a mass bird mortality event or some other environmental disaster results. This approach will also, no doubt, invite protracted and expensive litigation, which will further slow down the developers’ projects even before an environmental disaster occurs. We all need to work together instead.
Recently, the State announced negotiations for two new wind energy Operating Agreements with Operators, Diamond Offshore (DOW) and Cajun Wind, for two wind farm sites. The DOW project is presently sited in Ship Shoal, South Pelto and South Timbalier mineral lease blocks in the coastal waters of Lafourche and Terrebonne Parishes, and the Cajun Wind Project will be sited in the West Cameron mineral lease blocks of Cameron Parish. These Operating Agreements will allow developers to bypass the State’s new formal wind energy leasing laws altogether, including their environmental protections, without any environmental risk siting assessment being done beforehand. This should raise significant alarms since three of the largest bird migratory flyways in the North America. pass through the two chosen areas.
The State’s Office of Conservation has now posted a sample template for the Operating Agreements for written comments and scheduled three public meetings. Comments may also be made on the State’s overall approach to wind energy. Public comments on the Operating Agreement Template and the two projects are due in writing by the close of business on December 11, 2023. Public meetings are also scheduled for questions and comments on November 27, 2023 for the DOW project and November 29, 2023 for the Cajun Wind project. See details and Public Notice links below.
As these projects are in State waters, it is unlikely the federal NEPA and its environmental impact statement requirements will apply. Thus, the only time to force environmental considerations into the project development through agency action will be either NOW or at the Corps 404/State Coastal Use Permit stage, which may too late in the process to be effective. Relief is also doubtful at that permit stage since the State is acting as landowner/co-venturer, is issuing a permit to itself as well as its co-venturer, and is acting as the regulatory body overseeing the entire process.
PLEASE urge the State of Louisiana to reconsider its siting approach so that it considers the lives of birds and other animals in its siting and development of near shore wind energy. Our nation and our State need wind energy but only if implemented responsibly!
Orleans Audubon Society (OAS) plans to send comment letters for the proposed siting locations. (These proposed siting locations could not be worse for birds!) Andrew Wilson, OAS’s Conservation Chair is taking the lead on this and has prepared the attached written comment for the DOW LA Gulf Wind, LLC on behalf of OAS which may provide further thoughts for your comments. Assess the OAS comment letter here:
OAS LDNR Final Wind Energy Comment 11.24.23
PLEASE urge the state to:
- abandon the “Operating Agreement” approach and implement a lease program in accordance with the new state law
- if the State will not abandon the “Operating Agreement” approach, then insert language in the Operating Agreement to require environmental oversight (see attached OAS comment for language).
- gather environmental data and conduct risk/vulnerability assessments PRIOR to site selection,
- work closely with the Louisiana Department of Wildlife and Fisheries on the
environmental assessment, addressing the Department’s concerns - consider the Gulf of Mexico offshore wind siting map developed by NOAA and BOEM modeling experts which recommends that no wind farms be developed within 20 nautical miles of Louisiana’s coast due to concerns for population-level impacts on coastal bird species:
- consider the American Bird Conservancy’s Wind Risk Assessment map: https://abcbirds.org/program/wind-energy-and-birds/wind-risk-assessment-map/?gad_source=1&gclid=EAIaIQobChMI2KWNlKffggMVcy7UAR2eDAJ6EAAYASAAEgKouPD_BwE
Regarding the map, if you zoom in you will see that almost the entire coastline is “Critically Important” to birds.
Also be sure to include avian environmental concerns in your written comment. Based upon scientific studies conducted for other wind energy projects, mass mortality is expected to occur (i.e., birds colliding with wind turbines) if the projects are sited where they are currently being proposed. One of the problems is birds are much more likely to collide with wind turbines that are sited near shore versus in federal waters well offshore. The main areas of concern for birds, to be taken into account in assessments of wind farm sitings, are:
- neotropical migratory birds using the trans-Gulf route, crossing through
Louisiana’s coastal zone (Common Nighthawk, Swallow-tailed Kite, Prothonotary Warbler, etc.) - Colonial nesting waterbirds using Louisiana’s coastal zone and barrier
islands (e.g., Sandwich Tern, Royal Tern, Brown Pelican, etc.) - Threatened Piping Plover and Red Knot use of Louisiana’s coastal zone during their non-breeding season
- seabirds frequenting Louisiana’s coastal zone (e.g., Magnificent Frigatebird, Pomarine Jaeger)
Public hearings are scheduled for November 27 in Terrebonne Parish and November 29 in Cameron Parish.
LAFOURCHE/TERREBONNE PARISH
November 27, 2023: Hearing on DOW LA Gulf Wind Operating Agreement
12:30 PM at the Lafourche Parish Public Library (705 W 5th St, Thibodaux) and
5:00 PM at the Terrebonne Parish Main Library (151 Library Dr, Houma). For comments, reference Docket No. OMR 23-03
CAMERON PARISH
November 29, 2023: Hearing on Cajun Wind Operating Agreement
1:30 PM at the Cameron Parish Police Jury West Annex Building (148 Smith Circle, Cameron). For comments, reference Docket No. OMR 23-04
Written comments, due by the close of business on December 11, should be sent to:
Office of Mineral Resources
Post Office Box 2827
Baton Rouge, Louisiana 70821‐2827
OMR@la.gov
Comment letters MUST reference either one or both of these projects:
Re: DOW LA Gulf Wind, LLC
– Public Hearing Operating Agreement in Lafourche/ Terrebonne Parishes, Louisiana Docket No. OMR 23‐03
Re: Cajun Wind LLC
– Public Hearing Operating Agreement in Cameron Parish, Louisiana Docket No. OMR 23‐04