Structural Integrity

of Offshore
Wind Turbines
Oversight of Design,
Fabrication, and Installation
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2011
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Structural lntegrity
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TRAMSPÒRTATlÒM RESEARCH BÒARD
CF 7HE MA7ICMAL ACADEMIE5
Transportation Research Board Special Report 305
Subsciibei Categoiies:
Eneigy; biidges and othei stiuctuies
Tianspoitation Reseaich Boaid publications aie available by oideiing individual publi-
cations diiectly fiom the TRB Business Offce, thiough the Inteinet at www.TRB.oig oi
national-academies.oig/tib, oi by annual subsciiption thiough oiganizational oi indi-
vidual affliation with TRB. Affliates and libiaiy subsciibeis aie eligible foi substantial
discounts. Foi fuithei infoimation, contact the Tianspoitation Reseaich Boaid Business
Office, 500 Fifth Stieet, NW, Washington, DC 20001 (telephone 202-334-3213; fax
202-334-2519; oi e-mail TRBsalesCnas.edu).
Copyiight 2011 by the National Academy of Sciences. All iights ieseived.
Piinted in the United States of Ameiica.
NOTICE: The pioject that is the subject of this iepoit was appioved by the Goveining
Boaid of the National Reseaich Council, whose membeis aie diawn fiom the councils
of the National Academy of Sciences, the National Academy of Engineeiing, and the
Institute of Medicine. The membeis of the committee iesponsible foi the iepoit weie
chosen foi theii special competencies and with iegaid foi appiopiiate balance.
This iepoit has been ieviewed by a gioup othei than the authois accoiding to the pio-
ceduies appioved by a Repoit Review Committee consisting of membeis of the National
Academy of Sciences, the National Academy of Engineeiing, and the Institute of Medicine.
This study was sponsoied by the Buieau of Ocean Eneigy Management, Regulation,
and Enfoicement, U.S. Depaitment of the Inteiioi.
Ccver design by Debra Naylcr, Naylcr Design, Inc.
Ccver phctc. Middelgrunden cffshcre wind turbines in the strait cf Cresund, cutside
Ccpenhagen harbcr, Denmark. (Phctc by Tcre }channesen, iStcckphctc.)
Typesetting by Circle Graphics.
Library of Congress Cataloging-in-Publication Data
National Reseaich Council (U.S.). Committee on Offshoie Wind Eneigy Tuibine
Stiuctuial and Opeiating Safety.
Stiuctuial integiity of offshoie wind tuibines : oveisight of design, fabiication, and
installation / Committee on Offshoie Wind Eneigy Tuibine Stiuctuial and Opeiating
Safety, Maiine Boaid, Tianspoitation Reseaich Boaid of the National Academies.
p. cm. - (Tianspoitation ieseaich boaid special iepoit ; 305) 1. Offshoie stiuctuies-
Design and constiuction-Safety measuies-Goveinment policy-United States.
2. Wind tuibines-Design and constiuction-Safety measuies-Goveinment policy-
United States. 3. Wind powei plants-United States-Safety measuies. 4. Electiic
powei-plants, Offshoie-United States-Safety measuies. I. Title.
TC1665.N38 2011
621.4 53-dc22
2011004767
ISBN 978-0-309-16082-7
The National Academy of Sciences is a piivate, nonpioft, self-peipetuating society of
distinguished scholais engaged in scientifc and engineeiing ieseaich, dedicated to the
fuitheiance of science and technology and to theii use foi the geneial welfaie. On the
authoiity of the chaitei gianted to it by the Congiess in 1863, the Academy has a man-
date that iequiies it to advise the fedeial goveinment on scientifc and technical matteis.
Di. Ralph J. Ciceione is piesident of the National Academy of Sciences.
The National Academy of Engineering was established in 1964, undei the chaitei of the
National Academy of Sciences, as a paiallel oiganization of outstanding engineeis. It is
autonomous in its administiation and in the selection of its membeis, shaiing with the
National Academy of Sciences the iesponsibility foi advising the fedeial goveinment. The
National Academy of Engineeiing also sponsois engineeiing piogiams aimed at meet-
ing national needs, encouiages education and ieseaich, and iecognizes the supeiioi
achievements of engineeis. Di. Chailes M. Vest is piesident of the National Academy of
Engineeiing.
The Institute of Medicine was established in 1970 by the National Academy of Sciences
to secuie the seivices of eminent membeis of appiopiiate piofessions in the examination
of policy matteis peitaining to the health of the public. The Institute acts undei the
iesponsibility given to the National Academy of Sciences by its congiessional chaitei to
be an advisei to the fedeial goveinment and, on its own initiative, to identify issues of
medical caie, ieseaich, and education. Di. Haivey V. Finebeig is piesident of the Insti-
tute of Medicine.
The National Research Council was oiganized by the National Academy of Sciences in
1916 to associate the bioad community of science and technology with the Academy`s
puiposes of fuitheiing knowledge and advising the fedeial goveinment. Functioning in
accoidance with geneial policies deteimined by the Academy, the Council has become
the piincipal opeiating agency of both the National Academy of Sciences and the National
Academy of Engineeiing in pioviding seivices to the goveinment, the public, and the
scientific and engineeiing communities. The Council is administeied jointly by both
Academies and the Institute of Medicine. Di. Ralph J. Ciceione and Di. Chailes M. Vest
aie chaii and vice chaii, iespectively, of the National Reseaich Council.
The Transportation Research Board is one of six majoi divisions of the National
Reseaich Council. The mission of the Tianspoitation Reseaich Boaid is to piovide lead-
eiship in tianspoitation innovation and piogiess thiough ieseaich and infoimation
exchange, conducted within a setting that is objective, inteidisciplinaiy, and multimodal.
The Boaid`s vaiied activities annually engage about 7,000 engineeis, scientists, and othei
tianspoitation ieseaicheis and piactitioneis fiom the public and piivate sectois and
academia, all of whom contiibute theii expeitise in the public inteiest. The piogiam is
suppoited by state tianspoitation depaitments, fedeial agencies including the compo-
nent administiations of the U.S. Depaitment of Tianspoitation, and othei oiganizations
and individuals inteiested in the development of tianspoitation. www.TRB.org
www.nolionol-ocodemies.org
Committee on Offshore Wind Energy Turbine
Structural and Operating Safety
R. Keith Michel, Heibeit Engineeiing Coipoiation, Alameda,
Califoinia, 
Bruce R. Ellingwood, Geoigia Institute of Technology, Atlanta
George M. Hagerman, Jr., Viiginia Coastal Eneigy Reseaich Consoitium,
Viiginia Beach
Jan Behrendt Ibsoe, ABS Consulting, Inc., Houston, Texas
Lance Manuel, Univeisity of Texas at Austin
Walt Musial, National Renewable Eneigy Laboiatoiy, Golden, Coloiado
Robert E. Sheppard, Eneigo Engineeiing, Houston, Texas
Emil Simiu, National Institute of Standaids and Technology,
Gaitheisbuig, Maiyland
Susan W. Stewart, Pennsylvania State Univeisity, State College
David J. Wisch, Chevion Eneigy Technology Company, Houston, Texas

Madeline G. Woodruff, Study Diiectoi

Although many of the woild`s laigest wind faims aie located in the
United States, these installations aie entiiely land based. Land-based
wind iesouices aie plentiful but aie located piincipally in the cential
iegions of the countiy, iemote fiom the majoi population centeis wheie
electiicity demand is giowing but tiansmission line access and capacity
aie limited. Theie aie obstacles to installing an enhanced tiansmission
system capable of connecting land-based wind faims to the highly pop-
ulated aieas, paiticulaily with iegaid to peimitting.
Costs ielated to installation and maintenance aie signifcantly highei
foi offshoie wind faims than foi those located on land. Howevei, offshoie
wind faims offei a numbei of advantages that could offset these highei
costs. Offshoie installations can be located close to coastal metiopolitan
aieas, ieducing tiansmission infiastiuctuie iequiiements. The intensity
of offshoie wind eneigy is also gieatei, allowing the offshoie wind tui-
bine to opeiate at gieatei efficiencies than a compaiable land-based
installation.
Theie aie cuiiently offshoie wind piojects planned along the U.S.
East Coast, the Gulf of Mexico, and the Gieat Lakes. To date, most off-
shoie wind faims have been located in the wateis of the Euiopean and
Scandinavian nations-Geimany, Denmaik, and the United Kingdom
being the most impoitant. These countiies have been the leadeis in both
technological and iegulatoiy development ielated to offshoie wind powei
geneiation. The inteinational standaids foi offshoie wind tuibine design
and ceitifcation established by the Inteinational Electiotechnical Com-
mission (IEC) aie foimally iecognized in Euiopean national iegulations.
Some of these national iegulations also iecognize the guidelines and ieg-
ulations developed by classifcation societies.

 Structural lntegrity of 0ffshore Wind Turbines
In the United States, wheie offshoie wind eneigy has been much less
of a focus, iegulatoiy development has lagged. As a iesult, peimitting of
sites in U.S. wateis is pioceeding without a cleai set of national iegula-
tions foi the design, fabiication, installation, and commissioning of off-
shoie wind tuibines. The Mineials Management Seivice (MMS), which
has been ienamed the Buieau of Ocean Eneigy Management, Regula-
tion, and Enfoicement (BOEMRE), is iesponsible foi the oideily, safe,
and enviionmentally iesponsible development of offshoie ienewables on
the outei continental shelf. BOEMRE iequested that the Tianspoitation
Reseaich Boaid`s (TRB`s) Maiine Boaid conduct a study to guide the
agency in the iegulation and technical oveisight of the nascent offshoie
wind eneigy industiy in the United States.
Astudy committee consisting of 10 membeis fiom academia, national
ieseaich centeis, and industiy was appointed by the National Reseaich
Council (NRC). Membeis have expeitise in stiuctuial engineeiing, wind
eneigy, iegulation, thiid-paity veiification in offshoie platfoims and
wind tuibines, and oceanogiaphy. Biogiaphical sketches of the committee
membeis appeai at the end of this iepoit. The iepoit iepiesents the con-
sensus opinion of the committee membeis and piesents the committee`s
fndings and iecommendations on the standaids and piactices that could
be used in oveisight of U.S. offshoie wind installations, the iole of thiid-
paity ievieweis and BOEMRE in oveiseeing of the design and constiuc-
tion of offshoie wind tuibines, the necessaiy qualifcations of thiid-paity
ievieweis, and the selection piocess foi identifying and appioving thiid-
paity ievieweis.
The committee met thiee times ovei a 5-month peiiod. These face-
to-face meetings weie supplemented by numeious confeience calls. The
committee listened to piesentations fiom a wide iange of stakeholdeis,
including state and fedeial iegulatois, standaids development oigani-
zations, wind faim developeis, tuibine manufactuieis, and ieseaich
scientists and engineeis with expeitise in the wind eneigy industiy. The
committee also ieviewed vaiious studies and woikshop pioceedings
sponsoied by BOEMRE. These iesouices pioved invaluable as the com-
mittee discussed alteinative appioaches to oveisight piocesses and foi-
mulated the ideas that aie piesented in this iepoit.
 
ACKNOWLEDGMENTS
The committee acknowledges John Cushing, Loii Medley, and the othei
staff membeis of BOEMRE who piovided the committee with insight into
the iesponsibilities and woikings of BOEMRE and into the vaiious studies
on offshoie wind eneigy conducted undei the auspices of BOEMRE and
its piedecessoi, MMS. The committee also acknowledges the goveinment
and industiy iepiesentatives, listed below, who took time fiom theii busy
schedules to piesent backgiound infoimation and theii own ideas and
opinions to the committee at its meetings, and to the otheis who assisted
the committee by pioviding ielevant publications and answeiing questions
by telephone and e-mail.
The following individuals made piesentations at the fist committee
meeting, June 28-29, 2010:
 John Cushing, BOEMRE, U.S. Depaitment of the Inteiioi;
 Malcolm Shaiples, Piesident, Offshoie Risk and Technology Consult-
ing, Inc.;
 Faia Couitney, Executive Diiectoi, U.S. Offshoie Wind Eneigy
Collaboiative;
 Giovei Fugate, Executive Diiectoi, Rhode Island Coastal Resouices
Management Council;
 Elmei °Bud" Danenbeigei, MMS (ietiied);
 Kenneth Richaidson, Vice Piesident foi Eneigy Piojects, Ameiican
Buieau of Shipping;
 Jan Behiendt Ibsoe, Vice Piesident foi Global Renewable Eneigy, ABS
Consulting (committee membei);
 William Holley, Technical Advisoi foi the U.S. National Committee of
the IEC, Technical Committee 88, Chief Consulting Engineei, Wind
Systems, GE Eneigy; and
 John Dunlop, Senioi Pioject Engineei, Ameiican Wind Eneigy
Association.
The following individuals made piesentations at the second commit-
tee meeting, August 10-11, 2010:
 Thomas Lauiendine, Assistant Vice Piesident, Libeity Inteinational
Undeiwiiteis (foimeily with MMS);
 Structural lntegrity of 0ffshore Wind Turbines
 Jeff Shikaze, Piogiam Managei-Renewable Eneigy, Canadian Stan-
daids Association (CSA);
 Richaid McNitt, Business Development Managei, CSA Inteinational;
 Petei Vickeiy, Piincipal Engineei, Applied Reseaich Associates, Inc.,
IntiaRisk Division; and
 Tom McNeilan, Geneial Managei, Fugio Atlantic (on behalf of the
Offshoie Wind Development Coalition).
The iepoit has been ieviewed in diaft foim by individuals chosen foi
theii diveise peispectives and technical expeitise, in accoidance with
pioceduies appioved by NRC`s Repoit Review Committee. The pui-
pose of this independent ieview is to piovide candid and ciitical com-
ments that will assist the institution in making the published iepoit as
sound as possible and to ensuie that the iepoit meets institutional stan-
daids foi objectivity, evidence, and iesponsiveness to the study chaige.
The ieview comments and diaft manusciipt iemain confdential to pio-
tect the integiity of the delibeiative piocess.
The committee thanks the following individuals foi theii ieview
of the iepoit: C. P. °Sandy" Butteifeld, Bouldei Wind Powei Inc., Bouldei,
Coloiado; Vice Admiial James C. Caid (ietiied), The Woodlands, Texas;
Kent Dangtian, Dangtian OTC, LLC, Cypiess, Texas; John Headland, Mof-
fatt & Nichol Engineeis, New Yoik, New Yoik; Maiy Hallisey Hunt, Stiate-
gic Eneigy Institute, Geoigia Institute of Technology, Atlanta, Geoigia;
Albeito Moiandi, Ameiican Global Maiitime Inc., Houston, Texas; John
Niedzwecki, Zachiy Depaitment of Civil Engineeiing, Texas A&M
Univeisity, College Station, Texas; James Schneidei, Depaitment of Civil
and Enviionmental Engineeiing, Univeisity of Wisconsin-Madison,
Madison, Wisconsin.
Although these ievieweis piovided many constiuctive comments and
suggestions, they weie not asked to endoise the committee`s fndings oi
iecommendations, noi did they see the fnal diaft of the iepoit befoie its
ielease. The ieview was oveiseen by Lawience T. Papay, PQR, LLC, and
C. Michael Walton, Univeisity of Texas at Austin. Appointed by NRC,
they weie iesponsible foi making ceitain that an independent exami-
nation of this iepoit was caiiied out in accoidance with institutional
pioceduies and that all ieview comments weie caiefully consideied.
 
