Offshore Wind Energy Projects: Summary of a Workshop (2011)

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Offshore Wind Energy Projects A Workshop Peter Johnson, Rapporteur T here is a growing interest in offshore wind energy production in the United States. Several projects have been proposed or are in development, particularly along the Eastern Seaboard. The Energy Policy Act of 2005 vested responsibility for the safe and environmentally responsible development of offshore renewable energy production on the outer continental shelf with the Minerals Management Service (MMS) of the U.S. Department of the Interior.1 In mid-2009, MMS, in collaboration with the Federal Energy Regulatory Commission, issued a regulatory framework and interim guidelines for the orderly, safe, and environmentally responsible development of offshore renewable energy projects on the outer continental shelf. Under the current agreement, MMS is responsible for overseeing nonhydrokinetic renewable energy projects (such as wind).2 The regulations published in mid-2009 put forth a general framework for leases and project review but do not specify standards or prescriptive requirements for facility design, fabrication, and installation or for environmental and safety management, inspection, and facility assessment. Therefore, MMS asked the National Academies for assistance in these areas, beginning with a workshop to bring together interested parties and stakeholders for exchange of technical information, discussion of key issues, identification of problems or concerns, and review of possible approaches that MMS might consider. The following is the statement of task for this workshop: Statement of Task: An ad hoc committee will organize a workshop on offshore wind energy projects. The workshop will include presentations and discussion on design and operational options for turbines, blades, towers, substructures, foundations, and electrical connections to the grid. The workshop will highlight processes and procedures that can be used within the Minerals Management Service’s regulatory regime to minimize risk to safety and the environment and minimize disruptions to the supply of electricity. In particular, the workshop will examine the MMS process for selecting and managing certified verification agents (CVAs) and for identifying appropriate standards for assuring good engineering judgment and practice; for reviewing and approving designs, fabrications, and installations; and for determining acceptable qualifications and role for a CVA.3 MMS is now the Bureau of Ocean Energy Management, Regulation, and Enforcement within the U.S. Department of the 1 Interior. This agreement also gave joint responsibility to the Federal Energy Regulatory Commission and MMS for marine hydro- 2 kinetics projects. A CVA is an independent third-party organization that reviews the design and construction of a project and certifies that it 3 meets certain standards. 1 

OFFSHORE WIND ENERGY PROJECTS To conduct this project, the Transportation Research Board’s Marine Board convened a planning committee of six members, appointed by the National Research Council, to organize a one-and-a-half-day workshop to provide MMS with input from public and private institutions involved in offshore wind energy developments. The workshop was held on March 25 and 26, 2010, at the Keck Center in Washington, D.C. About 95 participants attended the workshop. The workshop agenda (see page 9) has links to each presentation in PowerPoint format. The planning committee members (see page 17) chaired the workshop, led various discussions, and moderated the sessions. The remainder of this section summarizes the presentations, discussions, comments from the participants (who are listed on page 13), and key results of the workshop. WORKSHOP TOPICAL OVERVIEW PLENARY SESSIONS (DAY 1) The workshop began with introductions of moderators and participants and several presentations to define the subject, the goals, and the background of relevant work to date conducted both in the United States and abroad. The first presentation by MMS Senior Technical Advisor John Cushing described the status of MMS programs and its expectations for the workshop. MMS goals for this workshop were stated as the following questions: • What constitutes good engineering judgment and practices for the design, fabrication, and installation of offshore wind energy structures? • How can or should existing standards and practices be used for the above? • What is the CVA role in determining appropriate standards and practices? • What is the CVA role in determining appropriate environmental and functional loads? • What is the CVA role in conducting monitoring programs and on-site inspections to verify compliance? • What constitutes acceptable qualifications for a CVA? The next (stage-setting) presentation by Malcolm Sharples, an MMS consultant, described studies and investigations recently conducted to understand the offshore wind systems that have been developed, experience to date in other settings, and analyses of safety and environmental issues that have been conducted to date. The workshop continued with three panel sessions: Panel A: Safety Principles for Construction and Operations Panel B: The CVA Process: How Can It Be Adapted for Offshore Wind Projects? Panel C: What Existing Standards Are Available and Could Be Applied or Adapted? For each session, a moderator presided over several speakers who presented their views of the topic and how to consider the issue. The presentations were followed by questions from the audience and general discussions. The workshop agenda (see page 9) has links to these presentations. 2 

