ACTION ALERT: Oppose Tidal Energy in Rosario Strait; Endangered Southern Resident Killer Whale Critical Habitat
Submit a public comment opposing the proposed permit by Orcas Power & Light Cooperative (OPALCO) to the Department of Energy | Federal Energy Regulatory Commission (FERC), [Docket No. Project No. 15368-001]. Public comments are due 09/30/25.
The Orbital Marine O2X is a 243-foot-long floating tidal turbine — larger than a Boeing 747 — capable of generating 2 megawatts of power from underwater currents with twin 20-meter rotors. Image: Heather Nicholson (2025).
What is happening and why it matters?
OPALCO has filed with FERC: (1) a notice of intent (NOI) to file an application for an original license for this pilot project and a draft license application with monitoring plans; (2) a request for waivers of the integrated licensing process regulations necessary for expedited processing of a tidal energy pilot project license application; (3) a proposed process plan and schedule; (4) a request to be designated as the non-federal representative for section 7 of the Endangered Species Act (ESA) consultation; and (5) a request to be designated as the non-federal representative for section 106 consultation under the National Historic Preservation Act (collectively the pre-filing materials).
OPALCO’s filing for a tidal energy pilot project in Rosario Strait, an area designated as critical habitat for the critically endangered Southern Resident killer whale (SRKW), poses significant risks to ongoing recovery efforts, as the survival of this population depends on undisturbed habitat and consistent access to abundant prey. The request to expedite licensing and bypass key elements of the Integrated Licensing Process (ILP) undermines the rigorous scientific review and stakeholder engagement essential for evaluating impacts on SRKWs and their designated critical habitat. Furthermore, OPALCO’s bid to act as the non-federal representative for ESA Section 7 consultation raises concerns about conflicts of interest and insufficient scrutiny, given that SRKWs depend on undisturbed acoustic environments and access to dwindling Chinook salmon populations, both of which could be jeopardized by in-water industrial development.
How will this impact orcas and salmon?
The proposed OPALCO tidal turbine project threatens to negatively impact Southern Resident killer whales (SRKWs), Chinook salmon, and the broader marine environment in several interconnected ways.
For SRKWs, the installation and operation of a tidal turbine in their designated critical habitat introduces chronic underwater noise and electromagnetic fields, which can interfere with echolocation, disrupt foraging, and displace them from key migratory and feeding corridors.
For Chinook salmon, the SRKW’s primary prey, turbine infrastructure and hydrodynamic changes may alter sediment transport, degrade spawning and rearing habitat, and pose physical injury or behavioral barriers to migration.
More broadly, the project risks disturbing sensitive marine ecosystems already stressed by vessel traffic, pollution, and climate change.
Fast-tracking this project without comprehensive, independent, peer-reviewed studies amplifies the likelihood of cumulative, long-term harm to these imperiled species and the ecological balance of the Salish Sea.
How to submit a public comment:
Please file comments using FERCs eFiling system at: FERC ONLINE COMMENT https://ferconline.ferc.gov/QuickComment.aspx
You must include your name and contact information at the end of your comments.
All filings must clearly identify the project name: Rosario Strait Tidal Energy Project
and docket number on the first page: P-15368-001
Tips for public comment:
1. Be respectful and polite.
2. Get personal, share your experiences and explain why you care.
3. Please do not copy and paste. New practices make it so that ‘pre-written templates only get counted ONCE. Meaning, if multiple people submit the same comment letter, it will only be recorded once. Make your comment personal and unique so it is counted!
Suggested talking points:
1. Not Safe for Endangered Killer Whales
The Southern Resident killer whales (SRKWs) are in danger of going extinct, and the U.S. government has marked their entire range as “critical habitat,” meaning it's essential for their survival. Rosario Strait is a place where they travel and hunt for food. Putting a tidal turbine there — with big spinning blades running almost all the time — could cause underwater noise, electric fields, and even crashes that would confuse or harm the whales. Saying the whales might "just stay away" isn't a solution especially if they avoid the area, it’s like taking away their home.
2. Bad for Salmon and Their Habitat
The turbine would also be in an area that’s important for Chinook salmon, which are the main food for SRKWs. The project includes anchors, cables, and other gear that would damage the ocean floor where salmon live and grow. These changes, even if small at first, can add up over time. The electric fields and constant noise from the turbine could also mess with how fish swim and migrate. This goes against efforts to save Chinook salmon under important environmental laws.
3. Disrespectful to Tribal Rights
Rosario Strait is a traditional fishing area for Coast Salish Tribal Nations. While OPALCO admits Tribes have raised concerns, they’re still trying to move forward without getting full approval or working closely with Tribal leaders. This disrespects treaty rights and ignores cultural traditions that go back thousands of years. The company’s plans don’t make up for the damage it could cause to Tribal fishing and marine life.
4. Wrong Place for a Risky Project
This project would be in a special protected marine area meant to keep nature safe. But OPALCO hasn’t explained how putting a large machine there fits with those goals. If this project is allowed, it could open the door for more industrial machines in places that should be left alone for animals and people to enjoy and protect.
5. Moving Too Fast Without Enough Research
Even though OPALCO calls this a “pilot” project, they’re asking for a 10-year license. That’s a long time to run a risky experiment in a fragile ecosystem. They haven’t done enough real-world testing to show how whales, fish, and other animals might react to the turbine. Many of their monitoring plans are based on guesses, not solid science. We need to understand and fix the risks before putting a machine like this in the water—not after it causes problems.
Scientific Resources:
NOAA Fisheries. (2021). Designation of Critical Habitat for Southern Resident Killer Whales.
https://www.fisheries.noaa.govLacy, R.C. et al. (2017). Evaluating anthropogenic threats to endangered killer whales to inform effective recovery plans.
Scientific Reports, 7, 14119.
https://doi.org/10.1038/s41598-017-14471-0Copping, A. (2020). Potential Effects of Marine Renewable Energy on Marine Animals: Knowledge Gaps and Research Priorities.
Pacific Northwest National Laboratory (PNNL).
https://tethys.pnnl.govYang, Z., Wang, T., & Copping, A. (2021). Characterizing Tidal Energy Hotspots in the Salish Sea.
PNNL Report PNNL-32302.
https://tethys.pnnl.govNMFS. (2014). Puget Sound Chinook Salmon Recovery Plan.
NOAA Fisheries Northwest Region.
https://www.fisheries.noaa.govWashington State Department of Ecology. (2022). Salish Sea Marine Survival Project Summary.
https://marinesurvivalproject.comNational Oceanic and Atmospheric Administration. (2016). Guidance for Assessing the Effects of Anthropogenic Sound on Marine Mammal Hearing.
https://www.fisheries.noaa.govSan Juan County. (2021). Marine Stewardship Areas – Rosario Strait.
San Juan Marine Resources Committee.
https://www.sjcmrc.orgMagnuson-Stevens Fishery Conservation and Management Act.
https://www.fisheries.noaa.gov/topic/laws-policies#magnuson-stevens-actU.S. Environmental Protection Agency. (2021). Electromagnetic Fields and Aquatic Life.
https://www.epa.gov
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