Sunday, August 19, 2007
Surfrider Files Motion on Proposed Florence Wave Park
On Aug 13, Surfrider filed a Motion of Intervention with the Federal Energy Regulatory Commission (FERC) on the proposed wave energy project off the Florence South Jetty. The motion is an administrative action that will secure "party" status for Surfrider in the permitting process. Surfrider is not opposed to wave energy development in Oregon and we recognize the value of renewable energy. However, there are some unique concerns regarding this particular project, including the proposed location and form of technology. In short, the goal of the motion is to position our local membership to have a greater influence in how permitting process moves forward. To read full motion, see first comment to this post.
Comments:
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UNITED STATES OF AMERICA
FEDERAL ENERGY REGULATORY COMMISSION
Project No. 12793-000
RE: Energetech America LLC)
SURFRIDER FOUNDATION’S
MOTION TO INTERVENE IN THE FLORENCE WAVE PARK PROJECT LICENSING PROCEEDING
I. Introduction
On April 16, 2007, Energetech America LLC (“Energetech”) filed a Preliminary Permit Application with the Federal Energy Regulatory Commission (FERC) for the Florence Wave Park Project (FERC No. 12793-000). On June 14, 2007, FERC issued a Notice of Application Accepted for Filing and Soliciting Motions to Intervene, Protests, and Comments regarding the preliminary permit application for the “Florence Wave Park Project”, to be located in the Pacific Ocean about 1 to 2.9 miles offshore Florence in Lane County, Oregon. The Notice established a deadline of August 13, 2007, for filing motions to intervene. In accordance with Rule 214 of FERC’s Rules of Practice and Procedure, 18 C.F.R. § 385.214, Surfrider Foundation hereby moves to intervene in Energetech America’s application for a preliminary permit.
II. Motion to Intervene
A. Statement of Interest
The Surfrider Foundation (“Surfrider”) is a 501(c)3 non-profit environmental organization dedicated to the protection and enjoyment of the world's oceans, waves and beaches for all people, through conservation, activism, research and education. As a grassroots organization, Surfrider’s efforts include promoting the right of low-impact, free and open access to the coastal environment. Surfrider Foundation is represented by over 50,000 members in the United States, including 721 members in the State of Oregon.
The project site and surrounding area proposed by Energetech is regularly used by Surfrider Foundation members for a variety of activities including surfing, diving, fishing, kayaking, beachcombing, and aesthetic enjoyment. Surfrider members are likely to be negatively impacted by the project through diminished aesthetics, recreational opportunities, environmental quality, and public safety. Surfrider is concerned about any wave energy proposals, and the potential impacts to ocean recreation, nearshore ecology, public safety, aesthetic and fishing access. (See Surfrider Foundation’s Statement on Wave Energy in Oregon at “Attachment A”). Surfrider Foundation will work to ensure that any wave energy proposals contain sufficient protection and, if necessary, mitigation measures. Surfrider has a considerable interest in the protection of the coastal resources that may be affected by this project.
B. Grounds for Intervention
Surfrider Foundation’s intervention in Energetech America’s preliminary permit application process is in the public interest as required by 18 C.F.R. § 385.214(b)(2)(iii). No other party in the proceeding will be able to adequately protect the interests of surfers, divers, recreational fishermen, kayakers, beachcombers, and other members of the public who use and enjoy the proposed project site and surrounding area. Accordingly, Surfrider Foundation has a direct and substantial legal interest in the outcome of this preliminary permit application process.
C. Statement of Position
The proposed project site for the Florence Wave Park Project is located within a major hub for ocean recreation in western Lane County. Surfers, divers, fishermen, kayakers, and beachcombers alike consider the South Jetty area to be a special place that contributes to their happiness and quality of life. This area is an oasis for ocean recreation on a long stretch of sandy beach coastline. The proposed project sight is directly in the path of southwest to west swells that produce the best waves for this area. The attenuation of wave height and severe alteration of natural aesthetics may negatively impact the South Jetty experience for traveling tourists, as well as local residents who choose to live in the area because of this natural resource.
