Summary of Key Findings and Recommendations - Structural Integrity of Offshore Wind Turbines - page 125

Lakes) and seismic activity (especially on the Pacific coast)—would
need to be covered appropriately.
- Transparency. Methodologies for strength analysis 1 differ among the
standards and guidance documents and are not always fully delin-
eated, making it difficult to compare the standards and guidance
documents against one another to determine whether they provide
equivalent safety levels, especially when applied to novel concepts.
The methodologies, assumptions, and data used for strength analy-
sis must be laid out clearly to provide the necessary transparency.
• BOEMRE's own regulations (published in 30 CFR 285) and accom-
panying guidance are inadequate in that they do not identify spe-
cific criteria that a proposed project must meet to be approved and
gain the necessary permits.
Although regulations 2 promulgated by BOEMRE require that
detailed reports for design, construction, and operation of offshore
wind turbines be submitted for BOEMRE approval, they do not spec-
ify standards that an offshore wind turbine must meet. Rather, a third
party (CVA) is asked to comment on the adequacy of design, fabrica-
tion, and installation and provide reports to BOEMRE indicating the
CVA's assessment of adequacy. Moreover, when a general level of per-
formance such as “safe” is stipulated, no guidance is provided on how
to assess whether this level of performance has been met.
• The United States urgently needs a set of clear and specific standards
to reduce uncertainty in the requirements that projects must meet,
facilitate the orderly development of offshore wind energy, and sup-
port the stable economic development of a nascent industry.
States and private companies are developing plans for offshore wind
energy projects in state waters and on the OCS. Well-defined U.S. reg-
ulations for development on the OCS are needed ( a ) to provide a
resource for states as they develop requirements for projects in state
waters and ( b ) to supply industry with sufficient clarity and certainty on

1

Some standards and guidance documents are based on strength or limit states design; others are
based on allowable stress design. The philosophies underlying these methods are fundamentally
different. See Chapter 4.

2

30 CFR Part 285, 74 FR 81, pp. 19638-29871.