BOEM and NOAA Fisheries
North Atlantic Right Whale and Offshore Wind Strategy

January 2024

U.S. Department of the Interior
Bureau of Ocean Energy Management

U.S. Department of Commerce
National Oceanic and Atmospheric Administration
NOAA Fisheries

Front Cover Photo Credits:[top] An adult and juvenile North Atlantic right whale seen in the Great South Channel in 2016. Image collected under MMPA
permit # 17355. NOAA/NEFSC/Allison Henry. [bottom] A North Atlantic right whale seen near the Block Island Wind Farm in
January 2023. Image collected under MMPA permit # 21482. Amy Engelhaupt/HDR.

Table of Contents
List of Figures ....................................................................................................................................... ii
Acronyms and Abbreviations .............................................................................................................. iii
1

Summary ....................................................................................................................................... 1

2

Issue Description ........................................................................................................................... 2
2.1
Background ................................................................................................................................... 2
2.2
BOEM & NOAA Fisheries’ Missions and Responsibilities .............................................................. 4
2.3
Status of the NARW ...................................................................................................................... 7
2.4
Intersection of NARWs and OSW .................................................................................................. 9
2.5
NARW and OSW Research and Monitoring Efforts..................................................................... 14

3

Strategy Framework .................................................................................................................... 16
3.1
Background ................................................................................................................................. 16
3.2
Strategy Goals and Objectives .................................................................................................... 17
3.3
Implementation and Timeline..................................................................................................... 23
3.4
Priority Actions ............................................................................................................................ 24

4

Partners ....................................................................................................................................... 26
4.1
4.2
4.3
4.4

5

Government ................................................................................................................................ 26
Industries .................................................................................................................................... 28
Academia/Research Organizations ............................................................................................. 29
Non-Governmental Organizations .............................................................................................. 29

Financial Resources...................................................................................................................... 30

APPENDIX A: NARW and OSW Strategy Action Plan Details ................................................................. 32
APPENDIX B: Avoidance and Minimization Measures .......................................................................... 41
APPENDIX C: Potential Actions to be Further Developed by the Agencies During Implementation of theStrategy ....................................................................................................................................... 51
APPENDIX D: Monthly Densities of North Atlantic Right Whales in U.S. Waters (2010–2019) ................ 53
APPENDIX E: References ..................................................................................................................... 66

BOEM and NOAA Fisheries North Atlantic Right Whale and Offshore Wind Strategy|iList of Figures
Figure 1a. Status of OSW activity overlaid on mean annual density of NARWs off the northeast UnitedStates (2010–2019) ..................................................................................................................................... 10
Figure 1b. Status of OSW activity overlaid on mean annual density of NARWs off the southeast UnitedStates (2010–2019) ..................................................................................................................................... 11
Figure D-1. Density of NARWs in U.S. waters during the month of January (2010–2019) ......................... 54
Figure D-2. Density of NARWs in U.S. waters during the month of February (2010–2019) ....................... 55
Figure D-3. Density of NARWs in U.S. waters during the month of March (2010–2019) ........................... 56
Figure D-4. Density of NARWs in U.S. waters during the month of April (2010–2019) .............................. 57
Figure D-5. Density of NARWs in U.S. waters during the month of May (2010–2019) .............................. 58
Figure D-6. Density of NARWs in U.S. waters during the month of June (2010–2019) .............................. 59
Figure D-7. Density of NARWs in U.S. waters during the month of July (2010–2019) ............................... 60
Figure D-8. Density of NARWs in U.S. waters during the month of August (2010–2019) .......................... 61
Figure D-9. Density of NARWs in U.S. waters during the month of September (2010–2019) ................... 62
Figure D-10. Density of NARWs in U.S. waters during the month of October (2010–2019) ...................... 63
Figure D-11. Density of NARWs in U.S. waters during the month of November (2010–2019) .................. 64
Figure D-12. Density of NARWs in U.S. waters during the month of December (2010–2019)................... 65

BOEM and NOAA Fisheries North Atlantic Right Whale and Offshore Wind Strategy| iiAcronyms and Abbreviations
ASRG

Atlantic Scientific Review Group

ATN

Animal Telemetry Network

BOEM

Bureau of Ocean Energy Management

BSEE

Bureau of Safety and Environmental Enforcement

BWRI

Blue World Research Institute, Inc.

CEQ

Council on Environmental Quality

COP

Construction and Operations PlanCZMA

Coastal Zone Management Act

DCO

Deputy Commandant for Operations

EBM

ecosystem-based management

ECP

Environmental Compliance Program

ESA

Endangered Species Act

ESP

Environmental Studies Program

GAP

General Activities Plan

GW

gigawatt

IKP

Indigenous Knowledge PlanLCP

low frequency cetaceans

MARAD

Maritime Administration

MMPA

Marine Mammal Protection Act

NARW

North Atlantic right whale

NEPA

National Environmental Policy Act

NGO

Non-Governmental Organizations

NMFS

National Marine Fisheries Service

NOAA

National Oceanic and Atmospheric Administration

NOAA Fisheries NOAA’s National Marine Fisheries Service
NOI

Notice of Intent

OCS

Outer Continental Shelf

OPR

Office of Protected Resources

OSW

offshore wind

PAM

passive acoustic monitoring

PBR

potential biological removal

PCOMS

population consequences of multiple stressors

PET

Population Evaluation Tool

POWERON

Partnership for an Offshore Wind Energy Regional Observation Network

PSO

protected species observer

BOEM and NOAA Fisheries North Atlantic Right Whale and Offshore Wind Strategy

| iii

PTS

permanent threshold shift

RAP

Research Activities Plan

RWSC

Regional Wildlife Science Collaborative for Offshore Wind

RSLL

received sound level limit

SAP

Site Assessment Plan

SFVsound field verification

TAP

Technology Assessment Program

UAV

unmanned aerial vehicle

UXO

unexploded ordinance

BOEM and NOAA Fisheries North Atlantic Right Whale and Offshore Wind Strategy| iv

1 Summary
The Bureau of Ocean Energy Management (BOEM) and the National Oceanic and Atmospheric
Administration (NOAA) Fisheries partnered to develop the North Atlantic right whale (NARW) and
offshore wind (OSW) strategy to focus and coordinate efforts related to NARW and OSW development.
In response to Executive Order 14008, Tackling the Climate Crisis at Home and Abroad, both agencies
share a common vision to protect and promote the recovery of NARWs while responsibly developing
OSW energy. This vision reflects the combined legislative mandates of the two agencies and theircommitment to developing OSW while protecting biodiversity.
This shared North Atlantic Right Whale and Offshore Wind Strategy (hereinafter called “Strategy”)
identifies a number of actions to achieve the common vision under three goals: (1) Mitigation andDecision-Support Tools; (2) Research and Monitoring; and (3) Collaboration, Communication, andOutreach. These goals and actions will allow for coordinated and efficient collaborations between
BOEM, NOAA, and our partners (including the OSW industry); collection and application of the best
available scientific information and data and insights to inform future decisions, including monitoringand mitigation programs; and implementation of effective measures to reduce risk and avoid andminimize impacts to NARWs. Immediate impact mitigation efforts include, for instance, avoiding leasing
in areas where major impacts to NARWs may occur, establishing noise limits during construction, andproviding guidance to developers on conducting robust sound field verification (for certain activities) toensure that expected impacts from OSW are not being exceeded.
The Strategy describes many potential actions for further development but does not define or require
specific policies or regulatory actions.1 A draft of this Strategy was made available for public comment in
October 2022, and the input received was taken into consideration in developing the final Strategy here.
The agencies intend to keep the Strategy as a “living” document that will be regularly evaluated andupdated as progress is made and new information becomes available. Furthermore, an interagency
implementation team will be formed to work with external partners in bringing the Strategy’s vision to
fruition.

1

This guidance document is not a rule, regulation, or other legally binding instrument, and the recommendations it contains
may not apply to a particular situation, depending on case specific facts and circumstances. Nothing in this document isintended to modify or amend any Federal statutes, regulations, permits, or leases, nor create any rights or cause of action ortrust obligation that any person or party may enforce through litigation or otherwise against the U.S. Government or any of its
employees or officers. This document is not legally enforceable. To the extent that there is any inconsistency between theprovisions of this document and any Federal statutes, regulations, leases, or permits, the statutes, regulations, leases, or
permits will control.

BOEM and NOAA Fisheries North Atlantic Right Whale and Offshore Wind Strategy|12 Issue Description
2.1

Background

Climate change poses a significant global threat, causing planet-wide physical, chemical, and biologicalchanges that substantially affect the world’s oceans, lands, and atmosphere. The most recent National
Climate Assessment puts the climate crisis in stark terms: “Without significant reductions in greenhousegas emissions, extinctions and transformative impacts on some ecosystems cannot be avoided, withvarying impacts on the economic, recreational, and subsistence activities they support” (U.S. Global
Change Research Program 2018).
To address this threat, a transition to cleaner, renewable energy is needed expeditiously and at scale(Intergovernmental Panel on Climate Change 2022). Decarbonization of the power sector, coupled withefficient electrification, can help decarbonize the transportation, building, and industrial sectors andprovide significant climate and health benefits (Donohoo-Vallett et al. 2023). In the United States, theBiden-Harris administration set the goals of net zero greenhouse gas emissions by 2050 and a pollutionfree power sector by 2035. Currently, 22 states, plus the District of Columbia and Puerto Rico, have
100% clean energy goals (Clean Energy States Alliance 2023). A May 2023 report from the Departmentof Energy, On the Path to 100% Clean Electricity, identified the rapid deployment of wind and solar
power as a key action to achieve 100% clean electricity (Donohoo-Vallett et al. 2023).
OSW is an abundant, efficient, and renewable alternative domestic energy resource found close to
major coastal cities, where more than half of the U.S. population resides and energy needs are high.
Compared to onshore winds, offshore winds are generally stronger and more consistent. As higher windspeeds can produce significantly more energy, there is increasing interest in developing OSW. In March
2021, in response to Executive Order 14008, Tackling the Climate Crisis at Home and Abroad,2 theDepartments of the Interior, Energy, and Commerce announced a national goal3 to deploy 30 gigawatts(GW) of OSW by 2030 while protecting biodiversity and promoting ocean co-use. Hence, the Bureau of
Ocean Energy Management (BOEM)4 plans, by 2025, to hold up to four additional OSW lease sales5 andcomplete the review of at least 16 plans to construct and operate commercial OSW facilities, which
would represent more than 27 GW of clean energy for the Nation's annual production of roughly
484 GW.
BOEM and NOAA’s National Marine Fisheries Service (NMFS, or NOAA Fisheries)6 recognize that OSWdevelopment (from siting to decommissioning) must be undertaken responsibly and in accordance withexisting environmental laws. This requires identifying and mitigating the impacts from OSW to
endangered species like the NARW (Eubalaena glacialis).7 The NARW population is currently in decline,2

www.whitehouse.gov/briefing-room/presidential-actions/2021/01/27/executive-order-on-tackling-the-climate-crisis-athome-and-abroad/3
www.doi.gov/news/interior-joins-government-wide-effort-advance-offshore-wind
4
www.boem.gov
5
www.boem.gov/sites/default/files/documents/renewable-energy/state-activities/OSW-Proposed-Leasing-Schedule.pdf
6
www.fisheries.noaa.gov/
7
www.fisheries.noaa.gov/species/north-atlantic-right-whale

BOEM and NOAA Fisheries North Atlantic Right Whale and Offshore Wind Strategy|2mainly due to vessel strikes and entanglement in fishing gear (Pettis et al. 2023), and regulations tofurther mitigate those effects are underway. OSW development must be carried out in a way that avoids
or minimizes the potential for introducing adverse effects to the species and the ecosystems on which it
depends by integrating science-based avoidance and minimization approaches throughout the OSW
siting, leasing, construction, operations, and decommissioning process to protect and conserve thespecies and its habitat.
Previous, current, and ongoing research efforts supported by BOEM, NOAA Fisheries, industry, andother partners and stakeholders over the past several decades provide the best available science toinform management decisions today on OSW development and its potential impacts to NARWs. Federal
agencies are working to better understand the effects of OSW development on NARWs and theirecosystem, and to develop and improve strategies to avoid, minimize, and monitor impacts to NARWs
from OSW development. As the OSW industry continues to grow and projects are proposed for andbegin construction, BOEM and NOAA Fisheries will continue to use this Strategy to implement measures
to reduce risk to NARWs, evaluate existing approaches, and collect and apply best available data andinsights to inform future decisions, including monitoring and mitigation programs.
BOEM and NOAA Fisheries developed this shared North Atlantic Right Whale and Offshore Wind
Strategy to focus and integrate past, present, and future efforts related to NARW and OSW
development. Both agencies share a common vision: to protect and promote the recovery of North
Atlantic right whales while responsibly developing offshore wind energy. This vision reflects the
combined legislative mandates8 of the two agencies and their commitment to developing OSW while
protecting biodiversity and promoting ocean co-use. The Strategy identifies several actions to achieve
the common vision and to meet the agencies’ legislative mandates under three main goals:(1) Mitigation and Decision-Support Tools; (2) Research and Monitoring; and (3) Collaboration,
Communication, and Outreach.
A draft of the Strategy was made available for public comment in October 2022, before being finalizedwith consideration of comments received. The agencies intend to keep this Strategy as a “living”
document that will be regularly evaluated and updated as progress is made and new information
becomes available.
BOEM and NOAA Fisheries recognize that there are ongoing efforts with similar goals and objectives
inside and outside of these two agencies. Executing this Strategy will involve collaboration andcoordination among the many Federal and non-Federal partners with shared interests. This Strategy isalso an integral step to most effectively organize BOEM, NOAA Fisheries, and their partners around ashared vision and a clear path to study and manage this issue.
This Strategy does not establish policy or require regulatory actions, interpret existing laws or
regulations, or establish any legal requirement; rather, it recognizes efforts to date and identifies areas
where BOEM and NOAA Fisheries will work together alongside our partners (including the OSW
industry) to further develop the information and science the agencies will use to inform their decisions
8

Outer Continental Shelf Lands Act; Endangered Species Act Section (7(a)(1)) to use programs and authorities to provide forconservation of the species and Section (7(a)(2)) to ensure actions funded/authorized/carried out are not likely to jeopardize
the species or destroy/adversely modify critical habitat.

BOEM and NOAA Fisheries North Atlantic Right Whale and Offshore Wind Strategy|3

to responsibly develop OSW while protecting and recovering NARWs. All OSW projects (ongoing,planned, and future) are subject to the National Environmental Policy Act (NEPA), Endangered Species
Act (ESA), and Marine Mammal Protection Act (MMPA), which all bear on fully understanding andmanaging the impacts of OSW energy development on NARWs, and there are many ways thatconditions can, and will continue to, be required for projects to mitigate effects on NARWs. BOEM andNOAA Fisheries will continue to work together to ensure a robust and comprehensive analysis of theeffects of OSW development on NARWs and develop and implement effective measures to avoid,
minimize, and mitigate and monitor effects of construction, operations, and eventual decommissioningof OSW projects.
Although this Strategy is focusing on OSW and NARWs in the Atlantic, BOEM and NOAA will monitor
potential impacts from OSW development in the Gulf of Mexico, where small numbers of NARWs haveoccasionally been recorded, most recently in 2020. The Strategy will be updated in the future as new
information becomes available.

2.2

BOEM & NOAA Fisheries’ Missions and Responsibilities

BOEM’s mission is to manage the energy and mineral resources of the OCS in an environmentally andeconomically responsible way. BOEM promotes energy independence, environmental protection, andeconomic development through responsible, science-based management of energy and mineral
resources on the OCS. BOEM ensures that environmental protection—informed by the best available
science as required by law—is a foremost concern and an indispensable consideration in BOEM’s
decision-making. The OCS Lands Act directs BOEM to study and consider coastal, marine, and humanenvironmental impacts, and BOEM must also comply with many other statutes, regulations, executive
orders, and policies in making decisions—including the ESA.
One of BOEM’s key programs is offshore renewable energy9 development on the OCS. In 2009, the U.S.
Department of the Interior announced final regulations for the OCS Renewable Energy Program, which
was authorized by the Energy Policy Act of 2005. These regulations provide a framework for issuingleases, easements, and rights-of-way for OCS activities to support production and transmission ofenergy from sources other than oil and natural gas, including environmental safeguards.
BOEM’s OSW development approval process typically comprises four distinct phases: (1) planning andanalysis; (2) leasing; (3) site assessment; and (4) construction and operations, with public andstakeholder engagements and consultation with Tribal Nations throughout the entire process. In thefirst two phases, planning and analysis and then leasing, BOEM obtains information regarding potential
areas suitable for OSW development along with information regarding potential existing ocean uses, thepresence of natural and cultural resources, and other key considerations before identifying an area to beconsidered in a formal Call for Information and Nominations, which is published in the Federal Register.
This Call for Information and Nominations, which identifies what is frequently referred to as a “callarea,” is meant to obtain comments and information from the public and nominations from companies
interested in commercial wind energy leases within the defined area.

