Temporary Withdrawal of All Areas on the Outer Continental Shelf from Offshore Wind Leasing and Review of the Federal Government’s Leasing and Permitting Practices for Wind Projects

January 20, 2025

Action Summary

  • Temporary Withdrawal of OCS Areas: All areas on the Outer Continental Shelf (OCS) are being withdrawn from wind energy leasing effective January 21, 2025, until the memorandum is revoked. This applies to new or renewed leases for wind electricity generation, while existing leases remain unaffected pending review.
  • Review of Existing Leases: The Secretary of the Interior, in consultation with the Attorney General, will conduct a comprehensive review of current wind energy leases to assess ecological, economic, and environmental factors, and to recommend potential terminations or amendments.
  • Comprehensive Assessment of Wind Leasing and Permitting: A temporary cessation on issuing new or renewed approvals, permits, rights-of-way, leases, or loans for onshore or offshore wind projects will take place. The review will involve multiple agencies, focusing on legal deficiencies, impacts on navigation, transportation, national security, and wildlife, as well as economic considerations related to energy costs and subsidies.
  • Lava Ridge Wind Project Moratorium: A temporary moratorium is imposed on all activities under the Record of Decision for the Lava Ridge Wind Project due to alleged legal issues and public interest concerns. A new, comprehensive analysis will be conducted to evaluate the project’s environmental and economic impacts.
  • Assessment of Defunct Windmills: The Secretary of the Interior, the Secretary of Energy, and the EPA Administrator are tasked with assessing the environmental and community impacts of idle windmills and reporting recommendations for their removal.
  • Judicial Coordination: The Attorney General may notify courts regarding pending litigation related to federal wind leasing or permitting and propose delays or stays to align with the review process.
  • Implementation and Legal Effect: The memorandum is subject to the availability of appropriations and does not create enforceable rights against the United States or its agencies. It is to be published in the Federal Register.

Risks & Considerations

  • The temporary withdrawal of areas on the Outer Continental Shelf from offshore wind leasing could impact research and development opportunities related to renewable energy at Vanderbilt University. This may limit potential collaborations with federal agencies and private sector partners in the field of wind energy.
  • The cessation and review of federal wind leasing and permitting practices may delay or halt ongoing and future projects that Vanderbilt might be involved in, particularly those related to environmental impact assessments and renewable energy technology development.
  • The focus on reviewing the environmental impact of wind projects could lead to increased scrutiny and regulatory requirements, potentially affecting research timelines and funding opportunities for projects related to environmental science and policy.
  • Vanderbilt’s engineering and environmental science programs may need to adjust their research focus and curriculum to align with the changing landscape of federal energy policies and priorities.

Impacted Programs

  • Vanderbilt School of Engineering may experience a shift in research priorities, particularly in the fields of renewable energy and environmental engineering, as federal policies evolve.
  • The Vanderbilt Institute for Energy and Environment could see changes in funding opportunities and research collaborations, necessitating a reevaluation of strategic partnerships and project focus areas.
  • Peabody College of Education and Human Development might need to consider the implications of these policy changes on educational programs related to environmental policy and sustainability.
  • The Office of Research may need to adjust its grant application strategies to align with new federal priorities and funding opportunities in the energy sector.

Financial Impact

  • The temporary halt on wind energy leasing could affect funding streams for research projects related to renewable energy, potentially leading to a reallocation of resources within the university.
  • Vanderbilt may need to explore alternative funding sources and partnerships to support its renewable energy initiatives, given the potential reduction in federal support for wind energy projects.
  • There may be opportunities for Vanderbilt to engage in policy analysis and advisory roles as the federal government reassesses its wind energy policies, potentially leading to new funding and collaboration opportunities.
  • The university’s involvement in environmental impact assessments and policy development could position it as a key player in shaping future energy policies, potentially enhancing its reputation and influence in the field.

Relevance Score: 3 (The memorandum presents moderate risks involving compliance and potential shifts in research focus and funding opportunities.)

Key Actions

  • Vanderbilt’s School of Engineering should evaluate the implications of the temporary withdrawal of offshore wind leasing on research and development in renewable energy technologies. This could involve exploring alternative energy sources or focusing on innovations that address the environmental and economic concerns highlighted in the memorandum.
  • The Vanderbilt Institute for Energy and Environment should consider conducting studies on the environmental and economic impacts of wind energy projects, particularly in relation to marine life and energy costs. These studies could provide valuable insights for policymakers and contribute to the national dialogue on sustainable energy practices.
  • Vanderbilt’s Office of Federal Relations should monitor developments in federal wind leasing and permitting practices to identify potential opportunities for advocacy or collaboration with government agencies. Engaging in discussions about the future of wind energy could position Vanderbilt as a leader in shaping energy policy.
  • The Department of Earth and Environmental Sciences should explore research opportunities related to the ecological impacts of wind energy projects, particularly in the context of the comprehensive assessment being conducted by federal agencies. This research could enhance Vanderbilt’s reputation in environmental science and policy.

