The Bureau of Ocean Energy Management (BOEM) is accepting comments through October 31 on its proposed Wind Energy Areas (WEAs) off the southern Oregon coast. This would be a very large project, perhaps the largest ever on our coast, and people who care about the coast need to take it seriously.

There are two WEA’s: the Brookings WEA, which extends from the California border to Cape Sebastian, and would cover 258,364 acres of ocean, beginning about twenty-five miles offshore. The Coos Bay WEA stretches from Reedsport to Florence and covers 61,204 acres, even farther offshore. The way BOEM is conducting this process is that the WEAs will be put up for lease to private entities, which will likely be multinational companies.

The lease winners then have an opportunity to develop more detailed proposals for installation of turbines. When, one might ask, will there be an Environmental Impact Statement gauging the impacts of, and possible alternatives to, such a massive project? Answer: not until much closer to the construction phase of the development. ORCA believes it should be sooner in the process, such as before the leasing, to take a serious look at the impacts of industrializing the ocean, especially the region near Heceta Bank, a part of the ocean known to be especially productive for fish and marine life.

BOEM at this stage only wants comments on where the WEA’s should be, and their size. They only want to hear about concerns related to specific WEAs, and/or concerns about the analysis used to choose particular sites. Nevertheless, it is important to raise concerns about development in marine areas that have been largely free of development.

Here are a few issues to keep in mind, which ORCA thinks the agency most needs to address: the south Oregon coast is not close to major transmission lines feeding large nearby population centers. On the contrary, the south coast is very sparsely populated, and the rugged landscape is highly fire, landslide and earthquake-prone. Getting the energy to the electrical grid would prove quite challenging, and likely environmentally destructive to both communities and landscapes. This is a facet of the plans that has not yet received much attention. BOEM has also provided no cumulative impacts analysis on how wind energy development will affect fish and wildlife in the California Current ecosystem Oregon is part of, nor analyzed its effects on upwelling and its crucial productivity, via nutrient provision, to the marine ecosystem. There are also serious unanswered questions about electromagnetic fields and their effects on birds and marine life.

You can either type (or cut and paste) in your comments directly or upload a PDF of your letter to the BOEM docket portal, which also has the basic BOEM notice, with the maps, here.

In 2021 the Oregon Legislature passed HB 2603 in response to the Facebook submarine cable disaster in Tierra del Mar. The company insisted on landing its new cable right in the middle of TDM, literally between residential houses. A litany of disasters ensued, including a frack-out, two sinkholes on the beach and a serious drilling accident which resulted in drilling fluid and abandoned equipment being permanently entombed under our seafloor. It was clear that Oregon, having no rules at all for submarine cable activity, was going to suffer other disasters in future as unscrupulous companies took advantage of our lax regulatory environment.

The Department of Land Conservation and Development was taxed with developing the implementing rules for the new legislation, which expand rules on uses of the seafloor. They have completed a draft of the rules, and now invite public comment. The deadline is November 3rd. Please send comments here. Many concerned residents, and ORCA as well, either have or will soon be doing so.

Information on the new rules is here.

While the new draft is a major step in the right direction for Oregon, significant gaps remain. For one thing, HB 2603 was very clear about the need to evaluate suitable landing sites. But the proposed rules only require the Department of State Lands to “consider the benefit of implementing corridors for infrastructure crossing the territorial sea…” – a much looser mandate that does not evaluate appropriate and inappropriate landing sites. It is the state that should be deciding the landing sites, not the industry, though they forcefully argue in favor of their right to choose the locations.

Second, the legislation clearly desired the agency to change fee structures to adequately protect and manage both the territorial sea and the ocean shore. But the proposed rules do not change the fee structure to a more appropriate, higher rate that holds the industry accountable. California has a much better track record: the City of Grover Beach, for example, negotiated a $400,000 annual fee for installed cables during their time of operation.

Clatsop County is poised to do its part in reducing Oregon’s housing shortage, especially for workforce and affordable housing. Unfortunately, the effort is also poised to damage Oregon’s cherished efforts to protect other aspects of the environment, such as riparian zones and wetlands. The planning commission is holding its first hearing on these proposals on November 14th.

Some of the Clatsop County proposals are sensible, such as reducing application fees from $1,200 to $85. But other proposals simply shut off more and more public participation opportunities in the name of getting housing built. Goal 1 is the first goal of the land use laws, and its purpose is the increase of citizen involvement. County proposals to allow duplex units, multi-family dwellings, mobile home parks and group housing as Type I dwellings means that all these would be allowed in the designated zones with no notice, no opportunity for public comment, and no appeal of the decision. The effects on community infrastructure, wetlands, roads and other concerns would never have a chance to be raised.

“Type I” is a bureaucratic term that does not indicate that it was created specifically to permit projects without any public involvement whatsoever. Theoretically these are projects that meet all the rules and standards, and thus need no public review. But Clatsop County is using it more and more, because it is so much more convenient to exclude the public. For example, the county has recently been working on an approval of the Alkire 9,000-square foot mansion with extensive landscaping that includes kitchen gardens, ornamental flower beds, chicken coops and viewing terraces, in a rural residential area in the forestlands, with no concern for fire danger, public resources or community – such as nearby Cannon Beach, which would have to provide any needed emergency services – at all. ORCA testified vigorously about this application to the Planning Department, even though the county said it did not have to listen to any public comment, because the Alkire mansion was a Type I approval.

The Clatsop County housing proposal also targets differences among communities, especially Arch Cape. Only Arch Cape requires road development to go through a conditional use process and have public involvement. The County finds this troublesome, and wants to eliminate it.

The county is proposing some very questionable things that need some study, such as reducing minimum lot sizes for properties with community water or sewer from 15,000 square feet to 10,000 square feet. How would that impact infrastructure costs and capacity? Perhaps most alarmingly, the county also wants to find ways to determine which EFU and forest dwellings could be a Type I use – requiring no public involvement – rather than a conditional use.

These proposals are new, and tentative, at this point. Come to the November 14th hearing and make your voices heard about how Clatsop County can address the housing shortage without compromising the environment.