9

www.boem.gov/renewable-energy

BOEM and NOAA Fisheries North Atlantic Right Whale and Offshore Wind Strategy|4Based on further resource evaluation and public feedback, BOEM typically winnows down the larger
area to ultimately identify areas for environmental analysis and consideration for leasing (i.e., draft windenergy areas). Additional reviews are undertaken on these draft wind energy areas until final windenergy areas are identified for a lease sale. Then, each subsequent lease sale, Site Assessment Plan
(SAP), and Construction and Operations Plan (COP) undergoes further evaluation under statutes—
including the NEPA, ESA, MMPA (as applicable)—and are also subject to additional review by other
Federal and State agencies, Tribal Nations, ocean users, and the public.
Thus, throughout each phase of the OSW development process from area identification for a lease salethrough the construction and operation of an OSW project, there are integrated opportunities foravoiding areas critical to NARW and identifying mitigation measures.
As of September 2023, there are 30 renewable energy lease areas in the Atlantic Outer Continental Shelf(OCS) with an installed OSW capacity of 42 megawatts. COPs for OSW projects on 18 of those leases
have been submitted to BOEM, with Records of Decision issued for four, and two currently underconstruction offshore Massachusetts and New York. BOEM anticipates completing the review of 16 OSW
projects by 2025. All these projects are anticipated to have fixed foundation turbines, though futureleasing plans in deeper areas of the Atlantic OCS contemplate the use of floating technology, which
could help contribute to the goal of 15 GW of floating OSW by 2035.
NOAA Fisheries is a steward of the Nation’s living marine resources, including fisheries, most marine
mammals, anadromous and marine endangered and threatened species, and their habitats andecosystems. NOAA Fisheries also assesses many living marine resources to promote their protection,conservation, recovery, and long-term sustainability. NOAA Fisheries' responsibilities for marine
mammals and endangered species are defined under the ESA and MMPA. Pursuant to these laws, NOAA
Fisheries lists species as threatened or endangered, designates critical habitat, promulgates protective
regulations, monitors, assesses, protects, and recovers marine mammals and endangered andthreatened species, and conserves the habitats upon which these species depend.
NOAA Fisheries strives to take an ecosystem-based approach to managing living marine resources,
recognizing the interconnectedness of ecosystem components and the value of resilient and productive
ecosystems to living marine resources. NOAA consults with Federal action agencies under Section 7(a)(2)of the ESA to ensure that actions they propose are not likely to jeopardize ESA-listed species or result in
the destruction or adverse modification of designated critical habitat and through that processestablishes non-discretionary measures to minimize the effects of incidental take of species andprovides conservation recommendations to support their conservation and recovery. Further, under the
MMPA, in response to an applicant’s requests, NOAA issues authorizations to incidentally take marine
mammals only in circumstances where the taking will not result in more than a negligible impact tomarine mammals, including ESA-listed marine mammals, and the authorization prescribes thepermissible methods of taking and other means of effecting the least practicable adverse impact onmarine mammal species or stocks and their habitat, as well as requirements pertaining to themonitoring and reporting of such taking.
NOAA Fisheries has responsibilities for the NARW under the MMPA and ESA. This species, whose range
overlaps with the area proposed for OSW development in the Atlantic OCS, is one of the mostendangered large whales in the world (Hayes et al. 2023). NOAA Fisheries, working with other Federal

BOEM and NOAA Fisheries North Atlantic Right Whale and Offshore Wind Strategy|5agencies and organizations and the Canadian government, is heavily invested in protecting andrecovering this species. The NARW provides important ecosystem services, and its potential extinction
could be a leading indicator for other ecosystem disruptions (Pershing et al. 2021). NOAA Fisheries
responsibilities under the ESA include NARW listing, recovery, critical habitat designation, andinteragency consultation. For example, NOAA Fisheries recently completed a 5-year review for the
NARW, which concluded that no change to the listing status was warranted and included
recommendations for future actions such as continuing to work with Federal action agencies to fully
utilize Section 7 of the ESA to help address impacts from anthropogenic activities to NARW, as well as
monitor and address impacts associated with new and emerging marine activities (e.g., OSW energy
development) to NARW.
Section 7(a)(1) of the ESA requires BOEM and NOAA (and all other Federal agencies) to “utilize theirauthorities in furtherance of the purposes of this Act by carrying out programs for the conservation ofendangered species.” This Strategy was developed by BOEM and NOAA Fisheries in accordance with
their respective obligations pursuant to Section 7(a)(1). Additionally, Section 7(a)(2) of the ESA requiresthat BOEM, as an action agency considering the approval of OSW activities that may affect the NARW,
consult with NOAA Fisheries to ensure that those activities are not likely to jeopardize the continued
existence of NARWs or result in the destruction or adverse modification of critical habitat designated forthe species. NOAA Fisheries, as the consulting agency, provides its opinion to BOEM on whether a
proposed OSW development action is likely to adversely affect NARW or its designated critical habitat
and, if so, whether the action is likely to jeopardize the species or result in destruction or adverse
modification of its designated critical habitat. BOEM and NOAA Fisheries are required by the ESA to use
the best scientific and commercial data available when carrying out these consultations.
At the end of the formal ESA Section 7 consultation process, NOAA Fisheries prepares a Biological
Opinion detailing how BOEM’s proposed OSW action may affect NARWs or its critical habitat and, as
noted, draws a conclusion as to whether the proposed action is likely to jeopardize the continued
existence of the species or result in the destruction or adverse modification of its designated critical
habitat. The “jeopardy” analysis considers whether the action will result in reductions in reproduction,
numbers, or distribution of the species, and then considers whether these reductions (if any) would
reduce appreciably the likelihood of both the survival and recovery of the species, as those terms aredefined for purposes of the ESA. If a “jeopardy” or “adverse modification” conclusion is reached, theBiological Opinion would include one or more Reasonable and Prudent Alternatives to the proposed
action that would avoid the likelihood of jeopardizing the continued existence of the listed species orthe destruction or adverse modification of designated critical habitat.
If a “no jeopardy” conclusion is reached, either based on the proposed action (including its mitigation
measures) or after adopting a Reasonable and Prudent Alternative, NOAA Fisheries issues with the
Biological Opinion an Incidental Take Statement that exempts a certain amount and extent of incidental
take from the prohibitions on take listed in ESA Section 9. The Incidental Take Statement includes
Reasonable and Prudent Measures and implementing Terms and Conditions determined to be necessary
and appropriate to minimize and monitor that take. The incidental take of marine mammals, including
ESA-listed marine mammals, must also be authorized under the MMPA. Developers proposing activities,
including surveys and construction activities, may request an incidental take authorization under the
MMPA from NOAA Fisheries (Office of Protected Resources [OPR], Permits and Conservation Division).

BOEM and NOAA Fisheries North Atlantic Right Whale and Offshore Wind Strategy|6When processing requests for incidental take authorizations for OSW activities under the MMPA, NOAA
Fisheries OPR may only authorize take of small numbers of marine mammals and must find that the
total authorized take will have a negligible impact on the affected marine mammal species and stock. In
any marine mammal incidental take authorization, NOAA Fisheries OPR must also prescribe mitigation
measures that will result in the least practicable adverse impact on marine mammals and their habitat—
paying particular attention to rookeries, mating grounds, and areas of similar significance—and include
requirements pertaining to monitoring and reporting. The Section 7 consultation carried out between
BOEM and NMFS includes all proposed Federal actions, including NOAA Fisheries OPR’s proposed
issuance of an MMPA incidental take authorization for an OSW activity.

2.3

Status of the NARW

NARWs are listed as endangered under the ESA and considered depleted under the MMPA. The species
is in decline (Pace III et al. 2017; Pace III et al. 2021) and experiencing an ongoing unusual mortality
event, which was declared in 2017 (Daoust et al. 2018; NOAA Fisheries 2022a). Preliminary estimates
based on data through December 2022 indicate there are approximately 360 individuals remaining,
including fewer than 70 reproductively active females (Hayes et al. 2023; Linden 2023).
The potential biological removal (PBR) level for the species, for the purposes of the MMPA, defined as
the maximum number of animals that can be removed annually while allowing the stock to reach or
maintain its optimal sustainable population level,10 is less than one (Hayes et al. 2023). In addition tovessel strikes and entanglement in fishing gear, which are the primary causes of NARW mortality andserious injury, modeling indicates that low female survival, a male-biased sex ratio, and low calving rates
are contributing to the population’s current decline (Pace III et al. 2017). The species has low genetic
diversity, as would be expected based on its low abundance, and the species’ resilience to future
perturbations is expected to be very low (Hayes et al. 2023).
Decreased prey abundance, climate-driven changes in habitat, and, potentially, ocean noise, also arecontributing to the species decline and could further reduce calving rates and increase susceptibility todisease and predation (Bishop et al. 2022; Matthews and Parks 2021; Meyer-Gutbrod et al. 2021;
Meyer‐Gutbrod et al. 2022). Entanglement in fishing gear appears to have had substantial health andenergetic costs that affect survival, reproduction, and decreased size at maturation for NARW (Rolland
et al. 2012; Stewart et al. 2022; Stewart et al. 2021; Van der Hoop et al. 2016). Sublethal effects fromchanges in prey availability are difficult to separate from other sublethal effects (e.g., entanglement infishing gear) but are directly linked to health, reproduction, and survival (Pirotta et al. 2023). Increasinglevels of ocean noise due to anthropogenic activities may also cause sublethal effects to NARW
(Matthews and Parks 2021). These stressors likely decrease the health of NARWs, which may cause adecrease in calving rates (Rolland et al. 2016). Calving rates have slowed from one calf per female every
3 to 4 years to one calf per female every 7 to 10 years (Pettis et al. 2023); in addition, the number offirst-time mothers is decreasing (Reed et al. 2022).

10

The term “optimal sustainable population” is defined in the MMPA as “with respect to any population stock, the number ofanimals which will result in the maximum productivity of the population or the species, keeping in mind the carrying capacityof the habitat and the health of the ecosystem of which they form a constituent element.”

BOEM and NOAA Fisheries North Atlantic Right Whale and Offshore Wind Strategy|7

NARWs feed primarily on the late-stage, lipid-rich copepod (Calanus finmarchicus) but supplement theirdiet with other zooplankton species (Baumgartner et al. 2017). NARWs must find and feed on dense
aggregations of copepods to survive (Baumgartner and Mate 2003). Climate-change-driven changes inocean conditions have shifted the distribution of NARW prey (e.g.,Grieve et al. 2017; Meyer-Gutbrod
and Greene 2018; Meyer-Gutbrod et al. 2021; Meyer‐Gutbrod et al. 2022; Record et al. 2019). NARWs
have in turn shifted their seasonal distribution into areas where they have not been observed regularly
for at least the past few decades, including Canada’s Gulf of St. Lawrence (Crowe et al. 2021) andsouthern New England (O'Brien et al. 2022; Quintana-Rizzo et al. 2021).
This shift in distribution has coincided with increased entanglements in fishing gear and vessel strikes(O'Brien et al. 2022). As of October 2023, the ongoing NARW unusual mortality event includes a total of
121 documented animals: 36 dead stranded NARWs, 34 seriously injured free-swimming NARWs, and 51
sublethal injuries/illness (i.e., morbidity) (NOAA Fisheries 2022a). Examinations by necropsy or photo
documentation have been conducted on 31 of the 36 dead whales. Final results from someexaminations are pending; however, preliminary findings indicate vessel strikes or entanglements infishing gear as the causes of death. Additionally, 33 live free-swimming non-stranded NARWs have been
documented with serious injuries from entanglements or vessel strikes, and 29 more have been
documented with sublethal injuries and/or illness (NOAA Fisheries 2022c). To date, more than 20
percent of the population has been impacted by the unusual mortality event based on the documented
cases and the 2017 abundance estimate, which is when the current event began. The actual situation iscertainly much worse, with cryptic mortality (i.e., unobserved mortality, see Pace III et al. 2021)
estimated to be 64% of all mortality.
Based on this information, roughly 237 animals have died since the population peaked at 481 in 2011,
exceeding the PBR level on average by more than 40 times for the past 5 years (Pace III et al. 2021).
Human-caused mortality is so high that no adult NARW has been confirmed to have died from naturalcauses in several decades (Hayes et al. 2023). Most animals have a low probability of surviving past 40
years even though the NARW can live up to a century. Consequently, for the remaining reproductively
active females (currently fewer than 70 in number) and any subsequent calves that might mature, their
lifetime calving potential has been reduced from more than a dozen to perhaps just two to three calves.
NARW births remain significantly below what is expected, and the average inter-birth interval remains
high. Additionally, there were no first-time mothers in 2022, underscoring recent research findings thatfewer adult, nulliparous females are becoming reproductively active (Reed et al. 2022). Finally, theproportion of the population with compromised body condition has increased steadily over the last 20
years. Today, about 42% of the population is known to be in reduced health (Hamilton et al. 2021), likely
contributing to the smaller body sizes at maturation (Stewart et al. 2022) and making NARWs generally
more susceptible to threats, including potential impacts from OSW development.
Due to the declining status of NARWs, the resilience of this population to stressors affecting theirdistribution, abundance, and reproductive potential is low. The species faces a high risk of extinction,and the population size is small enough that the death of even very few individuals can have ameasurable effect on its population status, trend, and dynamics. Furthermore, the loss of even one
individual a year (e.g., higher than the current PBR level) may reduce the likelihood of species recovery
and of their ability to achieve optimum sustainable population.

BOEM and NOAA Fisheries North Atlantic Right Whale and Offshore Wind Strategy|8

NOAA Fisheries’ North Atlantic Right Whale Priority Action Plan for 2021–202511 identifies the need to
improve our knowledge of factors that may limit NARW recovery, such as OSW development (NOAA
Fisheries 2021). The plan identifies the need for a thorough and comprehensive analysis of temporary
and long-term direct and indirect impacts of OSW development from construction and operation
through decommissioning. Assessing and mitigating threats associated with the development of OSW
has also been identified in NOAA Fisheries’ North Atlantic Right Whale Road to Recovery,12 which
describes NOAA Fisheries’ overall efforts to stop the current population decline and recover the species(NOAA Fisheries 2022b). Within the Road to Recovery, NOAA Fisheries identifies major existing threats
to NARWs, including entanglements, vessel strikes, ocean noise, and climate-driven changes in habitatand habitat use (including prey). Given these threats, OSW must be developed based on responsible
science-based decision-making and development and implementation of enduring avoidance,
minimization, mitigation, and monitoring approaches to avoid exacerbating the species’ dire status.

2.4Intersection of NARWs and OSW

Due to the status of NARW, science-based decision-making, and protective measures designed to ensure
survival and recovery of the species must be considered in managing NARWs. The most recent stock
assessment report (Hayes et al. 2023) indicates there are approximately 360 individuals and that the
PBR of this population is less than one individual. Given the uncertainty in the potential effects of thepresence and operation of OSW facilities on protected species and their habitats (Dorrell et al. 2022;
Raghukumar et al. 2023), management of OSW development should proceed with a focus on avoiding or
minimizing known and potential impacts to NARWs and their habitat. The precarious status of thespecies necessitates that all human impacts be avoided or minimized in such a way that NARWs canrecover in the coming years to be able to benefit from the long-term mitigation of climate impacts from
OSW development.
NARWs inhabit the waters of the U.S. and Canadian Atlantic, with some parts of their range designatedas critical habitat under the ESA (81 FR 4838, January 27, 2016) and Canada’s Species At Risk Act(Fisheries and Oceans Canada 2014). Within the areas proposed for OSW development in the UnitedStates, NARWs engage in migration, foraging, socializing, reproduction, calving, and resting behaviors
critical to their survival (Leiter et al. 2017; Muirhead et al. 2018; Quintana-Rizzo et al. 2021; Zoidis et al.
2021). The overlap between OSW development (planned, leased, and approved) and NARW habitat
extends to areas outside the immediate development sites (i.e., wind energy developments and export
cable corridors), where vessel traffic between ports and offshore sites would further overlap with the
distribution of NARWs (Figures 1a and 1b, and Appendix D). Noise and ecosystem-level changes
resulting from OSW development that may impact NARWs are also likely to extend beyond theimmediate OSW lease areas. In the Atlantic OCS off the southeast United States, NARW presence ishighly seasonal as evident in monthly density maps (Appendix D), with NARWs mostly present between
November and May. In the Atlantic OCS off the northeast and Mid-Atlantic regions, NARWs are present
year-round (Davis et al. 2017). See Appendix D for detailed maps of NARW density and distribution bymonth in relation to current and planned OSW activity. Given this, the potential for NARWs to beaffected by OSW activities is related to the timing and location of those activities.
11

www.fisheries.noaa.gov/resource/document/species-spotlight-priority-actions-2021-2025-north-atlantic-right-whale

12

www.fisheries.noaa.gov/species/north-atlantic-right-whale/road-recovery

BOEM and NOAA Fisheries North Atlantic Right Whale and Offshore Wind Strategy|9Figure 1a. Status of OSW activity overlaid on mean annual density of NARWs off the northeast UnitedStates (2010–2019)
Inset shows all designated NARW critical habitat under the ESA. Narrow lines leading from leases to land are cable routeeasements. Due to State/Federal jurisdiction, the easement shows as ending at the State waters boundary where other Stateand Federal regulations apply. All leases with approved COPs will include easements shortly after approval. Source: Roberts etal. (2023); Roberts et al. (2016).

BOEM and NOAA Fisheries North Atlantic Right Whale and Offshore Wind Strategy| 10Figure 1b. Status of OSW activity overlaid on mean annual density of NARWs off the southeast UnitedStates (2010–2019)
Inset shows all designated NARW critical habitat under the ESA. Narrow lines leading from leases to land are cable routeeasements. Due to State/Federal jurisdiction, the easement shows as ending at the State waters boundary where other Stateand Federal regulations apply. All leases with approved COPs will include easements shortly after approval. Source: Roberts etal. (2023); Roberts et al. (2016).