Responsibility foi the final content of this iepoit iests entiiely with the
authoiing committee and the institution.
Madeline Woodiuff, Senioi Piogiam Officei in NRC`s Division on
Engineeiing and Physical Sciences, seived as study diiectoi and assisted
the committee in the piepaiation of its iepoit undei the supeivision
of Stephen R. Godwin, Diiectoi, Studies and Special Piogiams, TRB.
Suzanne Schneidei, Associate Executive Diiectoi of TRB, managed
the iepoit ieview piocess. Noiman Solomon edited the iepoit, Janet M.
McNaughton handled the editoiial pioduction, Juanita Gieen managed
pioduction, and Jennifei J. Weeks piepaied the manusciipt foi pie-
publication web posting, undei the supeivision of Javy Awan, Diiectoi
of Publications, TRB. Amelia Mathis and Claudia Sauls piovided assis-
tance with meeting aiiangements and communications with the com-
mittee. The committee extends its sinceie giatitude to the diligent and
capable staff of the National Academies. Without theii effoits and sup-
poit, pioducing a iepoit with the depth and quality of this study in a
ielatively shoit time would not have been possible.
Acronyms and Abbreviations
Acionyms and abbieviations used in the iepoit aie listed below. A glossaiy
piovides peitinent defnitions.
AASHTO Ameiican Association of State Highway and
Tianspoitation Offcials
ABS Ameiican Buieau of Shipping
ACI Ameiican Conciete Institute
ACP Alteinative Compliance Piogiam
AISC Ameiican Institute of Steel Constiuction
ALARP as low as ieasonably piacticable
ANSI Ameiican National Standaids Institute
API Ameiican Petioleum Institute
ASCE Ameiican Society of Civil Engineeis
ATC Applied Technology Council
AWEA Ameiican Wind Eneigy Association
BOEMRE Buieau of Ocean Eneigy Management, Regulation,
and Enfoicement
BSH Bundesamt fui Seeschifffahit und Hydiogiaphie
(Geiman Fedeial Maiitime and Hydiogiaphic Agency)
BV Buieau Veiitas
CFR Code of Fedeial Regulations
CMS Conditioning Monitoiing System
COP constiuction and opeiations plan
CVA ceitifed veiifcation agent
DLC design load case
DNV Det Noiske Veiitas
EA enviionmental assessment
EIS enviionmental impact statement
EPACT Eneigy Policy Act of 2005
ESP electiic seivice platfoim

 Structural lntegrity of 0ffshore Wind Turbines
FERC Fedeial Eneigy Regulatoiy Commission
GAP geneial activities plan
GL Geimanischei Lloyd
GOM Gulf of Mexico
GW gigawatts
IEC Inteinational Electiotechnical Commission
IMO Inteinational Maiitime Oiganization
ISO Inteinational Oiganization foi Standaidization
kV kilovolts
LRFD load and iesistance factoi design
MMS Mineials Management Seivice
MRI mean iecuiience inteival
MW megawatts
NBS National Buieau of Standaids
NDT nondestiuctive testing
NEPA National Enviionmental Policy Act
NRC National Reseaich Council
NREL National Renewable Eneigy Laboiatoiy
NTL notice to lessees
OCS outei continental shelf
OEM oiiginal equipment manufactuiei
QA quality assuiance
QC quality contiol
PBD peifoimance-based design
PBE peifoimance-based engineeiing
PE piofessional engineei
PEIS piogiammatic enviionmental impact statement
PTC pioduction tax ciedit
SAP site assessment plan
SCADA supeivisoiy contiol and data acquisition
SFPE Society of Fiie Piotection Engineeis
TA&R Technology Assessment and Reseaich piogiam
TC technical committee
USACE United States Aimy Coips of Engineeis
USCG United States Coast Guaid
USDOE United States Depaitment of Eneigy
USDOI United States Depaitment of the Inteiioi
USGS United States Geological Suivey
WSD woiking stiess design

A
Array. A gioup of wind tuibines confguied in a giid layout.
Array losses. See turbine-tc-turbine interference.
B
Bearing. A device to allow constiained ielative motion between two oi
moie paits, typically iotation oi lineai movement.
C
Capacity. The iated continuous load-caiiying ability of geneiation,
tiansmission oi othei electiical equipment, expiessed in megawatts
(MW). The °size" of a powei plant is usually chaiacteiized by its net
powei geneiation capacity in MW.
Certincation. See Box 1.3
Class (or wind turbine class). Classifcations defned by IEC foi wind
tuibines based on thiee paiameteis: the aveiage wind speed, extieme
50-yeai ietuin 10-min aveiaged gust, and tuibulence.
Classincation. See Box 1.3
Classincation society. Industiy associations and companies that supply
seivices (such as ceitifcation) to the industiy, evaluating the design,
fabiication oi installation with iefeience to its own iules oi guidelines
iathei than an exteinally developed standaid oi guideline.
Code of Federal Regulations (CFR). Rules and iegulations defned by
the U.S. fedeial goveinment having the foice of law. Title 30, pait 250
(30 CFR 250) coveis °Oil and Gas and Sulphui Opeiations in the Outei
Continental Shelf." Pait 285 (30 CFR 285) coveis °Renewable Eneigy
Alteinate Uses of Existing Facilities on the Outei Continental Shelf."

 Structural lntegrity of 0ffshore Wind Turbines
Composite (tower or rotor). Engineeied mateiials made fiom two oi
moie constituent mateiials with significantly diffeient physical oi
chemical piopeities that iemain sepaiate and distinct on a macioscopic
level within the fnished stiuctuie.
Condition monitoring. Apiocess that involves a system of sensois and
monitoiing equipment used to iemotely monitoi specific piopei-
ties of a mechanical oi stiuctuial system (e.g., fluid tempeiatuies oi
mateiial stiain) foi the puipose of deteimining its ability to opeiate
noimally.
D
Deepwater. A watei depth iange foi offshoie facilities; typically beyond
500 feet (152 m) though theie is no defnitive watei depth iange.
Design basis. The extieme conditions undei which the wind tuibine is
designed to opeiate. E.g. 50- oi 100-yeai extieme wind and wave load-
ing events. Also includes potential fault conditions of the tuibine.
Developer. The entity in a wind pioject that designates and aiianges foi
the building of an infiastiuctuie on land oi an offshoie site in oidei
to pioductively exploit wind eneigy. Analysis of the land-sea and wind
iesouice chaiacteiistics aie ciucial in the development piocess.
Direct drive. A mechanism that takes the powei coming fiom a motoi
without any ieductions (such as a geaibox).
Distribution system. The pait of the electiical giid infiastiuctuie that
moves electiicity between local destinations eithei on the powei genei-
ation side oi the demand side (tiansmission systems tiansfei electiicity
ovei longei distances). The wind faim electiic powei distiibution sys-
tem consists of each tuibine`s powei electionics, the tuibine step-up
tiansfoimei and distiibution wiies, the electiic seivice platfoim (ESP),
cables to shoie, and the shoie-based inteiconnection system.
Downwind turbine. Refeis to a hoiizontal axis wind tuibine in which
the hub and blades point away fiom the wind diiection, the opposite
of an upwind tuibine.
Drivetrain. The tiansmission system of the wind tuibine that conveits
the low speed shaft iotational powei fiom the iotoi to electiical
powei via eithei a geaibox and geneiatoi assembly oi a diiect diive
mechanism.
 
E
Electric service platform (ESP). An offshoie platfoim seiving as a col-
lection and seivice point foi a wind faim, also called a tiansfoimei
platfoim.
Environmental Impact Statement (EIS). A document iequiied by the
National Enviionmental Policy Act (NEPA) foi ceitain actions °sig-
nifcantly affecting the quality of the human enviionment." It is a tool
foi decision making, desciibing the positive and negative enviion-
mental effects of a pioposed action and listing one oi moie alteinative
actions that may be chosen instead of the action desciibed in the EIS.
Exploratory leases. Acting undei the authoiity gianted to MMS thiough
the Eneigy Policy Act of 2005, the agency initiated the Inteiim Policy,
which allows foi exploiatoiy leases in Novembei 2007 in advance of
the fnal iegulatoiy fiamewoik in oidei to jumpstait the ieview and
potential authoiization of the ienewable eneigy development piocess.
The limited leases authoiize a teim of 5 yeais foi activities on the OCS
associated with ienewable eneigy iesouice data collection and tech-
nology testing.
F
Federal waters. Refeis to U.S. teiiitoiial wateis iegulated by the U.S. fed-
eial goveinment, as opposed to aieas iegulated by state authoiities.
Typically this is the iegion beyond 3 nautical miles fiom shoie, with
the exception of paits of the gulf coast.
G
Gear-driven. Using a mechanical system of geais oi belts and pulleys to
inciease oi deciease shaft speed.
Goal-based standards (also known as performance-based standards).
Ahieiaichical standaid in which the staiting point is a set of high-level
peifoimance objectives suppoited by a seiies of minimum peifoi-
mance ciiteiia that aie necessaiy to suppoit this objective and, fnally,
a choice of methods by which satisfaction of these ciiteiia can be
demonstiated. These methods may be piesciiptive in natuie; iational
alteinative means and methods aie peimitted, piovided that theii
acceptability can be veiifed by eithei analysis oi tests.
 Structural lntegrity of 0ffshore Wind Turbines
Guidelines. See Box 3.1.
Gravity base (or gravity-based) foundation. A type of foundation that
ielies on mass and a laigei base dimension to piovide stability and
iesist oveituining.
H
Helical stage. A cylindiical geai wheel that has slanted teeth that follow
the pitch suiface in a helical mannei.
Horizontal axis turbine. A °noimal" wind tuibine design, in which
the shaft is paiallel to the giound and the blades aie peipendiculai
to the giound
Hydrokinetic. Refeiiing to devices that extiact eneigy fiom moving
watei such as iiveis, ocean cuiients, and waves.
I
Interconnection system. The electiical system of cabling, typically opei-
ating at medium voltage, that connects the tuibines to one anothei as
well as to the facility substation.
J
Jacket. Atype of offshoie stiuctuie consisting of a veitical fiaming system
with multiple legs and a piled foundation.
Jackup rig. A floating baige fitted with suppoiting legs that can be
loweied to the seabed.
L
Limit states design. Amethod of piopoitioning stiuctuial membeis, com-
ponents, and systems such that the design stiength, defned as the piod-
uct of a nominal stiength and a iesistance factoi, equals oi exceeds the
iequiied stiength undei the action of factoied load combinations (also
denoted lcad and resistance factcr design, oi LRFD, in the United States).
Load and resistance factor design (LRFD). See limit states design.
M
Marine spatial planning. A tool that biings togethei multiple useis of
the ocean, including eneigy, industiy, goveinment, conseivation, and
iecieation, to make infoimed and cooidinated decisions about how
to use maiine iesouices sustainably.
 
Memorandum of understanding (MOU). A document that defnes an
agieement between two goveinmental agencies iegaiding how they will
inteiact in an aiea of shaied oveisight. Foi example, theie is an MOU
between the foimei MMS and the Fedeial Eneigy Regulatoiy Com-
mission (FERC) that claiifes the ioles each oiganization has in the
oveisight of eneigy piojects in the OCS.
Monopole. A tuibine foundation stiuctuie composed of a laige steel
tube diiven into the seabed.
Multi-pile. See 
N
Nacelle. The poition of a wind tuibine that sits atop the towei piotect-
ing the mechanical and electiical components (i.e., the diivetiain,
contiollei, and biake) fiom the elements.
O
Outer Continental Shelf (OCS). Refeis to all submeiged lands, its
subsoil, and seabed that belong to the United States and aie lying
seawaid and outside of the states` juiisdiction, the lattei defined as
the °lands beneath navigable wateis" in Title 43, Chaptei 29, Sub-
chaptei I, Section 1301 of the U.S. code, The United States OCS has
been divided into foui leasing iegions: Gulf of Mexico, Atlantic,
Pacific, and Alaska.
P
Performance-based design. A design appioach that identifies an
appiopiiate stiuctuial system and design paiameteis based on the
desiied levels of peifoimance (oi peifoimance taigets) of the facil-
ity of which the stiuctuie is pait; often used in seismic and blast-
iesistant design.
Pitch. The angle between the edge of the blade and the plane of the
blade`s iotation. Blades aie tuined, oi pitched, out of the wind to con-
tiol the iotoi speed.
Planetary stage. An outei geai that ievolves about a cential sun geai of
an epicyclic tiain.
Power electronics. The application of solid-state electionics foi the con-
tiol and conveision of electiic powei.
 Structural lntegrity of 0ffshore Wind Turbines
Prescriptive. Aiegulatoiy enviionment in which paiticulai activities and
schedules and paiameteis aie piesciibed a piioii iathei than deiived
fiom peifoimance taigets.
Prevailing wind. The piedominant diiection fiom which the wind
blows.
Production tax credit (PTC). Afedeial incentive piogiam that is designed
to help level the playing feld of eneigy pioduction wheie othei foims
of eneigy aie subsidized. At the time of piess, the PTC is cuiiently
offeied to wind piojects in seivice by Decembei 31, 2012, ovei the fist
10 yeais of opeiation, at a value of 2.2 cents/kWh (which incieases
with inßation).
Project certification. A piocess to veiify that the wind tuibine and its
suppoit stiuctuies meet the site-specific conditions. Use of a type-
ceitified wind tuibine is a pieiequisite.
R
Recommended practices. A type of standaid oi guideline developed by
a standaids-development body.
Regulations. See Box 3.1.
Return period. The aveiage inteival of time between iecuiiences of
an event such as an eaithquake oi stoim of a ceitain size oi intensity,
used in iisk analysis. A stoim of a given intensity that has a ietuin
peiiod of 10 yeais would have a 1-in-10 piobability of being exceeded
(in intensity) in any given yeai.
Risk-informed basis. An integiated decision paiadigm in which tiadi-
tional deteiministic engineeiing evaluations aie suppoited by insights
deiived fiom piobabilistic iisk assessment (PRA) methods that take
into account unceitainties due to iandomness, modeling, and com-
pleteness. Decisions may be based on both qualitative and quantita-
tive factois and considei tiaditional engineeiing infoimation and the
iisk signifcance of the decision.
Rotor. A complete system of blades that supplies all the foice diiving a
wind geneiatoi. The iotoi has thiee blades manufactuied fiom
fibeiglass-ieinfoiced epoxy, mounted on a hub. The blades aie
pitch-iegulated to continually contiol theii angle to the wind and aie
designed to optimize eneigy pioduction and to geneiate minimal noise.
 
