MMS ANPR AltEnergyOCS-UD-Comment-2006

Comment submitted to Minerals Management Service (MMS) By University of Delaware, College of Marine Studies Re: 30 CFR Part 285, RIN 1010–AD30 Alternate Energy-Related Uses on the Outer Continental Shelf Responding to: Advance Notice of Proposed Rulemaking (ANPR). This document authors: Willett Kempton, Jeremy Firestone, Richard Garvine This document date: 24 Feb 2006 This document constitutes comment on the MMS ANPR, per notification in the Federal Register, Vol. 70, No. 250, Friday, December 30, 2005, Proposed Rules, page 77345. The ANPR concerns portions of the Energy Policy Act of 2005, Section 388—Alternate Energy-Related Uses on the Outer Continental Shelf. Introduction This comment primarily addresses offshore wind power, for reasons given herein. We begin with a brief description of the offshore wind technology and resource. Both are very different from the resources now managed by MMS, and we feel these differences, if not accounted for, may lead to regulations imperfectly matched to this resource. Subsequent sections address specific questions asked by the ANPR. Other alternate OCS energy related technologies are reviewed in the final section. I. Technology available today This section briefly reviews the available offshore-class wind turbines, as we believe that an understanding of the technology may facilitate sound policy making. Although offshore wind developments have been built in Europe since 1991, ...