My letter to Local Electeds to Adjust the Proposed Location of the Westport Wave Power Project

I spent the weekend composing letters and emails to people that should be representing the citizens and visitors of Westport, Washington in defense against the proposed Grays Harbor Wave and Wind Energy proposal.



Honorable City and County Leaders:

On October 28, 2007, the Washington Wave Company ( http://www.pugetsoundtidalpower.com/Waves.htm ), filed an application to the Federal Energy Regulatory Commission (FERC Docket Number P-13058-000). The permit sought would enable this consortium to install 350 wave energy conversion buoys and 95 wind turbines in a 10 mile (north to south) by 2.8 mile wide (east to west) area. The area extends northward from the Ocean Shores north jetty and southward from the Westport south jetty at the entrance to Grays Harbor. With careful attention to location for the proctection of existing uses and the environment, Grays Harbor county should be the location of wind, tidal, and wave power generation facilities. However, this proposal would diminish if not obliterate these values if located as proposed.

The windmill platforms and wave energy conversion apparatus would be permanently located by connection to the sea bottom in water from 10 to 70 feet deep. The permit application touts community benefits including decreased erosion (through the absorption of wave energy), jobs, and new sources of electricity in Grays Harbor. In recent news reports in the Aberdeen Daily World, the project proponent intimated that such electricity would be "free" to locals, with the rest of the energy for sale on the open market. Unfortunately, the application makes no such representation. The project proponent also makes the bizarre claim that the structural charateristics of the array would "create" marine habitat for fish.

In contrast to these representations, the nearshore marine ecosystem in the Grays Harbor area is naturally sand-bottom and reef-depauperate. Any artificial reef-creating effects of the project would not likely support species that are naturally adapted to the area. In addition, the positioning of the array would conflict with the migration route of Pacific gray whales and transient orcas. And little if nothing is known about the effects on the ecosystem, animals, and people from the generation of an electro-magnetic field in the area of the generation conduits back to and through the shoreline.

Furthermore, while the energy absorbing effects of the array might reduce the well-known, chronic erosion of the beach at Ocean Shores, the Westport beaches within the first several miles south of the Westhaven jetty have been accreting, not eroding, for the past century (Southwest Washington Coast Erosion Study, WDOE, http://www.ecy.wa.gov/programs/sea/swces/overview/findings.htm ). One need only look at century-old photos of the Westport lighthouse standing proudly at the beach's edge to realize how much beach accretion has actually occured at Westport. In fact, Westport's sole instance of crisis erosion did not occur on the oceanfront. It occured inside Grays Harbor at Half Moon Bay, as the result of the confluence of extreme high tides and a winter storm of extreme intensity in the late 1990's. Ironnically, the Half Moon Bay area would be one area NOT "protected" by the proposed array, because the project proponent has to avoid placing the array within the navigation channel at and around the Grays Harbor entrance. Therefore, claims of protecting Westport from erosion are false, if not misleading. If the proponent were truly interested in coastal protection as a value imbued in this project, the project would be proposed for the beaches on the northside of the entrance to Grays Harbor and the northside of the entrance to Willapa Bay where an entire community is disappearing into the ocean.

As equally as important as the potential ecological effects, the placement of the proposed array in the nearshore marine environment at Westport would effectively destroy the in- and nearshore recreational opportunity at the beach there. Importantly, moving the location of the proposed array further south to the beaches at the SR 105 Junction would completely avoid the recreational impacts of the project in Westport as little if any such use occurs at that part of the beach.

Westport is Washington State's most accessible, prominent, and visited surfing destination, and surfing is a pillar of the economic base for Westport. Surfing generates as many if not more "visits" than even the local fishing opportunity (which is also exceptionally important to Westport). Surfers tend to stay for more than one day at a time, renting campsites, motel rooms, condos and houses, and spending money at local businesses that already account for hundreds of Westport jobs. Outside of the late Fall and Winter seasons, the beach from Westhaven State Park to the beach in front of the Westport by the Sea condominiums at Ocean Avenue, provides excellent surfing opportunity for participants of all ages and skill levels. This stretch of beach also supports myriad other water-borne recreation (fishing, surf fishing, clamming, wind and kite surfing, personal watercraft use, swimming, and general ocean play). Recreational uses, and surfing in particular, have featured as protected values in previous Federal coastal protection efforts, such as the recent reconstruction of the Westhaven south jetty at the end of the 1990's. There is no evidence in the permit application that the project proponent has even considered recreational use values. Because the fact of the matter is that the placement of the proposed wave energy converters and platform-based windmills would quell, if not totally obliterate the surf in all but the most extreme conditions (the limited winter season when the ocean is rarely useable anyways). In addition to the wave destroying effects of this proposal, the presence of bottom-mounted wave energy converters, combined with the typical 10-foot plus tidal changes, will inevitably expose converter buoys at the water's surface, leading to the high potential for direct contact for those who might persist in water-borne activities such as surfing, body surfing, and ocean swimming, should any such activities still be available after construction of the array.

As a Westport homeowner, environmental professional, a lawyer, and a surfer, this project affects me and my family. I have been surfing in Westport for almost 15 years now, and in the past five, bought land and am almost finished building a house here. I have engaged the city to genuinely avoid environmental issues attending to my own project. I am extremely grateful to the professionalism in the City adminstrator and building inspector for helping me in that reagrd. But I have mortgaged my own personal net worth to make an investment in this community which I love, and I believe the proposed location for the wave energy project represents a community threat and not a benefit. Further concerning me is the fact that the FERC has recently passed fast-track rules for processing permits for projects like this one. My examination of other similar FERC dockets for projects that are further along or already approved leads me to believe these applications are getting rubber stamped and scarcely scrutinized. Perhaps the primary reason is that local governments and organizations that might otherwise enjoin these permitting processes and advocate for affected resources are conflicted by a common interest in and support for the development of carbon-neutral energy production. This is a truly modern and desirable value, which I believe all conscientious people presently support. But we cannot allow the propigation of these "wave parks" and "wind farms" at the expense of existing values at the locations for which they are planned.

I am writing to request your concerted investigation, intervention, and advocacy during the license application process for the Grays Harbor Ocean Energy project. The public needs to have more than the sugar-coated facts presently marshalled by the project proponent to fully participate in this process. As it presently stands, my informal poll of several local business people indicated zero knowledge about the project. Thanks for your attention.

Respectfully,

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