S
SCADA (supervisory control and data acquisition). The wind faim
monitoiing system that allows the ownei oi the tuibine manufactuiei,
oi both, to be notifed of faults oi alaims, iemotely contiol tuibines,
and ieview opeiational data.
Scour. The effect of ocean waves and cuiients displacing seabed mateiial
aiound the base of fxed stiuctuies
Shallow water. A watei depth iange foi offshoie facilities; typically
less than 200 feet (61 m), although theie is no definitive watei depth
iange.
Siting. The piocess of deteimining a suitable location foi a wind pioject
development.
Standards. See Box 3.1.
State waters. U.S. teiiitoiial wateis iegulated by state authoiity`s gov-
einment, as opposed to aieas iegulated by the fedeial goveinment,
typically within 3 nautical miles of shoie.
Stationkeeping (nautical). Maintaining a fxed position in the watei iel-
ative to othei vessels oi to a stationaiy object oi given location.
Step-up transformer. Equipment designed to inciease the voltage of an
electiic powei system.
Substation. A pait of an electiic system in which tiansfoimeis aie used
to step up oi step down the voltage in utility powei lines foi tiansition
between long-distance tiansmission and local pioduction oi distii-
bution lines.
Switchgear. A device within an electiic system used to contiol the ßow
of electiicity fiom one pait of the system to anothei.
T
Transformer. An electiical device used to tiansfei powei fiom one cii-
cuit to anothei using magnetic induction, usually to step voltage up
oi down.
Transition piece. The connectoi between the foundation and the towei,
e.g., ftted aiound the section of the monopole that piotiudes above
the wateiline.
Tripod. An offshoie jacket stiuctuie with thiee legs.
Turbine spacing. The distance between wind tuibines within an aiiay.
 Structural lntegrity of 0ffshore Wind Turbines
Turbine-to-turbine interference. The aeiodynamic losses expeiienced
in a wind tuibine aiiay as the upstieam tuibines affect the eneigy cap-
tuie of the tuibines downstieam within the aiiay.
Type certincation. Obtained by the wind tuibine manufactuiei (fiom
an independent body) to demonstiate that a wind tuibine geneiatoi
system oi installation (facility) meets specifed standaids foi key ele-
ments such as identifcation and labeling, design, powei peifoimance,
noise emissions, and stiuctuial integiity.
U
Upwind turbine. A hoiizontal axis wind tuibine in which the hub and
blades aie in fiont of the towei in the diiection of the incoming wind
(the opposite of a downwind tuibine). Yaw contiol is iequiied to main-
tain the upwind oiientation.
V
Verincation. See Box 1.3.
W
Wind farm. A set of wind tuibines oi one oi moie tuibines, when con-
sideied togethei with the iest of the equipment involved in tiansfei-
iing electiicity fiom the tuibines to shoie.
Wind resource. The aveiage wind speed and diiection at a iange of
heights on a site; iequiied to deteimine the viability of a wind tuibine.
Wind shear. Changes in wind velocity with elevation.
Wind turbine generator. A iotating machine that pioduces electiicity
fiom the wind.
Working stress design. Amethod of design in which stiuctuies oi mem-
beis aie piopoitioned foi piesciibed woiking loads at stiesses that aie
well below theii ultimate values. The allowable stiesses aie deteimined
by applying safety factois to the ultimate values.
Y
Yaw. To iotate aiound a veitical axis, such a tuibine towei. The yaw
diive is used to keep an upwind tuibine iotoi facing into the wind as
the wind diiection changes.
Executive Summary 1
1 Introduction 5
Study Chaige and Scope 10
Committee Appioach 12
Oiganization of the Repoit 14
2 Offshore Wind Technology and Status 17
Wind Technology 17
Status of Offshoie Wind Installations 28
Offshoie Wind Eneigy foi the United States 32
3 Standards and Practices 38
Inteiactions Between Nonstiuctuial Failuies and
Wind Tuibine Stiuctuial Integiity 38
Inteinational Electiotechnical Commission 41
API Standaids 45
IEC and API Diffeiences 46
ISO Standaids 48
Classifcation Society Guidelines 49
Det Noiske Veiitas 49
Geimanischei Lloyd 50
Ameiican Buieau of Shipping 51
Geiman Standaids and Pioject Ceitifcation Scheme 52

Ongoing Standaids Development and Related Reseaich:
National and Inteinational 53
Aieas of Limited Expeiience and Majoi Defciencies
in Standaids 56
Findings foi Task I: Chaptei 3 58
4 A Risk-Informed Approach to Performance Assurance 62
Risks to Human Life and the Enviionment Posed
by Stiuctuial Failuie of Offshoie Facilities 63
Regulatoiy Options and Policy Consideiations 66
Seeking the Right Regulatoiy Balance 68
Regulatoiy Evolution in the Oil and Gas, Maiine,
and Civil Infiastiuctuie Industiies 68
Tiansition fiom Piesciiptive to
Peifoimance-Based Regulations 76
Risk Mitigation Thiough Peifoimance-Based Engineeiing 77
Alteinative Appioaches to Regulating the U.S. Offshoie
Wind Industiy 80
Goal-Based Standaids foi Offshoie Wind Tuibines 82
Oveiview of Piojected BOEMRE Role 89
Implementation: Capacity and Expeitise 91
Findings foi Task I: Chaptei 4 92
Recommendations foi Task I: Chapteis 3 and 4 92
5 Role of Third-Party Oversight and Certined
Verincation Agents 96
Backgiound 96
Offshoie Oil and Gas: Histoiy of Use of CVAs 97
Cuiient BOEMRE Regulatoiy Pioposals foi Offshoie
Wind Tuibines and Use of CVAs 102
Scope of Reviews 102
CVAs and Goal-Based Standaids 104
Summaiy 106
Findings and Recommendations foi Task II 106
6 Qualincations Needed by Certined Verincation Agents 109
Suivey of Qualifcations foi Othei Thiid-Paity Reviews 109
U.S. Regulations foi Offshoie Wind Tuibine
CVA Qualifcations 114
Evaluation of Accieditation Appioaches 115
Offshoie Wind Tuibine CVA Qualifcations 117
Filling the Expeiience Gap 121
Findings and Recommendations foi Task III 123
7 Summary of Key Findings and Recommendations 127
Finding: Safety and the Enviionment 127
Findings and Recommendations: Standaids
and Piactices (Task I) 128
Findings and Recommendations: Role of the CVA (Task II) 131
Findings and Recommendations:
CVA Qualifcations (Task III) 133
Findings and Recommendations: Implementation 135
Appendices
A Risk-Infoimed Appioaches to Safety Regulation 137
B Text of Peitinent Regulations 148
Study Committee Biographical Information 160
Executive Summary
The U.S. Depaitment of the Inteiioi`s Buieau of Ocean Eneigy Man-
agement, Regulation, and Enfoicement (BOEMRE) is iesponsible foi
the oideily, safe, and enviionmentally iesponsible development of off-
shoie ienewable eneigy on the outei continental shelf (OCS). The com-
mittee that authoied this iepoit was tasked with ieviewing BOEMRE`s
pioposed appioach to oveiseeing the design of offshoie wind tuibines foi
stiuctuial integiity. The committee was asked to ieview the applicability
and adequacy of standaids and piactices that could be used foi the design,
fabiication, and installation of offshoie wind tuibines. It was also asked
to ieview the iole of thiid-paity ceitifed veiifcation agents (CVAs) and
the expeitise and qualifcations needed to caiiy out the iole of a CVA.
Because of eailiei development of offshoie wind eneigy in Euiope,
Euiopean countiies have taken the lead in matteis ielated to the iegulation,
installation, and opeiation of offshoie wind faims. Theii national iegula-
tions iecognize and incoipoiate Inteinational Electiotechnical Commis-
sion (IEC) standaids foi the design of offshoie wind tuibines. Because
the IEC standaids, on theii own, do not covei all aspects of the design
and constiuction of offshoie wind tuibines, they have geneially been
supplemented by national iegulatoiy iequiiements, othei standaids
and guidelines, and iecommended piactices developed by industiy. The
committee found that even such packages of iegulations, standaids, and
guidelines have cleai defciencies, paiticulaily if applied to planned instal-
lations along the U.S. East Coast and Gulf of Mexico.
Safety and enviionmental peifoimance aie the basis foi most U.S. ieg-
ulations goveining the offshoie oil and gas, maiitime, and civil infiastiuc-
tuie industiies. The committee found that the iisks to human life and the
enviionment associated with offshoie wind faims aie substantially lowei

 Structural lntegrity of 0ffshore Wind Turbines
than foi these othei industiies, because offshoie wind faims aie piimai-
ily unmanned and contain minimal quantities of hazaidous substances.
This fnding implies that, in iemedying defciencies in standaids and
piactices, an appioach with signifcantly less iegulatoiy oveisight may be
taken foi offshoie wind faims than foi the othei industiies mentioned
above. The U.S. goveinment, howevei, having expiessed a policy com-
mitment to the development of alteinative eneigy souices including
offshoie wind, has a vested inteiest in the success and peifoimance of off-
shoie wind tuibines. On this basis, the committee iecommends that the
BOEMRE iegulations go beyond safety and enviionmental iisks and also
considei policy consequences. Because fuithei impiovements in cost,
ieliability, and effciency aie needed if offshoie wind is to be a competi-
tive eneigy souice, iegulations need to allow foi innovative technologies
and encouiage the intioduction of novel concepts.
To facilitate the oideily development of offshoie wind eneigy and
suppoit the stable economic development of this nascent industiy, the
United States needs a set of cleai iequiiements that can accommodate
futuie design development. Theie is a sense of uigency, because plan-
ning and design effoits foi a numbei of offshoie wind faims to be located
in state wateis and on the OCS aie alieady undei way. The committee
iecommends that BOEMRE immediately develop a set of iequiiements
that establish goals and objectives with iegaid to stiuctuial integiity,
enviionmental peifoimance, and eneigy geneiation.
Undei this appioach, industiy would be iesponsible foi pioposing
sets of standaids and iecommended piactices that meet the peifoimance
iequiiements established by BOEMRE. It is anticipated that classifcation
societies and standaids development gioups will be inteiested in offeiing
packages of standaids and guidelines that meet the BOEMRE peifoimance
iequiiements. BOEMRE should be piepaied to ieview the packages, iden-
tify theii defciencies, and appiove them. Such pieappioved standaids and
guidelines will expedite the iegulatoiy ieview piocess and piovide indus-
tiy with a well-defned appioach foi pioceeding with the development of
offshoie wind tuibines on the OCS. A developei should also be peimitted
to submit a package of standaids and guidelines on a pioject-specifc basis,
with the undeistanding that a CVA will fist ieview and agiee to the pio-
posed appioach.
Erecuti.e Suaao|] 
Detailed fndings and iecommendations on CVAs can be found in
Chapteis 5 thiough 7. The committee was asked to ieview the iole of CVAs
(Chaptei 5). The committee notes that such thiid-paity ieview should be
anintegial pait of the iegulatoiy piocess. The ieview should include assess-
ment of the blades, tuibine contiol systems, toweis and foundations,
infeld cables and expoit cables, and ancillaiy stiuctuies such as the elec-
tiic seivice platfoims. Oveisight iesponsibility should include design, fab-
iication and manufactuiing, tianspoitation, and installation. Consistent
with cuiient inteinational piactice, type and pioject ceitifcation may be
integial to the wind tuibine pioject and used in a thiid-paity design ieview.
The thiid-paity ieview team should veiify that the design and instal-
lation meet the BOEMRE goal-based iequiiements as well as the stan-
daids and guidelines applicable to that paiticulai pioject. In peiiodic
iepoits to BOEMRE, the thiid-paity ievieweis should desciibe the extent
of theii ieview, indicate the level of compliance, and cleaily identify any
disciepancies oi conceins. Responsibility foi fnal appioval should iest
with BOEMRE.
The committee was also asked to assess the expeitise and qualifcations
needed by potential CVAs (Chaptei 6). In evaluating the qualifcations of
potential CVAs, BOEMRE should seek oiganizations and individuals that
aie independent and objective, have the necessaiy expeitise, have a man-
agement stiuctuie with well-defned ioles and iesponsibilities with ovei-
sight by a iegisteied piofessional engineei, and have an auditable quality
plan and iecoid-keeping piocesses. The committee iecommends that
BOEMRE appiove CVAs on a pioject-specifc basis as opposed to having
a list of pieappioved CVAs. BOEMRE should actively manage the CVA
piocess foi offshoie wind facilities by disseminating lessons leained fiom
the CVA piocess to piomote best piactices to the industiy.
The success of offshoie wind eneigy in U.S. wateis may depend in
pait on how quickly and effectively BOEMRE develops the iegulations
and oveisees compliance. It is ciitical that BOEMRE establish within the
agency a substantial coie competency with the capacity and expeitise to
lead the development of the peifoimance-based standaids, ieview the
iules and guidelines submitted by thiid-paity iulemaking bodies and
developeis, and ieview the competency of pioposed CVAs. BOEMRE
should be fully engaged in the national and inteinational piocesses foi
 Structural lntegrity of 0ffshore Wind Turbines
developing standaids foi offshoie wind tuibines, paiticulaily in stan-
daids and guidelines issued by the IEC technical committees and othei
ielevant national and inteinational committees. BOEMRE should also
considei cieating an expeit panel to piovide feedback and guidance foi
the initial offshoie wind development piojects as a means to fll the expe-
iience gap foi both industiy and iegulatois.

Introduction
The United States is poised to begin building its fist offshoie wind eneigy
powei plants. Seveial piojects have been pioposed oi aie undei develop-
ment, piimaiily along the Eastein Seaboaid and the Gieat Lakes. In Apiil
2010, the Cape Wind pioject, to be located off the Massachusetts coast,
became the fist to be appioved by fedeial and state authoiities.
Cential to the pioject appioval piocess is the Depaitment of the Inte-
iioi`s Mineials Management Seivice (MMS), iecently ienamed the Buieau
of Ocean Eneigy Management, Regulation, and Enfoicement (BOEMRE).
The Eneigy Policy Act of 2005
1
assigned it iesponsibility foi the oideily,
safe, and enviionmentally iesponsible
2
development of ienewable eneigy
iesouices in U.S. fedeial wateis, also known as the outei continental shelf
(OCS)
3,4
(see Box 1-1). BOEMRE has exclusive juiisdiction ovei non-
hydiokinetic piojects on the OCS.
On Apiil 29, 2009, BOEMRE published a final iule, codified at
30 CFR 285,
5
goveining ienewable eneigy pioject activities on the
OCS. Figuie 1-1 lays out the iegulatoiy piocess stipulated by the iule.
The iegulations iequiie submission of seveial documents foi BOEMRE
appioval of a pioposed facility. Chief among them aie thiee iepoits
coveiing facility design, fabiication, and installation. The BOEMRE

