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Surfers 4 Solar | Haleiwa, Hawai‘i 96712 | Surfers4Solar.org | email@example.com
November 26, 2016, Draft of Letter to Department of the Interior Secretary, 1849 C Street, N.W., Washington DC 20240 from Surfers with Notable Experience on the North Shore of O‘ahu
Dear Secretary of the Interior,
We are pro-green energy surfers writing to ask you not to authorize development of wind farms in areas where they would damage O‘ahu’s North Shore surfing conditions because environmentally preferable alternatives, such as solar photo-voltaic (PV), are readily available, reasonable, and feasible. Please don’t allow at-sea wind platforms where they would cause diffraction of inbound open ocean swells and please don’t permit wind turbines in areas on land or in the ocean where they would disrupt the offshore winds that power our wind- and kite-surfing sails and groom our clean wave faces. Your website indicates your Department is “Protecting America’s Great Outdoors and Powering Our Future” and we believe you can achieve both by assessing and selecting solar PV with energy storage alternatives to the proposed wind farms. Maps of areas that should be excluded from wind farm development to conserve North Shore surfing’s ocean swells and offshore winds, and an example of North Shore acreages that should be considered for solar PV development, are shown in Figure 1.
Figure 1. Areas to avoid wind farm development (top) and areas that should be included in solar PV alternative analysis.
Until the solar alternatives and other less harmful, readily available energy solutions are exhausted, please don’t select harmful wind farm development as your agency’s preferred alternative. We believe Hawai‘i’s clean energy needs can be met without harming Hawai‘i’s “Great Outdoors” in the process.
The North Shore has seven miles of surf spots – the “Seven Mile Miracle” that would be adversely affected by wind farm development in the open ocean through which the swells pass to reach the North Shore or wind farm development downwind from the surf breaks. The quality, energy, and “cleanness” of surf would be reduced and disturbed if they passed by and through large heavy floating structures before reaching shore. The surf breaks that line the North Shore’s coast derive their perfect, clean wave face conditions from relatively strong, consistent offshore wind flow. Pipeline (Figures 2-6), the most famous surf spot in the world, and one of the most perfect waves in the World, is located due east of one of the at-sea wind farms under consideration by your Department and it is downwind from a land-based wind farm permit you’re currently assessing.
Figure 2. West swell hitting Pipeline (Photo by Duncan, Surfing Magazine).
Figure 3: Local Pro surfers John Florence (Currently Ranked #1 in the World), Dusty Payne (Photos by Zak Noyle), and Derek Ho (Photo by Surfline) surfing perfect Pipeline.
Figure 4. Pro surfers Nathan Fletcher (Photo by Zak Noyle) and Kelly Slater (local homeowner) and local Pro surfer Jamie O’Brien (photos by Brent Bielmann) surfing perfect Pipeline.
Figure 5. Perfect Pipeline on a west swell (Photo by Mike Cianciulli, Surline).
Figure 6. Members of Hui O He’e Nalu (Da Hui), a 300-member family of watermen founded in 1976 to work to assure local people’s rights to the ocean are not infringed upon.
Surfline.com explains the mechanics of Pipeline’s wave here: http://www.surfline.com/surf-news/the-mechanics-of-pipeline_63340/.
Hawai‘i, O‘ahu, and the North Shore’s number one economic driver is Tourism. Tourism is a $14 billion part of our economy, accounting for 22% of our GDP. More than 50 % of O‘ahu tourists tour the North Shore during their stay. Tourists spend an average of $150 to $400 a day in Hawaii. The economy of the residents of the North Shore is rooted in the beauty of our scenery, our clean powerful surf conditions, and our undeveloped country environment. Your proposed wind farms would adversely affect the availability and quality of surf available to the World population of surfers. The Hawai‘i Tourism Authority prioritizes “Maintaining the Brand” to assure long-term sustainability of the destination. Your proposed wind farms would cause irreparable harm to the North Shore brand and to our surfing-based economy.
A review of the 2010 Census data indicates the North Shore receives the following total annual value of sales: Retail $105,649,000; Food: $33,591,000; Rental Real Estate (including Turtle Bay Resort): $5,367,000 for a total annual tourism-related input of $144.6 Million. A 10 percent reduction to this net would cost our tourist-related businesses $14.4 Million annually. Your analysis of the effects of the proposed action should include an assessment of changes to the future number of tourists visiting the North Shore and the tourist dollars spent on the North Shore the projects may have.