BOEM and NOAA Fisheries North Atlantic Right Whale and Offshore Wind Strategy| 11

The activities associated with OSW development would introduce or further contribute to existing
stressors in the environment that affect NARWs (Daewel et al. 2022; Dorrell et al. 2022; Leiter et al.
2017; Maxwell et al. 2022; Quintana-Rizzo et al. 2021). The approaches identified in this Strategy areintended to mitigate the impacts of these stressors, while the Strategy’s recommendations on scientificresearch are designed to help the agencies understand the extent to which OSW activities willcontribute to and alter these stressors and, ultimately, the magnitude of potential impacts to NARWs.
The four primary stressors identified in this Strategy include the following (in no particular order):1. Exposure to noise. Sound-producing activities associated with OSW activities have the potential
to result in hearing impairment, masking of NARW vocal communication, physiological impacts(e.g., stress), and/or behavioral disturbance, as well as mortality and injury that may result fromexposure to detonations of unexploded ordnance (UXO). The severity and magnitude of impacts
are dependent upon the nature of the activity (e.g., most high resolution geophysical (HRG)sound sources used during site characterization are expected to have de minimis impacts, if any,see Ruppel et al. 2022).
2. Strikes from vessels. All vessels, including those associated with OSW activities, have thepotential to strike and potentially injure or kill NARWs. In addition, OSW activities may result in
shifts in species and/or vessel distribution, which may alter vessel strike risk from non-OSW
vessels (e.g., vessels could be displaced from lease areas and into areas used more frequently by
NARWs).
3. Entanglement. OSW activities may produce marine debris or involve appurtenances (e.g., fromfloating wind), which may cause entanglements that injure or kill NARWs. In addition, OSW
activities may alter entanglement risk through changes in fishing activities or by interacting withabandoned, lost, or otherwise discarded fishing gear (e.g., attached to turbine structures).
4. Changes to habitat. OSW development will result in habitat changes that may affect theabundance, quality, or availability of NARW prey (e.g., changes in ocean circulation and mixing
from in-water structures, including turbines and foundations, and impingement or entrainmentof prey in cooling water intakes associated with High Voltage Direct Current cable systems) or
attract predators (e.g., predators with an affinity for a new “reef structure” in the environment).
The consequence of NARW exposure to noise and/or pressure (particularly from construction activities)
and vessel strikes are generally well known. Conversely, the extent to which OSW development may
increase or alter entanglement risk and how changes in habitat may affect NARWs, particularly throughsublethal effects that do not result in mortality or serious injury, are not as well understood. Sublethal
effects can be direct or indirect, and often scientific quantification of indirect effects is challenging,
though some can be modeled.
Relative to the threat of changes to habitat, this Strategy identifies a need for quantitative assessmentsof potential OSW impacts on NARW prey availability and consumption potential. Based on the best
available science on ecosystem causation, this Strategy identifies the following conceptual cause-effectimpact pathway on female condition and calving rates that could occur if impacts to prey and foraging
habitats occur (Figure 2).

BOEM and NOAA Fisheries North Atlantic Right Whale and Offshore Wind Strategy| 12Figure 2. Conceptual cause-effect-impact pathway on NARW foraging ecology from OSW development
Although the above pathway is conceptual and additional research is needed, recent studies suggestthat OSW has the potential to alter local- to regional-scale ocean circulation, including upwelling anddownwelling, as well as primary and secondary production (e.g., Daewel et al. 2022; Floeter et al. 2022;
National Academies of Sciences 2023; Raghukumar et al. 2023). A National Academy of Sciences,
Engineering, and Medicine panel recently convened to assess potential impacts from OSW energy
developments in the Nantucket Shoals region on marine hydrodynamics and the availability of NARW
prey confirmed that OSW has the potential to alter local and regional hydrodynamics. The panel notedthat “the paucity of observations and uncertainty of the modeled hydrodynamic effects make it difficult
to assess the ecological impacts of offshore wind farms [energy development], particularly considering
the scale of both natural and human-caused variability in the Nantucket Shoals region,” and “as planningand construction of wind farms in the Nantucket Shoals region continue, further study and monitoringof the oceanography and ecology of the area is needed to fully understand the impact of future windfarms” (National Academies of Sciences 2023). In alignment with these recommendations, this Strategy
identifies modeling studies to understand the physical and ecological complexities of theseareas/regions and to assess potential impacts on hydrodynamics and NARW foraging resources, as wellas coordinated regional monitoring efforts to validate model outputs with respect to hydrodynamic andecological effects at turbine, wind energy developments, and regional scales.
Part of this Strategy is to further research the possibility of cause-effect-impact pathways for sublethal
effects, such as displacement from calving grounds, impacts of ocean noise, reduced lactation or
reduced nursing, and reduced ability to become pregnant or maintain a viable pregnancy. Such research

BOEM and NOAA Fisheries North Atlantic Right Whale and Offshore Wind Strategy| 13

is merited because sublethal effects may have a similar impact on the species as lethal effects by
reducing the potential for the population to grow (Moore et al. 2021; Sharp et al. 2019). Moreover,increased energetic costs (e.g., from potential displacement from foraging areas due to noise or preyavailability) could lead to increased susceptibility to other stressors (e.g., a shift in distribution canchange the overlap with vessel traffic and fishing activities). Cause-effect-impact pathways can also vary
based on body condition (Bishop et al. 2022; Christiansen et al. 2020; Moore et al. 2021; Pettis et al.
2017). Whales that are in compromised condition (e.g., injured, entangled, malnourished) and exposed
to stressors are likely to experience more severe consequences than healthy animals (Christiansen et al.
2020; Knowlton et al. 2022; Moore et al. 2021; Pettis et al. 2017).
Effects to NARWs could result from stressors generated from a single project; there is potential for theseeffects to be compounded by exposure to multiple projects. NARWs migrating along the U.S. Atlantic
Coast have the potential to travel near or through many currently proposed OSW developments along
the Atlantic Coast. In some cases, OSW development may occur in areas that are important for NARW
vital functions. For example, if the OSW development being considered in the Gulf of Maine moves
forward, it would occur in designated NARW critical habitat (Leiter et al. 2017; O'Brien et al. 2022;
Quintana-Rizzo et al. 2021; Stone et al. 2017).
It is important to keep in mind that the northwest Atlantic—in particular the mid-Atlantic shelf andslope—has been experiencing strong interannual and decadal-scale variability (Andres 2016; Forsyth etal. 2015; Gangopadhyay et al. 2019; Harden et al. 2020). The long-term warming trend in this region
since the 1980s is several times larger than the global mean warming trend (Forsyth et al. 2015;
Großelindemann et al. 2022). Enhanced regional warming in the northwest Atlantic as a response to
climate change has been seen in at least one climate model (Saba et al. 2016), but it is still unclear
whether the recent climatic variability is primarily a regionally enhanced response to climate change or
due to decadal variability in the climate system (e.g., the Gulf Stream or Meridional Overturning
Circulation) that may reverse sign in the future. Therefore, any efforts to model or observe the impactsof OSW projects will have to place the OSW-induced variability in this wider context.

2.5

NARW and OSW Research and Monitoring Efforts

Previous, current, and ongoing research efforts supported by BOEM, NOAA, the OSW industry, andother partners and stakeholders over the past 15 years provide the best available science to informconsideration of the effects of OSW on NARWs.
To ensure that BOEM and NOAA Fisheries had an inventory of available and planned research andmitigation methods and technologies prior to developing this Strategy, BOEM contracted with the Blue
World Research Institute, Inc. (BWRI) to synthesize current and near-term NARW research andmonitoring efforts, in-use or developing tools and methods, and measures to avoid or minimize OSWrelated impacts on the NARW population (see Silber et al. in review). BWRI canvassed OSW energy
industry representatives, NARW researchers, environmental groups, and others about their ongoing andplanned work and their views on innovations that may be applied in a 1- to 5-year time horizon. The
research emphasized emerging or novel uses of existing methodologies that study NARW occurrence,
distribution, and health, as well as potential impact-mitigating methods and technologies.

BOEM and NOAA Fisheries North Atlantic Right Whale and Offshore Wind Strategy| 14

The report’s findings acknowledge the magnitude of work previously and currently being undertaken
related to NARWs and OSW (as well as future planned efforts) but does not include an exhaustive list of
all research efforts to date. Examples of this work include support for workshops; working groups;
passive acoustic monitoring (PAM); vessel and aerial monitoring; photo identification; infrared camera
and related technology studies; satellite and unmanned aerial vehicle (UAV) remote sensing; tagging andtelemetry; oceanographic, ecological, and prey studies; noise and quieting; stress and health; modeling;
habitat-based density modeling and analysis techniques; and risk assessments (including vessel strike,entanglement, and population-level risk assessment) (Silber et al. in review). Overall, the BWRI reportdemonstrates how BOEM, NOAA Fisheries, and others have actively worked to understand NARWs andthe intersection of this species and OSW development, and to develop mitigation strategies thatminimize impacts to NARWs.
The following workshops held over the past 5 years provide an overview of areas where BOEM andNOAA Fisheries recently have been focusing efforts and will improve the understanding of theinteraction between NARW and OSW:●

March 2017 Workshop on Best Management Practices Workshop for Atlantic Offshore Wind
Facilities and Marine Protected Species (BOEM 2018)●

May 2018 Workshop on a Framework for Studying the Effects of Offshore Wind Development on
Marine Mammals and Turtles (Kraus et al. 2019)●

June 2019 Health Assessment Workshop for North Atlantic Right Whales (Fauquier et al. 2020)●

October 2019 Workshop on Monitoring and Surveillance: North Atlantic Right Whale Expert
Working Group (Oleson et al. 2020)●

October 2020 Workshop on New York Bight Passive Acoustic Monitoring (Wildlife Conservation
Society 2021)●

November 2020 Workshop on the State of the Science on Wildlife and Offshore Wind Energy
2020: Cumulative Impacts (Southall et al. 2021)●

Annual meetings of the Atlantic Scientific Review Group (ASRG) to advise on the status ofmarine mammal stocks●

June 2022 workshop convened by NOAA on Oceanographic Impacts of Offshore Wind Energy
Development: Implications for Protected Species (report under development)

As the OSW industry continues to grow and as projects begin construction, BOEM and NOAA Fisheries
will continue to work with our partners to evaluate existing strategies and to further collect and apply
newly available information to inform future decisions. This Strategy is an integral step to organize
BOEM, NOAA Fisheries, and their partners around a shared vision and clear path to effectively study andmanage this issue moving forward.

BOEM and NOAA Fisheries North Atlantic Right Whale and Offshore Wind Strategy| 15

3 Strategy Framework
3.1

Background

In March 2021, in response to Executive Order 14008, the Departments of the Interior, Energy, andCommerce announced a national goal to deploy 30 GW of OSW by 2030 while protecting biodiversity
and promoting ocean co-use. This Strategy’s shared vision, therefore, is to protect and promote therecovery of North Atlantic right whales while responsibly developing offshore wind energy. This Strategy
identifies areas where BOEM and NOAA Fisheries will work together, and with partners, to further
develop the information and science needed to responsibly develop OSW and protect and recover
NARWs.
This Strategy addresses three main goals: 1) Mitigation and Decision-Support Tools, 2) Research andMonitoring, and 3) Collaboration, Communication and Outreach. Specific priorities and actions undereach of those goals are then identified (see below; also see Appendix A for more detail on the actions).
This Strategy also lays out both agencies’ plan to engage stakeholders, partners, and other ocean users
throughout (per Goal 3) and identifies potential sources for financial resources needed for successful
implementation.
This Strategy is intended to be a “living” document that will be regularly evaluated and updated as we
make progress and new information becomes available. A joint BOEM-NOAA Fisheries NARW and OSW
Strategy implementation group will be formed to update progress regularly; to identify resources,
needs, and collaborations for continued implementation; and to employ adaptive approaches for
implementing of the Strategy. Other Federal agencies may be added to the implementation group basedon their contributions to the vision and components of this Strategy. The Strategy is an important part of
NOAA Fisheries’ broader overall strategy for NARWs laid out in NOAA Fisheries’ North Atlantic Right
Whale Road to Recovery (NOAA Fisheries 2022b).
BOEM and NOAA Fisheries recognize the ongoing efforts internal and external to Federal agencies withsimilar goals. For example, we are actively coordinating with the Regional Wildlife Science Collaborative
for Offshore Wind (RWSC)13 on several upcoming workshops, and we encourage additional coordination
with the RWSC to increase effectiveness, utility, and data sharing as it relates to responsibly developing
OSW. In December 2023, BOEM held a workshop focused on the development of improved predictive
tools for NARWs. As another example, NOAA Fisheries’ North Atlantic Right Whale Road to Recovery
highlights the need to address threats to the species and monitor its progress toward recovery; thisStrategy provides more detail on the threats and mitigation of these threats specifically related to OSW
energy development. This Strategy will be implemented in coordination with the NOAA Fisheries Road
to Recovery and other NOAA Fisheries and BOEM activities related to NARW protection and recovery.
It is important to note that this Strategy will not supersede the policy and regulatory processes of, or
create legal requirements for, the two agencies; it is intended to provide a framework and guidance foragencies and partners as they seek to improve the information and science needed to support OSWdevelopment. This work will also support the continued development and refinement of mitigation and
13

rwsc.org/

BOEM and NOAA Fisheries North Atlantic Right Whale and Offshore Wind Strategy| 16monitoring standards that will be adapted as new information is collected and collated under theStrategy.
Finally, NOAA and BOEM recognize that the majority of the funding required to support the actions
described in this Strategy will require support from multiple sources, including Federal and State
governments, developers, and other stakeholders. This funding has not been secured; this Strategy canbe used to bolster efforts to secure funding, to the extent permitted by applicable law, to further
information and science to support the agencies’ shared vision.

3.2

Strategy Goals and Objectives

This section identifies goals, objectives, and associated actions to be taken in order to achieve theobjectives of this Strategy; more details are provided in Appendix A. Section 3.4 identifies a list ofpriority actions to achieve research and mitigation needs.

GOAL 1: Mitigation and Decision-Support Tools
Develop, use, and evaluate measures that avoid or minimize impacts of OSW activities on NARWs andtheir habitat. Establish quieting performance standards for OSW. Work to improve and develop tools to
support decision-making as it relates to OSW development and NARW recovery. Ensure mitigation anddecision-support tool development are undertaken in close coordination with those entities involved inregulation, rulemaking, and decisions related to NARWs and OSW.
The definition of mitigation used in this Strategy is derived from the Council on Environmental Quality(CEQ) NEPA regulations (40 CFR 1508.1(s)). NOAA’s Mitigation Policy for Trust Resources14 (NAO 216123) uses the CEQ definitions (see below) and then divides mitigation into three elements: avoidance,
minimization, and compensation.15 As described below, this Strategy supports avoiding impacts as theprimary goal wherever practicable, followed by impact minimization.
●

Avoid – avoid the impact altogether by not taking a certain action or parts of an action or bymodifying the action to avert impacts●

Minimize – minimize the impact by limiting the degree or magnitude of the impact, the action,or its implementation

BOEM will consider recommendations from NOAA Fisheries based on the best available science andattempt to avoid issuing new leases in areas that may impact potential high-value habitat and/or highuse areas for important life history functions such as NARW foraging, migrating, mating, or calving. For
areas that are leased, permitting activities should minimize any known or potential threat to NARWs andtheir habitats, and developers and BOEM should support research and monitoring.
14

www.noaa.gov/organization/administration/noaa-administrative-orders-chapter-216-program-management/nao-216-123noaa-mitigation-policy-for-trust-resources

15

CEQ defines compensation as to “offset or compensate for the impact by replacing or providing equivalent substituteresources or environments.” This strategy does not focus on or address compensation to offset adverse effects of OSWdevelopment; it currently focuses on avoiding and minimizing impacts to NARWs from OSW. Thus, when the term mitigation
is used in this strategy, it refers to avoidance and minimization, not compensation.

BOEM and NOAA Fisheries North Atlantic Right Whale and Offshore Wind Strategy| 17

The key actions for this category are noted below and described in more detail in Appendix A.
OBJECTIVE 1.1: Refine existing, and develop additional, mitigation and monitoring measures,
including those that consider new technologies, that are effective at avoiding or minimizing
effects of OSW projects on NARWs, individually and cumulatively. Review and update thesemeasures (on a case-by-case basis or programmatic basis) as new information and technologies
become available.
OBJECTIVE 1.2: Prioritize research, development, and implementation of mitigation on quieting
technology and methods to reduce noise levels for all OSW phases.
OBJECTIVE 1.3: Develop risk-analysis and decision-support tools to improve how project-specific andcumulative environmental effects from OSW are evaluated for NARWs and their habitat
considering each primary threat to NARW recovery related to OSW, including entanglement,
vessel strike, acoustics/noise, and changes in habitat and habitat use (including prey).
OBJECTIVE 1.4: Improve marine spatial planning tools and approaches for OSW siting to inform
decision-making and support avoiding impacts as a priority and mitigating impacts as necessary.
With respect to OBJECTIVE 1.1, the agencies have developed a list of measures that have the potential
to avoid and minimize impacts to NARWs from OSW activities. These measures are categorized byrenewable energy development stages: (1) project planning, siting, and leasing; (2) site characterization,site assessment, and UXO surveys; and (3) construction and operations. The intent of the measures
identified for project planning, siting, and leasing is to avoid and minimize impacts to NARWs at theonset of exploring potential lease areas, which provides the most protection to the species. During sitecharacterization/UXO survey phases, the measures are designed to minimize noise from survey sources
into the marine environment and minimize exposure of NARWs to unavoidable noise sources. Lastly,
during construction and operation, the measures are designed to minimize noise footprints and NARW
exposure to noise during construction; avoid vessel strikes and entanglement; and ensure detection of
NARWs is maximized using protected species observers (PSOs) and PAM to trigger mitigative actions.
The agencies also have developed preliminary monitoring measures to better understand, detect, andmitigate impacts to NARWs during site characterization/assessment/UXO survey and construction andoperation phases. Details regarding these measures can be found in Appendix B.
The agencies are sharing these measures to communicate the types of measures that regulatory
agencies and project proponents have, and should continue, to consider for individual projects.
Avoidance, minimization, and monitoring measures may be proposed by developers or be applied by theregulatory agencies on a project-specific basis; thus, not all projects (planned, current, future) are
subject to the same measures. It is important to note that these measures will be updated, as
appropriate per the best available science, and that none of the measures included here supersede
measures developed during project-specific environmental review, permitting, and approvals processes
or other generally applicable regulatory requirements (e.g., vessel speed rule). Furthermore, althoughcommitments by developers to implement any or all of these measures in proposed plans or otherdocuments seeking authorization from BOEM or NOAA Fisheries may facilitate consultation, permitting,and authorization processes, they do not ensure approval of projects or other permits or authorizations,as those decisions are made on a case-by-case basis by the responsible agency.