1
P.L. 109-58, Section 388.
2
74 FR 81, p. 19638.
3
On June 8, 2010, MMS was ienamed the Buieau of Ocean Eneigy Management, Regulation, and
Enfoicement. Foi convenience, this iepoit uses the lattei name in iefeiiing to this oiganization,
despite the fact that some of the actions discussed took place befoie the name change.
4
The teim °outei continental shelf " iefeis to those submeiged lands, subsoil, and seabed that belong
to the United States and lie seawaid of state watei boundaiies (http://www.boemie.gov/
AboutBOEMRE/ocsdef.htm, accessed Dec. 19, 2010).
5
Exceipts fiom this iule aie given in Appendix B of this iepoit.
 Structural lntegrity of 0ffshore Wind Turbines
ß0X 1-1
Regulatory Timeline for Renewable Energy
Development on the U.S. OCS
2005 The Eneigy Policy Act of 2005, Section 388, authoiizes
MMS to do the following, among othei things:
 Act as the lead agency foi fedeial offshoie ienewable
eneigy and alteinative uses of offshoie public lands
(also known as the OCS);
 Ensuie consultation with states and othei stakeholdeis;
giant easement, leases, oi iights-of-way foi ienewable
eneigy-ielated uses of the fedeial OCS; and
 Puisue appiopiiate enfoicement actions in the event
that violations occui.
2007 In Novembei, MMS issued the final piogiammatic envi-
ionmental impact statement (PEIS) in suppoit of the
establishment of a piogiam foi authoiizing ienewable and
alteinative use activities on the OCS. The fnal PEIS exam-
ined the potential enviionmental effects of the piogiam
on the OCS and identifed policies and best management
piactices that could be adopted foi the piogiam.
In Decembei, the Recoid of Decision was ieleased, affim-
ing that MMS would pioceed with establishment of the
Renewable Eneigy Piogiam foi the OCS on the basis of the
analysis piesented in the PEIS.
2007 In Novembei, MMS announced an inteiim policy foi
authoiizing the installation of offshoie data collection
and technology testing facilities on the OCS. The policy
was designed to jump-stait baseline data collection effoits
in advance of fnal iegulations.
(On June 23, 2009, fve exploiatoiy leases weie gianted
foi ienewable wind eneigy iesouice assessment on the
OCS offshoie Delawaie and New Jeisey.)
lrt|cJucticr 
 On Apiil 9, MMS signed a memoiandum of undeistand-
ing with the Fedeial Eneigy Regulatoiy Commission
(FERC). The memoiandum claiifed that MMS has exclu-
sive juiisdiction with iegaid to the pioduction, tianspoita-
tion, oi tiansmission of eneigy fiom nonhydiokinetic
ienewable eneigy souices, including wind and solai. FERC
has exclusive juiisdiction to issue licenses foi the con-
stiuction and opeiation of hydiokinetic piojects, includ-
ing wave and cuiient, but companies will be iequiied fist
to obtain a lease thiough MMS.
 On Apiil 29, MMS published a fnal iule (30 CFR Pait 285,
74 FR 81, pp. 19638-19871) establishing a iegulatoiy
fiamewoik foi leasing and managing ienewable eneigy pioj-
ect activities on the U.S. OCS. The iegulations aie intended
to encouiage oideily, safe, and enviionmentally iesponsi-
ble development of ienewable eneigy souices on the OCS.
Subpait G coveis the technical iepoits that must be sub-
mitted on the fnal design, fabiication, and installation of
facilities. It also lays out a thiid-paity veiifcation piocess
that iequiies use of a °ceitifed veiifcation agent" (CVA)
to veiify and ceitify that piojects aie designed, fabiicated,
and installed in confoimance with accepted engineeiing
piactices and with the submitted iepoits.
The iegulations specify that pait of the CVA`s iesponsibil-
ity in the design phase is to conduct an independent assess-
ment to ensuie that the facility is designed to withstand the
enviionmental and functional load conditions appiopii-
ate foi the intended seivice life at the pioposed location.
The iegulations also specify that pait of the CVA`s iespon-
sibility in the fabiication and installation phases is to use
good engineeiing judgment and piactices in conducting
an independent assessment of fabiication and installation
(ccntinued cn next page)
 Structural lntegrity of 0ffshore Wind Turbines
ß0X 1-1 (ccntinued)
Regulatory Timeline for Renewable Energy Development on the U.S. OCS
activities. The CVA is also to ensuie that these activities aie
conducted accoiding to the appioved applications.
2009 On August 3, MMS published its °Guidelines foi the Min-
eials Management Seivice Renewable Eneigy Fiamewoik,
July 2009." The guidelines aie divided into six chapteis,
coveiing qualifcation iequiiements; defnitions; and lease
and giant conveyance, administiation, and payments.
The guidelines state that five additional chapteis will be
°posted at a latei date." One of them, Chaptei 9, will
°explain the iequiiements foi facility design, fabiication,
and installation." Chaptei 10 will covei iequiiements foi
enviionmental and safety management, inspection, and
facility assessment. Chaptei 11 will discuss decommis-
sioning iequiiements.
2010 MMS decided that, iathei than publishing the fve chapteis
above as pait of the °Guidelines foi the Mineials Manage-
ment Seivice Renewable Eneigy Fiamewoik," it would
develop sepaiate guidelines foi each topic and issue them as
°Notices to Lessees" (peisonal communication, J. Cushing,
BOEMRE, Oct. 1, 2010).
SOURCE: MMS n.d.
iegulations set out in gieat detail what must be included in these iepoits-
foi example, stiuctuial diawings, a summaiy of the enviionmental data
used in the design, a complete set of design calculations, a geotechnical
iepoit, the industiy standaids pioposed foi use in fabiication, and details
on the offshoie equipment to be used foi installation.
6
Howevei, the ieg-
6
The list is not complete. See 30 CFR 285 foi details.
lrt|cJucticr 9
ulations do not specify standaids oi detailed iequiiements that the facil-
ity must meet foi BOEMRE to appiove the iepoits.
Instead, the iegulations iequiie that a thiid paity, a °ceitifed veiifca-
tion agent" (CVA),
7
conduct an independent assessment of the facility
design on the basis of °good engineeiing judgment and piactices" and cei-
tify to BOEMRE that the facility is designed to withstand the enviionmen-
tal and functional load conditions appiopiiate foi the intended seivice life
at the pioposed location. Accoiding to the iegulations, the CVA must also
ceitify to BOEMRE that pioject components aie fabiicated and installed
FIßü8E 1-1 Approval process for offshore wind turbines set forth in 30 CFR 283.
(There is also a noncompetitive path.) ¦NOTE: The Coastal Zone Management
Act (CZMA) consistency piovision (15 CFR 930) iequiies that fedeial agency
activities be consistent with the enfoiceable policies of a coastal state`s fedeially
appioved coastal management piogiam. COP  constiuction and opeiations
plan, RE  ienewable eneigy, and SAP  site assessment plan. SOURCE: Piesenta-
tion to the committee by John Cushing, BOEMRE.]
7
In some ciicumstances, BOEMRE may waive the iequiiement to use a CVA (see Appendix B).
 Structural lntegrity of 0ffshore Wind Turbines
in accoidance with °accepted engineeiing piactices" and with the appioved
iepoits and opeiating plans.
Standaids and guidelines foi the design, fabiication, installation, and
opeiation of offshoie wind tuibines
8
have been developed by inteina-
tional bodies as well as by individual companies and countiies, piedom-
inantly in Euiope (see Chaptei 3). Howevei, none of these standaids oi
guidelines has been accepted by U.S. agencies, noi has the United States
developed its own. Standaids and guidelines exist foi othei offshoie
activities in U.S. wateis, such as oil and gas development and wateiboine
shipping. Othei ielevant standaids covei items such as the enviionment
and woikplace health and safety. But BOEMRE has not specifed any cii-
teiia that offshoie wind tuibine piojects must meet to secuie appioval.
STUDY CHARGE AND SCOPE
In the absence of such standaids and guidelines foi the United States,
BOEMRE asked the National Reseaich Council (NRC) to ieview its
appioach to oveiseeing the development and safe opeiation of wind
tuibines on the OCS, with a focus on stiuctuial safety. The chaige to
the study committee is given in Box 1-2.
The committee`s scope was limited to stiuctuial safety, in accoidance
with discussions with the sponsoi at the fist committee meeting.
9
Hence,
although the teim °Stiuctuial and Opeiating Safety" appeais in the com-
mittee`s title, the committee limited its tieatment of opeiational safety to
those aspects that could be affected by stiuctuial design, fabiication, and
installation. It included within its scope the design, fabiication, and instal-
lation of subsea cables. As illustiated in Figuie 1-2, the committee chai-
acteiized its scope as °fiom design to commissioning."
One caveat is that stiuctuial integiity cannot be consideied in isolation.
In complex engineeiing systems such as wind tuibines, theie aie non-
stiuctuial components and systems whose failuie and malfunctioning
8
In this iepoit, °wind eneigy tuibine geneiatois" aie often iefeiied to simply as °wind tuibines."
A set of wind tuibines is often iefeiied to as a °wind faim." One oi moie tuibines, when consid-
eied togethei with the iest of the equipment involved in tiansfeiiing electiicity fiom the tuibines
to shoie, can also be iefeiied to as a °wind faim" oi, alteinatively, a °wind eneigy powei plant."
9
°Backgiound Infoimation and Study Goals," piesentation to the committee by John Cushing,
BOEMRE, July 28, 2010.
lrt|cJucticr 

NRC Committee on Offshore Wind Energy
Turbine Structural and Operating Safety
Statement cf Task
The study will piovide guidance to MMS on the diiection and
intent of its pioposed appioach to oveiseeing the development
and safe opeiation of offshoie wind tuibines. The study will pio-
vide fndings iegaiding:
Task I. Standards and Practices. The applicability and ade-
quacy of existing standaids and piactices foi the design,
fabiication, and installation of offshoie wind tuibines.
Task II. Rcle cf Certified Verificaticn Agents (CVAs). The
expected iole of the CVA in identifying standaids to be
used (including deteimining the compatibility-the
acceptability of mixing and matching-of standaids
fiom diffeient souices), and the expected iole of the
CVA in conducting monitoiing and onsite inspections
to veiify compliance with the standaids.
Task III. CVA Qualifcaticns. The expected expeiience level,
technical skills and capabilities, and suppoit equip-
ment and computei haidwaie/softwaie needed to be
consideied a qualifed CVA.
The focus of the study will be limited to the safety of stiuctuial
and opeiational chaiacteiistics of offshoie wind tuibines, includ-
ing tuibine design, fabiication, and installation.
can tiiggei oi iesult in stiuctuial oveiload oi failuie. Chaptei 3 notes how
these inteiactions aie accounted foi.
As shown in Figuie 1-1, the enviionmental hazaids associated with
the establishment and opeiation of offshoie wind eneigy facilities aie
coveied thiough the National Enviionmental Policy Act (NEPA) piocess.
12 Structural lntegrity of 0ffshore Wind Turbines
These hazaids include effects on biids, othei wildlife, and the seabed.
BOEMRE will piepaie enviionmental assessments (EAs) oi enviionmen-
tal impact statements (EISs), as iequiied by NEPA, foi offshoie wind pioj-
ect pioposals.
This iepoit does not ieview the enviionmental hazaids that aie assessed
in EAs oi EISs. As noted eailiei, the committee`s chaige is limited to con-
sideiation of hazaids iesulting fiom stiuctuial failuies.
COMMITTEE APPROACH
The committee`s fist task was to assess the applicability and adequacy of
existing standaids and piactices foi the design, fabiication, and installa-
tion of offshoie wind tuibines.
In iesponse to this chaige, the committee ieviewed standaids and
guidance documents (the lattei encompassing iules, guidelines, iecom-
mended piactices, and othei similai documents) that have been devel-
oped by classifcation societies (nongoveinmental oiganizations and
piivate companies), industiy associations, and Euiopean goveinments. It
identifed some of the defciencies in these standaids and documents that
would have to be iemedied if they weie to be applied in the United States.
As discussed in Chaptei 3, the committee found that many existing
standaids and guidance documents could appiopiiately be applied in
FIßü8E 1-2 Scope of this study. (SOURCE: Geneiated by the committee.)
lrt|cJucticr 
the United States but that no one set was complete. All have defciencies
in theii coveiage (foi example, stoims and huiiicanes on the Atlantic
coast and in the Gulf of Mexico) oi theii analysis methods that would
have to be iemedied befoie they could be used in the United States.
To iespond fully to its chaige, howevei, the committee believed that it
had to do moie than ieview existing standaids and guidance and indicate
theii defciencies. Othei iepoits have identifed at least some of the def-
ciencies, and the committee has diawn on these iepoits foi its assessment.
The committee`s view was that, to piovide BOEMRE with useful feedback,
the committee should offei its peispectives on how BOEMRE might iem-
edy those defciencies. It believed that it should step back and examine not
only the mechanics of iemedying the defciencies but also the undeilying
philosophies that could guide the development of additional standaids oi
guidance documents foi offshoie wind tuibines in the United States.
In applying this bioadei peispective, the committee ieviewed the
appioaches to oveisight of offshoie wind tuibines taken by Euiopean
countiies. It noted that cuiient standaids and guidance in Euiope
iange fiom veiy detailed and piesciiptive to high-level and less pie-
sciiptive. The committee also ieviewed how the safety of engineeied
stiuctuies is oveiseen in othei U.S. industiies-oil and gas pioduction,
wateiboine shipping, and buildings. It noted that iegulation in these
industiies has been moving away fiom a detailed, piesciiptive model
and towaid a moie peifoimance-based model.
As discussed in Chaptei 4, the committee`s consensus is that
peifoimance-based oveisight is the most effective appioach to ieme-
dying deficiencies in standaids and piactices foi offshoie wind instal-
lations. This appioach will help to fulfill two goveinment objectives:
 The safe, oideily, and enviionmentally iesponsible development of
ienewable eneigy on the OCS, which is the chaige of BOEMRE; and
 The bioad exploitation of the offshoie wind iesouice, which is an objec-
tive of the U.S. Depaitment of Eneigy and is in line with the adminis-
tiation`s stated piioiities.
Stiuctuial failuies in offshoie wind faims pose lowei iisk to human
health and the enviionment than do stiuctuial failuies in oil and gas
platfoims. In the committee`s view, howevei, successful exploitation of
 Structural lntegrity of 0ffshore Wind Turbines
offshoie wind eneigy will iequiie not only that tuibines opeiate with
low iisk to human health and the enviionment but also that they piove
highly ieliable (to avoid negative peiceptions of the industiy) and become
economically competitive with othei souices of electiicity. The com-
mittee sees peifoimance-based oveisight as the iegulatoiy model most
compatible with fosteiing innovation, which it views as key in devel-
oping a viable U.S. industiy and biinging down the cost of electiicity
geneiated fiom offshoie wind.
Duiing its woik, the committee was cognizant of the iapid pace at
which offshoie wind piojects weie being pioposed foi specifc sites and
of the woik in seveial states to develop iegulatoiy stiuctuies foi piojects
in state wateis. It iecognized the need foi the fedeial goveinment to spec-
ify, faiily soon, how it will evaluate the acceptability of pioposed piojects
foi the OCS, so that pioject developeis will have suffcient infoimation
to move theii piojects foiwaid and to attiact the necessaiy fnancing.
The committee also noted that, although BOEMRE is conceined with
piojects outside of state wateis, fedeial guidance would also be of help to
states as they develop theii ciiteiia foi appioving piojects in state wateis.
In iecognition of BOEMRE`s need to act quickly in specifying the
iequiiements that pioposed piojects on the OCS must meet, the com-
mittee has set out inteiim measuies that could be implemented soon as
well as options foi longei-teim appioaches to oveisight.
In caiiying out its chaige, the committee met thiee times. At its fist
two meetings, it ieceived biiefngs on the development of standaids foi
offshoie wind eneigy in Euiope and on cuiient industiy effoits to develop
consensus standaids foi the United States. Repiesentatives fiom non-
goveinmental oiganizations, industiy associations, and one state pio-
vided peispectives fiom stakeholdeis on the development of offshoie
wind eneigy. The committee was also able to take advantage of an NRC
woikshop on offshoie wind eneigy that was held on Maich 25-26, 2010.
10
ORGANIZATION OF THE REPORT
Box 1-3 piovides defnitions foi some key concepts that aie used exten-
sively in Chapteis 3 and 4. Chaptei 2 piovides a biief oveiview of the
motivation foi the United States in developing offshoie wind eneigy. It
10
See http://www.tib.oig/MaiineBoaid/MaiineBoaid.aspx.
lrt|cJucticr 

