Home

Statement of

Norris McDonald

President

African American Environmentalist Association

Submitted To The

U.S. Army Corp of Engineers

Massachusetts Executive Office of Environmental Affairs

Cape Cod Commission

On The

 Cape Wind Energy Project

Off Shore Wind Park

 (File No. NAE-2004-338-1)

 At The

 Massachusetts Institute of Technology

Cambridge, Massachusetts

Thursday, December 16, 2004

 Introduction

My name is Norris McDonald and I am the founder and president of the African American Environmentalist Association (AAEA).  This written statement is being submitted to express our support for wind power in general and the Cape Wind Energy Project in particular. The African American Environmentalist Association (AAEA) supports wind power because of the emission-free nature of the technology. 

The African American Environmentalist Association was founded in 1985 and is a national, nonprofit organization dedicated to protecting the environment, promoting the efficient use of natural resources, enhancing human, animal and plant ecologies and increasing African American participation in the environmental movement. AAEA is based in the Washington, DC Metropolitan Area and we have chapters nationwide and members worldwide.

Wind energy is an excellent source of emission free electricity.  The Draft Environmental Impact Statement (DEIS) released by the Army Corps of Engineers on November 8, 2004, shows that Cape Wind will produce public benefits with positive environmental and economic impacts. The Cape Wind Energy Project will create jobs, decrease air pollution and greenhouse gas emissions, provide a renewable source of electricity, and lead the way for additional offshore wind projects.  The project creates no major negative impacts on the ecology of Nantucket Sound, local tourism, surrounding property values and will not be a hazard to air or sea navigation.  The Nantucket Sound site is also the best site out of the alternative sites considered for this project.

The combined hearing provides appropriate environmental reviews under the National Environmental Policy Act (NEPA), Massachusetts Environmental Policy Act (MEPA), and Development of Regional Impact (DRI.  A positive Record Of Decision (ROD) should be applied to this project upon completion of the Final Environmental Impact Statement so that the project can be initiated early in 2005.

Mitigation of Anticipated Impacts

Fortunately, this environmentally benign project has virtually no impacts to mitigate.  The only real point of contention is the visual impact and this is a subjective criterion.  AAEA believes the wind power structures are magnificent and reflect an aesthetic fusion of nature and technology (wind and power).  It is unfortunate that some gated community opponents and environmental advocates see the structures as anathema to the historical and natural views of the sound.  Beauty is in the eye of the beholder.  For those lacking an appreciation for beautiful technology, the visible structures of the wind park will be painted a marine, light blue/gray color to minimize contrast with the surrounding sea and sky.  Low-intensity lighting will be used for daytime and nighttime lighting.

The project will be visible from a number of National Register listed or eligible historic districts and individual structures.  The Visible Impact Assessment (VIA) found that, “the visual alteration of Nantucket Sound will constitute an alteration of the historic character, setting and viewshed of the properties and will have an adverse visual effect on them.”  Affected properties include two national historic list properties (the Kennedy Compound and the Nantucket Historic District), four historic districts and 10 individual historic properties.  The historic properties are located near or at the shorefront along the south side of Cape Cod, the northeast side of Martha’s Vineyard, and the north side of Nantucket.

The disturbance of the localized sediment due to the installation of the wind farm array and submarine cable system (115 kV line) is minimal.   The disturbance will be temporary and the ecology in the sound should return to a natural state soon after construction.  The state-of-the-art cable embedment technologies and techniques will minimize impacts.

No mitigation is necessary for wind or water flows because the 130 wind turbine generators (WTGs) will not have a significant impact on tidal or wind driven currents and wave conditions

Heat generated by the heavily insulated electric cable will be minimal and will not disturb habitat or water quality.

Virtually no mitigation is needed for the temporary disturbance of benthos invertebrates and shellfish due to laying the cable or from the structures. The applicant is also providing additional mitigation measures: shellfish reseeding funding, notification of registered lobster fishermen, avoiding privately licensed shellfish areas, among others. There will be minimum disruption to and mortality of finfish, eggs and larvae.  The project poses no threat to protected marine or terrestrial species.  The project will have minimal impact on land and sea vegetation.