BOEM and NOAA Fisheries North Atlantic Right Whale and Offshore Wind Strategy| 18

OBJECTIVE 1.2 recognizes that the benefits of quieting the oceans apply to many marine resources,
including marine mammals, sea turtles, fish, and invertebrates. With respect to addressing noise
impacts, the agencies share a common goal of reducing noise generated during OSW construction andoperation (NOAA’s Ocean Noise Strategy16 and BOEM’s Center for Marine Acoustics17). Though many
activities associated with OSW operation and construction produce noise, this Strategy currently focuseson quieting pile-driving and vessel noise. For example, when activities such as pile driving cannot be
avoided (e.g., using foundations that do not require pile driving), pile-driving-quieting technology andmethods may be required through approvals under OCSLA, ESA, and MMPA. Although developers are
already committing to using quieting technology (e.g., noise abatement systems during pile driving of
turbine and substation foundations), the effectiveness of such technology can be improved bybroadening the scope of quieting actions and through further technological innovation, especially withrespect to lower frequency hearing specialists like NARWs. BOEM intends to pursue development of aquieting performance standard for impact pile driving to set a common goal for providing additional
environmental protection, promoting predictability, and driving technological innovation. Goal 1
includes several actions involving quieting technology and methods (Appendix A) to reduce noise during
impact and vibratory pile driving of foundation piles and to encourage integration of vessel quieting
technology in new OSW vessels built in the United States.
OBJECTIVE 1.3 identifies the needs for decision-support tools that address the four identified stressors
to NARWs that may result from OSW development: entanglement, vessel strike, acoustics/noise, andchanges in habitat and habitat use (including effects to prey). This action includes assessing our current
understanding of these stressors to identify any data gaps, evaluating the current tools available tosupport evaluation of effects, and developing tools to provide for both qualitative and quantitative
analyses. Over time, the intent is to develop and combine tools to evaluate cumulative and synergistic
effects (Goal 2).
Finally, OBJECTIVE 1.4 recognizes that marine spatial planning tools for OSW siting are being developed
to inform BOEM’s identification of call areas and lease areas. BOEM will continue to use these tools in
the planning and leasing phase to avoid known and potential impacts to NARWs and their habitats tothe maximum extent practicable. Available information includes, but is not limited to, critical habitatand other biologically important habitats, occurrence data (both sightings and acoustic detections),
modeled density distributions, and the locations of management areas (e.g., Farmer et al. 2023; Farmer
et al. 2022). However, the proactive use of marine spatial planning tools to inform BOEM’s planning,
analysis, and leasing processes is unlikely to remove all areas from leasing that will present known andpotential threats from OSW activities to NARWs; in these instances, BOEM and NOAA Fisheries will work
to minimize these impacts during the leasing, site characterization/assessment, and Construction andOperation Plan phases.

16 oceannoise.noaa.gov/
17 www.boem.gov/center-marine-acoustics

BOEM and NOAA Fisheries North Atlantic Right Whale and Offshore Wind Strategy| 19

GOAL 2: Research and Monitoring
Identify, support, coordinate, and conduct research and monitoring to better understand the current
status of NARWs (e.g., abundance, distribution, life history, health, habitat use, and ecologicalinteractions);18 understand the impacts to NARW from project-level and cumulative effects from multiple
projects; and evaluate and address any uncertainty associated with the effects of OSW development.
Monitoring under this goal relates to “general monitoring,” specific to NARW and OSW, conducted toincrease knowledge of the species, improve tool development, and enhance understanding of theeffects of OSW development on NARWs. This activity differs from “mitigation monitoring” (i.e.,observation/detection), which is discussed under Goal 1 (Mitigation and Decision Support) and is carriedout to avoid or minimize an effect during a particular OSW activity (e.g., monitoring an area for NARWs
prior to starting pile driving). The actions under general monitoring are predominantly long-term efforts
and could involve collecting data before and during OSW construction, and during operation. The study
design for any particular general monitoring effort will differ depending on the specifics of the situation(e.g., location, desired data, methodology).
The key objectives for this category are noted below and described in more detail in Appendix A.
OBJECTIVE 2.1: Develop and disseminate a research plan that identifies key data gaps related to
NARW and OSW development and details how to work with partners, stakeholders, and otherocean users to fill data gaps. The research plan will include a variety of research methods (e.g.,
acoustic and vessel surveys, aerial surveys, tagging, eDNA, health assessments) appropriate to
the question being addressed.
OBJECTIVE 2.2: Support the development of studies, particularly those with sufficient statisticalpower, to predict and detect changes in NARW ecology, demographics, and health resulting
from OSW development (e.g., changes in foraging activity, residency in key habitats,displacement) at various scales (e.g., turbine, development, regional, ecosystem).
OBJECTIVE 2.3: Develop and support efforts to improve understanding of OSW impacts on
oceanographic and lower trophic level ecosystem processes for all foundation, turbine, mooring,and layout types, with a particular focus on understanding potential impacts on the distribution
and abundance of NARW zooplankton prey.
In implementing these key objectives, the following additional data and research areas are prioritized:●

18

Data and research to assess the potential of OSW to alter NARW foraging ecology, habitat andhabitat use (inclusive of foraging, calving, migration, socializing, and other behaviors), andpredation risk, as well as to assess when such alterations may have population-level
consequences (lethal and/or sublethal effects).

Note that NOAA Fisheries’ North Atlantic Right Whale Road to Recovery includes an objective of “Monitor Population and
Health,” which provides an understanding of individual health and reproduction, as well as distribution, abundance, andhabitat-use patterns of the population. NOAA Fisheries is developing a comprehensive U.S. strategy related to NARW
population and health status, as well as distribution and habitat use (NOAA Fisheries 2022b).

BOEM and NOAA Fisheries North Atlantic Right Whale and Offshore Wind Strategy

| 20

●

Data and research to assess how OSW development may contribute to or alter vessel strike risk.
Considering NOAA Fisheries’ existing NARW vessel speed regulations (87 FR 46921) andforthcoming modifications, research should include monitoring vessel strike risk associated with
OSW development and assessing how non-OSW vessel traffic affected by OSW development
may change risk (e.g., shifts in vessel patterns due to presence of OSW structures) and may
warrant additional mitigation through project-specific approvals.

●

Data and research to assess how OSW development may contribute to or alter entanglement
risk. Evaluate entanglement risk from appurtenances (e.g., cables) associated with OSWdevelopment or biological monitoring activities associated with development of floating andfixed wind technology. Develop approaches to reduce entanglement risk. Understand howchanges in fishing effort resulting from OSW development changes the risk profile for NARW
entanglement in fishing gear.

●

Data and research to assess, avoid, and minimize noise/acoustic impacts from OSW activities,
including long-term operation of wind turbines.

●

Data and research to assess the cumulative effects of OSW combined with stressors from otherhuman activities. The definition of cumulative effects for purposes of this Strategy is derived
from the CEQ NEPA regulations (40 CFR 1508.1(g)(3)) (2020): “Cumulative effects, which are
effects on the environment that result from the incremental effects of the action when added tothe effects of other past, present, and reasonably foreseeable actions regardless of what agency(Federal or non-Federal) or person undertakes such other actions. Cumulative effects can result
from individually minor but collectively significant actions taking place over a period of time.”●

Innovation and improvements in NARW detection technologies, including acoustic and visualtechniques.
Data sharing across the board and develop and support long-term data management andarchival systems for data collected as part of the Strategy.
Evaluation of uncertainties in ability to monitor, document, or detect impacts from OSWdevelopment on NARWs and develop plans to address those uncertainties.
Implement efforts identified in the NOAA Fisheries and BOEM Northeast U.S. Federal Survey
Mitigation Strategy19 to mitigate disruption of existing NARW survey strategies by OSWdevelopment.

●
●
●

19

repository.library.noaa.gov/view/noaa/47925

BOEM and NOAA Fisheries North Atlantic Right Whale and Offshore Wind Strategy| 21

GOAL 3: Collaboration, Communication and Outreach
While this goal is not discrete from the previously identified goals in this Strategy, BOEM and NOAA
Fisheries recognize that continued collaboration between the two agencies and partners is needed forthe success of this Strategy. Further, the two agencies recognize that internal and external
communication and outreach are important for the success of this Strategy. NOAA Fisheries and BOEM
will have a transparent process for communication and outreach to support all three goals of thisStrategy. BOEM and NOAA Fisheries will develop and implement this Strategy by strengthening
partnerships, combining resources, and sharing and communicating information. BOEM and NOAA
Fisheries will also ensure professional, transparent, and equitable communication; and engagement with
Tribes, Federal and State agencies, partners, and stakeholder groups.
The key objective for this category is noted below and described in more detail in Appendix A.
OBJECTIVE 3.1: Develop long-term and proactive coordination strategies, including establishing a
joint BOEM-NOAA Fisheries NARW and OSW Strategy implementation group, and shareoutreach and communications plans. This implementation group will engage regularly withpartners, Tribes, and stakeholders in a variety of ways such as informal meetings, formal
Requests for Information, and presentations to the RWSC and the NARW Consortium.
The actions for this goal include the following:●

For BOEM and NOAA Fisheries to collaborate effectively with each other and partners on
implementing this Strategy, including integrating this Strategy with NOAA Fisheries’ North
Atlantic Right Whale Road to Recovery●

To provide regular and predictable opportunities for partners and stakeholders to comment on
and contribute to the Strategy via subsequent updates of this “living” document●

To develop a collaborative environment to provide for interaction between stakeholders andpartners●

To emphasize scientific processes, including scientific integrity, peer-reviewed publications,scientific presentations, independent peer review, and publicly accessible data and documents●

To incorporate Indigenous and Local Ecological Knowledge●

To conduct outreach on the Strategy from development through implementation

Communication and outreach will consist of the following methods:●

Publications: Peer review is foundational to the scientific process (USGS Fundamental Science
Practices: Peer Review).20 Peer-reviewed publications ensure effective experimental
methodology and wide dissemination of results from the Strategy.

●

Presentations: NOAA Fisheries and BOEM will be proactive in presenting and communicating
the Strategy to scientists, policy makers, partners, Tribes, stakeholders, and the public,

20 www.usgs.gov/survey-manual/5023-fundamental-science-practices-peer-review

BOEM and NOAA Fisheries North Atlantic Right Whale and Offshore Wind Strategy| 22whenever appropriate. Such meetings may include scientific conferences, regional planningmeetings, workshops, and information seminars.

3.3●

Workshops: As new information becomes available, workshops will be used to further progresson different components of the Strategy. These workshops will serve to develop and inform
specific areas related to the Strategy as new information warrants.

●

Solicitation of Comments: There will be opportunities for partners and the public to provide
comments and input on the Strategy. NOAA and BOEM will share information on the public
input process as the initiative evolves.

●

Public Access to Information: Relevant documents will be posted online and available to the
public on a website dedicated to this Strategy.

●

Press Releases and Science Briefs: All important events—such as relevant meetingannouncements and start and completion of projects and plans—will be announced publicly via
press releases.

●

Independent Scientific Peer Review: Where appropriate, independent peer-review panels will
evaluate different components of the Strategy, such as associated research plans, changes instatistical designs, and new analyses based on new data.

Implementation and Timeline

As noted above, BOEM and NOAA Fisheries will form a joint implementation group for this Strategy. An
important first step is to request dedicated personnel from both agencies to coordinate, facilitate, andsupport ongoing activities to implement this Strategy. Another step is to seek support for continuing andimplementing the actions identified in this Strategy.21 This support will involve working with partners(Section 4) and identifying financial resources (Section 5) to implement this Strategy. Given that theStrategy is currently not fully resourced, it is premature to develop a specific timeline for completing theactions and meeting the goals defined herein.
BOEM and NOAA Fisheries recognize that there is still additional work necessary for the two agencies todevelop joint guidance and information for developers. For example, BOEM recently published the
Notice of Intent (NOI) Checklist22 and Marine Acoustic Modeling and Measurement Guidelines.23 Also, as
this Strategy was developed, a number of topics were identified through internal agency discussions andfrom public comment. These topics are described in Appendix C and require further development toassess if and how they integrate with the actions identified in this Strategy. As these topics are further
developed, they may be included in future updates to this living Strategy document. This ongoing work
will contribute to the Strategy’s vision—to protect and promote the recovery of North Atlantic rightwhales while responsibly developing offshore wind energy. Furthermore, this ongoing work willrecognize the dire status of NARWs and the uncertainty around the effects of OSW development on
NARWs and their habitat.

21

Note that many of the actions identified in this strategy serve multiple purposes and are part of NOAA Fisheries’ broader
North Atlantic Right Whale Road to Recovery.

22 www.boem.gov/sites/default/files/documents/renewable-energy/state-activities/BOEM%20NOI%20Checklist.pdf
23 www.boem.gov/node/30991

BOEM and NOAA Fisheries North Atlantic Right Whale and Offshore Wind Strategy

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3.4

Priority Actions

The list below identifies a prioritized list of actions to achieve priority research and mitigation needs:
OBJECTIVE 1.1: Refine existing, and develop additional, mitigation and monitoring measures,
including those that consider new technologies, that are effective at avoiding or minimizing effectsof OSW projects on NARWs, individually and cumulatively. Review and update these measures (on acase-by-case basis or programmatic basis) as new information and technologies become available.
Action 1.1.4: Support research to develop new avoidance and minimization technologies andincorporate advancement in NARW detection technologies as they occur.
OBJECTIVE 1.2: Prioritize research, development, and implementation of mitigation on quieting
technology and methods to reduce noise levels for all OSW phases.
OBJECTIVE 1.3: Develop risk-analysis and decision-support tools to improve how project-specific andcumulative environmental effects from OSW are evaluated for NARWs and their habitat considering
each primary threat to NARW recovery related to OSW, including entanglement, vessel strike,acoustics/noise, and changes in habitat and habitat use (including prey).
The following are the key tools to develop in this element:●

Action 1.3.3: Expand/modify Expert Relativistic Framework to address project-level andcumulative effects of noise and then noise plus other stressors. (Although this currently
focuses on noise, it could be expanded into a more comprehensive cumulative effects trade
off analysis.)●

OBJECTIVE 1.4: Improve marine spatial planning tools and approaches for OSW siting to
inform decision-making and support avoiding impacts as a first priority and mitigating
impacts as necessary.

●

Action 2.3.5: Conduct a risk assessment and improve understanding of how OSW
development will impact features of NARW critical habitat—as well as “high-value habitat”
per NOAA’s Mitigation Policy—and policy; develop strategies for how these impacts can be
avoided or minimized.

OBJECTIVE 2.1: Develop and disseminate a research plan that identifies key data gaps related to
NARW and OSW development and details how to work with partners, stakeholders, and other ocean
users to fill data gaps. The research plan will include a variety of research methods (e.g., acoustic
and vessel surveys, aerial surveys, tagging, eDNA, health assessments) appropriate to the question
being addressed.
●

Action 2.1.3: Review resources available and perform funding gap analysis on the priority
research questions identified in this Strategy.

OBJECTIVE 2.1: Support the development of studies, particularly those with sufficient statisticalpower, to predict and detect changes in NARW ecology, demographics, and health resulting from
OSW development (e.g., changes in foraging activity, residency in key habitats, displacement) atvarious scales (e.g., turbine, development, regional, ecosystem).

BOEM and NOAA Fisheries North Atlantic Right Whale and Offshore Wind Strategy

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●

Action 2.2.4: Develop a long-term PAM network to strategically collect baseline andsoundscape data.

●

Monitor and assess how OSW development changes NARW risk of vessel strikes andentanglement, including risk from OSW development itself, as well as risk from non-OSW
activities that are influenced by OSW development (e.g., shifts in fishing or vessel activity
due to construction and operation of OSW projects).

OBJECTIVE 3.1: Develop long-term and proactive coordination strategies, including establishing a
joint BOEM-NOAA Fisheries NARW and OSW Strategy implementation group, and share outreachand communications plans. This implementation group will engage regularly with partners, Tribes,
and stakeholders in a variety of ways such as informal meetings, formal Requests for Information,and presentations to the RWSC and the NARW Consortium.
●

Action 3.1.1: Form a joint Agency implementation group to fulfill the goals of this Strategy.

