It’s estimated that nearly 30 geophysical surveys now authorized by NMFS for East Coast offshore wind projects could result in as many as 109,000 harassment events for marine mammals, including a projected 243 incidents that could affect the critically endangered north Atlantic right whale.

That shows the need to “avoid, minimize, and mitigate threats that offshore wind development also poses to vulnerable ocean life,” according to the Natural Resources Defense Council, long an advocate for developing renewable energy sources including offshore wind.

The NRDC recently signed on to a 10-page statement with other environmental groups – including the Conservation Law Foundation, Defenders of Wildlife, National Wildlife Federation, NY4WHALES, the Southern Environmental Law Center and Whale and Dolphin Conservation.

The document is titled “Strong Mitigation Measures Are Essential to Protect the North Atlantic Right Whale During All Phases of Offshore Wind Energy Development.” It distills growing concerns among environmental groups, always supportive of renewable energy, that offshore wind development carries risk too.

“The seriously imperiled status of the North Atlantic right whale demands the implementation of the most stringent measures to safeguard this species during site assessment, construction, operations, and decommissioning of offshore wind energy projects,” the paper declares. “Risks from vessel collision and direct and indirect noise impacts on right whales, including potential habitat displacement that may exacerbate existing threats, need to be fully addressed from the start.

“Strong right whale protections are required to fulfill federal legal requirements for protecting marine mammals and endangered species4 and will ensure we can achieve the (Biden) administration’s commitment to deploy 30 gigawatts of offshore wind energy by 2030 while protecting biodiversity, cultural resources, and ocean uses.”

In a March 4 online posting, NRDC senior scientist Francine Kershaw wrote “we need offshore wind, and we need to do it right.”

The environmental groups are calling on NMFS and the Bureau of Ocean Energy Management to follow a policy of ‘mitigation hierarchy’ as prescribed in the National Environmental Policy Act.

That’s very close to the position that’s being taken by commercial fishing advocates, such as the Responsible Offshore Development Alliance, who argue NEPA principles have been sidelined in the federal government’s push for wind development.

BOEM and NMFS are obligated by law to do all they can to protect marine mammals, and “the agencies should follow the principles of the mitigation hierarchy and avoid, minimize, and mitigate impacts,” Kershaw wrote.

“Proven mitigation measures must be used to reduce impacts, including restricting vessel speeds to 10 knots or less to reduce the likelihood of vessel collisions, and new technologies to detect marine mammals and reduce noise emitted by the survey equipment should be used as they become available,” according to Kershaw. “The permitting process should be adaptable to reduce risks that may be identified in the future as more information on species and offshore wind development is available.”

BOEM planners and wind developers say those strategies are being included in construction and operation plans. But the environmental groups’ statement is one more sign of growing caution as the extent of BOEM’s offshore wind proposals grows.

In May 2021 similar doubts emerged from NRDC and West Coast groups with the intent of BOEM and California state officials to plan for future arrays of anchored floating turbines.

On the East Coast, the first two fully permitted projects in federal waters, Vineyard Wind and South Fork Wind off southern New England, and BOEM’s record-setting $4.37 billion sale of wind leases in the New York Bight, lie in waters frequented by a right whale population estimated at less than 340 animals.

With wind turbine arrays already planned off the New Jersey coast, the new leases farther offshore alarm some ocean activists.

“The ocean is far more valuable as an ecosystem, so we must minimize industrialization and be sure it is protective of marine life,” said Cindy Zipf, the executive director of Clean Ocean Action, a New Jersey-based group that successfully fought pollution and ocean dumping out of New York Harbor.

The group says it “supports responsible and reasonable offshore wind energy,” but called BOEM’s massive Bight lease offering “a reckless privatization, and will not ensure protection of marine life including whales, dolphins, turtles and the hundreds of other species that call the ocean home.”

During the first week of March 2022, NMFS had advisories out asking mariners to maintain slow speeds and lookouts for right whales reported in areas spanning the Northeast and Mid-Atlantic waters marked for wind energy development.

“Offshore wind will help eliminate dangerous greenhouse gas emissions, promising healthier air as well as thousands of well-paying clean energy jobs,” wrote Kershaw of NRDC. “But as we fight climate change, we can and must avoid, minimize, and mitigate threats that offshore wind development also poses to vulnerable ocean life.”

Kershaw focused largely on the potential effects of acoustic surveys used to map the sea floor in preparing for wind energy development.

“Some of the soundwaves used in geophysical surveys overlap with frequencies for marine mammal hearing, meaning they can be detected by these animals,” Kershaw wrote. “Noise exposure from geophysical surveys has the potential to damage the hearing and sensory abilities of some species if they are close to the source of the sound when it occurs.”

Another hazard is vessel collisions – a particular danger for right whales that travel and feed at the surface in low profile difficult for mariners to spot. Vessel strikes are a major factor in the right whale decline, according to whale researchers.

NMFS permits for the survey will allow some 6,300 total survey-days of geophysical activity, according to NRDC. The group proposes specific steps to reduce the hazard off the East Coast and similar measures for early planning now on the West Coast and Gulf of Mexico.

- Seasonal and temporal restrictions: surveys are to be avoided in essential habitat areas year-round or, for migratory species, during months of high use. Surveys must only start up during times of good visibility (daylight, clear weather conditions) when marine mammal presence can be sufficiently monitored.

- Observation and detection: before and during noise-producing activities, visual observers and passive acoustic monitors should both be used to look and listen for marine mammals and activate a shutdown of activities if a marine mammal is detected within a predetermined exclusion zone. Thermal detection cameras should also be used for activities extending into darkness or low-light periods.

- Vessel speed limits: vessels must maintain speeds of 10 knots or less at all times to reduce the risk and severity of collision during surveys or transiting to and from survey areas.

“These fundamental requirements are necessary to protect the critically endangered North Atlantic right whale from potential impacts posed by offshore wind energy site assessment and characterization work,” Kershaw wrote. “Many of these measures offer important benefits to other marine mammal species and sea turtles.”