Comment from Alex Pavlak, self

The draft views offshore wind as if it were as environmentally benign as a bridge. It ignores the fact that the whole point of wind power is to impact the environment, to reduce electric power system emissions. The emission impact is completely ignored. The usual assumption in the literature is that emissions are proportional to power, that is, if wind contributes 1% of the energy it will reduce emissions by 1%. By this method, PJM estimates Maryland offshore wind will reduce emissions by 0.17 lbs CO2/kWh. In reality a little wind saves natural gas, about 0.10 lbsCO2/kWh. Too much wind can cause base load coal plants to cycle and increase emissions There simply is no data from real systems. How can you issue an environmental impact statement that ignores electric power system emissions?