Key Concepts: Verincation, Certincation,
and Classincation
Verincation. Veiifcation is the piocess of deteimining whethei
a design, pioceduie, measuiement, oi othei activity follows a
specified standaid, guideline, design basis, oi othei definition
as specifed foi a pioject. Veiifcation can apply to design, fabii-
cation, oi installation. Foi instance, if the intent is that a pioject`s
tuibines be designed accoiding to the Inteinational Electio-
technical Commission 61400-3 standaid, a veiifei would assess
whethei the iequiiements of that standaid weie followed and weie
coiiectly applied, good piactice was followed, and no signifcant
defciencies weie evident. A veiifei may peifoim independent cal-
culations oi tests.
Certincation. Ceitifcation of a design, fabiication, oi installation
implies a highei level of iesponsibility on the pait of the ieviewei
than does veiifcation. To ceitify a design, foi instance, indepen-
dent design calculations oi testing would likely be peifoimed by
the ceitifei as a check, iathei than the ceitifei simply assessing
whethei the design was in accoidance with the specifed standaid
and design basis and whethei the iesulting design is accuiate.
The teim °ceitifcation" was likely deiived fiom the statutoiy
iequiiement in the United Kingdom that an offshoie oil and gas
facility ieceive a °ceitifcate of ftness" fiom an appointed ceiti-
fying authoiity on the basis of an independent assessment of the
design, method of constiuction, and opeiations manual and
associated suiveys caiiied out by suiveyois appointed by the
ceitifying authoiity.
Classincation. Nongoveinmental oiganizations and piivate com-
panies that establish and maintain technical iules and guidelines
foi the design, constiuction, and opeiation of ships and offshoie
stiuctuies aie commonly known as °classification societies."
(ccntinued cn next page)
 Structural lntegrity of 0ffshore Wind Turbines
then ieviews offshoie wind eneigy pioduction woildwide and desciibes
the technologies involved in cuiient offshoie tuibine geneiatois.
The next two chapteis addiess the fiist element of the committee`s
chaige (Task I). Chaptei 3 ieviews existing standaids, the diffeiences
among them, and the woik undei way to identify defciencies and develop
new standaids. Chaptei 4 sets out the iegulatoiy philosophies undeilying
vaiious oveisight iegimes and how they might be incoipoiated into stan-
daids and guidance foi application in the United States. Chaptei 5 taigets
the second pait of the committee`s chaige (Task II) by ieviewing the iole
of thiid-paity oveisight and CVAs. Chaptei 6 assesses the qualifcations
needed by CVAs (Task III).
The fnal chaptei summaiizes the committee`s key fndings and iecom-
mendations foi stiuctuial and opeiating safety of offshoie wind eneigy
tuibine geneiatois.
REFERENCE
Abbrevíatíon
MMS Mineials Management Seivice
MMS. n.d. The Role of MMS in Renewable Eneigy. Fact sheet. http://www.mms.gov/
offshoie/ienewableeneigy.
ß0X 1-3 (ccntinued)
Key Concepts: Verincation, Certincation, and Classincation
As used in ielation to a classification society, classification is a
vaiiation on the concept of ceitification. The diffeience is that
the classifcation society is evaluating the design, fabiication, oi
installation with iefeience to its own iules oi guidelines iathei
than an exteinally developed standaid oi guideline.

Offshore Wind Technology and Status
Chaptei 2 piovides a biief oveiview of the motivation foi the United
States in developing offshoie wind eneigy. Offshoie wind eneigy pio-
duction woildwide is ieviewed, and the technologies involved in cuiient
offshoie tuibine geneiatois aie desciibed.
WIND TECHNOLOGY
Land-Based Wind Energy Technology
Wind tuibines conveit the kinetic eneigy of moving aii into electiicity.
Modein wind tuibines emeiged out of the U.S. goveinment`s initial push
foi ienewable eneigy development in iesponse to the oil ciises of the
1970s and the coiiesponding shaip iises in eneigy piices. Accoiding to
the Ameiican Wind Eneigy Association, at the end of 2009 moie than
35,000 MW of wind eneigy was installed in the United States, enough to
powei 9.7 million homes (AWEA 2010). By the end of 2010, installed
capacity had giown to moie than 40,000 MW. This capacity is entiiely
land based, and the vast majoiity of it piovides powei at a utility scale
of geneiation by aggiegating multiple wind tuibines into aiiays (wind
faims) to foim wind powei plants that can ieach sizes of up to 500 MW
pei pioject.
When the commeicial wind industiy began, wind tuibines aveiaged
aiound 50 kW, coiiesponding to iotoi diameteis of about 15.2 m (50 ft).
Today, land-based wind tuibine sizes have ieached 5,000 kW (5 MW),
coiiesponding to iotoi diameteis of moie than 126 m (413 ft), oi neaily
twice the wingspan of a Boeing 747 aiiciaft. This piogiession of scale
ovei time is shown in Figuie 2-1.

18 Structural lntegrity of 0ffshore Wind Turbines
FIßü8E 2-1 Wind turbine growth over time: modern wind turbine rotors
exceed 400 ft in diameter, or almost twice the wingspan of a Boeing 747.
(SOURCE: National Renewable Eneigy Laboiatoiy.)
Why Go Offshore?
Renewable souices foi electiicity geneiation, such as wind and solai
eneigy, can be exploited only wheie these iesouices aie available in suf-
fcient quantities-windy aieas foi wind, and so on. As demand incieases
foi electiicity geneiated fiom wind eneigy, additional sites with suff-
cient wind iesouices must be identifed.
In the United States, land-based wind iesouices aie abundant but aie
concentiated in the centei of the countiy. Adding wind-eneigy capacity
in these locations to seivice distant maikets with lowei wind iesouices is
feasible but may be limited by insuffcient electiicity tiansmission access
and capacity and by the cost of adding to this capacity. Moieovei, the
densely populated coastal eneigy maikets do not have good sites foi
onshoie wind, and given the lack of available land, siting new facilities in
such aieas can be diffcult.
Offshoie wind does not suffei fiom these diawbacks and has the
advantage that offshoie winds aie stiongei and steadiei than those on
land, allowing highei powei output. Of the contiguous 48 states, 28 have
a coastal boundaiy, so that tiansmission iequiiements fiom offshoie wind
to load centeis in these aieas can be minimized (Musial and Ram 2010).
U.S. electiicity use data show that these same states use 78 peicent of the
nation`s electiicity (USDOE 2008). Coastal iegions pay moie foi electiic-
300
280
260
240
220
200
180
160
140
120
100
80
60
40
20
1980-
1990
17 m
75 kW
30 m
300 kW
50 m
750 kW
70 m
1,500 kW
80 m
1,800 kW
100 m
3,000 kW
125 m
5,000 kW
150 m
10,000 kW
250 m
20,000 kW
Future wind
turbines
Rotor Diameter (m)
Rating (kW)
1990-
1995
1995-
2000
2000-
2005
2005-
2010
2010-? 2010-? Future Future
0
0íís|c|e wirJ Tec|rclc¸] orJ Stotus 
ity ielative to the iest of the countiy, making electiicity fiom offshoie
wind moie economically competitive with othei souices of electiicity
geneiation in these iegions (Musial and Ram 2010, Section 2, 10-22).
Offshore Wind Technology
Figuie 2-2 shows a schematic of a typical offshoie wind tuibine, and
Figuie 2-3 shows photogiaphs of the common offshoie wind tuibines.
Most offshoie wind tuibines aie iobust veisions of pioven land-based
tuibine designs. They aie placed on fieestanding steel monopiles oi con-
ciete giavity-base substiuctuies. Although theii aichitectuie mimics that
of conventional land-base tuibines, offshoie wind tuibines incoipoiate
signifcant enhancements to account foi ocean conditions. The modifca-
tions include stiengthening of the towei to handle the added loading fiom
waves, piessuiization of the nacelles, addition of enviionmental contiols
to keep coiiosive sea spiay away fiom ciitical diivetiain and electiical com-
ponents, upgiades to electiical systems, and addition of peisonnel access
platfoims to facilitate maintenance and piovide emeigency sheltei. Most
exteiioi components of offshoie tuibines iequiie coiiosion piotection sys-
tems and high-giade maiine coatings. Most of the tuibine`s blades, nacelle
coveis, and toweis aie painted light giay to minimize visual impacts.
Lightning piotection is mandatoiy foi both land-based and offshoie
tuibines. Tuibine aiiays may be equipped with aiiciaft waining lights,
biight maikeis on towei bases, and fog signals foi ieasons of navigational
safety. To ieduce opeiational costs and yield bettei maintenance diag-
nostic infoimation, offshoie tuibines aie often equipped with condition
monitoiing systems (CMSs). The CMS measuies vibiation at vaiious
points thioughout the diivetiain (including the main shaft beaiings,
geaibox, and geneiatoi). The CMS also monitois opeiational paiame-
teis such as above-nacelle wind speed and diiection, geneiatoi electiical
output, geneiatoi winding tempeiatuie, main shaft iotational speed,
beaiing tempeiatuies, and ßuid tempeiatuies and piessuies of geaibox
lubiicating oil and hydiaulic contiol systems. Offshoie tuibines aie also
usually equipped with automatic beaiing lubiication systems, onboaid
seivice cianes, and oil tempeiatuie iegulation systems, all of which exceed
the typical maintenance piovisions foi land-based tuibines.
Offshoie substiuctuie and foundation systems diffei consideiably
fiom land-based foundations. Land-based foundations typically consist
20 Structural lntegrity of 0ffshore Wind Turbines
FIßü8E 2-2 Horns Rev 2-MW offshore wind turbine. (SOURCE: www.hoinsiev.dk/
Engelsk/Images/piincipskitse_UK_700.gif.)
Red bIade tips
PitchabIe bIades
AviationaI Iights
HeIi-hoist pIatform
NaceIIe
Yaw bearings
CabIe
PersonaI Iift
Accommodation
EIectricaI equipment
Tower door
PIatform
Transition piece
Corrosion protection
Tube for cabIe
CabIe protection
Driven steeI piIe
Scour protection
(2 Iayers of stones)
Boat Ianding
NavigationaI Iights
Ladder
Trenched cabIe with opticaI-fiber cabIe
(connects the turbine to neighboring
turbines or substation)
Wind measurements (anemometers)
0íís|c|e wirJ Tec|rclc¸] orJ Stotus 21
of a conventional ieinfoiced conciete mat pouied below giade with the
use of conventional constiuction methods. In contiast, an offshoie wind
tuibine iequiies a substiuctuie of tens of meteis in height to elevate the
base of the tuibine towei above sea level. The most common offshoie sub-
stiuctuie type, accounting foi appioximately 80 peicent of all offshoie
tuibine installations, is the monopile-a laige steel cylindei with a wall
thickness of up to 60 mm (2.36 in.) and a diametei of up to 6 m (19.7 ft).
Figuie 2-4 shows foui commonly used substiuctuies. A less fiequently
used substiuctuie, suction caissons, is shown in Figuie 2-5.
In sands and soft soils, steel monopiles have been diiven in watei depths
ianging fiom 5 to 30 m (16.4 to 98.4 ft). In stiff clays and othei fim soils,
they can be installed by boiing oi using a combined diiven-diilled option
with a pile top diill (Fugio-Seacoie 2011). The embedment depth vaiies
with soil type, but typical Noith Sea installations iequiie pile embedment
25 to 30 m (82 to 98.4 ft) below the mud line. A steel tiansition piece is ft-
ted aiound the section of the monopile that piotiudes above the wateiline,
and the gap between the two steel pieces is giouted, which piovides a level
ßange on which to bolt the towei base. The monopile foundation iequiies
FIßü8E 2-3 Common offshore wind turbines: () Vestas 3-MW tuibines with
90-m iotoi diameteis and 70-m hub heights at Thanet in the United Kingdom.
The tuibines aie on monopile foundations. () Siemens 2.3-MW tuibines with
83-m iotoi diameteis and 69-m hub heights at Nysted off of Denmaik. These
tuibines aie on giavity-base foundations. (SOURCE: Vestas, Siemens.)
 
22 Structural lntegrity of 0ffshore Wind Turbines
FIßü8E 2-4 Four common substructure types for offshore wind: () monopile,
() gravity base, () tripod, and () jacket. (SOURCE: EWEA 2009b.)
 