The project does not pose a threat to bats or waterfowl.  Collisions with wind turbines and wind towers will kill a minimal number of birds; not enough to significantly affect populations of gulls, migrating birds or shorebirds. The Endangered Species Act listed Roseate Tern (endangered) and Piping Plover (threatened) are not threatened by the project and the applicant has design controls, such as fencing and special lighting techniques, to mitigate any threat to endangered birds.  Also, the proposed turbine blades will not come within 75 feet of the water so low flying birds, such as ducks, should not be threatened.

There are virtually no noise impacts and minimal temporary impacts to marine navigation during construction – virtually none during operations and maintenance.  The wind turbines will be arranged in a grid pattern rather than randomly scattering them so that boats can navigate straight through the park.  The project area is 24 square miles with WTGs at least 2,000 feet apart.

There are no adverse aeronautical impacts.  The Federal Aviation Administration (FAA) issued a Determination of No Hazard To Air Navigation on April 9, 2003.  Each WTG will be lighted with FAA approved flashing lights.

The electromagnetic fields generated by the towers and the cable will have no adverse impacts.  The projects will not interfere with telecommunications towers, marine VHF radios, radar or sonar.

The emission free electricity provided by the wind park will help Massachusetts achieve attainment for ozone and other EPA criteria air pollutants.

Socioeconomics

Environmental Justice.  Although the DEIS states that there are no environmental justice issues, it should state that there are no environmental injustice issues.  It is correct that the project does not formally trigger thresholds requiring environmental justice analysis.  The important point from an environmental justice perspective is that, as the report states, “Because the Cape Wind Project will generate non-polluting electricity, operation of the project will be beneficial to human health…”   To the extent that electricity is provided to the New England Power Pool (NEPOOL), the wind project positively affects minority communities that are disproportionately impacted by pollution sites, particularly air pollution sites.

If opponents are successful in killing this project by delaying it through litigation, they are saying that although it is a good project, it s not good if it is in their backyard.  They must take the view that it should be built in Roxbury or other low-income communities in Western Massachusetts.  AAEA has a big problem with this type of environmental elitism.

Subsidy. The Production Tax Credit (PTC) could provide approximately $27 million in tax credits over a ten year period (approximately 1,489,200 megawatt hours (MWh) annually x 10 years = 1,489,200,000  kwhs x $0.018/kwh).  The Cape Wind Project will assist in meeting the Renewable Energy Portfolio Standard.

Jobs, Economic Benefits and Tax Revenues.  The project will create 154 jobs (50 permanent), tens of millions of dollars in annual output and income.  The project will also create an estimated permanent annual increase in real property tax revenues of $63, 000 for the Town of Barnstable and $217,000 for the Town of Yarmouth.  Charitable contributions will also be made to the towns.  According to the Department of Energy (DOE) the proposed Cape Wind Project will have U.S. economic benefits of $1.5 to $2.0 billion.

Commercial Fishing, Recreational Boating and Recreational Fishing.  The applicant is not requesting any restrictions on commercial fishing, so there should be no adverse impacts on this sector.  Recreational boating and fishing should not be adversely impacted because of the spacing of the towers (at least 2,000 feet).

Oceans Policy

The Federal government is currently establishing a comprehensive policy for our oceans through the recommendations of the U.S. Commission on Oceans.  President Bush will make the final recommendations.  AAEA believes that there is no need to alter the current law regarding the permitting of offshore wind facilities.  The NEPA EIS already provides for a comprehensive review process. AAEA also believes that Congress should provide grants to all coastal states for programs and efforts to enhance renewable ocean resources.

Conclusion

Wind energy is an excellent source of supplemental power.  The emission free nature of the technology makes it ideal as a source of green power.  It appears that the only real obstacle to its application is ‘Not-In-My-Back-Yard’ (NIMBY) scenic elitists.  Of course, their sensitivities should not be belittled or minimized.  However, the reason most industrial and pollution sites end up in poor and minority neighborhoods is because power elites can afford to keep them out of their backyards.  There should be some sensitivity to the fact that many Americans are sacrificing their health for industrial activity while others do not even want to see a remnant of a benign, environmentally friendly facility on their horizon.

Massachusetts Environmental Injustice

Clean Energy Windmills Can't Be Built Offshore Because Rich Might See Them

While

Ebola, E. coli Bioterror Labs Can Be Built In Boston Inner City

The Boston Redevelopment Authority, the city's development agency, approved plans for a biomedical research center that will house Boston University's proposed top-security biodefense laboratory. The Massachusetts environment agency has approved the biodefense lab. All that is left before construction can begin is an environmental review decision by the federal government. The Boston Zoning Commission will also vote on the zoning of the biomedical campus, called BioSquare II early in 2005. Pending environmental impact reviews, work on the facility should be underway by summer 2005. The eight-story National Emerging Infectious Diseases Laboratories facility will be patrolled by armed guards.

