Section 4(f) of the Federal Power Act authorizes the Federal Energy Regulatory Commission to issue preliminary permits for the purpose of enabling prospective applicants for a hydropower license [covers wave power but not wind power] to secure the data and perform the acts required by FPA section 9.3 which in turn sets forth the material that must accompany an application for license. The purpose of a preliminary permit is to preserve the right of the permit holder to have the first priority in applying for a license for the project that is being studied. Because a permit is issued only to allow the permit holder to investigate the feasibility of a project while the permittee conducts investigations and secures necessary data to determine the feasibility of the proposed project and to prepare a license application, it grants no land-disturbing or other property rights.
- There are no cables/wires underwater which threaten whales
- It has a smaller ocean floor footprint than cable systems
- It can be placed/removed in as little as a single day
- There is no driving of piles and thus none of the noise that pile-driving causes
- The structures are simple enough that they can be manufactured locally using facilities that exist in any marine industry in any reasonably-sized port.
- The core design withstands force 5 hurricanes and 60-foot swells
There are, of course, also many questions, which is why more studies need to happen before this or anything else is put in the water. Our approach is to proceed deliberately, following the rules, and doing the work of careful assessment and study using qualified experts and the insight and knowledge of local groups. If at any point it becomes clear that any project under consideration cannot be made viable, feasible, and environmentally compatible we will stop. Bookmark the page, print it out, memorialize this how you want. It is a commitment on our part.
The first that many local authorities and stakeholders learned of our plans was by a notice from a federal agency or a piece in the news. That is not what we wanted, and we are sincerely sorry for the shock and for any offense.
Just as with our removal of most mentions of wind turbines in our applications to the FERC, so to with our consultations: we acted based on our experience with the application for the project in Grays Harbor. Burt wrote an open letter explaining how we were surprised by the pace of the process:
I wish to extend my apologies for surprising state and local officials and organizations in the states where we have proposed projects. The FERC acted on our applications faster than I think it has ever acted for any applicant before, and, frankly, it caught it us off guard. We have not had time to contact the political, energy and ocean leaders in our project areas.
We have been preparing to contact the officials in the states affected by our applications in January and February, after the holidays and the Presidential transition and the new Federal agency heads are in place. I personally called FERC and asked them to open the public comment period in January or February, because opening it in December is rather unfair to the public - the holiday season is a big distraction and I don't think the public and agencies really get a "normal" 60-day comment period if it opens on November 28. A proposal for offshore energy development of course greatly concerns state and local officials and the affected public and interest groups. We have great experience in stakeholder consultation and the permitting processes and we like the FERC system, unlike almost every other developer, because it requires and directs an extensive consultation process with every stakeholder. We will follow that process and contact state and local leadership in our site areas beginning in January 2008. We have already contacted a few key people in each state. We look forward to receiving "official" comments on our applications to FERC during the 60-day period, and of course we want any feedback at any time to help us understand local concerns and learn how we can advance this tremendous opportunity in open partnership and collaboration.