Navigating the Labyrinth of Regulations on the Way to Net-Zero: A Summer Internship Reflection

Written by
Christian Perkins, MPA Student
Nov. 17, 2023

My decision to intern with a for-profit renewable energy firm was an unusual one. At Princeton’s School of Public & International Affairs (SPIA), the curriculum emphasizes public service, and faculty encourage students to explore work that advances the public good. Large renewable energy infrastructure, and offshore wind in particular, arguably satisfies those objectives, regardless of what type of entity owns the project. But the picture is made complicated by the joint ownership of the initiative I worked to develop, which is split equally between a Spanish firm called Ocean Winds and one of the world’s largest fossil fuel giants – Shell.

The initiative, SouthCoast Wind, is one of a handful of offshore wind projects currently under development in North America’s nascent offshore industry. Located some thirty miles south of Martha’s Vineyard, the 200 square mile lease area – affectionately called “Lease Area OCS-A-0521” – will eventually fit about 150 turbines that will generate electricity for over a million homes in New England. Along with the handful of other offshore projects in the U.S., SouthCoast Wind will contribute to the Biden Administration's ambitious 2050 net-zero objective by generating 30 gigawatts (GW) of offshore wind power by 2030. 

My role in this space was varied. Day to day tasks ranged from participating in meetings with relevant state and federal officials, addressing comments in the environmental impact report, and drafting emergency memos when survey vessels experienced an accident at sea. With no previous development experience, I struggled to keep up with the business jargon most MBAs learn on day one. 

map showing location of lease ocs-a-0521 south of martha's vineyard

Map from SouthCoast Wind Project Overview showing Lease OCS-A-0521 (from Bureau of Ocean Energy Management)

What I did bring was experience from the federal government. This experience, gained from spending a number of years at the Environmental Protection Agency (EPA), was especially useful in applying (and sometimes arguing) for the many permits required for these massive renewable projects. Navigating the bureaucracy of the multiple agencies involved in such a large project, speaking the same language as career technocrats, and advocating for the project’s bottom line were skills I thought the team could use more of, and I saw myself filling a small gap between project developers and career civil servants. 

During the three months I spent with SouthCoast Wind, I interfaced directly with a long list of government agencies to garner relevant permits: Bureau of Ocean Energy Management (BOEM), EPA, Army Corps of Engineers, National Marine Fisheries Service (NMFS), Department of Energy (DOE), Massachusetts and Rhode Island Energy Facilities Siting Boards (EFSB), Towns of Somerset, Swansea, Fall River, Falmouth, and others. I could go on. Each of these institutions can permit or deny a project’s operations or construction activities, meaning the overall success of the multibillion dollar venture rests in the hands of a wide array of government bodies. While onerous, the process is meant to protect the natural resources in the project area, and regulations about ocean mapping, wildlife surveys, and sea cable installation must be strictly adhered to if the turbines ever want to spin. 

The permitting effort is extensive. While there, I submitted construction plans outlining the ways we would protect the endangered North American Right Whale, argued with technocrats about aerial survey requirements, drafted protocols in case of a marine accident, and more. This work accentuated the tension between government and developers, but also highlighted both parties’ belief that the energy transition must happen rapidly, safely, and responsibly. 

Throughout the summer, I thought about the presence of the fossil fuel industry in the renewable energy space. What role should it play in the energy transition? Does its presence pose a moral conundrum to the broader buildout of renewables? In partnering with Shell, Ocean Winds is able to finance a massive project that otherwise may not have come to fruition. Likewise, these companies also have existing infrastructure - including highly skilled personnel - that may contribute to the effort. Whatever one thinks of the role of legacy emitters in this space, this experience will inform the energy policy work I do after Princeton. But while I’m more open now to serving the public from different sectors, you won’t find me in the pocket of big oil.

My experience at SouthCoast left me with two major takeaways. The first is the dire need of the U.S. government to reform the way it permits energy projects. If the Biden Administration is serious about its net-zero goals, construction, and connection of energy infrastructure must be sped up. The second is the need for interagency coordination. Often, the SouthCoast team had to submit multiple permit applications to different agencies, with contradicting feedback. If I return to the civil service, I’ll remember to stay in touch with my colleagHowues in the building next door. 

 

If you would like to learn more about Christian’s internship, including information on how to apply, you can reach him at [email protected]


If you’re a PhD student or a postdoc and interested in sharing your environmental policy-relevant research and internship experiences with the wider Princeton community, please reach out to either Neha ([email protected]) or Glen ([email protected]).