In May 2016, the Department of Interior’s Bureau of Ocean Energy Management provided a map of ocean areas they consider to be suitable for wind development (Figure 7, top) and in July 2016, they selected and enlarged a portion of the area (Figure 7, bottom) and invited wind farm lease requests.
Figure 7. Department of Interior maps delineating the area BOEM considers to be suitable for wind development (top) and their Oahu North ocean area two wind developers have asked to lease.
One ocean lease applicant for the northern “call area” (an entity called AW Wind Hawaii, LLC which is led by a Danish citizen, Jens [pronounced Yens] Peterson) proposes to build at least 51 floating windmills, and is clearly trying to reserve the option to build many more, possibly 100 or more. Each floating windmill is proposed to be built on a patented “Wind Float” platform similar to the photo shown on the applicant’s application. The photo on the application is of a single demonstration Wind Float windmill that was built in northern Portugal. The in-water portion of a floating wind structure is shown in Figure 8 (in shallow water, without anchors).
Figure 8: Examples of the in-ocean portion of an at-sea floating platforms (Alpha Wind).
The Wind Float platform that was built in northern Portugal is anchored in water that is only 40 to 45 meters deep. In contrast, the waters in much of the northern “call area” off Ka‘ena Point are about 1,000 meters (3,300 feet) deep. That is 5 to 6 times deeper than anyone anywhere in the world has ever successfully anchored floating windmills, and more than 20 times deeper than the applicant’s demonstration Wind Float in Portugal.
The small-scale demonstration Wind Float in Portugal is anchored by four steel-cabled anchor lines that spread out in four directions. The small-scale Wind Float itself consists of three large steel semi-submersible cylinders that have a diameter of 10 meters each (33-feet diameter each (the width of our houses), and extend down more than 70 feet into the water. The three cylinders are set in a triangle held together with various steel tubes and cross braces, and the windmill tower sits on one of the three cylinders. The single demonstration Wind Float in Portugal has a 2.4 MW (megawatt) Vestas brand wind turbine. For Hawaii, the applicant is proposing to use wind turbines in the 6 to 8 megawatt (MW) range. As a result, the size of the Wind Float cylinders that would be needed in Hawaii will be even larger than the ones used in Portugal.
Even with the smaller size of the Wind Float in Portugal, the total cross section of steel for each Wind Float will be 99 feet (three times the 33-foot diameter for each cylinder). Each cylinder would extend more than 70 feet down into the water, and then connect to the anchor cables. Even if only that smaller-sized Wind Float were built, and even if the applicant only built 51 of the windmills, which would mean a total metal cross section that waves will have to hit of about 1 mile. (51 times 99 feet equals 5,049 feet, and there are 5,280 feet in a mile.) If the applicant ends up building 100 larger sized Wind Float windmills (to accommodate the 6MW to 8 MW wind turbines it plans), then the total cross section of metal, that waves will have to hit, would be more than 2 miles.
Perhaps even more important than the one to two miles of total metal cross section that waves will run into, is the shape and configuration of the metal. The portion of a wave hitting and passing through a single Wind Float will have three large 33-foot-diameter metal cylinders (or larger) in a triangular shape in relatively close proximity to each other. As the waves hit a metal cylinder they will ricochet off in both directions laterally, and portions of the ricocheted wave energy will hit the other 33 foot cylinders almost immediately. As a wave hits and passes by the cylinders, the interactions of the deflected energy will be very complex. The deflected wave energy will soon move laterally (on an angle) enough to interact with deflected wave energy from the adjacent windmill in that row, as the diffracted waves wedge into each other (Figure 9). In addition to at least some net loss of swell energy reaching the world famous North Shore surf breaks and the Westside surf breaks, there is likely to be a very a significant increase in the messiness of the swell energy (in other words, a decrease in the “cleanness” of the swell energy that surfers want) as it hits and passes through the Wind Floats.
Figure 9. Diffraction of waves as they move past structures (Images NOAA and geology cafe.com).