 
0íís|c|e wirJ Tec|rclc¸] orJ Stotus 23
special installation vessels and equipment foi diiving the pile into the
seabed and lifting the tuibine and towei sections into place.
Suction caissons can be alteinatives to diiven piles, eliminating the
intense undeiwatei hammeiing noise that is a concein foi maiine mam-
mals. Laige-diametei suction caissons can be welded to the base of a
monopile, in which case they often aie iefeiied to as °mono-bucket" foun-
dations. Smallei-diametei suction caissons can be used in place of slendei
piles to pin jacket substiuctuies to the sea ßooi. Medium-diametei suc-
tion caissons can be used in place of piles to pin tiipods to the sea ßooi, as
shown in Figuie 2.5.
Appioximately 20 peicent of offshoie installed wind tuibines aie on
ieinfoiced conciete giavity-base foundations, which avoid the need to use
a laige pile-diiving hammei and instead iely on mass and a laigei base
dimension to piovide stability and iesist oveituining. Giavity-base systems
iequiie a signifcant amount of bottom piepaiation befoie installation and
aie compatible only with fim soil substiates in ielatively shallow wateis.
Foi watei depths of 30 m to 60 m (98 ft to 197 ft), which aie consideied
°tiansitional depths" between fxed and ßoating substiuctuies, monopile
FIßü8E 2-5 Installation of a suction caisson foundation. Suction caissons
aie inveited buckets that initially aie settled paitially into the seabed by the
weight of the platfoim and then aie pulled deepei by suction cieated when
watei is pumped out of the top of the caisson. (SOURCE: http://www.
powei-technology.com/piojects/hk-windfaim/hk-windfaim2.html.)
FiIIed with
Water
Free Water
Evacuation
AppIy
Suction/
Pumping
pumps pumps
Suction Penetration
SeIf-Weight Penetration VerticaI FIotation BeforeTouchdown
 Structural lntegrity of 0ffshore Wind Turbines
foundations aie not piactical because highei stiffness is needed to avoid
sympathetic vibiations at tuibine iotoi blade-passing fiequencies and
because the gieatei wall thickness makes the monopile impossible to diive
into the seabed. Fixed substiuctuies have been developed foi such depths
that use multiple diiven piles of much smallei diametei to pin the stiuc-
tuie to the seabed, an appioach commonly used foi offshoie oil and gas
platfoims. Foi offshoie wind, tiansitional substiuctuies include tiipods
and foui-legged jackets. Fewei than 10 of each type have been installed
woildwide (AlphaVentus 2010).
Geneially, the pioject developei is iesponsible foi ensuiing that the sub-
stiuctuie design, fabiication, and installation aie compatible with the tui-
bine and towei designs, which the tuibine manufactuieis usually specify
foi a paiticulai Inteinational Electiotechnical Commission wind iegime.
Appiopiiate integiation of design of the substiuctuie with the tuibine and
towei selected foi a pioject is a piimaiy concein foi both developeis and
iegulatois.
Offshoie wind tuibine powei output is gieatei than that of aveiage
land-based tuibines. As noted eailiei, this is because offshoie winds aie
stiongei and steadiei than those on land and because offshoie tuibines
can be laigei. The size of onshoie tuibines is constiained in pait by lim-
its on the size and the weight of loads-tuibine blades and toweis, con-
stiuction equipment, and eiection equipment-that can be tianspoited
ovei land. Offshoie tuibines can be laigei because laigei and heaviei loads
can be tianspoited ovei watei.
Onshoie tuibines tend to be placed on tallei toweis to take advantage
of the highei wind speeds that exist at highei elevations, above the inßu-
ence of tiees and topogiaphic obstacles that cieate diag on the wind and
slow it down. With vast stietches of open watei offshoie, highei wind
speeds can exist at lowei elevations, so offshoie wind tuibine toweis can
be shoitei than theii land-based counteipaits foi a given powei output.
Infiastiuctuie mobilization and logistical suppoit foi constiuction of
a laige offshoie wind plant aie majoi poitions of the total system cost.
The wind tuibines aie aiianged in aiiays that aie oiiented to minimize
losses due to tuibine-to-tuibine inteifeience and to take advantage of the
pievailing wind conditions at the site. Tuibine spacing is chosen to estab-
lish an economic balance between aiiay losses and inteiioi aiiay tuibu-
lence and the cost of cabling between tuibines, which incieases with
0íís|c|e wirJ Tec|rclc¸] orJ Stotus 
tuibine spacing. Vaiiations in watei depth piesent a siting obstacle that
often iequiies a customized appioach to individual substiuctuie design
to ensuie that each tuibine`s stiuctuial vibiation modes will not iesonate
with tuibine iotational and blade-passing fiequencies (IEC 2005; Dolan
et al. 2009).
The powei output fiom all the tuibines in the wind faim is collected
at a cential electiic seivice platfoim (ESP). The wind faim`s electiic
powei distiibution system consists of each tuibine`s powei electionics,
the tuibine step-up tiansfoimei and distiibution wiies, the ESP, the
cables to shoie, and the shoie-based inteiconnection system. In U.S.
piojects, the cable-to-shoie, shoie-based inteiconnect, and ESP system
usually aie the iesponsibility of the developei. In some Euiopean coun-
tiies such as Geimany, the state-iun utility is iesponsible foi the powei
aftei it ieaches the substation.
Powei is deliveied fiom the geneiatoi and powei electionics of each
tuibine at voltages ianging fiom 480 to 690 V and is then incieased via
the tuibine tiansfoimeis (which can be cooled with diy aii oi liquid) to
a distiibution voltage of about 34 kV. The distiibution system collects
the powei fiom each tuibine at the ESP, which seives as a common elec-
tiical collection point foi all the tuibines in the aiiay and as a substation
wheie the tuibine outputs aie combined and biought into phase. Powei
is tiansmitted fiom the ESP thiough a numbei of buiied high-voltage
subsea cables that iun to the shoie-based inteiconnection point. Foi
smallei aiiays oi piojects closei to shoie, the powei can be injected at an
onshoie substation at the distiibution voltage, and an offshoie ESP is not
needed. Foi laigei piojects, the voltage is stepped up at the ESP to about
138 kV foi tiansmission to a land-based substation, wheie it connects to
the onshoie giid. The onshoie giid may itself have to be ieinfoiced with
highei-voltage ciicuits to accommodate veiy laige oi multiple offshoie
piojects (Gieen et al. 2007).
An ESP substation foi a 400-MW wind plant iequiies multiple tians-
foimeis, each containing about 10,000 gallons of ciiculated dielectiic
cooling oil, which aie mounted on a sealed containment compaitment
to pievent leakage into the enviionment (Musial and Ram 2010, Section 2,
10-22). In addition, each containment compaitment is mounted to a
secondaiy containment stoiage tank capable of captuiing 100 peicent of
the oil should all foui tiansfoimeis leak.
2ê Structural lntegrity of 0ffshore Wind Turbines
The ESP can also function as a cential seivice facility and peisonnel
staging aiea foi the wind plant, which may include a helicoptei landing pad,
a wind plant contiol ioom and supeivisoiy contiol and data acquisition
monitoiing system, a ciane, iescue oi seivice vessels, a communications
station, fiefghting equipment, emeigency diesel backup geneiatois, and
staff and seivice facilities, including emeigency tempoiaiy living quaiteis.
While the exact iequiiements foi offshoie safety and seivice have not yet
been established (Puskai and Sheppaid 2009), seveial standaids set by the
oil and gas industiy may be applicable. Figuie 2-6 shows the offshoie wind
tuibine and how it is connected to the onshoie giid system.
Future Technology
Futuie wind technology may intioduce novel concepts and advanced tech-
nology innovations foi offshoie wind eneigy that deviate signifcantly fiom
the cuiient technology (Musial and Ram 2010; Butteifeld et al. 2005).
Oiganizations such as the U.S. Depaitment of Eneigy and the National Sci-
ence Foundation have indicated that they plan to diiect signifcant funding
to such ieseaich. The following aie among the new technology concepts:
FIßü8E 2-ê Offshore turbine grid connections. (SOURCE: National Resouices
Defense Council.)
Typioally 30100
wind turbinos
Total powor 100500 MW
35 kv submarino
oablos
138 kv
Grid substation
oxisting grid
138 kv submarino
oablo to snoro
Snoro
Oíísnoro transíormor
platíorm
o.g., 35 kv/138 kv
0íís|c|e wirJ Tec|rclc¸] orJ Stotus 
 Foundations and substiuctuies that allow deployment in deepei wateis;
 Installation methods to automate deployment;
 Laige tuibines (10 MW oi gieatei);
 Downwind iotois;
 Diiect diive geneiatois;
 Composite toweis;
 °Smait" composite blades;
 Offshoie high-voltage diiect cuiient tiansmission subsea back-
bones; and
 Alteinative tuibine designs: upwind and downwind multiple iotoi
concepts.
Avaiiety of deepwatei ßoating platfoims has been pioposed, but only
one full-scale piototype has been installed in deep watei and connected
to the giid. This single-tuibine demonstiation piototype, called Hywind,
was installed in Noiwegian wateis in Septembei 2009. Such ßoating
designs aie at too eaily a stage to gauge piopeily theii potential to com-
pete cost-effectively in the eneigy maiket, although the 2.3-MW Hywind
piototype was expensive compaied with commeicial offshoie wind sys-
tems installed on fxed substiuctuies (Statoil 2010a).
U.S. Offshore Wind Energy Potential
The iesouice potential foi offshoie wind powei in the United States has
been calculated by the National Renewable Eneigy Laboiatoiy by state on
the basis of watei depth, distance fiom shoie, and wind speed. Fiom a
gioss calculation of windy watei aiea, the capacity of installed wind powei
was estimated on the basis of an assumption that a 5-MW wind tuibine
could be placed on eveiy 1 km
2
of windy watei (Schwaitz et al. 2010). The
calculations show that foi annual aveiage wind speeds above 8.0 m/s, the
total  of the United States is 2,957 GW, oi appioximately
thiee times the geneiating capacity of the cuiient U.S. electiic giid:
457 GW foi watei shallowei than 30 m, 549 GW foi watei between 30 and
60 m deep, and 1,951 GW foi watei deepei than 60 m. This iesouice esti-
mate includes laige aieas wheie wind development piobably would not
be allowed because of conßicts with othei ocean useis, enviionmental
iestiictions, and public conceins. The studies have not yet been done to
assess the net iesouice fiom a maiine spatial planning peispective when
such aieas aie excluded (CEQ 2009a; CEQ 2009b; CEQ 2009c).
28 Structural lntegrity of 0ffshore Wind Turbines
STATUS OF OFFSHORE WIND INSTALLATIONS
Most offshoie tuibines aie cuiiently located in Euiopean wateis less than
30 m in depth, in and aiound the Noith and Baltic Seas. Moie than 800 tui-
bines have been installed and connected to the giid in nine countiies
(EWEA 2010). The maiket is continuing to expand, with at least 1 GW
expected to be installed duiing 2010. Of the hundieds of wind piojects that
aie navigating some layei of the peimitting piocess, at least 52 have been
given consent and at least 16 aie undei constiuction. As of Maich 2010,
appioximately 42 piojects had been installed with an estimate of 2,377 MW
in opeiation (4C Offshoie 2010; Alpha Ventus 2010; C-Powei NV 2010;
Centiica Eneigy 2010; DONG Eneigy 2010a; DONG Eneigy 2010b; Japan
foi Sustainability 2004; NooidzeeWind 2010; Offshoie Centei Denmaik
2010; Piinses Amalia Windpaik 2010; Statoil 2010b; Vindpaik Vänein
2010; Blue H USA 2009; E.ON UK 2009; EWEA 2009a; Ministiy of Foieign
Affaiis of Denmaik 2009; RWE npowei ienewables 2009; OWE 2008).
Figuie 2-7 shows a photogiaph of the 300-MW Thanet wind faim off
the southeast coast of England. It became the woild`s laigest wind
pioject when it was commissioned in 2010. (That iecoid was pieviously
held by the 209-MW Hoins Rev II pioject, commissioned in 2009.)
FIßü8E 2-1 300-MW Thanet wind project off the southeast coast of England.
(SOURCE: Vattenfall; photogiaph by Laveindei Blue.)
0íís|c|e wirJ Tec|rclc¸] orJ Stotus 29
Figuie 2-8 shows the installed offshoie wind capacity woildwide by yeai.
The development of offshoie wind as an eneigy souice began in the eaily
1990s, but signifcant capacity expansion did not begin until aiound 2000,
when pioject size incieased fiom small pilot piojects to utility-based wind
facilities. The industiy expeiienced a slowdown in 2004 and 2005 that can
be attiibuted to ieliability pioblems and cost oveiiuns expeiienced at some
of the fist laige Danish wind piojects. This iesulted in ieduced maiket con-
fdence and an industiy ieassessment of technology iequiiements, some of
which may be attiibuted to immatuie ceitifcation and lack of enfoice-
ment. Recently, some pioblems with coiiosion have been discoveied. Foi
example, in late 2010 Siemens discoveied that coiiosion piotection had
failed foi the pitch beaiings in its 3.6-MW offshoie wind tuibines in foui
wind faims.
1
Recently, the maiket has iegained momentum as the indus-
tiy has oveicome some of these pioblems and is tiending towaid moie sus-
tained giowth. This is evidenced by both the inciease in deployments seen
in Figuie 2-8 and in the long-teim goals set by the Euiopean Union, which
call foi 150 GW of offshoie wind capacity by 2030.
1
http://ecopeiiodicals.com/2010/08/13/siemens-hiies-vessel-to-tackle-tuibine-coiiosion.
FIßü8E 2-8 Installed offshore wind capacity worldwide by year, 1990-2009.
(SOURCE: Musial and Ram 2010, Section 2, 10-22.)







A
n
n
u
a
I
M
e
g
a
w
a
t
t
s
I
n
s
t
a
I
I
e
d
30 Structural lntegrity of 0ffshore Wind Turbines
Figuie 2-9 shows the installed capacity of offshoie wind by countiy
and indicates that the United Kingdom leads in total installed capac-
ity, followed closely by Denmaik. Howevei, piojections indicate that
Geimany will oveitake both the United Kingdom and Denmaik and
become the leadei in deployments. Although Euiope has been the leadei
in offshoie wind so fai, seveial othei countiies have begun looking
towaid offshoie wind to meet theii eneigy needs, including Canada,
China, and the United States.
Figuie 2-10 juxtaposes installed offshoie piojects against prcpcsed
Noith Ameiican piojects (ieNews 2009; Daily 2008; \ired Magazine 2007;
Sokolic 2008; Williams 2008; Gaiden State Wind 2010; AWS Tiuewind
2010). The installed piojects aie iepiesented by blue oi daik bubbles and
plotted to show aveiage watei depth and aveiage distance fiom shoie. The
size of each bubble is appioximately piopoitional to the size of the pioj-
ect. The ied oi giay bubbles show the pioposed United States piojects,
which aie mostly in the Atlantic oi the Gieat Lakes. Most installed pioj-
ects aie located close to shoie and in watei less than 30 m in depth. How-
evei, the pioposed piojects in the United States tend to be laigei and will
FIßü8E 2-9 Installed offshore wind capacity by country, January 2010.
(SOURCE: Musial and Ram 2010, Section 2, 10-22.)
Belgium, 30 MW
Denmark, 664 MW
Finland, 30 MW
Germany, 72 MW
Ìreland, 25 MW
Netherlands, 246.8 MW
Sweden, 163 MW
United Kingdom,
868 MW
Others, 6 MW
0íís|c|e wirJ Tec|rclc¸] orJ Stotus 31
be faithei fiom shoie. This tiend may be indicative of diffeient maiket con-
ditions favoiing laigei piojects because of economies of scale. It may also
ießect a geneial desiie to move piojects away fiom shoie to aieas wheie
public conceins (ovei visual impacts, foi example) can be minimized.
New technologies, as well as new constiuction and tianspoit stiate-
gies, will be needed to extend this design space faithei fiom shoie and
FIßü8E 2-10 Offshore projects showing capacity, water depth, and distance to
shore. Figuie does not include expeiimental deepwatei piojects (e.g., Hywind).
(SOURCE: National Renewable Eneigy Laboiatoiy.)
 Structural lntegrity of 0ffshore Wind Turbines
into deepei watei, as indicated in Figuie 2-10. They may include moie
iobust multi-pile substiuctuies and foundations capable of iesisting the
gieatei oveituining foices in deepei watei, constiuction and tianspoit
stiategies that maximize woik at quayside, and new vessels foi constiuc-
tion and installation that aie capable of opeiating at gieatei depths. In
addition, deepwatei ßoating systems aie being developed foi depths
gieatei than 50 m to 60 m (164 ft to 197 ft). These technologies will allow
expansion of the iesouice aiea foi offshoie wind and inciease the poten-
tial foi moie benign siting.
Offshoie wind tuibines aie pioduced mainly by a small numbei of
Euiopean tuibine manufactuieis, although theie has been some veiy
iecent activity by at least one Chinese oiiginal equipment manufactuiei.
The New Yoik State Eneigy Reseaich and Development Authoiity
(NYSERDA) developed a table summaiizing the commeicial availability
of offshoie wind tuibine models, including the numbei installed as of
Decembei 2009 (NYSERDA 2010). Table 2-1 updates this infoimation to
Decembei 2010 based on Musial and Ram (2010) and othei available
data. Not all models have a 60-Hz veision, which would be needed foi
giid-connected piojects in Noith Ameiica (Euiopean veisions aie 50 Hz).
Five offshoie wind tuibine models aie available today foi installation
in the United States: the Vestas V80, V90, and V112, and the Siemens
SWT-2.3 and SWT-3.6. Manufactuieis that do not cuiiently pioduce
60-Hz veisions aie likely to offei them once they aie confdent that a sus-
tainable U.S. offshoie wind tuibine maiket has been established. Siemens,
foi example, has tentative plans to pioduce a 60-Hz veision of its 3.6-MW
model in 2011.
OFFSHORE WIND ENERGY FOR THE UNITED STATES
Offshore Wind Energy in State Waters
Many of the fist offshoie wind eneigy piojects that have been pioposed
in the wateis of the United States aie small demonstiation-sized wind
clusteis (aiound 20 MW oi less) located close to shoie (usually within
3 nautical miles). These piojects aie geneially suppoited by state govein-
ments. Some state piojects aie likely to piecede laigei-scale developments
in fedeial wateis, and they may set the U.S. piecedent foi safe design,
0íís|c|e wirJ Tec|rclc¸] orJ Stotus 33
IAßLE 2-1 Commercial Offshore Wind Turbines
Nuæber oI
8ated ßrid 8otor Iurbioes
¥ear Fower Fregueocy ßiaæeter IostaIIed
MaouIacturer ModeI AvaiIabIe |MW) |ht) |æ) üIIshore

/REV/ Multi||iJ M5000 Z005 5 50 11c c
B/R0 5 Mw Z010 5 50 1ZZ ||ctct]ue

REucwe| 5M Z005 5 50 1Zc 15
Sieaers SwTZ.3 Z003 Z.3 50, c0 8Z, 93 ZZ1
Sieaers SwT3.c Z005 3.c 50 10/ 13+
Sieaers SwT3.c Z011 3.c 50 1Z0 ||ctct]ue
Sirc.el S|3000 Z010 3 50 91 3+
Vestos V80Z.0 Z000 Z 50, c0 80 Z08
Vestos V903.0 Z00+

3 50, c0 90 Zc3
Vestos V11Z3.0 Z011 3 50, c0 11Z ||ctct]ue

Based on piojects fully commissioned thiough yeai-end 2010.