A WORKSHOP Panel A Panel A included two presentations concerning general safety principles and their application to offshore wind energy systems. The presentations used examples from recent work in other regions and related industries such as offshore oil and gas development. Panelists noted the importance of addressing safety throughout the development process, to include design, fabrication, installation, operations and maintenance, and decommissioning and removal. Panel B Panel B consisted of three presentations by practitioners involved in some aspect of the CVA process and its potential application to future offshore wind projects. The presentations covered some history of how and why MMS incorporated the CVA process for offshore oil and gas and how it could be adapted for wind energy. They described how it has worked, what systems and functions it applies to, and what steps in the development process are incorporated. They also provided reasons why a similar process might be selected, adapted, and applied to the case of offshore wind energy development and how it might be modified to suit the special needs of this industry. Panel C Panel C consisted of three presentations on the subject of adapting existing standards from other industries and countries for U.S. offshore wind energy applications. One of them compared the standards for offshore structures issued by the International Electrotechnical Commission and the American Petroleum Institute and concluded that the differences between the two were minor. Another presented the Germanischer Lloyd guidelines and standards that cover certification of wind turbines and total wind farm systems in Europe. It referenced publications, the detailed requirements for certification, and the history of applications. A final presentation covered the current American Petroleum Institute structural standards in place for offshore platforms and the possible application of these to wind farms. Workshop Breakout Group Sessions The workshop continued with four breakout group sessions that met concurrently during the afternoon of the first day. Participants in each of the four breakout groups were asked to review existing data and information on the given subject presented in the plenary session and offer comments on how critical the issue was and what could be done to develop an effective and efficient process (using the CVA approach) for ensuring safe operating environments for U.S. offshore wind energy projects in the future. Comments offered by individual participants during the breakout group discussions included the following: • Group 1: CVA role and qualifications: – The CVA role is viewed as advisory for verifying conformance with appropriate standards and as an active validation role regarding appropriate environmental loads. The monitoring and inspection role would be defined on a case-by-case basis. – CVA qualifications could follow existing systems established by MMS for other applications, with appropriate expansion if needed for other than structural systems requiring a professional engineer certificate in civil engineering. 3 

OFFSHORE WIND ENERGY PROJECTS – Missing information could be obtained by working cooperatively with industry associations to create road maps and define codes. One option noted would be to create a volunteer advisory group to help MMS through the process, especially if the CVA role is expanded beyond structures. – There is a need to better define various agency regulator responsibilities and pursue active memoranda of understanding with other federal agencies. • Group 2: Standards and practices: – Industry could provide appropriate consensus standards that could be adopted by MMS, and MMS could then accept a design basis approach as an interim solution. MMS could also encourage interagency cooperation to develop common requirements. – MMS could determine what type classification and project certification may be used by the CVA. – Standards could incorporate current industry practices, with additional emphasis on health, safety, environment, and structural integrity. Certain standards would need to be site specific. • Group 3: Metocean4 data: – It would be helpful to have a definition of critical data needs in terms of design and use, as well as information on best practices for data collection, best sources of existing data, and effective dissemination strategies. – Early action to define a matrix of relevant variables for candidate standards, identify historical data and gaps, quantify the significance of the gaps, and fill gaps with a cooperative data collection effort would be helpful. One possibility would be to use a public–private cooperative covering a wide coastal area (within target regions) to meet multiple needs (variety of stakeholders). – It would be helpful to continue this forum for future discussions of data needs and developments and to disseminate information on data needs and gaps. Consideration of establishing an interagency task force with private-sector advisors to work on data tasks, especially identification of acceptable tools for data analyses and application to design loading, was suggested. • Group 4: Other system design issues: – It was pointed out that the safety of personnel is an important issue that needs careful consideration with regard to construction and installation, but especially with regard to maintenance operations. Participants observed that it is not clear who is responsible for setting standards for personnel safety, for training, and for oversight. – It may be necessary to consider the question of ship–structure allisions, especially if wind farms are installed in regions with high ship traffic. – It also may be useful to give attention to special aspects of offshore wind energy installations, such as seabed subsoil analysis, foundation design for towers, and total design for transmission cable systems. – A CVA program using much the same approach as that in place for offshore oil and gas might be considered, but with the option to modify and improve it as more experience with offshore wind energy is obtained. Meteorological and oceanographic. 4 4 

