MAINE OFFSHORE WIND RENEWABLE ENERGY AND ECONOMIC DEVELOPMENT PROGRAM

Statement to the Maine’s Wind Energy Agency by John Krueger

Balancing the objectives of the Maine Offshore Wind Renewable Energy and Economic Development Program is no easy task. Offshore wind can indeed be a responsible means to produce needed energy as we move from fossil fuels.  My concern is that the need for Maine to develop a successful offshore wind project should not be an excuse to use state funds to industrialize Sears Island at state expense.  If truly providing sustainable energy as quickly as possible is a goal, I believe that we should be choosing a site that is readily approved by local residents, so not to be litigated for years in the courts, is placed in an area with existing expertise, does not create unnecessary environmental risk or harm, already supports rail and road access, that the levelized cost of electricity is relatively low, and that the process recognizes that this is a complex endeavor that may substantially change in time as Floating Offshore Wind Technology develops.  Mack Point may be smaller than Sears Island and not offer the largest industrial site possible for a potential industry, but taking the smaller steps forward with Mack Point that take the least risk may get us to the market place quicker.  Big visions are realized with small steps.  

I recently toured the Mack Point location and found that this site is already working with large wind development projects, the location already has rail service, is already serving essentially as a marshalling port for two large wind farms in northern  and eastern Maine, provides access by land and sea, with a new upgraded rail line.  Mack Point is essentially ready to go.  Clearly the technology for offshore wind is still going through a learning process.  There are a number of potential obstacles ahead of us.  In my opinion, Maine should not be destroying a rare location like Sears Island on the premise that we have a failsafe plan.  In this memo, I note several areas that I call “to be determined,” TBD.  Each has the potential to challenge our plans going forward and have a large effect on the choice of a marshalling port.  Before destroying an environmentally sensitive location on the grounds that we have a solution, a less environmentally sensitive location, one ready to go, may be the better choice as we figure out our final plans. 

My concern is that economic development, in particular in regards to using Sears Island as a choice for a Marshalling point, has historically been a focus in Maine’s economic industrial development community.   Wassumkeag, now known as Sears Island, has been a magnet for proposed industrial developments.  These include a nuclear power plant, an aluminum smelter, a coal-fired generator, and a liquid natural gas terminal.  Instead, Sears Island has managed to preserve the terms of a Conservation Easement managed by Maine Coast Heritage Trust.  It still supports permanent protection of environmental and cultural resources; preserves its marine, shoreland, and forest ecosystems; and encourages educational and low-impact recreational uses of the island.  Over 34,000 people and huge migrations of birds visit this island every year. 

It is important that Maine be able to act quickly in response to climate change and the need for non-fossil fuel energy.  Choosing an area for industrial development that has a long and strong history of environmental conservation and protection, particularly when there is an already alternative existent industrial site nearby does not seem to be time efficient.  The State appears more concerned with punishing the NIMBY’s than taking a route that almost everyone in the community supports. 

If one is to compare and balance economic and environmental arguments there is a need to more fully evaluate the many To-Be-Determined (TBD) aspects of this project. 

I.

One TBD is the actual Volturnus Floating Wind Technology that is guiding the technical specifications for the Marshalling Port.  Volturnus did not advance to Phase 2 of the National FLoating Offshore Wind ReadINess (FLOWIN) Prize competition.  The FLOWIN Prize is a three-phase competition designed to inspire solutions to challenges related to supply chains and large-scale deployment in the offshore wind energy industry. Teams have developed pathways to manufacture their systems for deployment in gigawatt-scale offshore wind farms. Valturnus was one of only five teams that were announced as winners of Phase One  However that was a long time ago and Volturnus is no longer considered in the top group of technologies competing in location-specific implementation pathways for manufacturing and deployment. 