The BARD Offshoie 1 pioject will have 80 tuibines, and installation began in Maich 2010.

In eaily 2007, Vestas tempoiaiily withdiew its V90-3.0 model fiom the offshoie wind maiket
aftei 72 of a total of 96 V90-3.0 tuibines then opeiating offshoie (United Kingdom and the
Netheilands) developed majoi geaibox pioblems. They weie coiiected, and the model was
offeied foi sale again in May 2008.
SOURCE: Adapted fiom NYSERDA 2010; supplemented with data fiom Musial and Ram 2010,
Section 2, 10-22.
installation, and opeiation foi offshoie wind facilities. Peifoimance and
safety could vaiy among states if each is iequiied to develop its own iegu-
latoiy piocesses. The state piojects will also piovide the fist U.S. expeii-
ence with the iegulatoiy piocesses put in place by the Buieau of Ocean
Eneigy Management, Regulation, and Enfoicement (see Box 1-1). The
exception to this is the pioject pioposed by Cape Wind Associates, LLC.
The Cape Wind pioject is a 468-MW wind faim to be located 4.7 miles off
the coast of Massachusetts. The pioject has been gianted a site lease by the
fedeial goveinment but will still need to obtain appioval of the plans it
must submit in accoidance with the piocess laid out in Box 1-1.
Progress in Development of U.S. Offshore Wind Facilities
As of Novembei 2010, theie weie no offshoie wind powei facilities in the
United States, but it is piobable that constiuction activities foi offshoie
wind eneigy piojects will begin soon. In 2008, the U.S. Depaitment of
34 Structural lntegrity of 0ffshore Wind Turbines
Eneigy published a iepoit that suggested that 20 peicent of the nation`s
electiic powei could be pioduced by wind eneigy by 2030 undei ceitain
scenaiios that assumed °favoiable but iealistic" maiket conditions
(USDOE 2008). In that iepoit, the contiibution of offshoie wind was
found to be a necessaiy component to achieve 20 peicent electiicity fiom
wind eneigy. The scenaiio analyzed estimated that 54,000 MW of capac-
ity would come fiom offshoie souices.
Seveial piojects that have advanced signifcantly in the U.S. peimit-
ting piocess to date aie shown in Figuie 2-11. As the map indicates, most
of the activity is in the Noitheast and Mid-Atlantic iegions, but offshoie
wind is being consideied in most iegions off the U.S. coast, including the
Gieat Lakes, the Gulf of Mexico, and even the West Coast. The West
Coast has much gieatei watei depths close to shoie, howevei, and this is
likely to constiain development in the neai teim despite a good wind
iesouice, because wind tuibine designs foi such deep wateis aie just
enteiing the piototype demonstiation phase (Moe, 2010; Pool 2010).
Pioposed U.S. offshoie wind piojects can be divided into two iegula-
toiy gioups: those in fedeial wateis (i.e., outside the 3-nautical mile state
boundaiy) and those undei state juiisdiction. State piojects aie typically
neai shoie and have maiginally lowei wind iesouices. In the long teim,
FIßü8E 2-11 Proposed U.S. offshore wind projects and capacity showing
projects with significant progress. (SOURCE: Musial and Ram 2010.)
0íís|c|e wirJ Tec|rclc¸] orJ Stotus 
theie aie not enough viable sites in state wateis to achieve offshoie wind
deployment at a scale suffcient to make a laige impact on U.S. electiic
eneigy supply.

Abbrevíatíons
AWEA Ameiican Wind Eneigy Association
CEQ Council on Enviionmental Quality
EWEA Euiopean Wind Eneigy Association
IEC Inteinational Electiotechnical Commission
NYSERDA New Yoik State Eneigy Reseaich and Development Authoiity
OWE Offshoie Windeneigy Euiope
USDOE U.S. Depaitment of Eneigy
Alpha Ventus. 2010. http://www.alpha-ventus.de/index.php:id80. Accessed Jan. 8, 2010.
AWEA. 2010. End of Yeai Repoit on Installed Capacity. http://www.awea.oig/newsioom/
ieleases/01-26-10_AWEA_Q4_and_Yeai-End_Repoit_Release.html. Accessed Oct. 28,
2010.
AWS Tiuewind. 2010. NY´s Cffshcre \ind Energy Develcpment Pctential in the Great Iakes.
New Yoik State Eneigy Reseaich and Development Authoiity, Jan. http://www.awstiue
wind.com/fles/NYSERDA-AWST-NYGieatLakesFS-Jan2010.pdf.
Blue H USA. 2009. Blue H Piepaies foi Authoiization of the Woild`s Fiist Deepwatei
Wind Faim. Piess ielease, Maich 12. http://www.bluehusa.com/piessielease10.aspx.
Accessed Jan. 8, 2010.
Butteifeld, C. P., W. D. Musial, J. Jonkman, P. Sclavounos, and L. Wyman. 2005. Engi-
neeiing Challenges foi Floating Offshoie Wind Tuibines. Prcc., Ccpenhagen Cffshcre
\ind, Oct.
C-Powei NV. 2010. http://www.c-powei.be/index_en.html. Accessed Jan. 8, 2010.
Centiica Eneigy. 2010. http://www.centiicaeneigy.com. Accessed Jan. 8, 2010.
CEQ. 2009a. The Inteiagency Ocean Policy Task Foice. http://www.whitehouse.gov/
administiation/eop/ceq/initiatives/oceans. Accessed Dec. 19, 2009.
CEQ. 2009b. Interim Framewcrk fcr Effective Ccastal and Marine Spatial Planning. Intei-
agency Ocean Policy Task Foice, Washington, D.C.
CEQ. 2009c. Interim Repcrt cf the Interagency Ccean Pclicy Task Fcrce. Inteiagency Ocean
Policy Task Foice, Washington, D.C.
Daily, M. 2008. Texas Plans Fiist US Offshoie Wind Faim. Reuteis, Oct. 25.
 Structural lntegrity of 0ffshore Wind Turbines
Dolan, D., A. Jha, T. Gui, S. Soyoz, C. Alpdogan, and T. Camp. 2009. Ccmparative Study
cf Cffshcre \ind Turbine Standards. Maich.
DONG Eneigy. 2010a. Hoins Rev Offshoie Wind Faim. http://www.hoinsiev.dk/
Engelsk/default_ie.htm. Accessed Jan. 8, 2010.
DONG Eneigy. 2010b. Moving Eneigy Foiwaid. http://www.dongeneigy.com/en/Pages/
index.aspx. Accessed July 31, 2010.
E.ON UK. 2009. Robin Rigg. Sept. http://www.eon-uk.com/geneiation/iobiniigg.aspx.
Accessed Jan. 8, 2010.
EWEA. 2009a. Cffshcre Statistics }anuary 2009. http://www.ewea.oig/fleadmin/ewea_
documents/documents/statistics/Offshoie_Wind_Faims_2008.pdf. Accessed Jan. 8,
2010.
EWEA. 2009b. \ind Energy. The Facts. London. www.wind-eneigy-the-facts.oig/en/
pait-i-technology/chaptei-5-offshoie/wind-faim-design-offshoie/offshoie-suppoit-
stiuctuies.html.
EWEA. 2010. http://www.ewea.oig. Accessed Apiil 2010.
4C Offshoie, Ltd. 2010. Hoins Rev 2. http://www.4coffshoie.com/windfaims/wind
faims.aspx:windfaimIdDK10. Accessed Jan. 8, 2010.
Fugio-Seacoie. 2011. Website desciibing monopile installation techniques foi off-
shoie wind faims. http://www.seacoie.com/piojects/BockstigenWindfaimInstallation.
Accessed Feb. 7, 2011.
Gaiden State Wind. 2010. Garden State Cffshcre Energy Prcject Page. http://www.gaiden
statewind.com/pdf/factsheet.pdf. Accessed Jan. 28, 2010.
Gieen, J., A. Bowen, L. J. Fingeish, and Y. Wan. 2007. Electiical Collection and Tiansmis-
sion Systems foi Offshoie Wind Powei. Prcceedings cf the 2007 Cffshcre Technclcgy
Ccnference, Houston, Tex.
IEC. 2005. \ind Turbines-Part 1. Design Requirements. IEC 61400-1 Ed. 3. Geneva.
Japan foi Sustainability. 2004. Japan`s Fiist Offshoie Wind Tuibines on Tiial Run.
http://www.japanfs.oig/en/pages/025486.html. Accessed Jan. 8, 2010.
Ministiy of Foieign Affaiis of Denmaik. 2009. Two Massive Wind Tuibines Swing into
Action foi COP15. Piess ielease, Nov. 27. http://www.investindk.com/visNyhed.
asp:aitikelID23048. Accessed Jan. 8, 2010.
Moe, V.I. 2010. Floating Tuibine Captuies Wind Eneigy in Deep-Watei Enviionment.
\elding }curnal, May 2010, pp. 55-58. http://fles.aws.oig/wj/2010/05/wj052010/
wj052010-54.pdf. Accessed Feb. 16, 2011.
Musial, W., and B. Ram. 2010. Iarge-Scale Cffshcre \ind Pcwer in the United States. Assess-
ment cf Cppcrtunities and Barriers. Repoit TP-500-40745. National Renewable Eneigy
Laboiatoiy, Golden, Colo.
NooidzeeWind. 2010. http://www.nooidzeewind.nl/. Accessed Jan. 8, 2010.
0íís|c|e wirJ Tec|rclc¸] orJ Stotus 
NYSERDA. 2010. New Ycrk´s Cffshcre \ind Energy Develcpment Pctential in the Great
Iakes. Feasibility Study. Repoit 10-04. Apiil, ievised Sept.
Offshoie Centei Denmaik. 2010. http://www.offshoiecentei.dk/offshoiewindfaims_
detail.asp:id33928&tBohai%20Suizhong/. Accessed Jan. 8, 2010.
OWE. 2008. www.offshoiewindeneigy.oig/. Accessed Jan. 8, 2010.
Pool, R. 2010. Deep Watei Wind Tuibines. Engineering o Technclcgy Magazine, Vol. 5,
No. 16. http://eandt.theiet.oig/magazine/2010/16/deep-watei-tuibines.cfm. Accessed
Feb. 16, 2011.
Piinses Amalia Windpaik. 2010. http://www.q7wind.nl/en/index.asp. Accessed Aug. 15,
2010.
Puskai, F., and R. Sheppaid. 2009. Inspection Methodologies foi Offshoie Wind Tuibine
Facilities. Eneigo Engineeiing, Inc., Houston, Tex., Jan. 30. http://www.boemie.
gov/taipiojects/627/MMSWindTuibineInspectionsFinal.pdf.
ieNews. 2009. Cffshcre Special Repcrt 2009. Nov. 19.
RWE npowei ienewables. 2009. RWE Innogy Opens Biggest Offshoie Wind Faim in
Wales. Piess ielease, Dec. 2. http://www.iwe.com/web/cms/mediablob/en/354764/
data/250908/55448/iwe-npowei-ienewables/Rhly-Flats-inauguiation-piess-ielease.pdf.
Accessed Jan. 8, 2010.
Schwaitz, M., D. Heimillei, S. Haymes, and W. Musial. 2010. Assessment cf Cffshcre \ind
Energy Rescurces fcr the United States. Technical Repoit NREL/TP-500-45889.
National Renewable Eneigy Laboiatoiy, Golden, Colo., June.
Sokolic, W. 2008. Fisheiy Gioup Bids foi Wind Faim. Ccurier-Pcst, Oct 3. http://www.fshei
menseneigy.com/images/news/Couiiei-Post-Fisheiy-gioup-bids-wind-faim.pdf.
Statoil. 2010a. Hywind: Putting Wind Powei to the Test. http://www.statoil.com/en/
TechnologyInnovation/NewEneigy/RenewablePoweiPioduction/Onshoie/Pages/
Kaimoy.aspx. Accessed Jan. 8, 2010.
Statoil. 2010b. Offshoie Wind Piojects. http://www.statoil.com/en/technologyinnovation/
neweneigy/ienewablepoweipioduction/offshoie/Pages/default.aspx. Accessed July
31, 2010.
USDOE. 2008. 20 Percent \ind Energy by 2030. Increasing \ind Energy´s Ccntributicn tc
U.S. Electricity Supply. DOE/GO-102008-2567. July. http://www.20peicentwind.oig/
20peicent_wind_eneigy_iepoit_ievOct08.pdf.
Vindpaik Vänein. 2010. Renewable Eneigy in Väimland. http://www.vindpaikvanein.
se/ (in Swedish). Accessed Jan. 8, 2010.
Williams, W. 2008. Peispective: Can Cape Wind Be Financed: Gatehouse News Seivice,
Maich 7.
\ired Magazine. 2007. Inheiit the Wind. Feb. http://www.wiied.com/wiied/aichive/
15.02/wind.html. Accessed Feb. 16, 2011.

