Editor’s Note: The following is excerpted from comments submitted by the Martha’s Vineyard Commission last week to the Bureau of Ocean Energy Management, Regulation and Enforcement. The complete text of the comments may be read on the commission’s Web site at mvcommission.org.

The Cape and Islands have a clear interest in seeing the United States move from an economy based on polluting and largely foreign fossil fuels to one based on “clean” renewable energy. Our communities have some of the poorest air quality in Massachusetts, mainly because of air pollution from up-wind power and industrial plants. Also, we are especially vulnerable to the effects of climate change such as sea level rise and the projected increase in the number and severity of storms. At the same time, development of renewable energy facilities must carefully consider issues such as habitat and species protection, preservation of fishing/boating activities and protection of scenic resources, which though they might be of secondary concern in some communities, are critical to the Cape and Islands where the economy is driven by the vacation industry. For Martha’s Vineyard alone, this economy represents a gross domestic product of about $800 million a year and property values of about $18 billion.

Since the beginning of 2010, the Martha’s Vineyard Commission has spearheaded an effort to develop a wind energy plan for Dukes County. Our analysis of the potential benefits and detriments of various possible locations for wind energy development — including land and various locations in state and federal waters — led us to the conclusion that development in the federal RFI area set back more than 12 nautical miles from the coast offered the greatest advantages and the least negative impacts, compared to a number of other locations on land and in nearer waters. Therefore, the MVC is pleased that the federal government and the commonwealth of Massachusetts are now focusing their efforts on this RFI area.

Dating back to the MVC’s first comments about wind energy development, our 2005 comments on the Cape Wind project, the Martha’s Vineyard Commission has repeatedly called for creation of comprehensive planning and regulatory framework before considering specific offshore development projects, pursuant to the Oceans Act of 2000 and as recommended by the U.S. Oceans Commission in 2004. The aim is to balance the need for renewable energy development with the need to protect significant natural resources and human uses. We argued that, in the long run, such an ocean policy would allow appropriate future proposals to be fully evaluated and proceed through the process more quickly and efficiently, and be less vulnerable to legal challenge and delay. We called for a comprehensive planning process for the continental shelf involving solid scientific analyses and community input, resulting in a clear framework indicating where offshore wind and other types of human activities are permitted, and laying out a clear approval process. We called for the policy to include adequate protection of natural and scenic resources, and consider, for example, that the pristine, bountiful, wild and scenic ecosystems of the Cape and Islands — including Martha’s Vineyard and the Cape Cod National Seashore — have long been recognized by local, state and federal agencies as well as conservation organizations as deserving special protection for the benefit not just of local residents, but the broader public interest at the state and federal levels.

We appreciate that BOEMRE has now set out a transparent process for the selection of developers. However, the fact that this RFI is taking place before there has been any comprehensive marine spatial planning process for the area remains worrisome. A comparison of the processes followed by Massachusetts, Rhode Island, and BOEMRE illustrates our reasons for concern. With the Massachusetts Ocean Management Plan, the planners did their best to compile available data within very limited time and budget constraints that did not allow for gathering of additional data. The state ocean plan’s identification of areas for potential commercial-scale wind energy development now appears to pose serious problems based on information obtained since that plan was completed. The Rhode Island SAMP took more time and money, but its more comprehensive analysis, including original research where data was missing, should not only allow for better protection of resources, but also allow for a more expeditious project review and approval process. Although the delineation of the Massachusetts RFI area has taken into consideration some initial information about areas likely to have sensitive resources, the BOEMRE is proceeding with the RFI before comprehensive marine spatial planning for the area has been completed. The Massachusetts EEA is now carrying out a limited analysis of available data and hopes to do some data collection in the future. However, developers are already being invited to select blocks for development. Depending on the qualification process and the presence of competition for blocks, it is possible that developers will have staked out their blocks in the coming year, and all research and planning will be limited to those blocks, even if more widespread research would have indicated that development of other blocks might have less negative impacts.

Our concern is that once developers have selected certain blocks for development as required by the RFI, it will be difficult to relocate projects, especially after the developers have invested considerable time and money in studies of their original blocks, to say nothing about the increased political and community expectations that a project would move ahead expeditiously. Unless some major information comes to light that merits denial of a project in a given block, the project will likely go ahead there, perhaps with some mitigation, even if it turns out that another location would have had far fewer negative impacts. The current process will mean that only the areas the developers want are analyzed without studying other areas that may well be more suitable for development. How can the development versus protection of resources calculus be done when we don’t know which areas are most important for resources and which areas will involve the least damage to these resources? We realize that all governments are strapped for funds these days. However, it is well worth spending a few million dollars now in order to ensure that development costing hundreds of millions if not billions of dollars is located and planned as effectively as possible. We are in a catch-22 situation where the government wants developers to fund the research; however, at least in the case of non-competitive leases, they can only do this once they have secured development blocks. Although we can hope that developers select the “right” blocks or that remediation measures will be effective, this calculated gamble seems questionable given the environmental and economic importance of the natural ocean resources south of the Islands.