●

Action 3.1.2: Develop an outreach and communications plan that includes schedules forsoliciting and vetting adjustments periodically.

BOEM and NOAA Fisheries North Atlantic Right Whale and Offshore Wind Strategy| 25

4 Partners
The Strategy emphasizes a collaborative approach to support the protection, and promote the recovery,of NARW while responsibly developing OSW. Engagement with federally recognized Tribes, Federal andState agencies, industry, partners, stakeholders, and other ocean users will be critical to successfully
implementing the Strategy. Though not an exhaustive list, the following represents anticipated key
partners.

4.1

Government

The Bureau of Safety and Environmental Enforcement (BSEE) promotes safety, protects theenvironment, and conserves resources offshore through vigorous regulatory oversight and enforcement.
The agency ultimately will work to ensure that OSW development lessees and operators comply with all
required laws and regulations, and requirements in leases, plans and permits, including applied
mitigations and conditions of approval. Under 30 C.F.R. 285.417(2), BSEE has the authority to suspend
operations “when continued activities pose an imminent threat of serious or irreparable harm or
damage to natural resources; life (including human and wildlife); property; the marine, coastal, or
human environment; or sites, structures, or objects of historical or archaeological significance.” Moreinformation is available at www.bsee.gov.
NOAA Office of National Marine Sanctuaries is the trustee for a network of underwater parks, including
Stellwagen Bank and Gray’s Reef National Marine Sanctuaries in the U.S. Atlantic. Stellwagen Bank
National Marine Sanctuary is one of the world’s premiere whale-watching destinations and a historicallyimportant fishing ground. Gray’s Reef National Marine Sanctuary is a natural live-bottom reef and is partof the NARW calving grounds. NOAA Fisheries and NOAA National Marine Sanctuaries share NOAA’s
mission to 1) understand and predict changes in climate, weather, ocean, and coasts; 2) share thatknowledge and information with others; and 3) conserve and manage coastal and marine ecosystems
and resources. More information is available at sanctuaries.noaa.gov/about.
The Marine Mammal Commission is an independent government agency charged by the MMPA tofurther the conservation of marine mammals and their environment. The Commission works to ensurethat marine mammal populations are restored and maintained as functioning elements of healthymarine ecosystems. They provide science-based oversight of domestic and international policies andactions of Federal agencies with mandates to address human impacts on marine mammals and theirecosystems. More information is available at www.mmc.gov.
The U.S. Navy is responsible for compliance with a suite of Federal environmental laws and regulations
that apply to marine mammals and other marine protected species, including the ESA and MMPA. As
part of the regulatory compliance process associated with these Acts, the Navy is responsible formeeting specific requirements for monitoring and reporting on military readiness activities involving
active sonar and underwater detonations from explosives and explosive munitions. These military
readiness activities include Fleet training events and Navy-funded research, development, test, andevaluation activities. The U.S. Navy, BOEM, and NOAA Fisheries have partnered for decades on issues
related to marine mammal and endangered species protection and recovery. More information isavailable at www.navy.mil.

BOEM and NOAA Fisheries North Atlantic Right Whale and Offshore Wind Strategy| 26

The U.S. Department of Transportation’s Maritime Administration (MARAD) is responsible for
America’s waterborne transportation system. MARAD supports the technical aspects of the U.S.
maritime transportation infrastructure, such as ships and shipping, port and vessel operations, national
security, environment, and safety. MARAD promotes the use of waterborne transportation and ensuresthat its infrastructure integrates seamlessly with other methods of transportation. More information isavailable at www.maritime.dot.gov.
The Department of Energy supports a broad portfolio of OSW research, development, anddemonstration projects and continues to work jointly with the Department of the Interior to advance
OSW development. More information is available at www.energy.gov/eere/wind/wind-energytechnologies-office.
The Environmental Protection Agency works to protect human health and the environment. The agency
reviews all Federal environmental impact statements prepared by other agencies under NEPA andpermits projects under the Clean Air Act. More information is available at www.epa.gov.
The National Science Foundation is an independent Federal agency created by Congress in 1950 topromote the progress of science; to advance national health, prosperity, and welfare; and to secure
national defense. More information is available at www.nsf.gov.
The Deputy Commandant for Operations (DCO) of the U.S. Coast Guard is charged with developing andoverseeing the execution of operational planning, policy, and international engagement at the strategiclevel. Additionally, it establishes and maintains relations with interagency partners and maritime
stakeholders to support policy development and resource acquisition. The DCO also is charged withensuring the alignment within mission areas to optimize mission execution as the recognizedinternational leader of Maritime Safety, Security and Stewardship. More information is available atwww.dco.uscg.mil.
The U.S. Army Corps of Engineers is an engineer formation of the U.S. Army with three primary mission
areas: Engineer Regiment, military construction, and civil works. The Corps’ mission is to deliver vitalengineering solutions, in collaboration with partners, to secure our Nation, energize our economy, andreduce disaster risk. The Corps also has a role in authorizing certain components of OSW projects
through its implementation of Section 10 of the Rivers and Harbors Act and Section 404 of the Clean
Water Act. More information is available at www.usace.army.mil.
Federally Recognized Tribes are critically important partners, and NOAA Fisheries and BOEM will work
to ensure timely and meaningful government-to-government consultation on this Strategy andengagement with Tribes on wind-related actions affecting NARW, including follow-up and appropriate
action. The agencies recognize the cultural and spiritual significance of the NARWs to Tribes andIndigenous Peoples.
States set renewable energy goals and facilitate agreements for the purchase of OSW. States(individually and through the Atlantic States Marine Fisheries Commission) also are important partners
in living marine resource management, working closely with NOAA on sustainable fisheries, wildlife
conservation, aquaculture development, and habitat conservation. Some States have been proactive inestablishing developer-supported funds that support data collection priorities and communication

BOEM and NOAA Fisheries North Atlantic Right Whale and Offshore Wind Strategy| 27mechanisms (including the Responsible Offshore Science Alliance). States may review OSW lease sales
and projects in Federal waters under Section 307 of the Coastal Zone Management Act (CZMA).
However, State CZMA review of OSW projects is not automatic; it depends on whether State review isauthorized pursuant to NOAA’s CZMA regulations at 15 C.F.R. Part 930.
Fisheries Management Organizations (including the South Atlantic, Mid-Atlantic, and New England
Fisheries Management Councils and Atlantic States Marine Fisheries Commission) comprise fisheries
stakeholders along the East Coast and are bodies that advise NOAA Fisheries (and the States withrespect to the Commission) on the sustainable management of our Nation’s fisheries under the
Magnuson-Stevens Fisheries Management and Conservation Act, the Atlantic Coastal Fisheries
Cooperative Management Act, and various State laws. These organizations have been working withNOAA Fisheries for years to reduce the impact of fisheries on marine mammals and endangered andthreatened species.
Regional Ocean Partnerships include the Northeast Regional Ocean Council and Mid-Atlantic Regional
Council on the Ocean and are State and Federal partnerships that address ocean and coastal issues froma regional perspective. Both councils augment existing governance structures to generate new
information and facilitate communication to advance resource management priorities. Moreinformation is available at www.northeastoceancouncil.org and www.midatlanticocean.org.
Fisheries and Oceans Canada is responsible for safeguarding Canadian waters and managing Canada’s
fisheries and oceans resources. The agency conducts science and develops regulations to promote theprotection and recovery of NARW in Canadian waters and collaborates on transboundary research andmanagement efforts with NOAA Fisheries through discussions from leadership to staff levels. Moreinformation is available at www.dfo-mpo.gc.ca/index-eng.html.

4.2

Industries

OSW energy leaseholders, grantees, operators, and associated entities hold leases and authorizations
to conduct geophysical surveys and to construct, operate, and maintain OSW facilities. Industry is
responsible for implementing conditions of those authorizations to avoid and minimize the impacts of
OSW development on NARWs. Proactive engagement of industry to implement approaches to OSWdevelopment beyond regulatory requirements is an important component of this Strategy.
Commercial and recreational fishing industries comprise a highly diverse group (fishermen, dealers,
processors, retailers, restaurants, and suppliers) involved in catching fish and shellfish, and include thecommunities that depend on these industries. The fishing industry will be affected by the developmentof OSW. NOAA Fisheries engages with this community to protect and recover marine mammals andendangered and threatened species. Many members of this community are participating in modifying
gear to reduce risk to NARWs, including participation in the development of Ropeless or On-Demand
Fishing to reduce entanglement risk.
Other industries relevant to this Strategy include commercial shipping, whale watching, aquaculture,and ecotourism. We will work with these entities on relevant aspects of this Strategy.

BOEM and NOAA Fisheries North Atlantic Right Whale and Offshore Wind Strategy

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4.3

Academia/Research Organizations

The Regional Wildlife Science Collaborative for Offshore Wind (RWSC) was cooperatively establishedand is led by four sectors: Federal agencies, states, eNGOs, and the OSW industry. The RWSC supports
research and monitoring on wildlife and OSW by identifying priorities for scientific research andmonitoring at the project, regional and ecosystem-wide scales; coordinating and aligning funding tomeet those priorities; and ensuring appropriate data and standards are in place to support science
priorities. Working with RWSC is a priority for BOEM and NOAA. The RWSC has developed a draft
Science Plan,24 and BOEM and NOAA will work with RWSC to align activities. More information at
rwsc.org.
The North Atlantic Right Whale Consortium includes stakeholders from a variety of research and nongovernmental groups who share a common interest—research and using the results of that research toformulate science-based conservation measures to protect NARW. More information atwww.narwc.org.
The Atlantic Scientific Review Group (ASRG) advises NOAA Fisheries on the status of marine mammal
stocks under Section 117 of the MMPA. The ASRG is a representation of marine mammal and fisheryscientists and members of the commercial fishing industry mandated to review the marine mammal
stock assessments and provide advice to the NOAA Assistant Administrator for Fisheries. (Moreinformation at www.fisheries.noaa.gov/national/marine-mammal-protection/scientific-reviewgroups#atlantic-scientific-review-group)
The NARW Recovery Plan Implementation teams advise NOAA Fisheries on issues related to the status
and conservation of NARWs. These multi-disciplinary recovery teams are appointed by NOAA Fisheries
under the ESA to assist with the development and implementation of the NARW recovery plan. The
Northeast team (NEIT) advising NOAA on NARWs from Maine to Virginia and the Southeast team (SEIT)
advising NOAA on NARWs from North Carolina to Florida.
Scientists from academia and other public and private institutions are actively researching topics related
to NARWs and OSW. Collaboration with scientists is needed to identify efficiencies and integrate
relevant data, as appropriate, in analyses to fulfill the goals and priorities of this Strategy. Examples
include, but are not limited to, the Anderson Cabot Center for Ocean Life at the New England Aquarium,
the Center for Coastal Studies, and Duke University25.

4.4

Non-Governmental Organizations

Environmental Organizations in general have a mission to protect the environment, and many are
specifically interested in the protection and recovery of NARWs, as well as the advancement of offshore
renewable energy. Each particular organization has different focal areas and approaches, and different
working relationships with BOEM and NOAA Fisheries.

24 rwsc.org/science-plan/#chapters25

offshorewind.env.duke.edu

BOEM and NOAA Fisheries North Atlantic Right Whale and Offshore Wind Strategy| 29

5 Financial Resources
The effort to investigate, monitor, and mitigate the impact of OSW development on NARWs is complex
and will require a significant amount of resources. The scale of OSW development along the Atlantic
Coast continues to increase; thus, the scale needed for research and monitoring, mitigation anddecision-support tools, and coordination also increases. The complexity, cost, and longevity of this effort
mean that multiple funding sources will be needed to meet the goals of this Strategy. Listed below aresome of the potential funding sources the agencies hope to collaboratively leverage, to the extent
permitted by applicable law, to resource the Strategy.
NOAA Programs—As supported through congressional appropriations and supplemental funding, NOAA
Fisheries conducts science related to NARWs, provides scientific support for the regulatory process, hasregulatory responsibilities related to NARW status under MMPA and ESA, and is involved in the review
and approval of OSW development activities. In addition, as authorized by the Consolidated
Appropriations Act of 2023, NOAA Fisheries is developing a strategic partnership with the National Fish
and Wildlife Foundation to support activities that address the lethal and sublethal effects of humanactivities on NARWs using congressional appropriations, as well as donations. Funding through the
Inflation Reduction Act also provides substantial support for NARW science much of which is relevant to
the Research and Monitoring goal of this Strategy. Although these funds are not specifically dedicated tosupporting this Strategy, there is significant overlap, including support for expanding PAM for NARW andfor developing technologies to reduce vessel strike risk. Finally, there may be other resources within
NOAA more broadly, outside of NOAA Fisheries, that may be appropriate to use to further the goals of
this Strategy. This Strategy can be used to help direct available funding, identify further funding needs,
and develop partnerships to meet the shared vision to protect and promote the recovery of NARWs
while responsibly developing OSW energy.
BOEM Environmental Studies Program—BOEM’s Environmental Studies Program (ESP)26 develops,
funds, and manages rigorous scientific research specifically to inform policy decisions on thedevelopment of energy (both traditional and renewable), mineral resources, and carbon sequestrationon the OCS. BOEM’s ESP has an annual budget (of about $30 million) to support new and ongoingprojects. Its research covers physical oceanography, atmospheric sciences, biology, protected species,
social sciences, and economics, submerged cultural resources, environmental fates and effects, climate
science and conservation, and more. The ESP also supports research needs of BOEM’s Center for Marine
Acoustics.27 Given the large OCS area under BOEM jurisdiction (approximately 3.2 billion acres),leveraging partnerships to satisfy common scientific needs is a central component of BOEM’s approach.
Bureau of Safety and Environmental Enforcement (BSEE)—BSEE receives funding to support BOEM’s
environmental compliance and enforcement needs for joint OCS operations. However, BSEE’s
Environmental Compliance Program (ECP) will need to dedicate additional staff and operational funding
to support the tasks identified in this Strategy. Additionally, BSEE’s Technology Assessment Program(TAP), as well as new and emerging programs and the renewable energy program are available tosupport mission-specific research of equipment and operations that have the potential to impact NARW
26

www.boem.gov/environmental-studies

27

www.boem.gov/center-marine-acoustics

BOEM and NOAA Fisheries North Atlantic Right Whale and Offshore Wind Strategy| 30and/or their habitat. Findings from such research would be available to assist with policy development
and decision-making tools that can focus on reducing risks to NARWs through the development of
improved mitigation measures. It is expected that BSEE Renewable Energy program leads will work with
ECP and TAP management to best address NARW research needs.
OSW Developer Support—Developers can support this effort through complying with requirements ofproject approvals and authorizations or through voluntary efforts to fund or carry out actions related tothis Strategy. As part of this Strategy, BOEM and NOAA Fisheries will continue to identify the impacts of
OSW development on NARWs and ways for developers to mitigate and monitor these impacts. To aid inthis effort, Appendix B includes development of measures that could be implemented as lease terms,
plan conditions, or other mechanisms. BOEM and NOAA Fisheries highly encourage developers tocoordinate and share plans, results, and data to help improve the efforts and monitor progress on
addressing the information needs under this Strategy.
Other Support—There are elements of this Strategy that could be supported by other entities. Suchsupport should fit into the overall goals of the Strategy.
●

Other Federal Agencies—Other Federal agencies, such as the Department of Energy, havefunded environmental and technology improvements related to OSW development.

●

States—States are establishing programs to examine and mitigate the effects of OSWdevelopment on State resources. This Strategy will include coordinating with States tounderstand and integrate their efforts with Strategy implementation.

●

Non-Governmental Organizations (NGOs)—Various NGOs, foundations, and philanthropicinterests have interests related to marine ecosystem science, the conservation of protected
species, and the management of OSW development. We expect that some components of thisStrategy could be supported by NGOs such as The National Offshore Wind Research andDevelopment Consortium.

●

Academic Researchers and Institutions—Academic researchers can align their work with thisStrategy, working on priorities identified here and communicating results with NOAA Fisheries
and BOEM.

BOEM and NOAA Fisheries North Atlantic Right Whale and Offshore Wind Strategy| 31

APPENDIX A: NARW and OSW Strategy Action Plan Details
Actions to meet prioritized research and mitigation needs are identified with an * (see Section 3.4)

GOAL 1: Mitigation and Decision-Support Tools
Develop, use, and evaluate measures that avoid or minimize impacts of OSW activities on NARWs andtheir habitat. Establish quieting performance standards for OSW. Work to improve and develop tools to
support decision-making as it relates to OSW development and NARW recovery. Ensure mitigation anddecision-support tool development are undertaken in close coordination with those entities involved inregulation, rulemaking, and decisions related to NARWs and OSW.
OBJECTIVE 1.1*: Refine existing, and develop additional, mitigation and monitoring measures, including
those that consider new technologies, that are effective at avoiding or minimizing effects of OSW
projects on NARWs, individually and cumulatively. Review and update these measures (on a case-by-casebasis or programmatic basis) as new information and technologies become available.
No.

Action1.1.1

Periodically review, evaluate, and update avoidance and minimization measures that canbe implemented or required during all phases of OSW development, both at projectspecific and regional scales (Appendix B).

1.1.2

Work to ensure that all efforts to develop recommendations or requirements foravoidance, minimization, and monitoring measures are complementary to and consistent
with NEPA analyses, ESA and Essential Fish Habitat consultations, and MMPA
authorizations.

