TEXAS GENERAL LAND OFFICE COMMISSIONER DAWN BUCKINGHAM, BLD. April 29, 2024 ‘The Bureau of Ocean Energy Management Office of Leasing and Plans ‘Aun: Renee Bigner 1201 Elmwood Park Boulevard Now Orleans, LA 70123, Dear Ms. Bigner: ‘As Commissioner of the Texas General Land Office (GLO), I appreciate the opportunity 0 ‘comment on the Bureau of Ocean Energy Managements (OEM) proposal fora second offshore wind energy auction coveriig 410,060 acres in the Gulf of Mexico (the "Auction"). The GLO serves the schoolchildren and environment of Texas by exercising prudent stewardship of State lands, mineral, and natural resources, including state-owned submerged lands extending from the shoreline out 10.3 miles to the boundary of federal waters. Tis similarity in mission makes me ‘uniquely qualified to shed light on the folly ofthe Biden administration's decision to proceed with the Auction and its continued efforts to force-fed the American people falled "green" policies. ‘Acatme when consumer demand for electoni vehicles (EV) is waning, American automakers are sealing back EV manufacturing plans,* and EV start-ups are fling,” this administration proceeded to finalize a rule on March 20, 2024, requiring nearly all passenger cas sod in the US tobe cleouc by 2032. Forging, of eouse, this administation is concurrently pushing to shutter natural gas-fired power plan at atime when U.S. povier consumption kequirements are expected to increase by 12 t0 22 percnt between now and 2030? So how do they propose to fill his void in energy supply? Offshore win, of couse. Unfortunately for the Biden administration, offshore ‘wind projects just don't seer to pencil out. Just as year, BOEM auctioned approximately 200,000 acres for win leases off thecoastof Texas and received zero bids. In the ime since the filed st auclon, sted announced X was canceling two propose otshore wind projects loested off the ny i Ae Som A pie SERGE trons beat ar aoe Tp Coma Che 0S, 13,20, Msn o2R4N ‘Ei Sap ur Bed Th Las a a a2 270. pease {3 tema con Agcy Dee scare Pi Seng er alo Suds Ca Raton On $Ni8etnscit Pon ages Pps ae Plato Sr le ed we PT ‘ph 0, pap peep ga alo ste ea oer Pe 1POONodth Congress Aes, Austin, Teas 757011095 10. ox 247% Anti, Teas 27S 512448 St glatercgoePagel coast of New Jersey.° For ttt it took a $4 billion dollar write-down, Qrsted similarly announced in January that it was withdrawing and "repositioning" a potential project ofthe coast of Maryland because it is no longer commercially viable due to challenging market conditions.” This despite ‘bot federal and state tax incentives and subsidies. Rather than learn from the largest developer of offshore wind power inthe world, the Biden administration, through BOEM, is hell-beat to push forward with the proposed Auction ven if a lessee were to actually se a path to cking outa profit, introducing hundreds of wind turbines across 410,060 acres of ecologically-sensitive ocean is reckless and directly contradicts, the Biden administration's recent position when leasing federal tnd inthe Gulf of Mexio for oi, and gas development. Just ast year, BOEM sought to reduce the size of ~ and ultimately cancel an auction for oil and gas lasing inthe Gulf of Mexico due to concerms about the endangered Rice's whale. It took legal ation by the oil and gas industry and a ruling by the Sth Circuit Court, ‘of Appeals for that auction to proceed. Yet now, for a potential projet with a greater surface footprint, concerns about impacts othe Rice's whale are apparently unvoiced. According to Clean Ocean Action, the number of whales washing ashore on the east coast is unprecedented and coincides with National Marine Fisheries ‘Service's issuance of Incidental Harassment ‘Authorizations for preconstuetion activities carried out to assess sediment suitability for wind farms. This includes six endangered whales in a 33-day peiod. Iam aso greatly concerned about the hundreds of bird species that migrate south through the Cental and Mississippi Migratory Bitd Flyways. Studies estimate hat over a million birds are killed by wind turbines in the United States, each year BOEM's proposal to erect a gauntiet of wind turbines forthe estimated two billion birds? to migrate through each year risks dramatically increasing that number Further, th impact of wind turbines on fish species and local fishing communities a a whole are deeply troubling. BOEM itself was a co-participant in a study released just last month detailing ‘numerous impacts that offshore wind power projets have on fish and marine mammals, including noise, vibration, electromagnetic ficids, and heat transfer that could damage the marine environment." U.S. Departnent of Commerce concedes that the construction and operation of ‘wind turbines: (1) displace shermen from traditional fishing area; (2) changes the distribution, abundance, and species composition of fish in an area; (3) causes economic loss to commercial, recreational, and tribal ishing; and (4 reduces safety at sea!" As the head ofthe Texas agency in charge of disaster recovery, Tm also Keenly aware ofthe risks posed to these wind farms by hurricanes inthe Gulf of Mexico. According to a study by Carnegie Mellon, there i a higher than 25% probability that more than 10% of wind turbines inthe Gulf of Mexico are destroyed by hurricanes within 20 years. A single wind turbine comprises 335 tons "oe Gre Coe Deepa Wik Ot Wn "(Ot 203 sent pt omen ‘een ern cee cero omnis "tc Swe ep a et 8,200, pete 01a “pa oa op Can th pcr RN ye cr Cun nd emi Aditi OAA) ae“ Coy pee heer sam neers ny gam "Ema edn eens. Hote oo Ose Wind rs Algc US. CoA Ap 1 202, uote ome educa espace pete 2p 00 North Congres Aven, tn Tess 77-85 51246500 latex (Neos Ap. 20,Pagel of steel, 4.7 tons of copper, 2 tons of rae earth elements, over 1,200 tons of concrete and as much as 1400 liters of oil." This means that BOEM is willingly intodueing the next ecological and ‘navigational hazard to both he Gulf and the coustal communities I serve Fortunately forall involved, acess to state-owned submerged land for transmission lines to shore requires an easement approved by the Commissioner of the GLO." As Commissioner, Tam charged with determining whether the granting of an easement sin the best interest ofthe state. 1 can assure you that when weighing the interests, I will do so objectively and without being influenced by "green" policy goals. As of now, see a number of significant concer ~ economic, acca, and envtonmental= that must e addressed before a prospective Wid estes erated to cross state-owned submerged land ‘Thank you for your careful consideration of these comments. Respectfully, b Luks DAWN BUCKINGHAG, M.D. ‘Commissioner, Texas General Land Office ra Wa a Mac Win atl A 1 26 psn vk ween 70 Noth Cong Ave tin, Tex 7701-195 PO. Bo 247% Ain ea 78713873 12448 S001 ates goe