A WORKSHOP – Public education is important, especially in preparation for adverse conditions, possible outages caused by severe weather, and other hazards resulting in loss of power. FINAL WORKSHOP PLENARY SESSION: GROUP REPORT AND WRAP-UP In the final workshop plenary session, each of the four breakout groups reported on its discussions and observations to the full assembly of participants. This also allowed an opportunity for questions and comments from all. The workshop agenda (see page 9) has links to the four reports in PowerPoint format. Breakout Group 1 Breakout Group 1 focused on the role and qualifications to be expected of a CVA in a typical offshore wind energy project. Comments offered by participants included the following: • What constitutes good practice is a key question. • A CVA should incorporate good existing practices by cataloging what exists, preparing a road map, and defining the regulator’s responsibility. • It is important to develop agreement documents between state governments and the federal government to streamline the process. • A typical CVA role might focus on structures, because structural rules are already in place. • Perhaps the CVA should only advise on other items, because developers have a lot of existing private oversight. • The CVA role may need to be evaluated on a case-by-case basis. • Regarding CVA qualifications, perhaps a special advisory committee could be considered to perform an accreditation process. Several group members commented that the discussion was missing many of the lessons learned from European experience, which would be very instructive. Some also thought it would be useful to review road maps for codes and standards, especially those that are the responsibility of all regulators. One suggestion for an early next step was to establish a voluntary advisory group to coordinate with states and look beyond structures to turbines and other components of the wind energy system. Breakout Group 2 Breakout Group 2 focused on standards, specifically, what existing standards could be applied or adapted and what standards need to be developed separately because the wind energy system presents unique challenges not covered by previous regulations. Comments offered by individual participants included the following (not in order of importance): • Industry could develop consensus standards first, and then MMS could select a design basis and get interagency agreement on it. It will be important to determine what to accept as industry standards and how. 5 

OFFSHORE WIND ENERGY PROJECTS • Because MMS is mostly involved in structural safety standards, the role of a CVA could be established based on the needs of each project. It was noted that the American Wind Energy Association has a working group to design a road map and identify gaps. • Industry could specify safety management systems and develop and implement best practices with CVA oversight. • CVA organizational qualifications could include multidisciplinary expertise in engineering and a network of experienced inspectors. Breakout Group 3 Breakout Group 3 focused on questions regarding the adequacy of metocean data and issues related to using historical data to determine maximum design storm conditions for structural loading and other system requirements. This subject is more limited than others, but data needs are broader than just determining design standards for wind energy systems. Comments offered by individual participants included the following: • This issue should also include what data should be collected and measured in general by all agencies. • There is already a large amount of publicly available data, but these data need to be investigated for adequacy of measurement and analysis and adapted to unique conditions of wind energy systems (e.g., extrapolating wind data from surface buoy observations to the hub height of a wind turbine). The group also discussed other data needs, such as measurements of seabed geotechnic conditions in regions under consideration for wind farms. It was mentioned that European projects have collected such data and would offer a model for best approaches in the United States. It was also mentioned that public–private partnerships may be appropriate to use for future data collection, processing, and dissemination. An atlas for large regions might be helpful and could be produced with available data, with analyses focused on wind farm needs. One question raised was how to define best practices for applying data to set design standards so that a common product could be widely used. It was mentioned that the National Oceanic and Atmospheric Administration could possibly develop and package existing data sets in a form specifically tailored for use by wind projects if industry needs could be clearly defined. Breakout Group 4 Breakout Group 4 covered several topics that were not part of the other categories. Participants discussed what else creates risks to human health and the environment and considered how a CVA could address the dynamics of the system and what the drivers are. Comments offered by individual participants included the following: • Beyond design and construction, issues could include shutdown procedures, training of personnel, and how to accommodate marine transportation safety. For example, in Europe, platforms are designed to fail should a certain size ship collide with them, because losing the platform is considered preferable to sinking the ship. • Regarding the use of failure analyses, lessons could be learned from the offshore oil and gas industry. • The potential effect on utility customers of multiple power failures caused by a catastrophic event at a wind farm should be considered. 6 

