Wind across the sanctuary 

Two primary environmental crises threaten the survival of life on Earth: climate change and biodiversity loss.

We commend the Biden administration's leadership in directing an urgent transition to clean energy sources and the protection of natural habitat. Offshore wind energy is a vital part of that program, and the Sierra Club supports responsibly developed offshore wind as a critically needed climate change solution that must be brought to scale in an environmentally protective manner that avoids, minimizes, and mitigates potential impacts to California's marine resources. Advancing offshore wind to generate carbon-free electricity to fight climate change, reduce air pollution, and support thousands of well-paying jobs is critical to our future. We must also ensure that offshore wind is developed with the strongest level of protections in place for vulnerable coastal and marine habitats and wildlife. This approach will both protect the marine environment and support this important new industry.

Which brings us to the proposed Chumash Heritage National Marine Sanctuary and the plans for wind energy projects in an area immediately adjacent to the sanctuary's northern border off the Central Coast, aka the Morro Bay 399 Call Area or Morro Bay Wind Energy Area.

Morro Bay 399 provides key habitat for a host of marine resources, including large baleen whales, fragile sponges and corals, commercially and ecologically valuable fish, and iconic bird species. Both the ecological importance of Morro Bay 399 and uncertainty about the impacts of floating platform technology warrant a judicious approach to developing this important potential new resource. Full consideration of potential impacts to marine areas will lay the groundwork for a thoughtful and efficient expansion of offshore wind energy.

Per the Biden administration, the selection of the Morro Bay Call Area came "after years of collaboration between the Departments of the Interior and Defense to find areas offshore the Central Coast of California that are compatible with the Department of Defense's training and testing operations." The Defense Department and Bureau of Ocean Energy Management (BOEM) established a cooperative process to identify potential areas for offshore wind development. Since its designation, the Morro Bay Wind Energy Area has been extended 118 miles west and 23 miles east, adding 141 miles to the original area.

In a Jan. 31 letter to the National Oceanic and Atmospheric Administration (NOAA), wind power trade associations expressed concerns that the proposed boundaries of the sanctuary "could have substantial impacts on offshore wind development off the Central Coast," and "impose undue restrictions on the designation of sufficient lease acreage offshore of California" because the wind area would be "sea-locked"—i.e. "surrounded by national marine sanctuaries"—and the proposed boundary for Chumash Heritage National Marine Sanctuary would "eliminate any route to the shore for an export cable route and associated electrical substations."

The letter requests multiple carve-outs and reductions in the proposed sanctuary area for all potential cable routes, plus "setbacks and exclusion radii around ports that will support development in the Morro Bay WEA [Wind Energy Area] and avoid adding additional burden and oversight," and expresses concerns about possible confusion over the jurisdictions of NOAA and BOEM, the agency that traditionally leases offshore energy projects.

However, BOEM and NOAA have signed a Memorandum of Understanding to Responsibly Address Offshore Wind Energy. Most of the concerns expressed in the letter from the energy trade groups can be allayed by receiving expedient authorization from NOAA for the offshore cable from the turbines to cross the sanctuary, as the authors acknowledge. The National Marine Sanctuaries Act requires agencies whose actions are "likely to destroy, cause the loss of, or injure a sanctuary resource" to consult with the marine sanctuary program before taking such action. The program is then required to recommend reasonable alternatives to protect sanctuary resources. In other words, if cables proposed to run from offshore wind platforms to an onshore substation might impact critical sea otter habitat, oversight by a marine sanctuary will result in optimal placement.

The Biden administration has stated that moving the Chumash Heritage National Marine Sanctuary designation forward along with offshore wind energy development are "important and complementary goals." Per Secretary of Commerce Gina Raimondo, "Proposals like the Chumash Heritage sanctuary and Morro Bay 399 Area are great examples of how we can advance these goals in conjunction with each other."

"On California's Central Coast, we have a chance to both harness the wind energy potential of our ocean and better protect the area's extraordinary natural and cultural heritage," said Gina McCarthy, national climate advisor. "To tackle the climate crisis we must—and we will—move ahead simultaneously with conservation and smartly sited clean energy production."

The Chumash Heritage National Marine Sanctuary will assist in achieving those goals. Holistic ecosystem-based management is the foundation of all national marine sanctuaries. Refraining from carve-outs, cutbacks, or exclusions from the sanctuary area and its regulations will ensure the success of both conservation efforts and the smart siting of wind energy production.

For offshore wind developers and everyone else, that's a good thing. Δ

Andrew Christie is the director of the Sierra Club's Santa Lucia Chapter. Send comments for publication to [email protected].