1.1.3

Track evolving mitigation technologies and international mitigation strategies and/or
policies.

1.1.4*

Support research to develop new avoidance and minimization technologies andincorporate advancement in NARW detection technologies as they occur [see also Goal 2:
Research and Monitoring].

1.1.5

Encourage earlier timelines for submission of project-specific mitigation and monitoringplans to allow agencies sufficient time to review plans and incorporate of any agencyidentified changes (refer to NOI checklist28).

28 www.boem.gov/node/30996

BOEM and NOAA Fisheries North Atlantic Right Whale and Offshore Wind Strategy| 32

OBJECTIVE 1.2*: Prioritize research, development, and implementation of mitigation on quieting
technology and methods to reduce noise levels for all OSW phases. 29
No.

Action1.2.1

Develop and implement quieting performance standards for construction activities (e.g.,pile driving and UXO detonation).

1.2.2

Advance quieting technologies and methods (e.g., foundation types).

1.2.3

Promote integration of quieting technologies into all OSW vessels (new and existing) bycollaborating with the Department of Energy, Maritime Administration, and developers.
Consider engaging with individual ports and port authorities in setting vessel quieting
goals.

29 NOAA Fisheries strongly supports the use of quieter sources and techniques. Based on feedback from multiple stakeholders,

NOAA Fisheries wishes to clarify that the current differences in NOAA Fisheries’ marine mammal behavioral harassment
thresholds between intermittent (e.g., impact pile driving) and continuous sources (e.g., vibratory pile driving) does not meanthat innovative techniques using continuous sources will be impeded or penalized through the regulatory process (e.g., bemore concerning in the context of hearing impairment [temporary or permanent threshold shifts] and potential impacts on
prey species). NOAA Fisheries has begun the process of developing updated thresholds for behavioral disturbance, which will
undergo extensive internal, peer, and public review. NOAA Fisheries is actively supporting the use of quieter technologies(continuous or otherwise), intends to facilitate compliance processes wherever possible, and recommends dialogue with theagency before assumptions are made regarding the requirements or limitations for new or quieter technologies.

BOEM and NOAA Fisheries North Atlantic Right Whale and Offshore Wind Strategy| 33

OBJECTIVE 1.3: Develop risk-analysis and decision-support tools to improve how project-specific andcumulative environmental effects from OSW are evaluated for NARWs and their habitat considering eachprimary threat to NARW recovery related to OSW, including entanglement, vessel strike, acoustics/noise,and changes in habitat and habitat use (including prey).

30

No.

Action1.3.1[Cumulative] Consider Population Viability Analysis & Cumulative Effects modeling (e.g.,entanglement, vessel strike, acoustics/noise, and climate-driven changes in habitat andhabitat use (including effects to prey)). Multipath processes underway and when available,
for example:●

NOAA Fisheries Population Evaluation Tool (PET) Subgroup’s analysis●

Sea Mammal Research Unit – Interim Population Consequences of Disturbance(iPCoD) model with NARW case study

1.3.2[Cumulative] Develop an approach for improving the assessment of cumulative andsynergistic impacts of all phases of all OSW on NARWs considering existing and future
multiple stressors and cumulative effects, including those related and unrelated to OSW(e.g., fishing, climate change).

1.3.3*[Noise] Expand/modify Expert Relativistic Framework to address project-level andcumulative effects of noise and then noise plus other stressors.

1.3.4[Noise] BOEM fund NARW population consequences of multiple stressors (PCOMS) expert
elicitation of noise/construction impacts on NARW behavior.

1.3.5[Noise] Secure long-term modeling capacity for the purposes of assessing acute, chronic,
and cumulative impacts of noise and scenario testing of mitigation strategies (to include
incorporation of PAM data).

1.3.6[Vessel Strike] Investigate use of modeling options (similar to the NOAA Fisheries Vessel
Strike Risk Assessment Model developed for 2022 proposed Federal Vessel Speed
Regulations) to assess vessel strike risk from OSW development beyond what would be
minimized by any finalized vessel speed rule modifications and to determine whether
additional mitigation measures are necessary.

1.3.7[Entanglement] Evaluate entanglement risk from appurtenances (e.g., cables) associatedwith the development of floating wind technology or biological monitoring activities
associated with OSW development. Develop approaches to reduce entanglement risk.

1.3.8[Entanglement] Understand how changes in fishing effort resulting from OSWdevelopment changes the risk profile for NARW entanglement in fishing gear.

1.3.9[Habitat Change] Explore adding a wind module to the NOAA Fisheries’ Large Whale
Entanglement Decision Support Tool30 to evaluate the relative impacts of OSW on NARW
habitat.

www.fisheries.noaa.gov/feature-story/decision-support-tool-helpful-those-finding-ways-reduce-whale-entanglement-fishing

BOEM and NOAA Fisheries North Atlantic Right Whale and Offshore Wind Strategy| 34

OBJECTIVE 1.4*: Improve marine spatial planning tools and approaches for OSW siting to inform
decision-making and support avoiding impacts as a priority and mitigating impacts as necessary.
No.

Action1.4.1

Identify new and emerging marine spatial planning tools and approaches to continue toinform responsible OSW siting.

1.4.2

Develop efficient data sharing protocols between all stakeholders to support effective
marine spatial planning efforts.

BOEM and NOAA Fisheries North Atlantic Right Whale and Offshore Wind Strategy| 35

GOAL 2: Research and Monitoring
Identify, support, coordinate, and conduct research and monitoring to better understand the current
status of NARWs (e.g., abundance, distribution, life history, health, habitat use, and ecologicalinteractions); understand the impacts to NARW from project-level and cumulative effects from multiple
projects; and evaluate and address any uncertainty associated with the effects of OSW development.
OBJECTIVE 2.1: Develop and disseminate a research plan that identifies key data gaps related to NARW
and OSW development and details how to work with partners, Tribes, stakeholders, and other ocean
users to fill data gaps. The research plan will include a variety of research methods (e.g., acoustic andvessel surveys, aerial surveys, tagging, eDNA, health assessments) appropriate to the question being
addressed.
No.

Action2.1.1

Continue to update the baseline of relevant current and future NARW research related to
OSW development.

2.1.2

Periodically review, evaluate, and update priority research questions.

2.1.3*

Review resources available and perform funding gap analysis on the priority researchquestions identified in this Strategy.

2.1.4

Complete scoping phase of the Standardizing Integrated Ecosystem Based Assessment byengaging stakeholders and establishing a “common” understanding of the issues using
Conceptual Modeling in the ecosystem-based management (EBM) approach (a BOEMfunded project).

2.1.5

Develop processes to meet best science available standards,31 as applicable (e.g.,
independent peer review of publicly available data and information, integration of new
with existing data/products).

2.1.6

Disseminate results regularly to inform new lease areas and projects.

2.1.7

Coordinate with the RWSC and Federal and State partners to evaluate new data andemerging data gaps and to develop data access and sharing guidelines.

2.1.8

The agencies, in consultation with federally recognized Tribes, develop an Indigenous
Knowledge Plan (IKP) for the NARW, consistent with White House guidance.32 Future
iterations of the joint strategy will incorporate information gathered under the IKP.

31 www.ecfr.gov/current/title-50/chapter-VI/part-600/subpart-D/section-600.315
32 www.whitehouse.gov/wp-content/uploads/2022/12/OSTP-CEQ-IK-Guidance.pdf

BOEM and NOAA Fisheries North Atlantic Right Whale and Offshore Wind Strategy| 36

OBJECTIVE 2.2: Support the development of studies with sufficient statistical power to predict and detectchanges in NARW ecology, demographics, and health resulting from OSW development (e.g., changes inforaging activity, residency in key habitats, displacement) at various scales (e.g., turbine, development,
regional, ecosystem).
No.

Action2.2.1

Continue and improve efforts to track NARW abundance, distribution, health,reproduction, survival, and habitat use.

2.2.2

Continue and expand long-term aerial and vessel-based survey efforts of NARWs (including
the NARW Catalog and University of Rhode Island sightings database).

2.2.3

Evaluate, design, and implement regional and project-based aerial and vessel surveys tofurther evaluate the impact of OSW development on NARW distribution and habitat use.

2.2.4*Develop a long-term PAM network to strategically collect baseline and soundscape data.
● Measure the short and long-term changes in local and regional soundscapes
during OSW construction and operations.
● Quantify spatial and temporal masking and potential loss of communication spacefor NARWs.
● Quantify NARW detection rates before, during, and after construction and during
operation.
● Monitor for shifting baseline potential associated with climate change.
● Establish a NARW acoustic database catalog.
● Establish and maintain a web portal of historical PAM data and incorporate BeforeAfter-Gradient surveys with NOAA’s National Centers for Environmental
Information to streamline long-term storage of data and data products.
● Inform spatial scales for future monitoring of the operational noise of larger, directdrive turbines that may be installed at Atlantic Coast projects.

2.2.5

Explore and expand the use of satellite data, unmanned systems (gliders or autonomous
underwater vehicles [AUVs]) and emerging technologies (e.g., eDNA) for NARW
distribution and habitat use.

2.2.6

Develop and deploy safe, long-duration satellite tagging telemetry technology for tracking
high-resolution movements of NARW in and around OSW.

2.2.7

Coordinate activities conducted as part of this Strategy with NOAA Fisheries and Fisheries
and Oceans Canada’s NARW monitoring plans.

2.2.8

Support continued development of NARW habitat models focused on predictive habitatuse (including results from 1.3 above).

2.2.9

Continue development and sampling of stress and health indicators (e.g., hormones,
microbiome, new biomarker studies, baleen) blended with remote and other Visual Health
Assessments methodologies.

2.2.10

Improve analysis of monitoring data through artificial intelligence, automated acoustic
image processing, and near real-time data availability.

BOEM and NOAA Fisheries North Atlantic Right Whale and Offshore Wind Strategy| 37

OBJECTIVE 2.3: Develop and support efforts to improve understanding of OSW impacts on
oceanographic and lower trophic level ecosystem processes for all foundation, turbine, mooring, andlayout types, with a particular focus on understanding impacts on the distribution and abundance of
NARW zooplankton prey.
No.

Action2.3.1

Collect priority data and other information from field surveys to understand NARW habitat
use in and around OSW developments.

A

Collect oceanographic, zooplankton, and benthic data in areas with and without NARWs.

B

Support quantification of existing zooplankton data in OSW energy areas.

C

Support research on the plankton species abundance and distribution in southern New
England (Gulf of Maine vs. offshore) and continue to evaluate any climate-changeinfluenced effects.

D

Assess energy density of potential prey resources.

E

Quantify NARW feeding preferences using DNA analysis of scat.

F

Link prey resources and oceanography with tagged NARWs.

G

Conduct dedicated process studies in Nantucket Shoals frontal region (for an example, seeWhite and Veit 2020) to better understand mechanisms linking bathymetry, tides, fronts,
zooplankton, and NARW.

H

Collection of oceanographic and ecological observations through robust integrated
monitoring programs within the Nantucket Shoals region and in the region surrounding
wind energy areas before and during all phases of wind energy development to assess theregion’s complex oceanography and to validate future model outputs with respect topotential hydrodynamic and ecological effects at turbine, wind farm, and regional scales(see National Academies of Sciences 2023).

I

Explore use of CODAR (high-frequency radar) to assess oceanographic drivers of
distribution of NARWs and their prey.

J

Explore and expand the use of satellite data, unmanned systems (gliders or AUVs), andemerging technologies for routine physical and biological oceanographic monitoring.

2.3.2

Align current oceanographic modeling efforts per National Academies of Sciences (2023)
to evaluate potential impacts to oceanographic processes from OSW, with an initial focus
on the southern New England project areas and subsequent focus on other OSW
development areas.

BOEM and NOAA Fisheries North Atlantic Right Whale and Offshore Wind Strategy

| 38

No.

Action2.3.3

Hold a workshop among modelers to compare oceanographic model approaches, benefits
and drawbacks of each, and appropriate level of commonality and differences toeffectively assess and compare research findings using a multi-model approach. Workshop
would focus on the models’ ability to accurately predict the● Physical environment driving zooplankton distributions● Likelihood of conditions that may aggregate zooplankton● Likely changes in copepod distribution between pre- and post-OSW construction

2.3.4

Synthesize and report on observed changes in oceanographic processes after several yearsof OSW operation.

2.3.5

Conduct a risk assessment and improve understanding of how OSW development will
impact features of NARW critical habitat—as well as “high-value habitat” per NOAA’s
Mitigation Policy—and policy. Develop strategies for how these impacts can be avoided orminimized.

BOEM and NOAA Fisheries North Atlantic Right Whale and Offshore Wind Strategy| 39

GOAL 3: Collaboration, Communication and Outreach
While this goal is not discrete from the previously identified goals in this Strategy, BOEM and NOAA
Fisheries recognize that continued collaboration between the two agencies and partners is needed forthe success of this Strategy. Further, the two agencies recognize that internal and external
communication and outreach are important for the success of this Strategy. NOAA Fisheries and BOEM
will have a transparent process for communication and outreach to support all three goals of thisStrategy. BOEM and NOAA Fisheries will develop and implement this Strategy by strengthening
partnerships, combining resources, and sharing and communicating information. BOEM and NOAA
Fisheries will also ensure professional, transparent, and equitable communication; and engagement with
Tribes, Federal and State agencies, partners, and stakeholder groups.
OBJECTIVE 3.1*: Develop long-term and proactive coordination strategies, including establishing a joint
BOEM-NOAA Fisheries NARW and OSW Strategy implementation group, and share outreach andcommunications plans. This implementation group will engage regularly with partners, Tribes, andstakeholders in a variety of ways such as informal meetings, formal Requests for Information, andpresentations to the RWSC and the NARW Consortium.
No.

Action3.1.1*

Form a joint agency implementation group to fulfill the goals of this Strategy.

3.1.2*Develop an outreach and communications plan that includes schedules for soliciting andvetting adjustments periodically.

3.1.3

Conduct meetings with partners to provide periodic updates and receive feedback, as
needed.

3.1.4

Coordinate closely with the RWSC.

3.1.5

Develop a web page on “NARWs and Offshore Wind” to describe the current state of thescience, ongoing research and management efforts, and other outreach materials.

3.1.6

Identify similar activities and coordinate on or share progress of this Strategy to help
inform other NARW recovery efforts (e.g., NOAA Fisheries Road to Recovery).

BOEM and NOAA Fisheries North Atlantic Right Whale and Offshore Wind Strategy| 40

APPENDIX B: Avoidance and Minimization Measures
This appendix provides a general description of preliminary measures that BOEM and NOAA Fisheries
agree may have potential to avoid and minimize impacts to NARWs from OSW activities (siting todecommissioning). The agencies are sharing these measures to communicate the types of requirementsthat regulatory agencies and project proponents should consider for individual projects.
Consideration and implementation of these measures may be done at a project-specific scale, withdetails being provided in project-specific consultations, authorizations, or approvals. Other measures
may be implemented at a regional scale and may involve implementation by BOEM or NOAA Fisheries.
Note that this list of measures is not comprehensive and does not supersede measures that may berequired by the agencies during regulatory processes, such as COP approvals, ESA consultations, orprocessing of MMPA incidental take authorizations. Note also that commitments by developers to
implement any or all of these measures in proposed plans or other documents seeking authorizationfrom BOEM or NOAA Fisheries does not ensure approval of projects or other authorizations, as thosedecisions are made on a case-by-case basis.
The measures identified here will be updated as new information becomes available. As describedabove, NOAA Fisheries and BOEM are currently engaging in efforts outside this Strategy to develop
standard avoidance and minimization measures for OSW projects in the Atlantic OCS; the preliminary
measures identified here will complement those efforts. The most currently applied project-specificmitigation measures for OSW can be found on NMFS’ webpage on Incidental Take Authorizations for
Other Energy Activities (Renewable/LNG),33 which includes details on authorizations both in progress
and active, and on BOEM’s webpage on NMFS ESA Consultations34 for renewable energy, including
finalized Biological Opinions and/or Assessments.

Project Planning, Leasing, and Siting
NOAA Fisheries and BOEM will continue to collaborate to inform BOEM’s identification of wind energy
areas in consideration of the best available information on NARW distribution and habitat use. NOAA
Fisheries should provide BOEM information that BOEM should consider in identifying new wind energy
areas and new leases. This information may include marine spatial planning information, basic risk
assessments (e.g., high risk, medium risk, low risk) based on the best available scientific data anduncertainty, including predictive data on NARW distribution over the potential duration of the leasegiven anticipated changes in ocean conditions and the distribution and behavior of species due toclimate change. In general, BOEM will consider recommendations from NOAA Fisheries based on thebest available science and attempt to avoid issuing new leases in areas that may impact potential highvalue habitat and/or high-use areas for important life history functions such as NARW foraging,migrating, mating, or calving. BOEM and NOAA Fisheries will include potential lessees in theseconversations as early as possible to raise awareness of concerns over impacts to NARWs.