A WORKSHOP • Prescriptive standards could be valuable because many operators might not be original developers with extensive experience.5 • One issue that needs attention is public education, which should include explanations of past achievements as well as of the challenges ahead. • Adopting a total system perspective (e.g., towers, electrical, generators, operations) for safe operations was discussed.6 • Regulators need to be involved in hazard analysis for the total system. MMS RESPONSE TO THE COMMENTS After the breakout group reports and discussion, MMS responded with initial reactions. MMS Senior Technical Advisor John Cushing defined the process and path forward to address these issues as arduous and time consuming but necessary, because MMS wants to get it right from the start. MMS believes that, to the extent possible, it will be most effective to use industry-derived consensus standards as a basis for regulations and to develop a full regulatory process from this base. MMS has asked the National Academies to conduct a follow-on study after this workshop and will urge all workshop participants to remain engaged and offer advice as this work continues. MMS also understands that future work on this subject will require even more engagement among U.S. offshore wind energy developers, the offshore oil and gas industry, and regulators. It will also benefit from the more extensive experience of wind energy developers in Europe. Further discussion highlighted the following issues: • It would be useful to consider technical and environmental issues in more depth in future forums of this type and, possibly, to engage offshore oil and gas experts as well (some favored using Houston as a location for such a forum). • It would also be useful to continue this type of workshop with a specific focus on learning from the European experience and capturing European best practices in offshore developments for implementation here. • In Europe, much attention has been given to the design and installation of subsea cables, which are a factor affecting overall system reliability and safety. These issues may also affect U.S. offshore projects. • Further discussion and clarification are needed to specifically define the role of the CVA. Would the CVA evaluate the system design basis and determine whether it is valid, or would doing so be the sole responsibility of MMS? • Questions were posed regarding how MMS is engaging the U.S. Army Corps of Engineers (USACE) in the whole process. For example, USACE is involved in state waters and issues its own permits. WORKSHOP WRAP-UP At the conclusion of the workshop, participants made a number of observations based on the presentations, discussions, and comments: This comment should not imply that operators should not also be required to employ competent personnel who establish a 5 comprehensive safety management regime. A systems perspective encourages designers and operators to evaluate the interactions of various components and subsys- 6 tems that affect overall performance, failure modes, and level of risk. 7 

OFFSHORE WIND ENERGY PROJECTS • Although a lot of useful information is available to draw on to develop an adequate safety oversight and review program, this information has not been put into a decision matrix. Many participants felt that doing so would facilitate the process and improve the outcome. The major challenges are defining the scope, selecting the key issues, and deciding how to move forward. • It would be useful and productive to continue the dialog begun in this workshop and to continue to engage the organizations and stakeholders represented here. • The workshop served a useful purpose, included interactive discussions, and brought together a good cross-section of affected parties. It was noted that a few perspectives—venture capitalists, certain other agencies (e.g., the Bureau of Land Management), and local communities and mariners in affected regions—were missing and could be consulted in the future. Public communication about how wind farms relate to critical infrastructure questions is important to consider in the future. Expanding interaction with developments in Europe, from which many lessons can be learned, could also be useful. • Many participants noted the importance of continuing a total systems approach and seeking to learn as much as possible from other industries. Also noted was that it would be helpful to use a risk-based perspective and identify performance requirements as the process moves forward. • Developing a more common understanding of terms used in the industry as well as in the promulgation of regulations and standards would be helpful. • Whatever government process is implemented, participants emphasized that it should facilitate rather than hinder private development and that it therefore should be a simple and productive process. 8