CALL TO ACTION:
Friday, July 5th at 5:00 p.m is the last day to submit wirren comments on the Coastal Development Permit for Atlas wind.
Please consider submitting written comments as well as signing up for verbal comments.
You are encouraged to register to speak at the meeting on Friday, July 12th but also strongly encouraged to submit written comments on this item by the end of day - July 5th.
Submit written comments by going to www.coastal.ca.gov
Click on Monthly Meeting Agenda, go to Friday July 12, 2024 and scroll down to Item 9a - Application No. 9-24-0411 (Atlas Wind US LLC, San Luis Obispo Co.) and hit the “Submit Comment” button. Provide your input on the overall issue of site surveys and/or the concerns with this being a de minimis waiver. Written comments need to be submitted by 5p on Friday July 5th.
Here is a draft letter to help you in writing your comments.
Dear California Coastal Commissioners and Staff,
I am writing to voice my deep concern about the staff report advocating for approval of a Coastal Development Permit (CDP) for Equinor/Atlas Wind to conduct HRG surveying in state and nearshore waters off the Central Coast.
In general, the report was short, superficial, and wholly inadequate for approval of a project of this magnitude, importance and level of potential impacts, only 32 pages. In contrast, the 2012 Staff report for PG&E seismic surveys was 406 pages and included extensive research on local biology and cultural resources, geology, soils, public safety, land use and recreation impacts, traffic and transportation issues, and commercial fishing. Information about socioeconomic effects, and a mitigation and monitoring program included in the 2012 report are similarly absent in the current document. Also missing are underwater noise assessment reports, a larval mortality modeling report, and a proposed long-term fish monitoring program and acoustic surveys with nearshore geophones. The current Atlas Wind CDP report excludes most of those topics and, when mentioned, few details are provided. Incredibly, the report does not even provide a list of threatened or endangered species in the area.
Furthermore, the report indicates that there is no requirement for a new CEQA review and that use of an outdated 2014 CEQA document is sufficient. Meanwhile, there is growing public concern about the rush to permit offshore wind energy development, and cutting corners like this will further erode public trust in the process, and in the regulatory bodies themselves.
The Staff report cherry picks newspaper articles, research data, and personal conversations to make biased conclusions in favor of Atlas Wind. For example, while the report cites Dr. Arthur Popper as an expert who backs up their claims that HRG surveying is safe, it fails to include the fact that Dr. Popper also points to many information gaps, including the reality that impacts of HRG surveys on fish in the Pacific Ocean have never been studied, and so he cannot state conclusively that there will be no impacts. Most importantly, Dr. Popper reveals that loud sounds (powerful vibrations) outside the hearing range of animals, can cause tissue damage, even when inaudible to the animal. Vulnerable life forms include zooplankton, krill and larva which form the base of the food chain and upon which all other marine life depends. Even small impacts to this system can have wide reaching detrimental consequences on whole ecosystems, including those affecting endangered whales and sea turtles. It is imperative that the potential for such impacts be studied prior to the commencement of surveys, and not be ignored in favor of expediting the process. In fact, why are you permitting surveying at all prior to the adoption of “best practices” for this activity as previously required by the CCC?
Biological monitoring studies should be established before any further survey work is done. Independent acoustic monitoring must be required to keep to wind energy companies honest and to ensure compliance with all limits and regulations designed to protect marine mammals.
We were disappointed that the Staff report does not take into consideration the mass mortality events of hundreds of whales and thousands of other cetaceans on the East Coast that coincide with location and time of HRG surveys. Sadly, it seems negative data from offshore wind development is restricted from public review and legitimate analysis.
While I have serious concerns about the staff report as described above, I am grateful that site assessment activities will be prohibited around Diablo Canyon/Point Buchon MPA as well as near the mouth of the Morro Bay Estuary. However, the cable landing site now being promoted is in a very popular destination area between Morro Bay and Cayucos known as “Dog Beach”. Hundreds of people visit this location daily as one place where they can let their dogs off leash to play, swim and walk on the beach. It is also very close to residences in Cayucos and the Morro Bay. High decibel sound is dangerous. High Voltage DC cables are dangerous. Jet plowing that will be needed to bury the high voltage cables is dangerous as it resuspends toxic metals contaminating the water. Why is there is no mention of public safety in the report? Do you intend to cut this beach off from public access temporarily during construction, or even permanently?
I urge you to recommend that this action be denied, due to the high level of potential harms, or at least deferred, until a more thorough analysis is conducted on the potential impacts. If this CPD is approved, it will appear that the CCC is rushing the permit to appease wind developers to the detriment of the people, animals, and environment that the Commission is entrusted to protect.
Thank you for your time and attention.
Sincerely