Comment from Jo-Ann Taylor, Martha's Vineyard Commission

September 19, 2012 Re: BOEM-2011-0082 Right-of-Way Grant of Submerged Lands on the Outer Continental Shelf to Support Renewable Energy Development Dear Madams and Sirs, BOEM proposes to streamline the issuance of R-O-W grants for undersea transmission of electricity or other energy product by cable or pipeline, and has specifically produced draft Form 009 for comment. The draft provides “The Grantor hereby grants to the Grantee the exclusive right and privilege…to conduct activities…described in the General Activities Plan…” The draft provides for the Grantee to indemnify BOEM for damages to the environment, property, persons, etc. and to provide a surety bond to insure that funds are available to pay damages. • Holding the developer responsible for damages is essential and it is important to provide a bond ensuring availability of funds. However, the exclusivity for responsibility would appear to also exclude the kind of cooperative cabling that would most efficiently transmit electricity from large areas of Outer Continental Shelf presently the subject of leasing interest from multiple developers. Is it necessary for each developer to lease its own R-O-W? It would be desirable to include the option of sharing rights-of-way while maintaining accountability for damages. • Although it is essential to hold the developer responsible for damages, it is perhaps equally important for the R-O-W to be located and developed in the most responsible manner and location. Must the choices for siting and development of transmission lines be strictly market-driven? There should be mechanism within the leasing procedure to reward thoughtful planning to avoid or minimize damages in the first place. Thank you for the opportunity to provide input on draft Form 009. The Martha’s Vineyard Commission appreciates BOEM’s effort to include local input. Sincerely, Jo-Ann Taylor Coastal Planner, Martha’s Vineyard Commission