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May 10, 2008 <br /> Honorable C. Stephen Allred <br /> Assistant Secretary for Land and Minerals Management <br /> U.S. Department of the Interior <br /> Room 6615 <br /> 1849 C Street,NW <br /> Washington, DC 20240 <br /> Dear Assistant Secretary Allred: <br /> We the undersigned hereby formally request that the Minerals Management Service (MMS) <br /> initiate a "consensus-based" management process, consistent with Department of the Interior <br /> (DOI) policies and proposed regulations (73 Fed. Reg. 126), for the Cape Wind proposal. DOI <br /> Environmental Statement Memorandum No. ESM03-7,Procedures for Implementing <br /> Consensus-Based Management in Agency Planning and Operation, sets forth "requirements" for <br /> agency decision-makers involved in environmental planning and review, such as that conducted <br /> under the National Environmental Policy Act (NEPA). The policy requires community <br /> involvement in the NEPA process in an effort to achieve "agreement from diverse interests." <br /> ESM03-7,¶2. <br /> Policy No. ESM03-7 calls for the development of a "community alternative" as a part of <br /> consensus-based review. Such a process is ideally applied to situations where project proposals <br /> are controversial, have caused conflict within the local impacted community, and where the <br /> potential impacts will fall upon a large and diverse group of interests. The Cape Wind project <br /> proposal is a clear example of such a project. While there is strong community support and <br /> agreement that the development of renewable energy is desirable, there is an equally strong <br /> debate over the means by which the resources should be developed. Those in opposition to the <br /> Cape Wind project, including the agencies, towns and organizations we represent, adamantly <br /> believe that the proposal, in the applicant's proposed location, will severely harm the region. <br /> Better alternatives exist, and after nearly seveh years of conflict, it is clear that consensus-based <br /> management is the best way to achieve such a result. As directed by¶3.e. of ESM03-7, MMS <br /> must make use of"dispute resolution processes" under which to conduct the consensus-based <br /> process and identify the community alternative, which should in turn serve as the preferred <br /> alternative in the FEIS. Id. ¶3.d. <br /> At the outset of its review of this proposed project, we believe MMS should have employed <br /> consensus-based decision-making to facilitate the involvement of the community an <br /> d avoid the <br /> current conflict surrounding the proposal. Nonetheless, the current review of the DEIS gives <br /> DOI an excellent opportunity to implement the policy. We request that MMS adhere to policy <br />