Last July, the U.S. Coast Guard announced the start of a Port Access Route Study (PARS) along the entire U.S. Pacific Coast (PacPARS). This is the first such all-encompassing Pacific Ocean study, although regional PARS were done in the past.
There have been two recent important study developments. One, expected and procedural, was the close of the public comment period on Jan. 25. The Coast Guard received comments from 52 individuals and organizations. The comments present the top challenges and concerns, at least on the public side, that the USCG must confront as it starts the next phase of the study.
The second development is something of a showstopper. On Feb. 25, the USCG announced a big change within PacPARS: that USCG District 11—which encompasses California, Arizona, Nevada, and Utah—would place four areas under the magnifying glass.
District Eleven’s focus will be on vessel traffic patterns near Point Mugu and south of the Channel Islands in the Pacific Missile Range, the San Francisco Bay, Humboldt Bay and Morro Bay.
Humboldt Bay and Morro Bay are the offshore Wind Energy Areas (WEAs) identified by the Bureau of Ocean Energy Management (BOEM). Many people wonder: How long will Humboldt Bay and Morro Bay steer in circles, always trimming their sails, waiting for a process that’s admirably deliberative but very slow? The USCG writes that PacPARS will take several years to complete. That does not sync with offshore wind which demands answers ASAP in order to establish at least the broad parameters for projects to proceed.
In its new notice, the Coast Guard writes that the four focus areas are “high-interest zones for traffic congestion and safety.” The USCG writes that the study is to “proceed expeditiously” to completion. That reference to timeliness is not part of the original Notice. District 11’s work may take three to six months. Public comments are due by May 26.
The updated, expanded focus will be on safety concerns and vessel transits. Upcoming recommendations could address vessel-routing measures, vessel separation, precautionary zones and inform “other agencies concerning the impacts of their future endeavors.”
A paramount concern for the USCG, across the entire Pacific study area, is the ability to manage new and diverse ocean-based demands, from wind and offshore energy to aquaculture to marine wildlife sanctuaries, yet still maintain the paramount right of navigation over all other uses.
In the original PacPARS announcement, the Coast Guard asked for comments on nine broad questions. Topics included navigational hazards, vessel-routing measures and possible changes, challenges today within certain areas and transit routes and future challenges from new ocean developments.
District 11’s new focus follows that same approach, presenting general questions about the four sub-areas and then specific questions pertaining to Point Mugu and the WEAs.
It’s no surprise that fishery interests weighed in on PacPARS. It’s also not surprising that many fishery comments directly reference offshore wind, even before District 11’s new spotlight. For many fishers, wind and the WEAs are the only issues.
The Pacific Coast Federation of Fishermen’s Associations highlights two emerging concerns: Aquaculture Opportunity Areas in the Southern California Bight and “the placement of large scale, industrial offshore wind-energy facilities.” It’s not just facility placement. Concerns arise from related operations. In response to a USCG question about navigational hazards, the association writes that “presently, other vessel traffic is the primary navigational hazard.” Fiber optic cable operations in fishing areas, for example, resulted in a recent entanglement and the loss of fishing gear.
In the future, the association wrote, “we suspect these interactions will increase in frequency and severity as new users of the ocean space (offshore renewables) and increased activity with current users (aquaculture) take place in fishing grounds.”
Another off-shore wind concern stems from inadequate port facilities near the WEAs. Construction and support vessels will likely need to make use of Port Hueneme, Los Angeles/Long Beach or San Francisco, resulting in increased traffic. The association references a 2005 USCG study of Humboldt Bay.
“Because Humboldt Bay has a breaking bar, a narrow entrance channel and no general anchorages within the bay, transits of this area present significant hazards to vessels carrying oil or hazardous material as cargo,” the Coast Guard wrote. Off-shore wind turbines may not be deemed hazardous cargo, but the Humboldt Bay bar still presents safety issues.
The Alliance of Communities for Sustainable Fisheries, based in Monterey, is a regional group that works to represent fishing interests in state and federal processes.
Their comments make passing reference to a broad range of concerns. But wind is at the top. They cite many issues, including:
- Large vessel traffic will need to avoid a wind project site, possibly containing up to 350 floating turbines. That will displace tow boats and barges which transit nearby. Displacement will present safety concerns and will “effectively further limit—beyond the footprint of the wind farms – fishing area(s),” the alliance writes.