Klare X. Allen and her four children live several miles from a proposed bioterror lab site, near Roxbury's Egleston Square,.where researchers plan to explore the deadliest microorganisms known to science -- germs of unknown or lethal pathogenesis, some of which spread easily on air currents. The work is dangerous. Allen is the community organizer for the Roxbury-based environmental advocacy group Alternatives for Community & Environment (ACE), located in an office building in Dudley Square. ACE is BU's most stubborn antagonist, but her voice and that of her neighbors are frequently ignored.

Support for the project has been helped with $128 million in federal funding pledged to offset total project costs of $178 million for Boston University's lab and $2.9 billion more expected to pour into the facility over the next two decades. Political leaders of all ranks support the project, maintaining that it will boost the city's economy and solidify Boston's standing as a biotech hub. Proponents believe the facility will be a magnet for scientific talent and create an estimated 660 permanent jobs. Mayor Thomas M. Menino, Governor Mitt Romney, Senator Edward M. Kennedy.and US Representative Michael E. Capuano, whose district includes the South End, all support the project.

Lab opponents questioned the logic of locating a high-containment facility in a densely populated neighborhood. Opponents believe biodefense researchers, in the name of counterterrorism, could be called upon to use recombinant methods like gene splicing and shuffling DNA molecules to make pathogens more potent and transmissible or resistant to available therapies, or even to engineer new strains and then work in reverse to explore countermeasures.

BU's biodefense lab has attracted local and national controversy because it would be required by the federal government to primarily research pathogens that could be used as agents of bioterror and because it would contain so-called biosafety level 4 labs, which research the world¡¦s most highly hazardous - and often incurable - pathogens such as Ebola. Level 4 is the highest level of biological containment.

The types of research likely to be conducted in the facility include the study of cures and treatments for anthrax, hemorrhagic fevers, SARS, and other such deadly pathogens.

Easy To Site Toxic Facility In Minority Community -- Hard To Site Wind Facility In Exclusive Waterfront Community

By Stephen Smith, Globe Staff  |  January 19, 2005

Three Boston University researchers became ill last year after being exposed in a laboratory to a potentially lethal bacterium called tularemia, university and public health authorities said yesterday.

It was the first known instance of researchers in a Boston lab becoming infected with a biological agent they were studying, according to a city public health official. And it came at an awkward time for BU -- when it was seeking local and federal approval for a high-security lab to study the most feared infectious diseases in the world.

How the workers became infected remains unclear, although BU officials said that researchers had violated procedures intended to protect them from exposure. Two researchers became ill in May and a third in September, apparently after separate exposures. But their illnesses were not linked to tularemia until October.

BU reported the cases to city, state, and federal health authorities in November -- about the time public hearings on the high-security lab were being held. But neither the university nor the government agencies disclosed the cases to the public at the time, saying there was no risk to public health because tularemia is not transmitted from person to person.

Boston Mayor Thomas M. Menino, who learned of the cases from BU and city public health officials, also decided against telling city residents.

"Right from the moment that he was made aware of the situation, the Public Health Commission assured him there was no public threat whatsoever, and he's made it clear that if there was any public threat whatsoever, the public would have been advised immediately," said Seth Gitell, the mayor's spokesman.

With Menino's enthusiastic backing, the city Zoning Commission gave its final approval to the high-security biolaboratory last week.

The lab still must be approved by the National Institute of Allergy and Infectious Diseases -- which is considered likely because it's the same agency that in 2003 selected BU as one of two sites nationally for sophisticated new labs able to study anthrax, plague, and other deadly pathogens.

BU and public health officials discussed the cases publicly for the first time yesterday after media inquiries.

The president of the Conservation Law Foundation, which has opposed building the high-security lab in an urban neighborhood as dense as the South End, said last night that the accident highlights the risk of studying dangerous biological and chemical agents.

"The assurances that BU has given that it can maintain perfect control of these facilities are called into question," said Philip Warburg, leader of the environmental group. "We're also disturbed that this incident is only coming to light today."