33 www.fisheries.noaa.gov/national/marine-mammal-protection/incidental-take-authorizations-other-energy-activities-

renewable
34 www.boem.gov/renewable-energy/state-activities/nmfs-esa-consultations

BOEM and NOAA Fisheries North Atlantic Right Whale and Offshore Wind Strategy| 41

After reviewing the best available information, if BOEM decides to initiate the planning and analysis
phase for potential future leasing in areas that overlap with NARWs and their habitat, BOEM will
partner with NOAA’s National Centers for Coastal Ocean Sciences to use marine spatial planningapproaches. The use of spatial planning tools and coordination with NOAA Fisheries will ensure best
available information is incorporated into those tools (Randall et al. 2022) and supports BOEM’s
iterative determination of optimal locations for wind energy areas with the least impact to NARWs
and their habitat.
The lease does not grant the lessee the right to construct any facilities; rather, the lease grants the rightto use the lease area to develop its plans, which must be approved by BOEM before the lessee can moveon to the next stage of the process. Developers must include measures to avoid and minimize impacts to
NARWs and their habitat in their COPs.
Developers should evaluate multiple project design options such as the type, number, size (physicaldimensions and power output), location, and orientation of wind turbines and offshore substations, witha focus on identifying design options that avoid and minimize impacts to NARWs and their habitat within
and with adjacent projects; tradeoffs for other resources need to be evaluated during project planning.

Site Characterization and UXO Surveys
Although the Renewable Energy Regulations currently are being modernized (88 FR 7657),35 lessees willcontinue to be required to submit physical characterization and baseline environmental survey data
results in support of a plan submission. BOEM will work with NOAA Fisheries to ensure that all survey
activities fall within the scope of existing ESA consultations and, if not, will initiate Section 7(a)(2)consultation under the ESA. The following are preliminary measures that BOEM and NOAA Fisheries
agree may apply to site characterization and UXO surveys:●

Equipment and Effort: Lessees should avoid using air guns and, wherever possible, only use
equipment that is unlikely to impact NARWs. Where the use of sub-bottom profilers (e.g.,compressed high intensity radar pulse [CHIRP], boomers, and sparkers) cannot be avoided,
lessees should implement project design criteria and best management practices, such as thoseoutlined in NOAA Fisheries ESA programmatic consultation (issued June 2021, as amended
September 2021)36 (Anderson 2021) (or any updated versions of this document or similar
guidance issued by the agencies) for all geophysical and geotechnical surveys carried out overthe life of the leases. Examples include the following: using lowest practicable sound source
levels; deactivating the acoustic source when not acquiring data or preparing to acquire data,
except as necessary for testing; and minimizing survey efforts to the maximum extent
practicable.

●

Clearance Zones: A clearance zone is an area around a sound source, monitored by PSOs,
wherein a detection of a NARW triggers a delay in turning on the sound source. The size ofclearance zones for NARWs are established in project-specific approvals. Use of clearance zones
can minimize the extent of exposure to acoustic sources and the amount and severity of
behavioral disturbance.

35 www.federalregister.gov/documents/2023/02/06/2023-02398/renewable-energy-modernization-rule-correction
36 media.fisheries.noaa.gov/2021-12/OSW-surveys-NLAA-programmatic-rev-1-2021-09-30-508-.pdf

BOEM and NOAA Fisheries North Atlantic Right Whale and Offshore Wind Strategy

| 42

●

Shutdown Zones: Shutdown zones are an area around a sound source, monitored by PSOs,
wherein a detection of a NARW triggers a shutdown of the source (i.e., a stop of using thesource). The size of shutdown zones are identified in project-specific approvals. Shutdown zones
can minimize the extent of exposure to acoustic sources and the amount and severity of
behavioral disturbance.

●

Protected Species Observers (PSOs): Use trained, third-party PSOs with no duties other than toeffectively implement mitigation and monitoring measures during survey activities. Adopt
standards for protected species monitoring (e.g., minimum visibility, PSO protocols). Locate
PSOs at the best vantage point(s) to ensure coverage of the entire visual clearance andshutdown zones, and as much of the behavioral harassment zones as possible. Ensure PSOs do
not exceed 4 consecutive watch hours on duty at any time, have a 2-hour (minimum) break
between watches, do not exceed a combined watch schedule of more than 12 hours in a 24hour period, and are well equipped (binoculars, infrared if appropriate).

●

Vessel Strike Risk Reduction: Vessel captains, trained crew members, and PSOs should maintaina vigilant watch for all protected species and slow down, stop their vessel, or alter course, as
appropriate and regardless of vessel size, to avoid striking any protected species. The presenceof a single individual at the surface may indicate the presence of submerged animals in thevicinity; therefore, precautionary measures should always be exercised upon the sighting of asingle individual. Developers should also monitor, daily, available sources of NARW presence inthe area vessels may be transiting. Vessels underway should not divert their course to approachany protected species. All vessels should have a dedicated observer watching for NARWs at all
times and slow to 10 knots or less at any time and/or location that NARWs may be present andat any time when visibility is poor. Any use of PAM in transit corridors to aid in detection andawareness of NARW presence should complement visual monitoring efforts.
All OSW-associated vessels must comply with all regulations for the protection of NARWs in
effect at the time, including vessel speed regulations and approach regulations (62 FR 6729; 73
FR 60173, 87 FR 46921). In addition, vessels must follow all vessel strike reduction measures, as
specified in individual project approvals (e.g., NOAA Fisheries MMPA Incidental Take
Authorizations and ESA Biological Opinions, and BOEM leases and conditions of COP approval).

Construction and Operation
For existing leases, lessees will submit a COP. BOEM’s regulations require that BOEM first analyze andevaluate the COP before approving, disapproving, or approving it with modifications (30 CFR 585.628(f)).
If disapproved, BOEM will inform the lessee of the reasons and allow the lessee an opportunity toresubmit a revised plan addressing the concerns identified. BOEM recently published the NOI
Checklist,37 based on BOEM’s regulations, and describes how BOEM will process incomplete COP
submissions. The checklist is designed to 1) provide clarity to lessees; 2) establish a pre-application andpre-NOI process with lessees and cooperating agencies that will benefit all stakeholders; and 3) improvethe efficiency of proposed OSW project reviews by avoiding delays to the NEPA analysis after the NOI
has been published. During the environmental review of the COP, BOEM will work with NOAA Fisheries
to ensure environmental review under applicable statutes evaluate measures to avoid (primary goal) or
37 www.boem.gov/node/30996

BOEM and NOAA Fisheries North Atlantic Right Whale and Offshore Wind Strategy| 43minimize (secondary goal) impacts to NARW and high-value habitat and/or high-use areas for importantlife history functions such as NARW foraging, migrating, mating, or calving. The results of theseenvironmental reviews, including any conditions that result from ESA consultation or an MMPA
authorization, will ultimately inform COP conditions of approval.
If new information becomes available indicating that activities previously authorized by BOEM through aplan approval (e.g., SAP, General Activities Plan [GAP], COP) are now resulting in an imminent threat ofserious or irreparable harm or damage (e.g., injury or mortality) to NARWs, BSEE has the authority tosuspend operations. Likewise, BOEM may require the lessee to submit a plan revision if activities
previously authorized by BOEM are resulting in undue harm to NARWs. The plan revision would detail
new measures that will be taken to increase protection of NARWs impacted by the activities authorizedunder the plan approval. BOEM will determine if the new measures are adequate and, if warranted,
could then reinitiate ESA Section 7(a)(2) consultation with NOAA Fisheries prior to approving any plan
revision. BOEM also will use any new information to inform future project decisions and mitigation
strategies. In addition, reinitiation under Section 7 of the ESA is required when certain conditions aremet (50 CFR § 402.16). The measures outlined below apply to foundation installation activities (e.g., piledriving and drilling) and other activities, including but not limited to, UXO detonation and cable landfall
construction or other pile-driving activities. Developers should work with the agencies when considering
the following:●

Foundation Installation Time/Area Restrictions: Project schedules should avoid installingfoundations during the time of year when NARWs are most likely to occur in the lease areas andalong vessel routes, including known areas of higher NARW density and persistence, andincluding, but not limited to, Nantucket Shoals, Cape Cod Bay, calving grounds, and designated
NARW critical habitat. Avoiding foundation installation during these times/areas also minimizes
vessel traffic; thereby lowering vessel strike risk. Time/area restrictions also minimize risks attimes when NARWs are predicted to be present, but monitoring of NARWs may not be effective.

●

Quieter Foundations and Impact Piling Noise Reduction: The agencies are committed torequiring developers to reduce noise levels during construction to the maximum extent
practicable and ensure actual noise levels are within the bounds of those analyzed within aproject’s environmental review process. Sound fields generated during impact pile driving
should be reduced to the maximum extent practicable with a goal of not exceeding NOAA
Fisheries’ Level A permanent threshold shift (PTS) limits for low frequency cetaceans (LFC) at
distances greater than 1,000 meters from each foundation. This would limit the potential for
PTS for species of greater concern, such as NARWs and other baleen whales (all considered LFC).
Although developed for LFCs and linked to acoustic thresholds used in the context of the MMPA
and ESA, implementation of this measure also is meant to afford protection to other groups ofmarine mammals, such as mid-frequency cetaceans and pinnipeds, as well as sea turtles andfishes. Application of the Level A LFC Received Sound Level Limit (RSLL) also reduces zones for
temporary threshold shift and behavioral impacts to some extent.
In order to reduce noise levels during construction, the agencies are committed to working withlessees to develop standards for determining where it would be preferred to use foundation
designs that do not rely on pile driving (e.g., gravity-based foundations), as well as to notdetonate UXOs when other means of removal are possible. Factors for consideration that

BOEM and NOAA Fisheries North Atlantic Right Whale and Offshore Wind Strategy| 44minimize impacts to NARWs and habitat may include engineering feasibility, impacts of thefoundation type on benthic resources and environmental conditions, and impacts of noise
during construction. Where pile driving and UXO detonations cannot be avoided, lessees should
use the most effective methodologies available to reduce noise to the maximum extent
practicable, including, but not limited to, use of noise abatement systems (e.g., double big
bubble curtains) and a hammer schedule that results in the lowest sound exposure level to
NARWs as possible.
●

Clearance Zones: Clearance zones are an area around a pile (or detonation location), monitored
by PSOs, wherein a detection (visual or acoustic) of a NARW triggers a delay of the start of theactivity. Use of clearance zones can limit 1) the potential that an activity would begin when a
NARW is close enough to a pile or explosion to experience mortality, serious injury, nonauditory injury, or auditory injury (e.g., PTS) and 2) the amount and severity of temporary
threshold shift and/or behavioral disturbance. The size of clearance zones for NARWs areproject and activity specific but, for foundation installation and UXO detonation, are generally
unlimited (i.e., any distance from PSOs or within a large PAM detection distance). PAM ofclearance zones should be carried out for 24 hours in advance of foundation installation
activities (e.g., pile driving and drilling) and other activities such as UXO detonation.

●

Shutdown Zones: Shutdown zones are an area around a pile (or other activity) that is monitored
by PSOs, wherein a detection (visual or acoustic) of a NARW triggers a stop of the activity. Use of
shutdown zones can avoid exposure of NARWs to noise or other conditions that could result inmortality, non-auditory injury, and auditory injury (e.g., PTS) and minimize the amount andseverity of temporary threshold shift and/or behavioral disturbance.

●

Protected Species Observers (PSOs): The agencies require use of trained, third-party PSOs withno duties other than to effectively implement mitigation and monitoring measures during
construction activities and are developing standards for protected species monitoring (e.g.,
minimum visibility, PSO protocols). PSOs are not construction personnel and must be approved
by NOAA Fisheries prior to deployment. PSOs must be located at the safest and best vantage
point(s) to ensure coverage of the entire visual clearance and shutdown zones, and as much of
the harassment zones as possible. PSOs must not exceed 4 consecutive watch hours on duty at
any time, have a two-hour (minimum) break between watches, not exceed a combined watch
schedule of more than 12 hours in a 24-hour period, and be well equipped to effectively monitor
for large whales during various conditions. During foundation installation and UXO detonation,
three PSOs are recommended at each platform (e.g., three PSOs at the pile-driving vessel andany secondary, dedicated PSO vessel(s) located further from the pile), with minimum
requirements to be included in project-specific approvals. If aerial-based PSO monitoring isused, the minimum number of PSOs will be included in project-specific approvals.

●

Sound Field Measurement: Sound field verification (SFV) will need to be conducted for activities
the agencies deem necessary, including but not limited to pile driving, UXO detonation, andoperations. To properly validate acoustic modeling results for pile driving, measurements should
be collected from each foundation installed. There is inherent variability in the sound levels
produced during foundation installation in a complex environment. Some variation can bepredicted based on foundation, construction, and environmental parameters. Lessees willconduct Thorough SFV Monitoring (defined as recording along a minimum of two radials with at

BOEM and NOAA Fisheries North Atlantic Right Whale and Offshore Wind Strategy| 45

least one radial containing three or more recorders) for the first three foundations of a project,
and when a foundation is to be installed with a substantially different set of values for theseparameters. The exact number of Thorough SFV Monitoring measurements per project cannot
be provided a priori, as different situations may require different measurements. The SFV
process should be sufficient to assess sound propagation from the foundation and the distances
to isopleths for potential injury and harassment. The measurements should be compared to themodeled PTS and Level B (behavioral) harassment zones for marine mammals (and the injury
and behavioral disturbance zones for sea turtles and ESA-listed fish), thus the plan should
include the target modeled sound levels that each monitored installation will stay below.
Interim results from each pile for which thorough monitoring is conducted would be submitted
to BOEM and NMFS within 48 hours of pile installation. Abbreviated SFV Monitoring consistingof a single acoustic recorder unit (at least a bottom and midwater hydrophone) at
approximately 2,460 feet (750 meters, with location dependent on project-specific details,
including consideration of the location of noise abatement systems) should be performed on
any foundation installations for which Thorough SFV Monitoring is not planned, to assess
whether any particular pile or location led to received levels above what was modeled. For
additional guidance refer to BOEM Nationwide Recommendations for Impact Pile Driving Sound
Exposure Modeling and Sound Field Measurement for Offshore Wind Construction andOperations Plans.38 BOEM may also develop additional guidance on requirements for instituting
and reporting SFV. SFV will be used to identify that developers are not generating noise levels
above those modeled and assumed in environmental reviews. If SFV suggests distances toharassment thresholds are being exceeded, developers must take action to reduce noise levels
to those modeled.
●UXO Detonation: The agencies are committed to working with Federal partners and lessees todevelop and implement standard protocols for addressing unexploded ordinances, including
implementation of best available technology to avoid or minimize exposure of NARWs and their
sensitive habitats to in-situ disposal (low order incineration or high order detonation). If disposal
is necessary, after demonstrating that avoidance through micrositing is not feasible, low orderincineration is preferred over high order detonations.

●

Vessel Strike Risk Reduction: Vessel captains, trained crew members, and PSOs should
maintain a vigilant watch for all protected species and slow down, stop their vessel, or altercourse, as appropriate and regardless of vessel size, to avoid striking any protected species. The
presence of a single individual at the surface may indicate the presence of submerged animals inthe vicinity; therefore, precautionary measures should always be exercised upon the sighting ofa single individual. Vessels underway must not divert their course to approach any protected
species. All vessels should have a dedicated lookout or PSO watching for NARWs at all times andslow to 10 knots or less at any time/location that NARWs may be present and at any time when
visibility is poor. Any use of PAM in transit corridors to aid in detection and awareness of NARW
presence should complement visual monitoring efforts. All OSW-associated vessels should
comply with all regulations for the protection of NARWs in effect at the time, including vessel
speed regulations and approach regulations (62 FR 6729; 73 FR 60173, 87 FR 46921). In addition,
vessels should follow all vessel strike reduction measures as specified in individual project

38 www.boem.gov/node/30991

BOEM and NOAA Fisheries North Atlantic Right Whale and Offshore Wind Strategy| 46

approvals (e.g., NOAA Fisheries MMPA Incidental Take Authorizations and ESA Biological
Opinions, and BOEM leases and conditions of COP approval).
●

Marine Debris and Gear: Implement routine clean ups of abandoned, lost, or otherwise
discarded fishing gear and/or other debris associated with OSW development within the lease
areas. Implement measures designed to avoid and minimize interaction between protected
species and any gear in the water that is related to OSW construction or operations, including
but not limited to anchor and buoy lines.

●

Adaptive Planning: Empirical data collected during construction and operations of all OSW
projects can be used to inform and improve the reliability of future risk assessments and inform
adaptive management of approved projects. Develop an adaptive framework to quickly
incorporate results from empirical data to resolve unanticipated issues so that impacts to
NARWs are minimized quickly and efficiently.

Decommissioning
Per BOEM’s regulations (30 CFR 585), all plans (Research Activities Plans [RAPs], SAPs, GAPS, and COPs)
must include a conceptual description of decommissioning methodologies. However, prior to any
decommissioning activities occurring, a detailed project decommissioning plan will be submitted to
BOEM for environmental and technical review. This review will be undertaken in consideration of
applicable laws and regulations, and best management practices at that time, including appropriate
measures to avoid and minimize impacts to NARWs from decommissioning activities. Decommissioning
applications must be submitted by Lessees to BSEE in accordance with 30 CFR 285.902.39

Project-Specific Monitoring Measures
Pre-construction monitoring is essential to document and understand the baseline conditions in a
project area. Long-term monitoring is also necessary to assess the environmental impact of projects
throughout construction and operations. Data collected prior to and during the COP approval process
will be used to evaluate the potential impacts of a project on NARWs and their habitat. The data
generated by the monitoring measures listed below will assist in assessing the impacts of OSWdevelopment on NARWs, their habitat, and habitat use.
During construction and operations, long-term monitoring and targeted monitoring (e.g., during piledriving) will assist in evaluating the effectiveness of mitigation measures, whether additional measures
are necessary to minimize unanticipated impacts, and the impacts of the project. Together withbroader-scale monitoring efforts, these project-specific monitoring measures will be used by BOEM andNOAA Fisheries to evaluate, track, and avoid and minimize impacts to NARWs. These monitoring studies
should be designed to also contribute to cumulative impact analyses to assess the spatial and temporal
accumulation of OSW development on NARWs, their habitat, and habitat use. BOEM and NOAA
Fisheries also encourage coordination of research and monitoring studies through the RWSC and the
NOAA Fisheries and BOEM Federal Survey Mitigation Strategy to increase effectiveness, utility, and data
sharing.