Opportunities

  • The memorandum presents an opportunity for Vanderbilt’s Law School to engage in legal analysis and advocacy regarding the regulatory and legal challenges associated with wind energy projects. By examining the legal deficiencies and public interest concerns mentioned in the memorandum, the Law School can contribute to the development of more robust legal frameworks for renewable energy.
  • Vanderbilt can capitalize on the focus on environmental impacts by developing interdisciplinary programs that integrate engineering, environmental science, and policy studies. These programs could prepare students to address complex challenges in the renewable energy sector and enhance Vanderbilt’s educational offerings.
  • The emphasis on assessing the impact of defunct and idle windmills offers an opportunity for Vanderbilt’s Environmental Engineering Program to innovate in the area of windmill decommissioning and recycling. By developing sustainable solutions for windmill removal, Vanderbilt can contribute to reducing the environmental footprint of renewable energy infrastructure.

Relevance Score: 3 (The memorandum requires some adjustments to Vanderbilt’s research and advocacy strategies in renewable energy and environmental policy.)

Average Relevance Score: 3.8

Timeline for Implementation

  • Temporary Withdrawal of Areas on the OCS: Effective January 21, 2025.
  • Review of Federal Wind Leasing and Permitting Practices: N/A – No specific deadline is provided, as the review is to occur pending completion of a comprehensive assessment.

The shortest and most urgent directive is the withdrawal effective January 21, 2025, which implies an urgent response.

Relevance Score: 5

Impacted Government Organizations

  • Department of the Treasury: The memorandum is addressed to the Secretary of the Treasury, directing involvement in the comprehensive review of the government’s leasing and permitting practices for wind projects.
  • Department of Justice (Attorney General): The Attorney General is instructed to review legal challenges relating to wind project leasing and may provide notice to courts regarding pending litigation.
  • Department of the Interior: Central to the order, the Secretary of the Interior is tasked with leading the assessment of wind leasing practices, reviewing existing wind energy leases, and imposing temporary moratoriums on certain project activities; the Bureau of Land Management under this department is also implicated through its prior actions.
  • Department of Agriculture: The Secretary of Agriculture is required to consult on the review of the federal wind leasing and permitting practices, particularly in terms of environmental and commercial impacts.
  • Department of Energy: The Secretary of Energy is directed to participate in the assessment of wind project practices and review energy-related impacts associated with wind energy projects.
  • Environmental Protection Agency (EPA): The Administrator of the EPA is mandated to assess the environmental impacts associated with onshore and offshore wind projects as part of the comprehensive federal review.
  • Department of Commerce / National Oceanic and Atmospheric Administration (NOAA): The Secretary of Commerce, through NOAA, is consulted during the review process to evaluate the environmental and economic implications of wind energy projects.

Relevance Score: 3 (The order impacts 7 major agencies, and including the Bureau of Land Management considered separately, the order affects around 8 government bodies, which fits within the 6–10 range.)

Responsible Officials

  • Secretary of the Treasury – Consulted as part of the comprehensive assessment of Federal wind leasing and permitting practices.
  • Attorney General – Responsible for coordinating consultation on existing wind leases in conjunction with the Secretary of the Interior and for providing legal notices to courts regarding litigation.
  • Secretary of the Interior – Leads the review of existing offshore wind energy leases, manages the temporary withdrawal of areas from wind energy leasing, oversees the moratorium and review of the Lava Ridge Wind Project’s ROD, and, with other officials, assesses the environmental impact of defunct windmills.
  • Secretary of Agriculture – Directed to cease issuance of new or renewed wind project permits and participate in the comprehensive review of Federal wind projects.
  • Secretary of Energy – Required to halt new approvals for wind projects and collaborate in the assessment of environmental impacts related to wind energy practices.
  • Administrator of the Environmental Protection Agency – Tasked with halting permits for wind projects and jointly assessing environmental impacts with other officials.

Relevance Score: 5 (Directives affect multiple Cabinet-level officials with broad agency oversight and national policy implications.)