From Three Tree Journal (tres_arboles), January 17, 2008
The Surfrider Foundation, a national ocean recreation advocacy organization is developing a policy position on wave energy projects and their potential effects on recreational uses. As a policy wonk, tres_arboles recognizes their need to avoid stridency on this issue, and approach it with critical, but supportive attention. On the one hand, the technology being proposed up and down the United States west coast and around the Hawaiian islands, has the potential for myriad human, environmental, and ecological effects when the arrayed technology is fully deployed in the near-shore marine environment. On the other hand, the technology has the promise of perpetually renewable, carbon-free electricity, decreasing our national dependence on all forms of carbon consuming, pollution spewing, climate change inducing forms of energy production. These latter concerns are largely shared by all but the most growth-crazed, anti-environmental ideologues in society today. So present here, as it almost always is in the policy development arena, is the nuanced competition of values that makes developing policy far more intricate than the “one side versus the other” to which we are so frequently treated in the ordinary news media.
Surfrider is an organization of local chapters, some of which are little more than an individual with a MySpace page. In contrast (fortunately), others are membered by conscientious surfers that are capable of providing scrutiny and analysis of issues affecting surf access and environmental matters of concern to surfers. Hopefully, that’s the case with the Oregon chapters now tracking the (at least three by my last count) proposed “wave park” buoy arrays that could diminish, if not destroy the surfability of the locations where they are proposed (among all of the other environmental and ecological issues they raise).
Surfrider presently supports the use of “adaptive management” in the development of the buoy arrays that are the infrastructural element of wave energy production that most concerns environmentalists, fishing organizations, and recreationalists. I am thankful that Surfrider appears engaged. However, I question the value of adaptive management in the context of the construction of these wave buoy “farms” or “parks.” Adaptive management is an approach to managing an ongoing activity that involves monitoring the activity to determine whether the activity is causing certain, predicted, and pre-agreed outcomes. Adaptive management is valuable because it enables, and in fact it relies on the ability to change the activity while it is ongoing, if monitoring shows it is not meeting those predicted, pre-agreed outcomes.
While the Surfrider blog entry is a brief one, and as such I might be making stuff up to fill in the blanks, it appears that the adaptive management proposed for the Oregon preliminary permits will assess certain issues during the incremental installation of the buoys under those permits. This does not really follow the classical adaptive management model in any way! Assessing the fishery, environmental, and recreational effects of a one buoy field will not inform the probable outcome of a 10 buoy field. And in turn, monitoring the effects of a 10 buoy field will not in any way help assess the move to a 200 buoy field, as proposed there. That is, it’s not enough to learn that one or three or ten buoys do not knock down the waves enough to enable the deployment of several tens, if not 100’s more. What if the monitoring shows that crabbers can crab the ground around ten buoys, but not fifty? Will the developer then pull 40 buoys and proceed to seek its FERC license on a reduced ten buoy project? What if that developer is beholden to shareholders?
I sincerely doubt that the types of corporate ventures that are underwriting these experiments in energy production will be willing to scrap or even slightly diminish their deployed investment if it’s already installed, producing electricity, and providing return on investment. Even if the monitoring shows that the array has eliminated fishery access to a productive crabbing ground or flattened a previously dependable surfing wave, these arrays consist of expensive equipment that will be expensive to deploy and maintain. In my experience as an environmental professional, developers are almost always willing to do damage in one form or another and simply incur an expense such as the payment of “in lieu fees” or “compensatory mitigation.” These compensatory arrangements enable the developer to absorb a cost they can turn around and pass on to their consumers, rather than avoiding the damage their development proposal will cause, or by diminishing the project or undoing it after-the-fact. While a compensatory approach might work with local commercial interests where the compensation involves buying out the fishers and crabbers, how do you compensate for the elimination of something so valuable that monetary evaluation would be trivial? Like a surf spot?
tres_arboles is tuned-in, but remains unsure of the answers to these questions. Hopefully, the values underlying these questions will be respected by FERC and the wave energy development community, before everyone gets glassy-eyed over the prospect of clean, renewable energy.