The problems with the decrease in “cleanness” of the wave energy, and increase in the messiness from the random deflected waves, will further increase as the wave and swell energy passes through the next row of Wind Float windmills. The North Shore’s powerful swells are generated thousands of miles away in the open ocean areas of the western and northern Pacific. Once energy is taken out of the swell and once diffaction disturbances are introduced, it wouldn’t somehow be “reconstituted” as the swell moves toward shore, it would be lost. There is no question the giant floating structures that are currently proposed, would adversely affect our west swells.
In August 2016, in our discussions among ourselves regarding the proposed offshore wind farm, we realized many of us have already noticed changes in wind we believe are related to the two realtively-new existing North Shore O‘ahu wind farms. These wind farms seem to be taking energy out of the wind and reduced consistency of wind flow (Figures 10 – 12). This has reduced the cleanliness of the wave faces and affects the consistency of the wind used by windsurfers and kite surfers.
Figure 10. Wake turbulence visible in clouds formed when energy is removed from wind cools and reaches dew point (http://www.dgem.nl).
Wind conditions on windy days (when winds are above 18 mph) are especially important to windsurfers and kite surfers at Mokuleia and at the surf spots located between Sunset Beach and Malaekahana. Sunset Point wind surfers, surfers, and ocean paddlers have noticed that since the wind farm was built four miles due east of Sunset Point six years ago, east winds on windy days are “more gusty”, more “crinkely” and less “filled in”. Gusty less consistent strong winds result in bumps on the wave faces and lulls in wind used by windsurfers and kite surfers surfing large heavy waves.
Surfers and summer paddleboarders at Waimea Bay are affected by the reduction in consistency and cleanliness of the offshore down-valley winds by the wind farm located immidiately adjacent to the shore. Surf faces at Waimea are bumpier because off-shore winds are more disorganized as a result of the recently-installed wind farm.
These changes in conditions from the existing wind farm has reduced the number surfable days and reduced the quality of surf conditions. It also increases surfing injuries. The additional wind turbines proposed for installation downwind from the North Shore would be even larger than the existing ones so they would be likely to cause even further deterioration of our wind and wave face conditions.
Figure 11. Wind flow is disturbed by wind turbine blades; please don’t situate wind turbines downwind from North Shore surf spots (Diagram from Lee et. al. 2012. Journal of Solar Energy Engineering).
Figure 12. Strong offshore wind is critically important to clean wave faces with fewer bumps at Waimea Bay (Photo of Mason Ho and John Florence by World Surf League (WSL), Keoki).
These adverse effects to wind were not disclosed to the public in NEPA documents for your existing wind farms so please ensure these effects are included in your assessments of your proposed projects. Please don’t erect any more wind farm structures in the areas shown in Figure 1 and once existing permits have expired, please don’t re-authorize the two existing wind farms. Doing so would cause unnecessarily deterioration of the North Shore’s offshore wind conditions. The proposed windmills should not be constructed or re-powered because there are readily available, feasible solar PV alternatives that wouldn’t harm the human and natural environment.
We notice many members of the public indicated a preference for a solar alternative in the NEPA scoping comments you’ve received for the proposed wind projects. The National Environmental Policy Act of 1969, as amended (Pub. L. 91-190, 42 U.S.C. 4321-4347, January 1, 1970, as amended by Pub. L. 94-52, July 3, 1975, Pub. L. 94-83, August 9, 1975, and Pub. L. 97-258, § 4(b), Sept. 13, 1982) (NEPA) requires you to “objectively evaluate all reasonable alternatives” and to “Include reasonable alternatives not within the jurisdiction of the lead agency.” You are pursuing these projects to help meet Hawai‘i’s clean energy needs. Therefore, please ensure NEPA analyses your Department conducts related to these wind farm developments include assessments of a solar alternative that would meet the same energy need as the proposed wind farm. We feel it is the Department of Interior’s responsibility, pursuant to the NEPA, to always assess a solar alternative to any proposed wind farm. We believe that within the State of Hawai‘i, the solar alternative will (until better technology becomes available) always be the environmentally preferable alternative to any wind farm project. Given the risks to resources which are entrusted to your Department, we would expect solar to be your Department’s preferred alternative within the State of Hawai‘i.
