The EA presents the environmental and socioeconomic impacts of these events on physical resources (like air, water, and subsurface geology), biological resources (like birds, bats, fish, marine mammals, and turtles), and socioeconomic resources (like aesthetics and visual impacts, military operations, fishing, navigation, and recreation).
The EA considers a series of alternatives to this proposed action which entail further reductions to the area available for leasing for various reasons: protecting North Atlantic right whale populations, excluding development within 15 or 21 nautical miles of the Massachusetts coastline, or limiting telecommunications cable impacts. The EA also considers a no-action alternative, meaning not issuing commercial or research leases and not allowing further site characterization activities within the area.
While the EA represents a significant step forward in BOEM’s leasing process for Rhode Island Sound, it is important to note its limitations. First, while the EA presents BOEM’s evaluation of the environmental impacts of leasing and site characterization, it does not represent a final Finding of No Significant Impact (FONSI) allowing leasing to move forward. Text in the EA suggests “no significant impacts” from various events on a number of resource types – for example, “no significant impacts” are expected: (1) from vessel discharges or collisions; (2) on recreational resources, the geology of the sites, or water quality; or (3) “on marine mammals or the associated wildlife viewing activities”. Further, BOEM found “no expected threat of significant impact” on bird species. BOEM has solicited public comment, and will next decide whether to issue a FONSI or conduct additional analysis. Notably, BOEM’s final EA for mid-Atlantic offshore wind leasing found no significant impact there; although some environmental concerns are different in New England, such as the presence of right whales, the mid-Atlantic FONSI suggests that in at least certain areas BOEM believes leasing will have no significant impact. Nevertheless, BOEM has not yet issued a FONSI or taken other steps required under NEPA before it may issue leases in the area off Rhode Island and Massachusetts.
Second, the EA does not directly consider the environmental impacts of developing and operating offshore wind generation facilities. If and when a lessee is prepared to propose wind energy generation on its lease, the lessee would submit a Construction and Operation Plan (COP) for BOEM approval. If a COP is submitted, BOEM would then prepare a separate site- and project-specific NEPA analysis to evaluate the potential environmental and socioeconomic consequences associated with the proposed project when considering whether to approve, approve with modification, or disapprove the COP.
Third, the EA does not cover nearby areas outside the identified WEA. In May 2012, BOEM also identified a separate area offshore Massachusetts for consideration for potential future wind energy leasing. This area, which is adjacent to the joint Rhode Island/Massachusetts area, is being evaluated separately from the joint area. Expect a separate EA covering the area offshore Massachusetts later this year.
Nevertheless, the Rhode Island/Massachusetts EA advances BOEM’s process for sorting through the eight expressions of competitive interest for offshore wind sites in Rhode Island Sound. Further environmental analysis, selection of one of the alternatives considered, or issuing a FONSI, may be a likely next step.
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