1. ADAPTIVE OPERATIONAL PLAN
It is not possible to anticipate all potential impacts to the environment and commercial fishing operations that might arise from offshore wind development along the northeast Atlantic shelf. Some impacts may be immediate and easily observed, while others may be more subtle and take years to manifest. A sustained monitoring and research effort will be necessary to fully understand the impacts of development.
The Commission recommends that the information obtained from these ongoing studies serve as the basis for an adaptive operational plan, in which the developer, DEEP, and other stakeholders periodically assess information gathered and make “course corrections” to mitigation efforts.4
2. MITIGATION FUND
The Commission advises that the developer commit some amount of money “up front” to a mitigation fund. This fund should be separate to the funding source used to support activities pursuant to the Adaptive Operational Plan (see above).
The mitigation fund should be used to offset economic losses or burdens to the commercial fishing industry, elements of the environment,5 and other stakeholders that arise from unavoidable impacts of offshore development. This fund should not be used in place of avoiding or minimizing impacts. Developers should follow the principle of first avoiding conflicts or impacts, then minimizing those that are unavoidable, mitigating the impacts from new development through appropriate use of communications and technology, and finally, only once those have been adhered to, considering compensation for any residual losses.
3. DECOMMISSIONING PLAN AND FUNDING
The Commission recommends that the developer provide plans for decommissioning installations at the end of their service life, including for infrastructure, such as cables, that is in state (non-federal) waters. The Commission suggests that this plan include information on procedure for decommissioning and intended state of the installation site after decommissioning is complete. Developers should also identify the source of funding for decommissioning and provide assurances as possible that this funding will be available at the time of decommissioning.
4. WILDLIFE RISKS
The Commission recognizes that proposals will be in various stages of completion. It is therefore important that the application contain three main components. These components are an Assessment and Monitoring Plan, an Avoidance and Mitigation Plan, and a Data Reference and Sharing Plan.
4.1 Assessment and Monitoring Plan
The Commission recommends that developers consult with experts to provide a site-specific inventory including all species at risk of impact that could reasonably be expected to be present at the development site. The developer should also plan for inventory and monitoring where it doesn’t currently exist for these species.
4.2 Avoidance and Mitigation Plan
The Commission recommends, for each species grouping, that the developer provide information on a plan to anticipate and avoid risks to species arising from each stage of offshore development (pre- construction, construction, operational, transitional, and decommissioning), and all locations where project activities will occur including, but not limited, to interconnection, transmission, and turbine locations.
5. HAZARDS TO NAVIGATION, SAFETY AT SEA, AND INTERFERENCE WITH FISHING OPERATIONS
Installation of wind turbines in offshore areas transited by commercial fishermen has the potential to pose serious hazards to navigation and safety, and may also interfere with deployment of certain fishing gears. The Commission encourages the bidder to present an assessment of potential hazards and measures that will be taken to minimize those hazards.