March 3, 2008
Grover Fugate, Executive Director
Coastal Resources Management Council
Oliver Stedman Government Center
4808 Tower Hill Road, Suite 3
Wakefield, RI 02879-1900
Re: Proposed moratorium on renewable energy proposals
Dear Mr. Fugate:
In order to confront the challenge of global climate change, increase stability in electricity prices and develop a clean energy economy, the Conservation Law Foundation and Environment Rhode Island enthusiastically and energetically support expanded and ambitious investment in renewable energy, including wind, on land and in the waters of Rhode Island. Offshore wind power certainly has a place in our energy future, because offshore areas hold some of the most productive areas for wind power projects in the New England region.
We believe that the impact wind farms have on the immediate local environment is in most cases far outweighed by the fact that we must substantially increase our investment in wind power to help eliminate our dependence on fossil fuel and avoid the catastrophic consequences of global warming. As with land based projects, decisions about where wind power projects are located in the ocean should be made in the context of a larger management plan that takes into account other uses.
Therefore, we support the development of an ocean special area management plan (SAMP) for Rhode Island’s waters. If done correctly, such a plan should promote development of renewable energy in Rhode Island, while ensuring the protection of the ocean ecosystem. A comprehensive plan could make the process of deciding what happens in the ocean more efficient by creating a clear decision-making process and eliminating unnecessary bureaucracy. Having such a plan will help promote renewable power in ocean waters while balancing the needs of competing uses like ecosystem protection, marine transportation, fishing and recreation.
While we support the development of an ocean SAMP, we are concerned about the proposed moratorium, and strongly urge that you postpone making any decisions on the moratorium until the following concerns are addressed:
1. The principal problem with the proposed moratorium is that no information has been provided about the proposed ocean SAMP. The moratorium proposal does not say what product will be delivered in a year. The best result of an ocean SAMP would be clear guidelines that help developers understand from an ecological perspective whether development in a given location would be acceptable or not. You are also quoted in a recent article as suggesting that the plan would require funding in the amount of $6 million, $2 million of which would support installation of a met tower. Why CRMC – or any other public entity – is the appropriate entity to install or site such met towers is not evident.
2. It is also not clear what work requires the remaining $4 million, or where that funding would be obtained. Without a clear and public plan, the suggested moratorium could end up being just a one year delay that gets us no closer to improved ocean management or development of renewable energy projects in Rhode Island. A well crafted approach to ocean planning might justify a one year moratorium. However, no information has yet been provided that would yet support that conclusion.
3. At such time as it is appropriate to consider a moratorium, we suggest that CRMC make clear in the written proposal that met towers, experimental projects and other data collection and pilot efforts appropriate for pursuing renewable energy projects, by public or private developers, can be allowed during the moratorium.
We appreciate CRMC’s taking a proactive role in ocean management planning and the promotion of renewable energy projects in Rhode Island. However, proposing a moratorium before the ocean planning effort that justifies that moratorium is described puts the cart before the horse. We urge CRMC to release an outline of the proposed SAMP, as well as the proposed schedule and funding, so the public can determine if the proposed moratorium would advance the goals of well-sited renewable energy and whether the SAMP would address the right topics and could reasonably be expected to be complete within the one year time frame.
Sincerely,
Cynthia Giles
Director, Rhode Island Advocacy Center
Conservation Law Foundation
Matt Auten
Advocate, Environment Rhode Island
