Commonsense environmentalism being destroyed by ‘wind-less revolution’

The Ocean State has become ground zero for the most important environmental battle in modern times. In recent months, the offshore wind enterprise (OSW throughout) has pushed new boundaries in challenging seminal issues pertaining to our [human] health and well-being – regressing even to the point of physical violence. The current state can be described as nothing less than “divisive” and is to our own detriment — commonsense environmentalism is being destroyed.

While under pressure from the previous environmental regime, the powers-that-be have agreed that we must do something [to combat climate change], and somehow arrived at a fast track massively scaled enterprise to facilitate OSW as the solution. Yet, there is stark disagreement and opposition from lesser-heard voices as the strategy may come with unacceptable costs to the very environment we are all seeking to protect.

This divisive wedge is upending the trust we’ve all had within the institution of science, which has historically favored environmentalism — most often assumed to be based on continued hypothesis-based inquiry, commonsense parsing of observable patterns and correlations, and without bias or influence.

Obvious, however, is that unbiased marine science and the resulting traditional environmental policymaking itself is not guiding rational decision making — in the case of OSW, infused funds are directing science objectives toward facilitating furtherance of industrial objectives. This is not a new phenomenon and is not necessarily a terrible thing under all circumstances. For instance, science is conducted within industry all the time. Drug companies conduct clinical trials, goods manufacturers conduct consumer safety experiments, and food producers evaluate methods to reduce contamination, to name just a few examples. All are critically important toward advancing their respective disciplines and improving safety for all of us.

Recent reports have started to reveal the types of conflicts brought by OSW, fueling lack of public trust. One example: London’s Natural History Museum has been under fire for accepting a sponsorship contract from Orsted which contained a gag clause. The clause prohibits the museum from making any statement that might discredit the sponsor. That sounds like a reasonable business contract term, though how far does this type of gag clause extend?

Transparency is needed to discern whether associated research is then subject to being scrubbed. For instance, if an affiliated scientist studies climate change and finds that an action from which the sponsor has a vested interest (oil/gas and various renewables) is cause for a negative environmental impact, is it even allowed to be reported? And will it be reported? Or will the line of scientific inquiry even be further pursued? These types of relationships can be positive, though they are very delicate and can become problematic conflicts that impede unbiased science from running its course.

Another example, closer to home, was EnergyCentral.com’s report that “if” a certain OSW project is selected, “then” a grant will be administered to several institutions. This is not a grant or donation; it is stated very clearly as a quid pro quo to entice project approvals. The infusion has since been named the Environmental Justice Grant. Have we resigned to such blatant selling of influence? Frankly, “justice” is not needed if injustices aren’t done to begin with.

It is quite literally a whale of a problem

Well-respected scientists from intuitions in receipt of these funding infusions are quoted repeatedly [in reference to increasing whale mortality since OSW inception] stating “there is no scientific basis for any of the stuff we’ve been hearing over the last year or two.” This is carefully crafted conjecture and sows great confusion — these same scientists co-authored one of the most comprehensive documents on the subject, long before OSW existed, establishing that marine mammals are well known to be impacted by anthropogenically generated noise and further study is required.

Here at OSW ground zero, researchers from the same institution said “it’s cheaper to pay professors and graduate students than to hire consultants.” This is a correct statement, and a great pitch to a for-profit enterprise when you are a state university in need of funds, as they all are. Consequently, the OSW work occurring off Rhode Island is based on academic data acquisition, not its independent analysis by an unbiased third-party consultant, which is always the case in these infrastructure programs. In hindsight it is an obvious conflict of interest, and the recurring promise of additional money is doing the talking.

While no one can fault a creative means to fundraise, the public needs to understand the conflicts that may arise. Here, it is a very dire situation — the commonsense environmentalism that comes from compassion for the environment is missing — we’re now left with business transactions to guide environmental policy. OSW is a heartless enterprise capitalizing on the concerns for climate change without adequate due diligence, forcing environmental powerhouses to remain silent, and leaving no room for compassionate intent.

I will spare the biology lesson, but it is all about middle-school level understanding of acoustics — sound travels very fast and far through water, and we also know that numerous marine species are dependent on sound for numerous aspects of their livelihood; these animals navigate the vastness of the oceans (often in conditions where vision is not useful) to hone in on each other, to attract mates, to give birth in opportune areas, to find food, to evade physical strikes against underwater mountains and other natural structures, and even avoid unnatural structures such as ships and ghost fishing gear. When their ability to navigate becomes compromised, there are injuries and deaths.