The landowners/lessees of the 4,500 acres of flat agricultural lands designated as grazing lands in Figure 1 are interested in solar PV. Several of them already have experience grazing cattle, sheep, and goats under arrays of solar panels. An example grazed solar farm is visible on Highway H-2, south of Mililani Technical Park Exit 7. Solar PV development on the North Shore’s flat grazing land areas would provide more power than the two currently-proposed wind farms combined. This assumes 40% efficiency of the wind farm (best-case scenario); if wind turbine efficiency in this harsh at-sea environment is 20% due to maintenance issues, solar on just half the area highlighted in Figure 1 would provide power equal to the proposed wind farms. Additional flat grazing land is located in other areas of O‘ahu and in large grazing areas on the nearby Neighbor Islands, not to mention all the rooftops, roads, and other existing developed areas that could be outfitted with solar. Sites for solar PV development are vast and sufficient to power urban Honolulu without having to erect any more wind turbines in areas where they would cause great harm to the natural and human environment.
To provide energy at night, solar PV should be paired with energy storage such as batteries, Hydrogen (from electrolysis), or hydroelectric system development. Solar PV installation should be limited to existing developed areas and grazing land; more productive agricultural land should be reserved for food crops. These solar PV and energy storage systems are currently readily available, reasonable, and feasible. There is more than enough suitable land and interested landowners to power urban Honolulu with solar PV so that our surf, our communities, and our natural resources need not be so greatly harmed by unnecessary wind farm developments.
Please don’t authorize wind farms in areas where they would damage O‘ahu’s North Shore surfing conditions because environmentally preferable alternatives, such as solar photovoltaic PV, are readily available, reasonable, and feasible. Because the harmful effects of your proposed wind farm projects extend well beyond adverse effects to North Shore surf conditions, and because solar PV does not have such serious unmitigatable adverse effects, we hope your Agencies will select solar as their preferred alternatives to the proposed wind farm projects. Until the solar alternatives and other less harmful, readily available energy solutions are exhausted, please don’t select harmful wind farm development as your preferred alternative. We believe Hawai‘i’s clean energy needs can be met without harming Hawai‘i’s (and the International surfing community’s) “Great Outdoors” in the process.
We notice many members of the public indicated a preference for a solar alternative in the NEPA scoping comments you’ve received for the proposed wind projects. The National Environmental Policy Act of 1969, as amended (Pub. L. 91-190, 42 U.S.C. 4321-4347, January 1, 1970, as amended by Pub. L. 94-52, July 3, 1975, Pub. L. 94-83, August 9, 1975, and Pub. L. 97-258, § 4(b), Sept. 13, 1982) (NEPA) requires you to “objectively evaluate all reasonable alternatives” and to “Include reasonable alternatives not within the jurisdiction of the lead agency.” You are pursuing these projects to help meet Hawai‘i’s clean energy needs. Therefore, please ensure NEPA analyses your Department conducts related to these wind farm developments include assessments of a solar alternative that would meet the same energy need as the proposed wind farm.
Please don’t authorize wind farms in areas where they would damage O‘ahu’s North Shore surfing conditions because environmentally preferrable alternatives, such as solar photovoltaic (PV), are readily available, reasonable, and feasible. Because the harmful effects of your proposed wind farm projects extend well beyond adverse effects to North Shore surf conditions, and because solar PV does not harm the environment, we hope you will select solar as your preferred alternative to the proposed wind farm projects. Until the solar alternatives and other less harmful, readily available energy solutions are exhausted, please don’t select harmful wind farm development as your agency’s preferred alternative. We believe Hawai‘i’s clean energy needs can be met without harming Hawai‘i’s (and the International surfing community’s) “Great Outdoors” in the process.
Surfers 4 Solar
(Alphabetical Order) John Amundson, Konrad Bright, Chris Bruns, Jeff Bushman, Tim Caroll, Larry Cass, Sunny Erickson, Serena Erstad, Eric Forgerson, Douglas Godfrey, Chip Hartman, Coco Ho, Michael Ho, Blake McElheny, Dan Moore, Jamie O’Brien, Emilia Perry, Tamayo Perry, Carol Philips, Makua Rothman, Kevin Senn, Mike Slattery, Jamie Sterling, Reo Stevens, Jock Sutherland, Mike Takahashi, John Thompson, Tai Vandyke