Comment from McQuilling Renewables

In support of BOEM’s planning process to determine whether to offer a lease for commercial OCS mineral development offshore the Commonwealth of Virginia, McQuilling Renewables suggests a maritime traffic assessment on commercial and recreational marine uses in and around the Virginia Request for Information Area. Drawing on the skills, experience and global shipping supply chain network of McQuilling Partners, McQuilling Renewables, based in Garden City, NY, brings individually crafted marine supply chain solutions to US offshore industries. McQuilling Renewables conducted a similar assessment of marine activity in an Area of Analysis (AoA) beyond the 60-meter depth contour for the New York State Energy Research and Development Authority (NYSERDA) with the purpose of supporting BOEM’s decisions on future lease sites for the offshore energy industry. The study paints a picture of marine traffic in deep water off New York State and characterizes marine uses by their persistence, density, navigational flexibility, maneuverability, economic effect, regulatory oversight, and purpose. The report was published in early 2025 and is available at https://www.nyserda.ny.gov/About/Publications/Offshore-Wind-Plans-for-New-York-State under 25-14 Offshore Wind Planning in the New York Bight: Maritime Assessment–Commercial and Recreational Uses Study [PDF]. A similar assessment for the OCS acreage in and around the RFI Area would illustrate the types and density of existing marine traffic so that offshore mining developers can assess logistical challenges in the area, including utilization days and busy seasons, and plan accordingly to prevent conflict. In turn, traffic developed from mineral exploration and development would inform coastal users and fisheries of the potential impacts of work in this area. Additionally, potential hazards on the seabed (unexploded ordinances) or underwater military uses (submarine channels) in and around the RFI Area should be assessed. In the report for NYSERDA, McQuilling Renewables analyzed ocean uses through various visual data portals, including the Mid-Atlantic Regional Council on the Ocean (MARCO) Data Portal, Marine Cadastre, New York Geographic Information Gateway (NYGIS) and the Northeast Ocean Data Portal. Investigative methods used in this report included gathering, analyzing and reporting on data from: regional online portals; historical vessel traffic positions and projections; boating statistics; offshore weather/sea state buoys; economic assessments and projections; previous NYSERDA studies; domestic and international regulatory guidance; marine safety considerations; U.S. Gulf oil and gas experience; publicly available online research; scholarly sources; and project based information from an offshore energy site being constructed in US waters. Projections of offshore marine traffic growth were incorporated based on an analysis of existing and projected projects. Non-offshore energy related marine traffic growth was also estimated using economic models and trade statistics in the region. The types of vessel traffic analyzed included all types of commercial, government, and private/recreational vessels. This Maritime Assessment introduced a number of novel concepts across a range of topics, namely: •Established seven criteria to classify marine uses as commercial or recreational •Introduced the concept of marine transit traffic as compared to marine destinational traffic as a way to further classify uses, including establishing methodology to assess impact of activities •Produced commercial marine traffic growth forecasts from 2024-2040 based on 2017-2022 AIS data trend line analysis from a grid of aliquots •Produced commercial marine traffic growth forecasts from 2024-2040 based on GDP versus cargo movements using econometric modeling •Used weather, sea state ocean metadata as conditioners for inferring presence and persistence of recreational vessels in/around area of analysis (AoA) where vessel position AIS data was lacking •Employed discretionary use from recreational USCG boating statistics, along with National Weather Service advisories and met-ocean data as conditioners for presence and persistence of recreational vessels in/around AoA where vessel position AIS data was lacking Based on this previous work, McQuilling is uniquely positioned to assess multiple use conflicts related to offshore mining in the Virginia Request for Information Area, enabling BOEM and mining companies to consider ways to eliminate, mitigate, and monitor for impacts related to this offshore industry development. For more information, please contact: Avril Montanti McQuilling Renewables 1035 Stewart Ave Garden City, NY 11530