The Volturnus technology that is driving the specifications for a Marshalling Port did not meet the requirements that FLOWIN believes are important: 

1.   Innovation in Design: The competition highlighted the importance of innovative designs that can withstand harsh marine environments and provide stability for floating wind turbines.

2.   Supply Chain Development: A significant lesson learned is the need to develop robust supply chains that can support the manufacturing and deployment of large-scale floating offshore wind energy systems.

3.   Manufacturing Pathways: Teams were encouraged to develop clear pathways for mass manufacturing, which is crucial for scaling up production and reducing costs.

4.   Technical Support: The provision of technical support through vouchers for national laboratories emphasizes the role of collaboration between industry and government research institutions.

5.   Environmental Considerations: Designs that minimize environmental impacts while maintaining cost-effectiveness were recognized, underscoring the balance between sustainability and economic viability.

Overall, the “winning” designs aimed to address the challenges of manufacturing and logistics gaps in the offshore wind energy industry, with a focus on achieving the goals of reducing costs and deploying gigawatt-scale floating offshore wind energy farms. The competition’s emphasis on technical support from national laboratories also indicates a commitment to ensuring that these designs are not only stable but also economically viable for mass production.  Indeed only one of the selected designs used concrete in the design.  Other designs are lighter in construction Concrete poses additional interest here in Maine as one important source of concrete is Dragon Cement in Thomaston, which is scheduled for closing.  Already concrete is being delivered to Mack Point from Turkey. Any project development must consider the Levelized Cost of Electricity of the Floating Wind technology and not be dependent upon obsolete designs. 

We all are proud of our University of Maine talents, but we should not let our biases for this important university cloud choose the best proven technology with the best Levelized Cost of Electricity. 

II.

Another significant TBD is the cost of building on Sears Island as opposed to Mack Point, owned by Sprague.  The cost and even the design of the two options both appear to be in transition.  Without providing significant data, the State has implied that the cost of a Marshalling Port on Sears Island will be less. 

After working with a marine engineering firm, Sprague proposed an alternative layout, which provides several compelling advantages over both the original Mack Point and the Sears Island plans proposed by the state’s contractor (Moffat & Nichol).  

This plan takes advantage of the studies undertaken by the state to maximize use of natural water depths reducing dredge requirements by up to 85 percent. In addition, it minimizes wetlands impact by avoiding an area of freshwater wetlands. Lastly, it reduces the risk of discovery of contaminated soil by limiting tank removal to an area of currently unused jet fuel tanks deemed clean by the Air Force prior to their divestiture of the former jet fuel yard. Contrary to misconceptions in some press reports, the Sprague Mack Point Terminal option is a viable, cost-effective solution and deserves full analysis.

From a financial perspective, the state says they already own Sears Island while they will need to pay rent at Mack Point. This assumes that rent will cause higher utility rates to Maine residents.  However, because the upfront costs to build on Mack Point would be much cheaper than Sears Island, when accounting for the decreased dredging required in the revised plan configuration, the cost of rent is no longer the limiting cost factor.  As a result, the state would be paying less in interest costs going forward assuming this project is funded with bonds. Whether at Mack Point or Sears Island, the state will need to charge project developers for the future use of the facility to fund bond repayments as do all the current state-owned facilities in southern New England. Sprague envisions a public/private partnership where it is reimbursed for its contributions via a portion of the lease fee charged to developers for no net impact to the ratepayers. 

I strongly believe that taking Public Land such as Sears Island for a very large industrial project is an example of modern day colonialism.    

III.

When balancing environmental and economic factors, the Sears Island choice appears to have the most environmental risks, once the Sprague plan with reduced dredging is factored in. 

If the wind port is built on Sears Island, more than 45 acres of upland will be cleared, graded, and compacted; 1,215,000 cubic yards of earth will be removed; and more than 17 acres of marine habitat will be filled with over 800,000 cubic yards of the harvested soil. This will destroy acres of eelgrass meadows, essential fish habitat, a fisheries nursery area, and shellfish beds. About one-third of the island will be changed forever.  The port on Sears Island would damage or destroy streams, wetlands, and terrestrial and marine habitat. 