The project may also result in significant environmental impacts. The installation of wave energy platforms and anchoring cables may interfere or entangle grey whales that migrate along Oregon’s coastline. The extraction of wave energy may alter sediment transport, thereby impacting both beach geomorphology and related ecology. Finally, the potential impact of electromagnetic fields (EMF) on the behavior of salmonids, sharks, mammals, and other marine life remains unknown. All of these environmental impacts raise legal concerns in that they may cause violations of the Clean Water Act, codified at 33 USC §§ 1251 et seq., the Coastal Zone Management Act, codified at 33 U.S.C. § 1451 et seq., and the Endangered Species Act, codified at 16 USC §§ 1531 et seq., as well as Oregon state environmental protection laws.
The project may also produce negative economic impacts. The project area indicated in the preliminary permit encompasses important crabbing grounds used by commercial fishermen from Florence, Newport, and other ports. The area is also regularly used by recreational salmon fishers and crabbers who are significant contributors to the local economy. Additionally, a number of small businesses in Florence benefit from the beauty of the surrounding environment, including those businesses that cater to recreational, cultural, and tourism activities. Establishing a wave energy park would marginalize some of Florence’s best attributes, and in the process reduce the related economic benefits.
Finally, the Florence Wave Park Project may pose a threat to public safety. While the applicant has stated that wave energy platforms will be engineered to withstand a 100 year event, data from buoys off the central Oregon coast show that significant wave heights have markedly increased over the past twenty years. Given current uncertainties related to climate variability, it is unclear whether the engineering standards for platforms –which weigh an estimated 300 metric tons - would be sufficient to adequately protect the safety of local residents and visitors.
Surfrider Foundation will be seeking appropriate license conditions and will oppose any license that does not adequately address the above stated concerns. Surfrider Foundation wishes to be informed regarding progress reports or any other filings by the preliminary permit applicant. This includes being added to all official service and mailing lists regarding the aforementioned preliminary permit application. Please send such information to the following contacts:
Gus Gates
240 Rhododendron Drive
Florence, OR 97439
Pete Stauffer
PO Box 550
Port Orford, OR 97465
III. Conclusion
Surfrider Foundation represents interests not yet represented by any other party to the proceeding. Our intervention is in the public interest as required by 18 C.F.R. § 385.214(b)(2)(iii). Therefore, we respectfully request that the Commission grant this timely motion to intervene.
Respectfully submitted this 13th day of August, 2007.
_______________________________
Peter Stauffer
Surfrider Foundation
PO Box 550
Port Orford, OR 97465
(503) 887-0514
UNITED STATES OF AMERICA
FEDERAL ENERGY REGULATORY COMMISSION
CERTIFICATE OF SERVICE
I hereby certify that I have this day served the foregoing document upon each person
designated on the official service list compiled by the Secretary in this proceeding.
Dated this 13th day of August, 2007.
____________________________
Peter Stauffer
Surfrider Foundation
Attachment A:
Statement on Wave Energy in Oregon
The Oregon Chapter of Surfrider Foundation recognizes that wave energy may offer important benefits as a renewable source of energy, as well as a cutting-edge industry for coastal communities.
Surfrider also recognizes that there are many questions and concerns about wave energy, including potential impacts to ocean recreation, nearshore ecology, public safety, aesthetics, and fishing access
Statement
Surfers and other recreational ocean users are affected by the development of wave energy in Oregon, and are a key stakeholder group in local and state planning efforts.
Surfrider believes the following principles must be applied when evaluating or planning for potential projects:
• Protect surfing and other ocean recreation opportunities by ensuring that project sites do not impact or overlap with priority recreational areas
• Consider impacts to the environment through comprehensive assessments and application of best available science
• Ensure public safety through designs standards and development of emergency response plans
• Require baseline data and frequent monitoring to quantify impacts to the environment and threats to public safety
• Evaluate the impact of EMFs (electromagnetic fields) on the behavior of fishes, sharks, and marine mammals
• Consider fishing and other existing uses of proposed project areas to assess lost opportunities and evaluate trade-offs
• Proceed incrementally and cautiously to ensure that impacts from one project are understood before proceeding with additional projects
• Initiate comprehensive planning for Oregon’s ocean ecosystem to ensure an appropriate balance between emerging industrial uses and conservation
• Employ adaptive management to ensure that new information is applied to assess needs for modification, mitigation, and/or removal.