- Shifting traffic must avoid the Monterey Bay National Marine Sanctuary, a move that would place vessel operations upwind of the WEAs. In an emergency, a powerless vessel could drift into a floating turbine. “Given the distance from shore, in excess of 30 (nautical miles), it will take shore-based rescue vessels hours to reach a stricken vessel,” the alliance comments, while adding, “accidents involving multiple turbines could endanger the state’s power grid.”
- The alliance cites concerns that “conventional marine radars do not work well inside or near the turbines.” They request that the Bureau of Ocean Energy Management (BOEM) or wind developers provide “modern technology, such as pulse-compression radar.”
- The alliance seeks two nautical-mile transit lanes for small vessel traffic in off-shore wind lease planning and establishing the lanes prior to project bidding so that the lanes do not end up in leased areas.
- In a final comment, and highlighted in bold text, the alliance recommends “that serious consideration be given to the option of limiting the size of (off-shore wind) leased areas to allow large vessel traffic to flow in its established routes.”
Tom Hafer, president of the Morro Bay Commercial Fishermen’s Organization, presents similar comments. Like the alliance, wind is his singular focus – he doesn’t cite any other PacPARS issues.
Vessels caught north of the WEA in rough weather, Hafer writes, or with power issues that require a quick return home, will have to travel through the WEA rather than go around, an extremely hazardous transit at night or in fog. Hafer also writes that “radar is rendered ineffective in a WEA” because of false targets and interference caused by the blades of the wind turbines” and that the fishing fleet should be outfitted with pulse compression radars.
Morro Bay fishers want a four nautical-mile wide corridor. Hafer points out that “we are between San Francisco and Los Angeles harbors with multiple large barges, ships, tugs and tows traveling across our waters.” Furthermore, “we will need the corridors well lighted on both sides like a runway thru the WEA and a similar lighted corridor to go around the WEA.”
Finally, Hafer seeks corridors for the WEA Service Operation Vessels (SOV). “We need to know where we can safely set our gear,” he writes. “It is very important that these corridors are decided before BOEM leases the area, otherwise there will be issues with wind companies not wanting to share their area.”
The issue of wind turbine impacts on radar was given new urgency on Feb. 22 when the National Academy of Sciences released a report “Wind Turbine Generator Impacts on Marine Vessel Radar.” The academy writes that turbines clutter an operator’s display, “leading to complications in navigation decision-making.” This work was on fixed turbines, not floating turbines, as planned in California.
The degree and specificity of advance planning highlights some important distinctions between fishers and other wind interests. Importantly, a WEA is an area or territory, not a project. A WEA is where project planning starts. Its status does not set directives.
Consider, for example, related concerns raised by the American Clean Power Association (ACP), a trade group that works to advance renewable energy; the American Wind Energy Association became part of ACP in January 2021.
In its comments to the USCG, the association clearly states that “navigation safety is a priority of the U.S. offshore wind industry. ACP and our members strongly believe that offshore wind in the U.S. can be constructed and operated in ways that are compatible with mariner safety and safe vessel navigation.”
ACP writes that maritime safety, across all operations, from fishing to transit lanes, has already been part of BOEM’s up-front WEA planning process, work that included Coast Guard participation. In the Morro Bay area, for example, ACP notes that BOEM analyzed vessel data, using USCG information, to determine vessel traffic patterns and identify how they may conflict with potential offshore wind energy development.
In effect, then, this advance planning already filtered the flaws that would doom a project in a certain location. The WEAs wouldn’t have been established if conflicts and challenges had been deemed unresolvable.
ACP writes that there is still work to be done regarding vessel traffic issues. These can be resolved, however, through individual project Navigation Safety Risk Assessments, construction and operation plans and conditional requirements. The association urges the USCG to “avoid imposing measures or making recommendations that negatively impact existing WEAs,” which have already passed a critical review.
The association opposes a uniform recommendation for a 2 nautical-mile buffer between turbines and traffic lanes. Rather, it supports “the evaluation of navigation risks at the project level on a case-by-case basis to allow for safe transit.” ACP cites the USCG’s own work in a New York port access route study: “There is no international standard that specifies minimum distances between shipping routes and fixed structures.” The comments also point to successful European projects. “These wind farms have not created navigation hazards,” according to the association.
The Coast Guard was asked about an update for PacPARS’ completion, given District 11’s corollary work. Lt. Cmdr. Sara Conrad, spokesperson for PacPARS, in an email reply, referenced “overlapping projects” and an effort to “ensure aligned progress.” To that end, Conrad says the USCG plans to publish a preliminary PacPARS study that is “commensurate” with demands set by other project timelines.
Tom Ewing is a freelance writer specializing in energy, environmental and related regulatory issues.