Mass Audubon's Position Statement on Wind Energy Development
Summary Position Statement
Mass Audubon supports the responsible planning, permitting, and production of renewable energy resources including wind energy. We believe that renewable energy resources are essential to the environmental well being of our nation and planet. Such facilities, however, must be conditioned to minimize adverse impacts to living resources. Energy conservation and efficiency are also important components of environmentally sound energy policy.
Wind energy technology can make a significant contribution to the renewable energy supply mix. Wind farms are proposed on an unprecedented scale off the coast of Massachusetts, and several land-based projects are underway as well. As this industry evolves and expands, state and federal regulatory and planning mechanisms must also evolve to ensure that new wind energy facilities will be sited, designed, and built in an environmentally sound manner.
Potential impacts of concern in relation to wind farms include direct and indirect impacts to birds, other living resources, and their habitat. The state and federal government should undertake a coordinated planning program to guide and facilitate appropriate, fair, and orderly development of the wind energy industry in Massachusetts. A statewide plan for siting wind energy facilities should be developed, with public input, resulting in a blueprint for the development of wind energy over the next five to ten years. The geographic area of this plan should encompass all lands within the state as well as state and federal waters off the Massachusetts coast. The resulting plan should identify areas where both the wind energy is commercially viable and environmental impacts are minimized.
In addition to the statewide siting plan, criteria should be developed for more precisely evaluating the site-specific environmental impacts of projects proposed within areas generally identified as probably suitable in the statewide plan. These criteria should then be applied statewide in energy facility site permitting and other applicable regulatory processes. Similarly, standardized pre- and post-construction monitoring protocols should be established to assess wind energy project impacts on birds, other living resources, and habitat. Project permits should be conditioned to enable modification if actual bird hazards unacceptably exceed predicted risks. The statewide plan should include adaptive management mechanisms providing for monitoring of early projects to inform permitting for subsequent projects.
Existing regulatory programs address many of the environmental impact issues associated with wind energy projects. Amendments to update these regulatory programs and clarify their application to wind energy projects are needed. However, projects already in the permitting process are being processed through existing regulatory programs.
State and federal leasing programs should be developed to guide offshore wind farm development, ensure appropriate compensation to the public, and avoid unacceptable conflicts with other public interests in these public trust areas. Projects occupying public lands or waters that receive regulatory permits while leasing programs are not yet in place should be recaptured for lease payments once the leasing programs are implemented. Financial security for decommissioning of facilities should be provided to ensure they will be removed when the facility reaches the end of its useful operational period of time.
This position statement identifies measures that are needed to fill gaps in state and federal oversight, in order to promote the orderly and environmentally sound development of wind energy facilities, and to compensate for use of public trust resources. A summary of issues that need to be addressed include:
- Development of a planning framework for environmentally sound site selection
- Establishment of leasing programs for use of state and federal offshore waters
- Refinements to permitting processes
- Establishment of protocols for pre- and post-construction monitoring