Developer Jim Gordon, of the Cape Wind project, may have been thinking "It is sometimes better to apologize than ask for permission" when his company omitted the dredging of Horseshoe Shoal from their Final Environmental Impact Report to the State of Massachusetts. But when it comes to a project of this magnitude, 130 440' wind turbines and a 100' electrical platform slated for 25 square miles of the Nantucket Sound, a public waterway, off the coast of Cape Cod and the Islands an apology just won't cut it.
Mark Weissman, board member of the Massachusetts Marine Fisheries Commission and consultant to the Alliance to Protect Nantucket Sound (comment on FEIR HERE) testified at the Cape Cod Commission's public hearing, March 19, 2007, on the adequacy of Cape Wind's Final Environmental Impact Report that the FEIR omitted critical information on the dredging required in order for construction barges to get in and around 12 turbines that would be located in less than 12 feet of water, some would be in water only 7-8 feet deep. Since the draw of construction barges and tug boats (a fleet of these vessels ranging from 90-400' long would be required during construction and pile driving activities) is from 10-14 feet of water it would be impossible for those boats to navigate without dredging massive "harbor-sized "deep-water ports" at each of the many shallow-water turbine sites and dredge miles of deep wide channels for transiting the shoal to the sites".
"This undisclosed dredging and possible blasting would have grave consequences on the marine life and habitat of Nantucket Shoal. Weissman concluded that "A supplemental must be required (by the Massachusetts Environmental Protection Act) to address the impacts to habitat and marine resources of these extraordinary alterations of large portions of the Shoal (*Note: a shoal is a sandbank or sandbar that makes the water shallow (accumulation of sediment in a river channel or on a continental shelf that is potentially dangerous to ships. On the continental shelf it is conventionally taken to be less than 10 m (33 feet) below water level at low tide. Shoals are formed by essentially the same factors that produce offshore bars.) that would be required to erect many of the turbines."
In a Letter to the Editor of the Cape Cod Times on March 22, 2007, Mark Rodgers, spokesperson for Cape Wind wrote:
"Mr. Weissman stated that Cape Wind's final environmental impact report neglected to mention dredging Horseshoe Shoal, which Mr. Weissman incorrectly claimed would be needed to create access for a construction barge used in installing the wind turbines. Mr. Weissman went on to speculate about damage such dredging would cause. The reason Cape Wind's final environmental impact report makes no mention of dredging Horseshoe Shoal is that no dredging is needed for a construction barge to access the wind turbine locations"
On April 10, 2007, Jack Coleman, a former paid media consultant to the pro-wind farm non-profit Clean Power Now who has written about the project as a proponent for two years, wrote an analysis of Mr. Weissman and Mr. Rodgers statements titled Valid criticism - from the opposition on Cape Cod Today, an on-line newspaper, showing charts of the area and pointing out that dredging would most likely have to occur.
"Cape Wind wants to build its turbines in one of the most ecologically dynamic settings on the East Coast, a shoal that's continually buffeted by currents, wind and waves. " Jack Coleman
The following excerpts are from Coleman's blog post Valid criticism - from the opposition:
"Two Cape Wind supporters I spoke with about this were both dismissive. I am of a different opinion -- whether dredging of Horseshoe Shoal is needed is hugely significant, and I suspect it's the main reason MMS extended its regulatory review. It's not just areas directly adjacent to the turbines that may need to be dredged -- the same may be true of water less than 12 feet deep for hundreds of feet in all directions around these specific turbines, to allow tugboats and huge construction barges room to maneuver."
"But after spending roughly $30 million before generating a single kilowatt-hour, why would Cape Wind risk jeopardizing the project with a questionable omission in its documentation to MMS? I can only conclude the omission is not accidental. If the amount of dredging needed is even half as much as critics like Weissman allege, it would still involve an immense amount of material removed from the seabed. Material that have to be dredged from Horseshoe Shoal -- and placed elsewhere. The eyes glaze at the thought of the additional red tape involved. By not addressing this in the FEIR, Cape Wind may have crossed its fingers and hoped for the best. Who knows, maybe it'll pass muster. Then again, maybe not."
"Cape Wind has dodged more than its share of bullets -- lawsuits, well-funded lobbying in Washington, overheated rhetoric about avian carnage and navigational mayhem. But when it comes to dredging, that string of good fortune may come to an end. This issue, and proponents' dismissal of its importance, is an Achilles heel that Cape Wind ignores at its peril."
Suddenly, the Editors of capecodtoday.com, also wind farm supporters, closed the comments on Coleman's post stating that :
"Cape Cod TODAY regrets to inform our readers that Jack Coleman failed to contact the developer for their response before publishing this post. Cape Wind categorically denies that any dredging will take place in constructing the wind farm. They state that having reduced the proposed footprint from 170 to 130 turbines two years ago they have amble space to rearrange the placement should any specific sites prove difficult and that there is 12 feet of high water around each proposed turbine site. More importantly, any dredging would require many additional permits which would be nearly impossible to acquire according to the developer (*emphasis added). "
Within several minutes, the comments were opened back up along with "a wager to any and all Cape Wind supporters. Seeing how it is apparently beyond the realm of possibility that dredging will be needed for this project, how about a wager of one dollar with odds of, say, 1,000 to 1? If I lose, I will gladly pay $1 to any and all people willing to accept this wager. And if they lose, they each pay me $1,000." From Jack Coleman.