Surfrider Foundation is an environmental organization dedicated to the protection and enjoyment of the world’s oceans, waves, and beaches. Our membership in Oregon includes surfers, windsurfers, fishermen, kayakers and other ocean users.
FEDERAL ENERGY REGULATORY COMMISSION
Project No. 12793-000
RE: Energetech America LLC)
SURFRIDER FOUNDATION’S
MOTION TO INTERVENE IN THE FLORENCE WAVE PARK PROJECT LICENSING PROCEEDING
I. Introduction
On April 16, 2007, Energetech America LLC (“Energetech”) filed a Preliminary Permit Application with the Federal Energy Regulatory Commission (FERC) for the Florence Wave Park Project (FERC No. 12793-000). On June 14, 2007, FERC issued a Notice of Application Accepted for Filing and Soliciting Motions to Intervene, Protests, and Comments regarding the preliminary permit application for the “Florence Wave Park Project”, to be located in the Pacific Ocean about 1 to 2.9 miles offshore Florence in Lane County, Oregon. The Notice established a deadline of August 13, 2007, for filing motions to intervene. In accordance with Rule 214 of FERC’s Rules of Practice and Procedure, 18 C.F.R. § 385.214, Surfrider Foundation hereby moves to intervene in Energetech America’s application for a preliminary permit.
II. Motion to Intervene
A. Statement of Interest
The Surfrider Foundation (“Surfrider”) is a 501(c)3 non-profit environmental organization dedicated to the protection and enjoyment of the world's oceans, waves and beaches for all people, through conservation, activism, research and education. As a grassroots organization, Surfrider’s efforts include promoting the right of low-impact, free and open access to the coastal environment. Surfrider Foundation is represented by over 50,000 members in the United States, including 721 members in the State of Oregon.
The project site and surrounding area proposed by Energetech is regularly used by Surfrider Foundation members for a variety of activities including surfing, diving, fishing, kayaking, beachcombing, and aesthetic enjoyment. Surfrider members are likely to be negatively impacted by the project through diminished aesthetics, recreational opportunities, environmental quality, and public safety. Surfrider is concerned about any wave energy proposals, and the potential impacts to ocean recreation, nearshore ecology, public safety, aesthetic and fishing access. (See Surfrider Foundation’s Statement on Wave Energy in Oregon at “Attachment A”). Surfrider Foundation will work to ensure that any wave energy proposals contain sufficient protection and, if necessary, mitigation measures. Surfrider has a considerable interest in the protection of the coastal resources that may be affected by this project.
B. Grounds for Intervention
Surfrider Foundation’s intervention in Energetech America’s preliminary permit application process is in the public interest as required by 18 C.F.R. § 385.214(b)(2)(iii). No other party in the proceeding will be able to adequately protect the interests of surfers, divers, recreational fishermen, kayakers, beachcombers, and other members of the public who use and enjoy the proposed project site and surrounding area. Accordingly, Surfrider Foundation has a direct and substantial legal interest in the outcome of this preliminary permit application process.
C. Statement of Position
The proposed project site for the Florence Wave Park Project is located within a major hub for ocean recreation in western Lane County. Surfers, divers, fishermen, kayakers, and beachcombers alike consider the South Jetty area to be a special place that contributes to their happiness and quality of life. This area is an oasis for ocean recreation on a long stretch of sandy beach coastline. The proposed project sight is directly in the path of southwest to west swells that produce the best waves for this area. The attenuation of wave height and severe alteration of natural aesthetics may negatively impact the South Jetty experience for traveling tourists, as well as local residents who choose to live in the area because of this natural resource.
The project may also result in significant environmental impacts. The installation of wave energy platforms and anchoring cables may interfere or entangle grey whales that migrate along Oregon’s coastline. The extraction of wave energy may alter sediment transport, thereby impacting both beach geomorphology and related ecology. Finally, the potential impact of electromagnetic fields (EMF) on the behavior of salmonids, sharks, mammals, and other marine life remains unknown. All of these environmental impacts raise legal concerns in that they may cause violations of the Clean Water Act, codified at 33 USC §§ 1251 et seq., the Coastal Zone Management Act, codified at 33 U.S.C. § 1451 et seq., and the Endangered Species Act, codified at 16 USC §§ 1531 et seq., as well as Oregon state environmental protection laws.
