Comment from Paul Pimentel, Vineyard Power

Greg Adams BOEM Economics Division 381 Elden Street Mail Stop 4050 Herndon, VA 20170-4817 Dear Mr. Adams, I am writing this letter in response to the Request for Information on the State of the Offshore Renewable Energy Industry-Auction Format Information Request (AFIR). I am a resident of Massachusetts who resides on Martha’s Vineyard and a member of Vineyard Power Cooperative. I am pleased that BOEM has identified, and is considering using, the Multiple-Factor Auction (MFA). From the beginning of this process our community has been advocating for a Multiple Factor Auction, for both the Massachusetts RFI and Rhode Island AMI, which accounts for non-monetary factors that would include direct and indirect community benefits. As a member of Vineyard Power, who is a potential auction participant, I request that BOEM employ the MFA as the first part in a two-phase auction. My motivation is to ensure that some benefits of renewable energy development, in the waters surrounding our community, stay local and is attributed to the community most impacted by this development. Specifically, we believe that developers, who account for those communities most impacted by offshore wind development, should be granted a discount in the non-monetary phase of the auction. We request the auction reflect your stated objective in its broadest term. Specifically that, “BOEM will award commercial renewable energy leases on the outer continental shelf to those who value the areas the most,” and by value we imply both monetary and non-monetary attributes. Thank you the opportunity to respond to the AFIR and for considering my input to this matter.