To assemble the wind turbines, a crane that can reach nearly 800 feet tall will be permanently installed on the western shore of the island, towering over any recreational activity or educational programs currently taking place on the other side, requiring a new access road and rail line.

The facility will be lighted all night and a security fence will surround the whole operation—so visitors will no longer be able to walk around the island. Noise and traffic will dramatically increase, and the experience of being on the island will be irreparably diminished.

Sears Island is known as a top birding hotspot in Maine. Industrial development, with the accompanying noise and constant lighting on the western shore, would disturb birds’ feeding habits and interrupt their migration routes; they would most likely bypass Sears Island altogether. It would significantly diminish the public’s ability to enjoy what has become a very important recreational feature, not only for local people, but for people who come here from all over the U.S. and even from around the world. Sears Island draws people to the area who also shop in our stores, eat in our restaurants, stay in our motels and inns. 

IV.

Choosing a protected environmentally significant location will risk significant delays in construction.  Minimizing the value of environmental risk in favor of economic development is opening this project time table to significant regulatory delays. 

The length that Maine will go to tilt the balance for Economic Development over Environmental is easily shown by the recent passage of LD 2266 ,  An Act Regarding Offshore Wind Terminals Located in Coastal Sand Dune Systems.  This bill overturns EPA protections of a sand dune on Sears Island so it may be bulldozed into the ocean, along with over 1.2 million cubic yards of soil, creating a new 25-acre tarmac off of the Island to support the experimental Off-Shore Wind Manufacturing, Assembling, and Launching port. The dune formed naturally over time behind the jetty that was constructed illegally by the Maine Department of Transportation decades ago.

This is not the first time that Maine has sought to degrade environmental protection laws on Sears Island in favor of economic gain. The state’s plan to develop Sears Island into a logistical hub for future floating offshore wind facilities faces the same legal constraints that thwarted a state effort in the 1990s to transform the island into a marine terminal.

In fact, a 1996 federal consent decree won by the U.S. Environmental Protection Agency against the Maine Department of Transportation for illegally destroying wetlands on Sears Island outlines the same environmental violations the state seems determined to commit again.

In November 1996, EPA and Maine DOT signed a federal court consent decree that “permanently enjoined” Maine DOT from destroying freshwater wetlands on Sears Island. The state paid $10,000 in civil penalties plus another $700,000 in environmental mitigation.

In addition, Maine’s recent emergency approval to set aside coastal sand dunes legal protections on Sears Island appears to violate federal regulations forbidding projects in the planning process for review under the National Environmental Policy Act from making any “decisions or new commitments of resources… that would either have an adverse impact on the environment or limit the choice of reasonable alternative sites.”

V.

Another TBD determined component to this plan for a Marshalling Port is the determination of the transmission line corridor entrance at the Maine Coast.  Maine coastal properties have the highest property values and perhaps the highest standards for aesthetic values, and strong resistance to land uses inconsistent with obstructions to coastal views.  These conversations will be difficult, particularly in regards to topics like eminent domain. There is value in Maine demonstrating a process of choosing locations for development that already have the least environmental value.

In Summary

Combating climate change does not require paving over Sears Island.  Of note is the conclusion from the Intergovernmental Panel on Climate Change’s latest report that reducing conversion of intact ecosystems is far better at combating climate change than building new wind farms. Green energy projects are critically important, but they must be sited in places that don’t result in even more environmental damage.  We may be in a learning phase of development and a quicker use of an existing location and trials of multiple technologies may get us faster to the finishing line. 

Offshore wind can indeed be a responsible means to produce needed energy as we move from fossil fuels.  But let’s see offshore wind come at the right time, using the right technology, at the right place.

— John Krueger, FoHLHCA Board Member and Northport resident