150 comments later, there are still no takers.
See Jack Coleman's analysis HERE
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Comments: 3
And if dredging is such an issue, there are plans to begin doing just that on Nantucket Shoal to save 40 high end summer homes. I think powering 75,000 homes on Cape Cod with clean-renewable energy should supercede the needs of 40 summer home residents. If dredging is really a concern, why focus the efforts on Cape Wind when a far larger scale project is going to start up in the next few months:
The $23 million erosion-control project calls for dumping enough sand to widen the beach and reshape the collapsed bluff along a 3-mile stretch of Nantucket from Sesachacha Pond to Codfish Park.
http://www.capecodonline.com/apps/pbcs.dll/article?AID=/20070430/NEWS/704300329
The USACE Dredging permit Volume One is over 600 pages long. There's a reason why, "Cape Wind categorically denies that any dredging will take place in constructing the wind farm." Valid Criticism by Jack Coleman sheds light on the possibilities.
Thank you for providing these links, Dona, and keep the unvarnished truth coming.
If the regulators ignore the public safety hazard warnings associated with Cape Wind, we'll have more than dredging permits to be concerned about. Public safety is assured by the National Environmental Policy Act NEPA, under which Cape Wind is being reviewed. The number one pubic policy consideration is public safety.
In November of 2004, The Nantucket, Martha's Vineyard and Barnstable Airports filed a formal objection to the placement of 130 Turbines in the middle of the 3 airports flight paths. These concerns were based on recent radar studies conducted by the UK Ministry of Defense. The FAA has not yet responded to their appeal.
David F. Scudder, Vice President of Hy-Line Cruises in his letter to Senate and House Conferees of February 26, 2006:
"On the basis of public safety concerns, we have consistently and adamantly been against the wind farm project in the Sound since its inception. Navigating Nantucket Sound in all kinds of weather and traffic conditions is challenging enough without the introduction of these structures to complicate and restrict our routes."
Port Captain Charles Gifford:
"My name is Captain Charles Gifford, I am the Port Captain for the Wood's Hole, Martha's Vineyard, Nantucket Steamship Authority. I'm a U.S. Coast Guard licensed Master Mariner and an approved instructor at the Massachusetts Maritime Academy."
"The Steamship Authority annually makes 22,000 trips transporting close to three million passengers and over 600,000 cars and trucks to the Islands of Martha's Vineyard and Nantucket. It is our opinion that the 130 wind turbines planned for Horseshoe Shoals and Nantucket Sound has a potential for creating a significant hazard to safe navigation for our vessels and other users of the waterways."
National Air Traffic Controllers Union Cape Air Approach:
"could not think of a worse place to put these turbines."
National Air Traffic Controllers' Cape TRACON to the USACE:
"Placing 130 of these turbines in this area, in our opinion, is a disaster waiting to happen." "We have some very serious worries over the location of this project. Cape Wind Associates has published "Airplane Flight Routes" on its web site, which depicts flight paths that are well clear of the proposed Wind Farm. The reality of this situation is quite different. This is a very heavily traveled area for air traffic. If you were to ask me, where is the worst possible place to construct a hazard to aviation and jeopardize safety in the Cape and Islands airspace, I couldn't have picked a better spot than the current location."
"The evidence of endangerment to all who travel by air or sea over and upon Nantucket Sound is compelling."
Nantucket Memorial Airport to Congressman Delahunt:
"The Sound is a primary lifeline to Nantucket Island for both surface marine activity and aviation. It appears obvious that any interruption of reliable radar coverage would pose a serious concern to the safety of this area. The vertical obstruction also poses a challenge to any search and rescue efforts in a relatively large area."
Barnstable Airport Manager to the FAA Marion Blakely:
"The purpose of this letter is to seek the FAA's cooperation to immediately suspend its current finding of "No Adverse Effect", regarding the proposed Cape Wind Farm proposed for Nantucket Sound. This project not only poses a threat to more than 24 square miles of pristine waterway, but more so the FAA's previous ruling is more than four years old and quite rudimentary, given the immersion of new facts surrounding the numerous negative effects of large-scale wind projects such as the one proposed for Nantucket Sound."
An average of 400,000 flights travel in this airspace annually. An average of 3 million ferry passengers per year are transported across Nantucket Sound by the Steamship Authority.
The National Environmental Policy Act NEP assures public safety and Cape Wind presents a threat to public safety. Marine Minerals Management Service should deny Cape Wind's application.
We can assure reasonable public safety guided by NEPA, or permit Cape Wind. The expert testimony clearly indicates that we can't have both Cape Wind and public safety in Nantucket Sound.