The permitting agencies for these projects already well recognize this as fact. For instance, NOAA’s National Marine Fisheries Service (NMFS) is tasked with issuing Incidental Take Authorizations (ITAs), which represent variances to the Marine Mammal Protection Act (MMPA). “Take” is defined under the MMPA as “to harass, hunt, capture, or kill, or attempt to harass, hunt, capture, or kill any marine mammal.”

Huh?

Yes, permits are issued that allow mammal harassment. NMFS explicitly states that “Most incidental take authorizations have been issued for activities that produce underwater sound.” For just one of the projects in question, Revolution Wind, the permitted harassment accounts for numerous thousands of marine mammals.

Consequently, and by no surprise, there have been an increasing number of whale deaths since OSW has started, and with statistically significant correlations to noise-making activities. We all agree that correlation does not mean causation. However, scientists’ jobs are to study correlations. One hypothesis requiring study is that these mortality events are caused by natural events, or other stressors. Though the null hypothesis must also be considered — that dismissive opinions have forgone commonsense environmentalism because of gag clauses. An open question, and of great concern — are there any institutions with the capacity to properly parse out this correlation that are not engaged in conflicted relationships? Even some of the most respected scientists in the world have been quick to jump to the increase in whale mortality being the result of “vessel strikes,” without further analysis. Yes, this makes perfect sense — as we say “a deaf whale is a dead whale” and it is this root cause that desperately needs a closer look.

The public is dependent on science and educational institutions for disseminating scientific information. Here in the U.S., the Mystic Aquarium has been challenged when one recent humpback whale necropsy on Block Island was not performed completely “due to its remote location,” yet images circulated on social media of families with young children taking selfies with this deceased animal — it was not that difficult to access. Mystic has received funds from Orsted to study the impacts of their OSW activities on whale deaths, presenting one of these conflicts needing to be more transparent. The funds also supported the development of a public exhibit endorsing OSW. It is unclear if a gag clause is in place, like the British Museum.

In response to this whale fatality, a  Mystic researcher was quoted as saying “Since 2016, only 11 dead humpback whales have been found in Rhode Island waters.” “Only” requires some context. The entire population of humpback whales within the western North Atlantic is around 13,000 animals, and 11/13,000 is 0.085% of the entire population. For comparison, “only” 0.087% of the world’s population was killed from COVID-19 — about 7 million people. Look at the panic that ensued. I’d argue that whales are just as important (probably more important) as humans to make the world turn.

The criticism OSW has drawn is a consequence of its own very narrow field of view — as some heroic measure and our only hope to save the planet. Will windmills magically change Earth’s climate in a few decades, undoing two centuries of anthropogenic industrial impacts? Absolutely not. So then, at what cost is it worth it, and who really benefits? If it is not the environment, it’s simply a new vehicle to move money as some “Blue Economy.”

The whales aren’t alone — science is easy prey

Each OSW project also weighs impacts to endangered species via a biological opinion. The document for Revolution Wind comes in at an overwhelming 657 pages. Referenced are 15 endangered or threatened species (according to the U.S. Endangered Species Act) which are unlikely to be impacted by the project. One of which is the Nassau grouper which does not live within 2,000 miles of the project location. We all love grouper, and I’m glad it got a nod. Thereafter the document references 11 endangered species which may be directly impacted, including a variety of whales and turtles.

The glaring omission, and it’s a serious one, is virtually no reference to sharks, tuna, billfish, swordfish — migratory species. NOAA has an entire program for managing these species, and there is no analysis from this group. Many of the sharks we have here in Rhode Island (more than a dozen species) are listed under various threat levels — vulnerable, threatened, endangered — and are subject to domestic and international fisheries management regulations. Sharks are known to be sensitive to low frequency sound and to electrical impulses, leaving a gap in the discussion of EMF from the subsea cables.

Confusing throughout these environmental impact and biological opinion presentations is that the laypersons’ definition of endangered or threatened is different than the federal government’s definition. The Biological Opinion references only those on the formal ESA list; though this is not the global standard. The Red List maintained by the International Union for the Conservation of Nature (IUCN) is what a school-aged child would reference when tasked with researching an endangered species.

