RON SADLER

P0 Box 41! North BeniL Oregon 97459 ronsadQjuci.
net RECE WED Bureau of Ocean Energy Management Pacific Region Office of Strategic Resources 770 Paseo Camarillo, Second Floor

2013 Camarillo, California 93010
EUREAUOFOCEAN WERGYMANA9MEgr October 21, 2013 RE: RESPONSE
TO REQUEST FOR PUBLIC COMMENT, DOCKET NO. BOEM 2013-0050; MMAA 104000, WIND POWER OFFSHORE OREGON PERSONAL BACKGROUND: I had
a 34 year career within the U.S. Department

of Interior. Much of that time was spent working
on implementation

of the National Environmental Policy Act.

I hold

a Masters degree

in Natural Resource Administration
with an emphasis
on NEPA implementation.

I have worked with various Congressional committees

in Washington, D.C. on NEPA-related matters, testified
as an expert witness

in various judicial proceedings,
and lectured

at various colleges and universities. SUMMARY
OF PRESENT SITUATION: You have received

a proposal submitted
by Principle Power Inc. seeking

a commercial lease for wind energy development

on the OCS off of Coos Bay, Oregon.1 You have requested public comments regarding the potential environmental consequences

of wind energy development

in the area.2 You have acknowledged
that Principle Power was one of seven entities that received funding for demonstrating
“the ability to progress toward achieving the national goals of the National Offshore Wind Strategy”, and that three of the seven award recipients will receive additional funding

in the spring of 2014. Additionally, you have acknowledged
that the “lease request

to BOEM

is an effort to move forward

in the DOE funding process”.3 You also make

ft clear to the public that, before any lease
is issued, an analysis Principle Power, Inc., Unsolicited Application
for an Outer Continental Shelf Renewable Energy Commercial Lease- Principle Power WindFloat Pacific Pilot Project”, May 14,2013 2 Federal Register, Volume 78, No. 189, Sept. 30,2013, pgs. 59968- 59972. ibid. pg. 59970.under National Environmental Policy Act (NEPA) must be completed.4 As a citizen of Coos County,

I am well aware that our aquatic ecosystems have been seriously compromised

in the past, and that there
is little margin for error
in properly implementing future development projects. Absolute and complete compliance with both the letter and intent of NEPA

is critical

if our ecosystems are to remain functional.
My comments herein will be directed towards the NEPA process. POSSIBLE SIMPLISTIC APPROACH
TO NEPA It is possible

to envision

a relatively simple and straightforward NEPA process that BOEM could undertake. An EIS could be prepared that considered

all seven of the award recipients

as possible alternatives, and documented how the technical, economic, and environmental aspects were balanced

to determine which three projects were selected for continued funding

in a process that was not arbitrary
or capricious. If Principle Power Inc. were to be one of the selected recipients,

a supplemental analysis would be required. Principle Power has identified three sites that would be suitable locations: Coos Bay in Oregon, Point Conception

in Central California, and off Humboldt County

in Northern California.

A proper EIS would document how the balancing

of technical, economic, and environmental considerations

led logically

to the decision
as to which location was chosen for implementation. Unfortunately,
this simple and straightforward NEPA process

is not available

in any instance involving Principle Power Inc. The reason for this is: The Principle Power WindRoat Pacific Pilot Project

is irrevocably linked
to the Jordan Cove Export LNG project. This relationship

is documented

in Principle Powe?s lease application itself, which specifically states: “An offshore grid and subsea cable would be used to export produced electricity

to facilities

at the planned South Dunes Power Plant, a combined cycle natural gas power plant associated with the Jordan Cove Energy Project”5; and, “Jordan Cove Energy and Principle Power are negotiating a power purchase agreement with

a term and price sufficient

to meet the economic needs of the WindFloat Pacific Project”.6 Further, Principle Power states unequivocally that “Power generated from the WindFloat Pacific project will be delivered

to the Jordan Cove project

in the Port of Coos Bay and will not be offloaded

to the national electric grid.”7 ibid. Principle Power Application,

op cit, page

I 6 ibid. ibid, page

9Furthermore,

in its application Principle Power has made

a rather obvious attempt
to facilitate circumvention

of the regulations

in the upcoming NEPA process
by seeking

to prematurely limit the choice among reasonable alternatives.

It has done this by repeatedly treating the Jordan Cove LNG facility as if it were

a fait accompli rather than

a proposal undergoing the earliest stages of the NEPA process. Specifically: “The Jordan Cove Energy Project

is a $7.5 billion dollar liquid natural gas export facility currently under development (emphasis provided)

at the International Port of Coos Bay”8; “The existence (emphasis provided)

of the Jordan Cove Energy Project
at Coos Bay and its ability to purchase power from WFP created

a strong marketopportunity”9; and,- .the electric infrastructure being developed (emphasis provided)

in association with the Jordan Cove project created an obvious grid interconnectionopportunity”.1° The certainty ascribed
by Principle Power to the “existence”

of the Jordan Cove LNG facility

is all the more remarkable given the fact that FERC

is still in the NEPA scoping stage and has not yet even published the draft EIS for the project. Assuming the final record of decision allows

it, the issuance
of a permit to begin construction

of the Jordan Cove facility

is years away. TOWARDS

A VIABLE NEPA PROCESS As documented above, WindFloat

is directly linked to and intended

to be an integral part of the Jordan Cove LNG facility. FERC

is currently

in the beginning process
of preparing
an EIS for the Jordan Cove facility. Existing NEPA regulations clearly address connected actions, and clearly call for actions
to be considered within the scope of a single EIS if they “cannot
or will not proceed unless other actions are taken previously

or simultaneously”

or “are interdependent parts of a larger action and depend on the larger action for theirjustification”.11 It is clear that the WindFloat proposal and the Jordan Cove proposal are interdependent
and interconnected,
and that the location
of WindFloat was selected primarily

to enhance the effectiveness

of their co-operation. Therefore, in order to comply with the letter, spirit, and intent of NEPA, both facilities must be included within the scope of a single EIS. As an example
of the benefits
of a single EIS, BOEM has requested information from interested

or affected parties relating
to such things as geological and ibid, page

I ibid, page

5Ia. ibid. 40 CFR

I 508.25(a)(

I )000ii).geophysicalconditionsinthearea,historicandarchaeologicalresourcespotentiallyaffectedbyconstructionandoperation,otherusesoftheareasuchascommercialandrecreationalfishing,recreationalactivities,etc.,andotherrelevantenvironmentalinformationrelatedtoprotectedspeciesandhabitats,birds,fish,etc.ThesetypesofdataarepreciselywhatanEISisdesignedtoprovide,thusBOEMwouldnothavetoindependentlygatherandaddressthesesubjectsifajointEISweretobeprepared.REQUESTSNEPAregulationsstatethatininstanceswhereoneormoreFederalagenciesareinvolvedinanactionorgroupofactionsthataredirectlyrelatedtoeachotherbecauseoftheirfunctionalinterdependenceorgeographicalproximity,suchagenciesaretoformallyjointogetherinordertofacilitatethepreparationofasingleEIS.12IaskThatBOEMpetitiontobecomeacooperatingagencywithFERCinthepreparationofTheJordanCoveLNGExportterminalEIS.IaskthatBOEMtableanyactionrelatingtotheApplicationThranOCSRenewableEnergyCommercialLeaseuntilformaladoptionoftheFinalRecordofDecisionterminatingtheJordanCoveEISpmcess. A1240CER1501.5(a)(2)