39 www.ecfr.gov/current/title-30/chapter-II/subchapter-B/part-285/subpart-I/subject-group-ECFR0c2b7ea7919f137/section-

285.902

BOEM and NOAA Fisheries North Atlantic Right Whale and Offshore Wind Strategy| 47

BOEM and NOAA Fisheries encourage scientifically rigorous monitoring studies that are standardized
across OSW development projects within the region. All monitoring studies and research activities
should be based on scientifically rigorous study designs. Regional experts should be consulted todevelop effective monitoring and study designs with adequate sample sizes and appropriate spatial andtemporal coverage to allow the detection of potential impacts of OSW developments on NARWs, theirhabitat, and habitat use. All monitoring study designs should be reviewed by BOEM and NOAA Fisheries
and, where appropriate, independently peer reviewed prior to initiation and then annually reviewed
during the study period. These designs should include clearly stated goals and objectives for monitoring
and use regionally standardized field and analytical methodologies.
To facilitate the application of data collected by developers, the agencies will develop reporting
standards and identify existing (or develop as necessary) databases for data storage and access (e.g.,
www.northeastoceandata.org). A centralized, publicly accessible data portal would allow for data to be
integrated across projects and queried to answer a range of scientific questions to inform management
decisions. The goal is for all monitoring data to be stored in standard format (e.g., RWSC standards for
PAM data processing and management)40 in an openly accessible repository to facilitate transparency,
data analysis, and sharing of information.
None of the preliminary monitoring measures below supersede measures that are or may be requiredby the agencies during regulatory processes such as COP approvals, ESA consultations, or processing of
MMPA incidental take authorizations. In addition, project-specific approvals may contain additional
measures. Note that the implementation of any or all of these measures by developers does not ensure
project or permitting approval as those decisions are made on a case-by-case basis.
The following preliminary monitoring measures may be considered by BOEM and NOAA Fisheries during
project environmental review processes, in addition to any other measures adopted by the agencies(e.g., from ESA Biological Opinions or MMPA ITAs):●

Ensure all environmental reviews are informed by baseline data on the use of the project area
by NARWs, to include at least 3 years of baseline data. Implement continued monitoring during
the construction period and for at least 3 years post construction to assess impact of the projecton NARWs and their habitat. Establish long-term monitoring for the duration of construction
and operations to evaluate the potential impacts on key components of the ecosystem (e.g.,
NARWs and their prey). Conduct monitoring using rigorous scientific designs with the intent of
measuring the impact of OSW development on NARWs, their habitat and habitat use, and theeffectiveness of measures described above. Report data in a timely manner and make publicly
available. See additional aerial survey and long-term PAM measures below.

●

Conduct monitoring to assess the impacts of the physical presence and operation of theturbines. Monitoring should assess changes in the atmospheric and oceanographic
environment—including benthic and pelagic habitats and oceanographic features (e.g.,
stratification and fronts)—particularly as these environments relate to NARW feeding behavior
and ecology.

40 rwsc.org/wp-content/uploads/2022/12/RWSC-PAM-Data-Management-Storage-Best-Practices.pdf

BOEM and NOAA Fisheries North Atlantic Right Whale and Offshore Wind Strategy

| 48

●

Conduct monitoring for changes to fishing operations and displacement of fishing effort into
other areas. Monitor changes in fishing activity to detect changes in bycatch or entanglement
rates of protected species, particularly NARWs.

●

Fully implement NMFS and BOEM Survey Mitigation Strategy and a Northeast Survey Mitigation
Program, including incorporating measures to implement necessary NARW survey mitigation
activities as lease term stipulations, as COP conditions, and by other means.

●

Develop and implement plans for research and monitoring to address new and emerging issues
and technology in a scientifically rigorous and systematic way. Consider including requirementsthat OSW infrastructure (e.g., turbine foundations, submarine cables, substations, and otherequipment) be instrumented to meet project and regional monitoring objectives.

●

When feasible, conduct aerial surveys for a minimum of 3 years prior to BOEM starting its
environmental review process in the lease areas and surrounding waters to collect baseline dataon the presence, abundance, distribution, and seasonality of NARWs, their habitat, and habitatuse. Surveys should follow a similar protocol to the aerial surveys conducted in the
Massachusetts and/or Rhode Island Wind Energy Areas and should be flown on a regular basis.
Surveys should continue during construction and operational phases of OSW development andbe used beyond monitoring purposes with the goal of assessing effects of OSW development on
marine megafauna species.

●

Use long-term PAM to develop baselines and monitor changes in the presence of marine
species, as well as changes in ambient noise due to operations for 1 year before construction
and up to 10 years post construction. The number of devices in each lease area should be
sufficient to ensure that vocalizing baleen whales could be detected based on the assumption of
a 10-kilometer detection range for NARW calls. The sampling rate of the recorders should
prioritize the detection of baleen whale vocalizations but also should have, at a minimum, thecapability to detect and store acoustic data on noise from vessels, pile driving, and wind turbine
generator operation.
Following the RWSC PAM data management best practices document41 would ensure that theappropriate steps are taken prior to deployment, sufficient metadata is captured, and the data
are processed and archived in a standardized fashion. The data will be processed to document,at the very least, the presence of baleen whale vocalizations, as well as standard metrics ofambient noise. Archiving the full acoustic record at National Centers for Ecological Information
will allow for complete transparency of the data. Baleen whale detections also will be submitted
to BOEM, BSEE, and NOAA Fisheries at least twice a year.
As an alternative to conducting PAM in its project area, the lessee may opt to meet thismonitoring measure through an annual deposit to BOEM’s Environmental Studies Program insupport of its Partnership for an Offshore Wind Energy Regional Observation Network(POWERON) initiative. The lessee’s contribution would cover activities within its lease area, suchas the purchase of instruments, annual deployments and refurbishment, data processing, andlong-term data archiving. Funding from BOEM—such as monies received through the Inflation
Reduction Act, other partners, and potentially other lessees—will support long-term PAM
throughout the region, which will enable broader-scale analyses on cumulative effects to marine

41 rwscollab.github.io/pam-data-mgmt/

BOEM and NOAA Fisheries North Atlantic Right Whale and Offshore Wind Strategy| 49species. Under this option, the lessee will be expected to cooperate with the POWERON team tofacilitate deployment and retrieval of instruments within the project area. If necessary, thelessee may request temporary withholding of the public release of acoustic data that has beencollected within its project area.
●

Use both long-term and real-time PAM to collect baseline information on the presence,
distribution, and seasonality of NARWs in transit routes and to minimize risk of vessel strike oftransiting vessels. Additionally, real-time PAM can be deployed beyond required monitoringzones to detect NARWs to provide better situational awareness for operators during
construction.

●

Monitor to implement mitigation (e.g., use PSOs and PAM) and identify the effectiveness of
mitigation measures.

●

If any additional telemetry technologies (e.g., satellite, acoustic, and multi-sensor D-tagging) are
adopted as part of monitoring, users should follow similar best practices described above,
including data sharing, storage in relevant network (e.g., Animal Telemetry Network [ATN], MidAtlantic Acoustic Telemetry Observation System), and archiving at the National Center for
Environmental Information. In addition, all animal tracking data should be made publicly
accessible within 18 months after data collection ends, acoustic and other archival tag data
should be submitted to the ATN web portal at a minimum of every 6 months during the life of a
project, and the fv months after data collection ends. Any future use of data in the publicdomain should be done in accordance with the ATN data sharing policy.

BOEM and NOAA Fisheries North Atlantic Right Whale and Offshore Wind Strategy| 50

APPENDIX C: Potential Actions to be Further Developed by the
Agencies During Implementation of the Strategy
As this Strategy was developed, a number of topics were identified through internal agency discussions
and from public comment. These topics require further development to assess if and how they integratewith the actions identified in this Strategy. Some items included in this appendix are in various stages ofdevelopment. As these topics are further developed, they may be included in future updates to thisliving Strategy document.
●

In order to comply with the regulatory requirements for results of environmental data to
support RAPs, SAPs, GAPs, or COPs as described in 30 CFR 585, developers may be able to electto direct established, appropriate levels of funding to BOEM to support environmental datacollection, as a lease or plan approval option. This approach would address, standardize, andcoordinate research needs and efforts. Mechanisms will be identified based on available
authority. In addressing research and monitoring needs identified in this Strategy, these funds
would conceivably assist in the implementation of the goals of this Strategy.

●

Continue to support research and monitoring to assess the effects of proposed OSW
development in leases south and west of Nantucket Shoals.

●oSupport the recommendations of the National Academy of Sciences Committee’s reporton the Evaluation of Hydrodynamic Modeling and Implications for Offshore Wind
Development: Nantucket Shoals.

oConduct research to better understand NARW foraging in the area and the potential
effects of OSW development on NARW prey and foraging habitat and behaviors.

Continue to work to evaluate the transferability of European OSW research, as well as evaluate
the current U.S. approaches, to better understand the potential of OSW structures to cause
habitat change, and the potential implications thereof to NARWs.
oSupport activities with the National Academy of Science42 and with the International
Council for the Exploration of the Sea●

Continue research to understand the potential effect of different turbine sizes and wind energy
development layouts/designs on NARW habitat and prey.

●

Improve availability and utility of Protected Species Observer data for conservation andmanagement uses, specifically in terms of NARW sightings and in understanding the impacts ofvessels and construction on NARW behavior and the potential for injury.

●

Develop criteria for nighttime and low-visibility monitoring plans to increase the potential for
effective monitoring of NARWs during activities carried out in these conditions and to minimize
the impact or potential impacts of OSW activities on NARWs or their habitats.

●

Develop a framework to implement BOEM and BSEE’s authority to suspend OSW operations if,
based on the best available decision-support tools available at the time, there is an imminent
threat of serious or irreparable harm or damage (e.g., injury or mortality) to NARWs.

42 www.nationalacademies.org/our-work/evaluation-of-hydrodynamic-modeling-and-implications-for-offshore-wind-development-nantucket-shoals

BOEM and NOAA Fisheries North Atlantic Right Whale and Offshore Wind Strategy

| 51

●

Continue to develop regional approaches to science and management.

●

Consider the criteria for how operators could develop underwater noise management plans forinclusion in a COP. For example, an underwater noise management plan could consider the daily
and/or seasonal amount of acoustic energy that will be introduced into the marine environment
over the lifetime of the project. The plan should describe how equipment, technology, and bestpractices will be used to produce the least amount of noise practicable to avoid and minimize
noise impacts to the environment. Every effort should be made to implement these low-noise
options, and where this is not practicable, justification would need to be provided as to why thisis not practicable.

●

Understand Level A LFC RSLL reduces zones for temporary threshold shift and behavioral
impacts to some extent, but more reduction may be needed. Consider working towards a more
stringent (or additional) RSLL aimed at further reducing impacts.

●

Establish a vessel noise management plan on best practices for vessel quieting and low-noise
equipment or operations per project and follow the most current International Maritime
Organization’s Guidelines to reduce underwater vessel noise, to the extent reasonable andpracticable.

BOEM and NOAA Fisheries North Atlantic Right Whale and Offshore Wind Strategy| 52

APPENDIX D: Monthly Densities of North Atlantic Right Whales in U.S.
Waters (2010–2019)

BOEM and NOAA Fisheries North Atlantic Right Whale and Offshore Wind Strategy| 53

Figure D-1. Density of NARWs in U.S. waters during the month of January (2010–2019)
Narrow lines leading from leases to land are cable route easements. Due to State/Federal jurisdiction, the easement shows as
ending at the State waters boundary where other State and Federal regulations apply. All leases with approved COPs will
include easements shortly after approval. Source: Roberts et al. (2023); Roberts et al. (2016).

BOEM and NOAA Fisheries North Atlantic Right Whale and Offshore Wind Strategy| 54

Figure D-2. Density of NARWs in U.S. waters during the month of February (2010–2019)
Narrow lines leading from leases to land are cable route easements. Due to State/Federal jurisdiction, the easement shows as
ending at the State waters boundary where other State and Federal regulations apply. All leases with approved COPs will
include easements shortly after approval. Source: Roberts et al. (2023); Roberts et al. (2016).

BOEM and NOAA Fisheries North Atlantic Right Whale and Offshore Wind Strategy| 55

Figure D-3. Density of NARWs in U.S. waters during the month of March (2010–2019)
Narrow lines leading from leases to land are cable route easements. Due to State/Federal jurisdiction, the easement shows as
ending at the State waters boundary where other State and Federal regulations apply. All leases with approved COPs will
include easements shortly after approval. Source: Roberts et al. (2023); Roberts et al. (2016).

BOEM and NOAA Fisheries North Atlantic Right Whale and Offshore Wind Strategy| 56

Figure D-4. Density of NARWs in U.S. waters during the month of April (2010–2019)
Narrow lines leading from leases to land are cable route easements. Due to State/Federal jurisdiction, the easement shows as
ending at the State waters boundary where other State and Federal regulations apply. All leases with approved COPs will
include easements shortly after approval. Source: Roberts et al. (2023); Roberts et al. (2016).

BOEM and NOAA Fisheries North Atlantic Right Whale and Offshore Wind Strategy| 57

Figure D-5. Density of NARWs in U.S. waters during the month of May (2010–2019)
Narrow lines leading from leases to land are cable route easements. Due to State/Federal jurisdiction, the easement shows as
ending at the State waters boundary where other State and Federal regulations apply. All leases with approved COPs will
include easements shortly after approval. Source: Roberts et al. (2023); Roberts et al. (2016).

BOEM and NOAA Fisheries North Atlantic Right Whale and Offshore Wind Strategy| 58

Figure D-6. Density of NARWs in U.S. waters during the month of June (2010–2019)
Narrow lines leading from leases to land are cable route easements. Due to State/Federal jurisdiction, the easement shows as
ending at the State waters boundary where other State and Federal regulations apply. All leases with approved COPs will
include easements shortly after approval. Source: Roberts et al. (2023); Roberts et al. (2016).

BOEM and NOAA Fisheries North Atlantic Right Whale and Offshore Wind Strategy| 59

Figure D-7. Density of NARWs in U.S. waters during the month of July (2010–2019)
Narrow lines leading from leases to land are cable route easements. Due to State/Federal jurisdiction, the easement shows as
ending at the State waters boundary where other State and Federal regulations apply. All leases with approved COPs will
include easements shortly after approval. Source: Roberts et al. (2023); Roberts et al. (2016).

BOEM and NOAA Fisheries North Atlantic Right Whale and Offshore Wind Strategy| 60Figure D-8. Density of NARWs in U.S. waters during the month of August (2010–2019)
Narrow lines leading from leases to land are cable route easements. Due to State/Federal jurisdiction, the easement shows as
ending at the State waters boundary where other State and Federal regulations apply. All leases with approved COPs will
include easements shortly after approval. Source: Roberts et al. (2023); Roberts et al. (2016).

BOEM and NOAA Fisheries North Atlantic Right Whale and Offshore Wind Strategy| 61Figure D-9. Density of NARWs in U.S. waters during the month of September (2010–2019)
Narrow lines leading from leases to land are cable route easements. Due to State/Federal jurisdiction, the easement shows as
ending at the State waters boundary where other State and Federal regulations apply. All leases with approved COPs will
include easements shortly after approval. Source: Roberts et al. (2023); Roberts et al. (2016).

BOEM and NOAA Fisheries North Atlantic Right Whale and Offshore Wind Strategy| 62Figure D-10. Density of NARWs in U.S. waters during the month of October (2010–2019)
Narrow lines leading from leases to land are cable route easements. Due to State/Federal jurisdiction, the easement shows as
ending at the State waters boundary where other State and Federal regulations apply. All leases with approved COPs will
include easements shortly after approval. Source: Roberts et al. (2023); Roberts et al. (2016).

BOEM and NOAA Fisheries North Atlantic Right Whale and Offshore Wind Strategy| 63Figure D-11. Density of NARWs in U.S. waters during the month of November (2010–2019)
Narrow lines leading from leases to land are cable route easements. Due to State/Federal jurisdiction, the easement shows as
ending at the State waters boundary where other State and Federal regulations apply. All leases with approved COPs will
include easements shortly after approval. Source: Roberts et al. (2023); Roberts et al. (2016).

BOEM and NOAA Fisheries North Atlantic Right Whale and Offshore Wind Strategy| 64Figure D-12. Density of NARWs in U.S. waters during the month of December (2010–2019)
Narrow lines leading from leases to land are cable route easements. Due to State/Federal jurisdiction, the easement shows as
ending at the State waters boundary where other State and Federal regulations apply. All leases with approved COPs will
include easements shortly after approval. Source: Roberts et al. (2023); Roberts et al. (2016).

BOEM and NOAA Fisheries North Atlantic Right Whale and Offshore Wind Strategy| 65

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The Mission of the Bureau of Ocean Energy Management is to manage development of U.S.
Outer Continental Shelf energy and mineral resources in an environmentally and economically
responsible way.

The mission of NOAA Fisheries is the stewardship of the nation's ocean resources and theirhabitat. We provide science-based conservation and management for sustainable fisheries andaquaculture, marine mammals, endangered species and their habitats.