Gitell said that because the Zoning Commission was concerned solely with land development issues, it was not necessary to inform commission members about the exposures of the BU researchers.

Gitell said there were also concerns that publicizing the incident could jeopardize ongoing investigations into the exposures by the city Public Health Commission and the US Centers for Disease Control and Prevention.

Dr. Thomas J. Moore, acting provost of BU's medical campus, said the university did not believe that the cases of tularemia exposure were relevant to the ongoing debate over the development of the high-security facility, known as a Biosafety Level 4 lab. The researchers who became ill were working in a Biosafety Level 2 lab, which has far less stringent safety standards and is allowed to work only with less dangerous material.

"The security levels in a BSL-4 laboratory are so far beyond what you would see in a BSL-2 laboratory that this would never happen there," Moore said. "This has for sure heightened our awareness and attentiveness to safety issues in labs that operate at a lower level of security."

The first exposures happened last spring, with two researchers falling ill in late May. They complained of flu-like symptoms and one was hospitalized overnight. The third infected researcher fell ill in September and required hospitalization for several days, Moore said. All three recovered fully after receiving antibiotics.

University officials declined to identify the researchers or describe in greater detail their job duties, citing privacy concerns.

They worked in a lab that in 2003 received a five-year grant from the federal government to develop a vaccine against tularemia, an illness spread by insects and animals, including rabbits. Often called "rabbit fever," it is also viewed as a potential agent of bioterrorism. In 2000, an outbreak of tularemia on Martha's Vineyard ignited panic after a laborer died and about a dozen other people became infected.

The scientists at BU believed that they were working with a strain of the germ that had been altered specifically for vaccine research so as not to cause illness. But a highly infectious strain of tularemia was mixed with the harmless variety. The source of the contamination is being investigated by federal health officials.

The tularemia linked with the illnesses was supplied by a laboratory in Nebraska that federal authorities, citing security concerns, declined yesterday to identify.

Because the researchers assumed that they were working with a form of tularemia not known to cause illness, they did not immediately link their symptoms to their research.

It was after the third researcher became ill that faculty members began to suspect that something could be seriously wrong in the laboratory inside the university's Evans Biomedical Research building on Albany Street in the South End.

Subsequent DNA tests on the tularemia being studied in the BU lab showed that the bacteria identified as coming from Nebraska contained the harmless strain and a highly infectious type.

"The deck was stacked against [the researchers] because they were working with something they had no idea they were working with," Moore said.

But Moore acknowledged that researchers in the lab had violated policies requiring them to work with tularemia inside an enclosed box, called a hood, that sends air through sophisticated filters.

Instead, the tularemia samples were sometimes worked with in the open, in part because the enclosed research boxes were sometimes filled with material that should not have been kept there, Moore said.

Blood tests were performed on about 60 university researchers, and those tests showed that only the three workers who had become ill tested positive for tularemia. After the exposure was determined, BU in November shuttered the lab for decontamination. The part of the lab where the tularemia research was conducted remains closed.

Eleven researchers were placed on paid leave in November, to ensure the integrity of the investigation, and six remain off the job.

The investigation into how the exposure happened continues. Samples of tularemia were sent directly from the Nebraska lab for CDC analysis, and those tests showed no presence of the dangerous strain, deepening the mystery around the episode.

"At this time it seems to me there's no evidence conclusively to link the contamination to Boston or to Nebraska," said Jennifer Morcone, a CDC spokeswoman. "Certainly, everyone would like to determine the source of the contamination to make ceratin nothing like this could happen again."

Infectious disease specialists at other universities said that BU appeared to have acted properly by notifying health agencies. They also said that BU was not obligated to alert the public to the exposure of researchers.

"I don't know what the point would be of telling the public because there was no danger to the public," said Karl Klose, a professor of microbiology at the University of Texas at San Antonio

As a result of the exposures, BU as well as the Boston Public Health Commission are moving to tighten oversight of research. To improve safety in the dozens of public and private research labs in Boston, the Public Health Commission intends by this spring to start a mandatory training program for lab workers, emphasizing the reporting of illnesses in researchers. The commission also plans to hire a lab safety inspector who will make unannounced visits to research sites to make certain they are following safety protocols, said John Auerbach, Public Health Commission executive director.

Alice Dembner and Beth Daley of the Globe staff contributed to this report. Stephen Smith can be reached at stsmith@globe.com.