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GUEST SPEAKER: I
convened this meeting

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because I believe that
the review is limited

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as it stands now.

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And in order for the
Environmental Impact Assessment

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to be effective, it
needs to consider

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a number of other
alternatives in order

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to provide a larger scope
for the project impacts,

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both positive and negative.

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The draft Environmental Impact
Assessment, as it stands now,

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considers the
number of turbines,

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the location of the
turbines, and a very limited

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no-build option.

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This alternatives
analysis fails to create

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a clear vision of the
situational context

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of the project.

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In this presentation,
I will be discussing

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ways in which we can revise
the Environmental Impact

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Assessment so that it better
evaluates all alternatives

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and I will provide arguments
for why it is necessary to spend

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the time and money to do so.

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First, we need to define
the goal of the project

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if we are to
effectively evaluate

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alternative approaches.

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Alternatives
analysis should paint

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a picture of the
multitude of options

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available to reach this goal.

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So I believe that the
goal of the project

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is to provide energy for
the growing electricity

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demand in the region.

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And studies have shown that
new energy facilities will

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need to be built within
the next 15 years

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to meet this growing demand.

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So we should use this goal to
frame to project evaluation.

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And sending a clear
goal at the beginning

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helps to consider
better alternatives.

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And it's necessary
to take a step back

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and to see the project and its
impacts in the larger context.

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So if we all agree to this, that
the goal is to meet the growing

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electricity demand, we must
determine that this product

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is the best option.

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And the Environmental
Impact Assessment

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is the way that we'll do that.

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So to do this, we need to
make three major revisions

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to the Environmental
Impact Assessment.

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One, we need to consider
alternative forms

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of energy production
and their environmental,

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economic, and social impacts if
this plant is not to be build.

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So if we do not
build offshore wind,

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we would build
wind farms on land.

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And what will the land
use impacts of that be?

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Will we need to build a natural
gas plant to meet demand,

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or is solar an option?

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So we need to really consider
the greater alternatives.

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It will be difficult to do
a full Environmental Impact

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Assessment of all of these
theoretical alternatives.

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We can pick a few items to
focus on, for instance, carbon

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emissions or land use.

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Second, we need to consider
the impacts of wildlife

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and coastal communities
based on cumulative impacts,

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if this project isn't built and
other clean energy products are

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not built and we're not meeting
our greenhouse gas emission

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targets.

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Third, if this
project is perhaps

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the best way to meet
our energy needs,

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then we need to consider
alternative ways

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to mitigate the impacts from
this project on wildlife

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and navigation.

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Some mitigation
efforts could include

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moving the wind farm further
offshore or presenting--

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providing better
long term monitoring.

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So including all of
these alternatives

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in the more comprehensive
alternatives

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analysis will lead to
two major benefits.

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One, it will increase the
opportunity for public buy-in

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by making a more
transparent process.

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This is really important
for complex problems

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like energy development.

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And by including a more
comprehensive analysis,

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or alternatives
analysis, the project

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will be less likely
to be fought later on.

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Because the public will
be better able to use

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this document to see the
decision-making process.

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The public will see that the
Environmental Impact Assessment

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did not just consider the
impacts of the proposed

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pre-design project that
was already going to happen

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but will see it in
a greater context

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of the different
alternatives that

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were considered along the way.

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This will, while spending
this money upfront,

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it will be expensive to do
all of these extra studies,

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it will be important in
saving money down the pipeline

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in delays and litigation.

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And second, because there
is not much precedent

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for Environmental Impact
Assessments of offshore wind

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in the United States,
we have the opportunity

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to set the standards
for evaluation.

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This project will
set best practices,

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so let's make them
best practices

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and establish mitigation and
monitoring practices as well as

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the robust alternatives
analysis that I proposed.

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Again, we should, we
should be sure to engage

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the public around
this alternatives

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analysis during the review
of this draft, the comments

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on this draft Environmental
Impact Assessment,

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so that there's public buy-in
and support of the project

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and that the public understands
what alternative options would

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look like.

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So finally, we need to recognize
that, internally as the EPA,

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that Environmental Impact
Assessments are not

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unbiased and purely scientific,
but that they operate

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within a political framework.

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So because of this and
because of our recent decision

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to limit greenhouse gas
emissions in power plants,

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we need to create
a better framework

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for analyzing alternative
energy projects

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and present a better
framework for analyzing

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all of those impacts and risks.

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We cannot encourage clean energy
development at a great cost

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to local ecosystems.

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But we must create
a system in which

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a sound case for wind generation
can be made, including--

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So this, by doing this,
we need to examine,

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have an assessment that
examines all other options,

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including meeting energy
needs from less clean sources.

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So for these
reasons, I recommend

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revising the draft
Environment Impact Assessment

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to include these comments.

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Thank you.