The project may also produce negative economic impacts. The project area indicated in the preliminary permit encompasses important crabbing grounds used by commercial fishermen from Florence, Newport, and other ports. The area is also regularly used by recreational salmon fishers and crabbers who are significant contributors to the local economy. Additionally, a number of small businesses in Florence benefit from the beauty of the surrounding environment, including those businesses that cater to recreational, cultural, and tourism activities. Establishing a wave energy park would marginalize some of Florence’s best attributes, and in the process reduce the related economic benefits.
Finally, the Florence Wave Park Project may pose a threat to public safety. While the applicant has stated that wave energy platforms will be engineered to withstand a 100 year event, data from buoys off the central Oregon coast show that significant wave heights have markedly increased over the past twenty years. Given current uncertainties related to climate variability, it is unclear whether the engineering standards for platforms –which weigh an estimated 300 metric tons - would be sufficient to adequately protect the safety of local residents and visitors.
Surfrider Foundation will be seeking appropriate license conditions and will oppose any license that does not adequately address the above stated concerns. Surfrider Foundation wishes to be informed regarding progress reports or any other filings by the preliminary permit applicant. This includes being added to all official service and mailing lists regarding the aforementioned preliminary permit application. Please send such information to the following contacts:
Gus Gates
240 Rhododendron Drive
Florence, OR 97439
Pete Stauffer
PO Box 550
Port Orford, OR 97465
III. Conclusion
Surfrider Foundation represents interests not yet represented by any other party to the proceeding. Our intervention is in the public interest as required by 18 C.F.R. § 385.214(b)(2)(iii). Therefore, we respectfully request that the Commission grant this timely motion to intervene.
Respectfully submitted this 13th day of August, 2007.
_______________________________
Peter Stauffer
Surfrider Foundation
PO Box 550
Port Orford, OR 97465
(503) 887-0514
UNITED STATES OF AMERICA
FEDERAL ENERGY REGULATORY COMMISSION
CERTIFICATE OF SERVICE
I hereby certify that I have this day served the foregoing document upon each person
designated on the official service list compiled by the Secretary in this proceeding.
Dated this 13th day of August, 2007.
____________________________
Peter Stauffer
Surfrider Foundation
Attachment A:
Statement on Wave Energy in Oregon
The Oregon Chapter of Surfrider Foundation recognizes that wave energy may offer important benefits as a renewable source of energy, as well as a cutting-edge industry for coastal communities.
Surfrider also recognizes that there are many questions and concerns about wave energy, including potential impacts to ocean recreation, nearshore ecology, public safety, aesthetics, and fishing access
Statement
Surfers and other recreational ocean users are affected by the development of wave energy in Oregon, and are a key stakeholder group in local and state planning efforts.
Surfrider believes the following principles must be applied when evaluating or planning for potential projects:
• Protect surfing and other ocean recreation opportunities by ensuring that project sites do not impact or overlap with priority recreational areas
• Consider impacts to the environment through comprehensive assessments and application of best available science
• Ensure public safety through designs standards and development of emergency response plans
• Require baseline data and frequent monitoring to quantify impacts to the environment and threats to public safety
• Evaluate the impact of EMFs (electromagnetic fields) on the behavior of fishes, sharks, and marine mammals
• Consider fishing and other existing uses of proposed project areas to assess lost opportunities and evaluate trade-offs
• Proceed incrementally and cautiously to ensure that impacts from one project are understood before proceeding with additional projects
• Initiate comprehensive planning for Oregon’s ocean ecosystem to ensure an appropriate balance between emerging industrial uses and conservation
• Employ adaptive management to ensure that new information is applied to assess needs for modification, mitigation, and/or removal.
Surfrider Foundation is an environmental organization dedicated to the protection and enjoyment of the world’s oceans, waves, and beaches. Our membership in Oregon includes surfers, windsurfers, fishermen, kayakers and other ocean users.
Check out Winston Ross' recent article in the Register Guard @
https://mail.surfrider.org/exchweb/bin/redir.asp?URL=http://www.registerguard.com/news/2007/08/18/a1.waveenergy.0818.p1.php?section=cityregion
Post a Comment
https://mail.surfrider.org/exchweb/bin/redir.asp?URL=http://www.registerguard.com/news/2007/08/18/a1.waveenergy.0818.p1.php?section=cityregion
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