Important to note is that IUCN data does not necessarily align with federally protected status for any given country – the law of the land is always slower going. A Red List query of those endangered, threatened, vulnerable, or data-deficient within the Rhode Island marine environment revealed a list of 192 species. That’s a delta of 181 species. Curiously, both the Bureau of Ocean Energy Management and NOAA are IUCN member organizations. So, while a biological opinion may be written to the letter of the law according to the ESA, the omission of 181 species, even by reference for consideration is disingenuous if not unethical.

Who is responsible for monitoring the ongoing and recurring impacts to these 192 species, and cumulative impacts across multiple projects? Well, no one, and it’s unlikely the ESA will be amended very quickly. It’s a process requiring a lifelong commitment from someone wanting to champion the given species. Just one example is the Atlantic horseshoe crab. The horseshoe crab is referenced by the IUCN, and popularly considered to be endangered, though is not on the ESA list despite its being petitioned for review in 2023.

Consequently, the horseshoe crab is not referenced in the biological opinion document and will indeed suffer impacts from Revolution Wind. Horseshoe crabs are reasonably common within Narragansett Bay and will undoubtedly see habitat disruptions when trenching for cable placement. Who cares about horseshoe crabs? Well, you should. They’re among the most important marine species exploited to benefit human health, providing a natural source for proteins used to verify sterility of medications and medical devices — supporting more than a $100 million market. Impacts from OSW? Not a mention, but rest assured, your blackened grouper sandwich is safe.

Justification for ocean-related study and ultimate preservation all comes from the underlying acceptance that it is a critical resource to us — our lives depend on a healthy ocean — this is indisputable. The ocean is the world’s largest carbon sink, largest oxygen producer, and provides us with everything from food to medicine. So, leave it alone. Protect it. Don’t turn it into a construction site with unknown long-term consequences, all while hiding behind the letter of the law which will never keep up with reality.

All one must do is spend a brief time within inshore ports and harbors, where I spent the first 20 years of my career, to see how human industrial processes impact the natural environment. This critical interface of land and water should be fenced off — this is where border patrol is most needed. Industrialization reaching beyond these gates will just continue to drag the garbage, quite literally, along with us.

A mind-bending reality is that the overwhelming majority of those who study or otherwise make a living in marine-related fields have never experienced being out on or underwater firsthand. I can assure you with great confidence that there are no armies of scientists underwater at these OSW sites, certainly with no routine frequency. Data is acquired with sensors and robotics. It’s important and useful data but omits “the human element” — it is compassionless data, and therefore not reflecting the true value of the space and its inhabitants to decision-makers. Absent consideration for that value, we are selling the ocean way short, and consequently continuing to work in spite of our own well-being. This needs to change.

Humans are only compassionate toward what we understand, and frequently only understand what we intimately experience. In my own line of work as a diver, I consider it a gift to see and experience what I do every day, even when doing the most mundane of tasks observations are made, questions asked, scientific inquiry catalyzed, and most importantly, a compassionate position reinforced.

When considered from this direct personal interpretation of ocean space, it is a distinct impossibility that an industrialized process out on the ocean is without negative impacts. So, is the net impact to our benefit or to our detriment? That cannot be answered in metrics of carbon dioxide reduction. It cannot be answered with metrics of displaced fisheries; it cannot be answered with financial commitments to mitigation activities [mitigating environmental damage caused]. It can only be answered with deep personal reflection on what kind of world we want to live in. In my sincerest and most professional opinion, the answer will only come when considering compassion for the environment and its inhabitants, as it is not our planet. We only cohabitate.

To be blunt, “they” say there’s no impact to the whales. I say go ask the whales. I have extended an offer to any party interested in having the experience to come on out for a dive adjacent to a ship, adjacent to pile driving, adjacent to a bubble curtain, adjacent to running sonar, adjacent to a compromised power cable, adjacent to a failing physical structure. Once these things are experienced, and that experience is well conveyed and appropriately considered, then right and well-informed decisions will be made. Until then, our decisions are being made absent any common-sense environmentalism, and wholly blinded by a truly wind-less revolution.

Michael Lombardi is a Rhode Island resident and has spent in excess of 7,000 hours underwater providing services, performing scientific work, developing life-critical technologies, and taking on a variety of complex technical and social challenges throughout his 30-year career in the marine and undersea sector. His work can be found at www.oceanopportunity.com.