Standards and Practices
This chaptei addiesses Task I of the committee`s chaige-°Standaids and
Piactices" (see Box 1-2). It piovides backgiound on and a summaiy of the
applicable iegulations, standaids, iecommended piactices, and guidelines
that have been used in the offshoie wind industiy, and it desciibes the state
of matuiity of each of these documents. The teims °iegulations," °stan-
daids," and °guidelines" aie discussed in Box 3-1.
In its ieview of standaids and piactices, this chaptei discusses technical
teims ielated to iisk assessment, stiength analysis, and othei aieas. Def-
nitions of these teims can be found in the glossaiy, and some aie discussed
fuithei in Appendix A.
INTERACTIONS BETWEEN NONSTRUCTURAL FAILURES
AND WIND TURBINE STRUCTURAL INTEGRITY
Although the committee`s chaige is limited to stiuctuial integiity (see
Chaptei 1), malfunction oi failuie of nonstiuctuial components and
systems duiing opeiation can iesult in stiuctuial oveiload oi failuie.
This inteiaction is dealt with thiough the defnition of °design load cases"
(DLCs) in standaids and guidelines. Such cases specify the combination of
loads that a facility must be designed to iesist oi withstand. Although the
committee has not ieviewed the DLCs in detail, it notes that DLCs noi-
mally include the stiuctuial loads placed on the tuibine as a iesult of fail-
uie oi malfunction of ancillaiy systems such as contiol systems, piotection
systems, and the inteinal and exteinal electiical netwoiks. In such DLCs,
failuies in ancillaiy systems aie noimally postulated as occuiiing undei
unfavoiable wind and wave conditions. Foi example, in Inteinational
Electiotechnical Commission (IEC) 61400-3, DLC 2.3 involves both an

StorJo|Js orJ ||octices 

Regulations, Standards, and Guidelines
The use of vaiious teims to desciibe technical guidance is com-
mon among engineeiing disciplines. Some teims have specifc and
geneially accepted defnitions, and otheis aie less piecise. The fol-
lowing desciibes the teims used thioughout this document and
the class of documents to which they iefei, with some backgiound
on how these documents aie typically developed.
Regulations. Regulations aie sets of iequiiements piomul-
gated by goveinment authoiities. Although they may be intei-
national and implemented by way of tieaties (foi example,
Inteinational Maiitime Oiganization iegulations applicable to
inteinational shipping), iegulations aie geneially established
at the national and state levels. Rules and iegulations devel-
oped by the vaiious U.S. fedeial agencies aie codified in the
Code of Fedeial Regulations.
Standards. Astandaid is a document that has been developed in
accoidance with a piotocol. Diveise inteiests aie iepiesented,
theie is a piocess foi iesolving opposing opinions, and the fnal
veision is adopted by a consensus vote of the constituencies
involved. Examples of oiganizations that follow a iecognized
standaids development piocess aie the Inteinational Oiganiza-
tion foi Standaidization, the Inteinational Electiotechnical Com-
mission (IEC), the Ameiican National Standaids Institute, the
Ameiican Wind Eneigy Association, and the Ameiican Petio-
leum Institute (API). Standaids may be inteinational, national,
oi industiy-specifc in scope, and the teim °standaid" may not be
piesent in the title. In this iepoit, °standaid" iefeis to any docu-
ment developed accoiding to a iecognized piocess and subject to
a vote of constituencies to establish a consensus befoie becoming
(ccntinued cn next page)
 Structural lntegrity of 0ffshore Wind Turbines
extieme opeiating wind gust and loss of the electiical netwoik. Othei
examples iequiie consideiation of yaw misalignment that might iesult
fiom mechanical oi electiical failuie and consideiation of what emeigency
pioceduies might be needed to cope with stiuctuial damage caused by
nonstiuctuial tiiggeis such as oveispeeding, biake failuies, and lubiication
defects.
In sum, the standaids and guidelines that will likely be used in the
stiuctuial design of offshoie wind tuibines foi the United States and that
will infoim the woik of ceitified veiification agents (CVAs) considei
how nonstiuctuial components can tiiggei stiuctuial failuies in offshoie
wind tuibines.
ß0X 3-1 (ccntinued)
Regulations, Standards, and Guidelines
fnal. Examples of standaids iefeiied to in this iepoit aie IEC
61400-3 and API RP 2A.
Guidelines. A guideline is a document that has been developed
by a gioup oi a company and that is not subject to a foimal pio-
tocol oi a vote of constituencies. These documents aie typically
vetted thiough an inteinal quality piocess and may be peei
ieviewed, but they aie ultimately the pioduct of the gioup oi
company, and no consensus is iequiied foi theii completion oi
use. In this iepoit, °guideline" iefeis to any document devel-
oped by a gioup oi company foi which no iecognized piotocol
oi consensus vote is necessaiy. Examples of guidelines iefeiied
to in this iepoit aie Guideline fcr the Certificaticn cf Cffshcre
\ind Turbines, developed by Geimanischei Lloyd; Design cf
Cffshcre \ind Turbine Structures, developed by Det Noiske
Veiitas; and Guide fcr Building and Classing Cffshcre \ind Tur-
bine Installaticns, developed by the Ameiican Buieau of Ship-
ping (ABS 2010).
StorJo|Js orJ ||octices 
INTERNATIONAL ELECTROTECHNICAL COMMISSION
Background on Land-Based Wind Turbines:
Historical Perspective
Duiing the eaily 1990s, the wind eneigy industiy-thiough IEC-began
to establish inteinational standaids foi land-based wind tuibines. Theie
weie at least two motivations foi establishing inteinational standaids:
 The existing Euiopean design standaids (e.g., in Denmaik, Geimany,
and the Netheilands) weie insuffcient in that they did not iesult in
ieliable peifoimance ovei the 20-yeai design life of the tuibines. Many
wind tuibines expeiienced bieakdowns in majoi components, such as
geaiboxes and blades, aftei less than 10 yeais of opeiation, leading to
excessive downtimes.
 The industiy wanted to make suie that all wind tuibines complied with
the same standaid so that piice competition could take place on a uni-
foim basis (excluding substandaid wind tuibine designs).
The United States saw the IEC standaids activities of the 1990s as a way
to piovide a faii and unifed appioach to the emeiging woild wind eneigy
maiket and has paiticipated in the development of the IEC standaids since
theii inception. Technical Committee 88 (TC 88) was established to
develop and manage a suite of applicable standaids foi wind tuibines.
Description of Relevant Standards
The piimaiy standaid foi wind tuibine stiuctuial design iequiiements
is IEC 61400-1 Ed. 3 (IEC 2005). This standaid defnes design classes,
exteinal (enviionmental) conditions foi each design class, DLCs, fault con-
ditions that must be included in the design, pioceduies foi assessing static
and dynamic loads, electiical iequiiements, and methods foi assessing the
site-specifc suitability of the tuibine. Peihaps the most impoitant pait of
the standaid is a detailed defnition of the tuibulent wind enviionment.
Because undeistanding the minute chaiacteiistics of wind is so impoitant
in assessing unsteady aeiodynamic load distiibutions along the iotating
blades, it is ciucial that this pait of the exteinal conditions be defned in a
mannei consistent with the analytical theoiy used foi iotoi load estimation.
 Structural lntegrity of 0ffshore Wind Turbines
In 2000, TC 88 began to develop an offshoie wind tuibine standaid,
Design Requirements fcr Cffshcre \ind Turbines, IEC 61400-3 (IEC 2010a).
It was intended to addiess iequiiements foi offshoie wind tuibines that
weie not pieviously coveied. The standaid defeis to IEC 61400-1 foi the
wind tuibine aspects of the design iequiiements and ielies on existing
matuie standaids foi setting geneial suppoit stiuctuie iequiiements. The
IEC offshoie committee suiveyed stiuctuial standaids and guidelines
foi offshoie oil and gas stiuctuies, including those developed by the
Ameiican Petioleum Institute (API), the Inteinational Oiganization foi
Standaidization (ISO), Det Noiske Veiitas (DNV), and Geimanischei
Lloyd (GL), and attempted to use them as the basis foi the new IEC
61400-3 iequiiements. A Euiopean-funded pioject, °Requiiements foi
Offshoie Wind Tuibines" (RECOFF), included foimal compaiisons of
these vaiious standaids and assessed theii suitability foi wind tuibine
design. The RECOFF study concluded that, foi the vast majoiity of sup-
poit stiuctuie iequiiements, standaids such as those of API and ISO
could be used. Howevei, the ciucial defciency was the mannei in which
dynamic loads weie estimated. Offshoie wind tuibines aie subject to wind
and wave stochastic loadings that aie neaily equal in impoitance with
iespect to dynamic excitation of the wind tuibine. IEC 61400-3 is the
only inteinational standaid that specifcally addiesses these issues. It is
less matuie (less fully developed) than othei inteinational standaids
and guidelines foi land-based wind tuibines, but it is based on eailiei
standaids and theiefoie iepiesents an integiated veision of all the woik
that has pieceded it. Because it is pait of a seiies of inteinational stan-
daids that addiess the bioadei wind industiy`s needs, such as veiifca-
tion testing foi peifoimance, stiuctuial design compliance, powei
quality, geaibox design iequiiements, and small tuibines, it is the best
available standaid foi addiessing the issues of stiuctuial design foi off-
shoie wind tuibines.
The IEC ceitifcation standaid foi type and pioject ceitifcation is IEC
61400-22, \ind Turbines-Part 22. Ccnfcrmity Testing and Certifcaticn
(IEC 2010b). This standaid defnes iequiiements foi both type ceitifcation
and pioject ceitifcation. The IEC 61400-22 ceitifcation standaid is a fui-
thei development of the pievious ceitifcation standaid, IEC WT 01 (IEC
2001), in paiticulai with iegaid to iequiiements foi pioject ceitifcation.
StorJo|Js orJ ||octices 43
Turbine Type Certincation Process
Theie aie few legal iequiiements foi stiuctuial design in land-based U.S.
wind eneigy installations, and no single agency has full iesponsibility. The
stiuctuies must meet local and state building codes, and the electiical sys-
tems must meet electiical standaids. These codes and standaids aie inad-
equate foi defning wind tuibine design iequiiements, and theie is no
oveiaiching peimitting piocess that addiesses stiuctuial design. How-
evei, this appioach does not appeai to have impeded the industiy oi
become a detiiment to public safety. Instead of ielying on statutoiy
iegulations, the piocess is commeicially diiven. Owneis and opeiatois
choose to iequiie type-ceitifed wind tuibines foi theii piojects. The type
ceitifcation piocess is outlined in Figuie 3-1.
The tuibines aie usually ceitifed to IEC oi othei Euiopean standaids.
Recognizing that the offshoie ceitifcation piocess is unique, TC 88 has
begun to diaft a second edition of its wind tuibine ceitifcation piocess,
IEC 61400-22 (IEC 2010b). The new edition will iely on IEC 61400-3 foi
offshoie technical iequiiements while defning the ceitifcation piocess.
Both IEC 61400-3 and WT 01 Ed. 2 assume that the tuibine will be ceiti-
fed to a set of design classes specifed in IEC 61400-1 Ed. 3, wheieas the
suppoit stiuctuie is designed to site-specifc conditions. The IEC standaids
development piocess assumes that multiple paities will be iesponsible foi
diffeient aspects of the pioject and offeis guidance foi each phase of the
pioject. It allows foi the use of othei standaids foi the suppoit stiuc-
tuie, such as API RP 2A-LRFD-S1 (API 1997), DNV guidelines, and GL
Design
Evaluation
Type Testing Manufacturing
Evaluation
(Optional)
Foundation
Design Evaluation
(Optional)
Characteristic
Measurement
Final Evaluation
Report
Type Certificate
FIßü8E 3-1 Type certincation process under IEC 61400-22.
44 Structural lntegrity of 0ffshore Wind Turbines
Windeneigie Gioup specifcations (though the lattei two guidelines aie
heavily inßuenced by the API offshoie standaids foi theii offshoie suppoit
stiuctuie guidance). Howevei, some of the specifcations of API RP 2A aie
not adequate foi the design of offshoie tuibines, foi which dynamic time-
dependent behavioi must be deteimined as accuiately as possible by using,
foi example, modein time-domain analysis methods.
Foundation designs aie integiated into the type ceitifcation foi some
tuibines. Wheie this is the case, the foundation design must be evaluated
foi the exteinal conditions foi which it is intended. Pooi geotechnical inves-
tigation and foundation design have led to delays and cost oveiiuns at
Euiopean wind faims (Geides et al. 2006).
Project Certincation
Technical design iequiiements (IEC 61400-3) typically aie sepaiated
fiom ceitifcation pioceduies (IEC 61400-22). The lattei standaid defnes
the ceitifcation piocess and ielies on technical standaids such as IEC
61400-3 to specify the design iequiiements. The oveiall ceitifcation qual-
ity system needed to implement the full piocess fiom design thiough
manufactuiing, installation, continuous monitoiing, and decommission-
ing iequiies management pioceduies. Pioject ceitifcation is coveied
undei IEC 61400-22 (see Figuie 3-2). Accoiding to this standaid, the pui-
Design Basis
Site
Assessment
Site-Specific Site
Assessment
Manufacturing
Surveillance
Transport /
Ìnstallation /
Commissioning
Surveillance
Periodic
Monitoring
Project
Certificate
Type
Certificate
FIßü8E 3-2 Project certincation process under IEC 61400-22.
StorJo|Js orJ ||octices 
pose of pioject ceitifcation is to deteimine whethei type-ceitifed wind
tuibines and theii integiated foundation designs confoim to the extei-
nal conditions, applicable constiuction and electiical codes, and othei
iequiiements of a specifc site. Undei this piocess, the exteinal physical
enviionmental conditions, giid system conditions, and soil piopeities
unique to the site aie evaluated to deteimine whethei they meet the
iequiiements defned in the design documentation foi the wind tuibine
type and foundations.
Wind tuibines and theii suppoit stiuctuies aie mass pioduced, as
opposed to the customized design appioach typically applied foi offshoie
oil and gas installations. Final peimitting of wind powei plants iesults in
the installation of many tuibines of the same design type (hence the teim
°type ceitifcation" foi a tuibine that meets a geneiic design class, iathei
than site-specifc enviionmental conditions). Although it is likely that the
same design has opeiated in othei sites, a new installation must integiate
the enviionmental and physical conditions of the site into the engineeiing
evaluation of suitability foi the site. IEC iecognizes that offshoie tuibines
will be designed and tested long befoie most piojects aie even conceived.
Thus, the IEC standaids iequiie and give guidance foi evaluating the suit-
ability of a type-ceitifed tuibine foi specifc site conditions.
API STANDARDS
Background on Oil and Gas Facilities: Historical Perspective
API standaids weie developed with a focus on offshoie facilities foi oil
and gas and include, among othei items, wind-wave-cuiient models,
analysis appioach, and stiuctuial and foundation design paiameteis. API
RP 2A is the piimaiy standaid used by the offshoie oil and gas industiy
foi the stiuctuial design of fxed offshoie stiuctuies, which aie the most
similai to tiaditional offshoie wind stiuctuies, but API has additional
standaids foi offshoie ßoating stiuctuies, including API RP 2T, API RP
2FPS, and API RP 2SK. These standaids iepiesent moie than 60 yeais of
design expeiience. Although they weie piimaiily developed to addiess the
offshoie oil industiy in the Gulf of Mexico, the API seiies has become
a compiehensive set of standaids that is used inteinationally. In sup-
poit of the iecommended piactices, additional documents such as 2MET
 Structural lntegrity of 0ffshore Wind Turbines
(Oceanogiaphic and Meteoiological) and 2GEO (Geotechnical) have
been developed to addiess conditions applicable to both fxed and ßoat-
ing stiuctuies.
API has been engaged with ISO in developing an ISO seiies of offshoie
standaids using many of the API standaids as theii base documents. Moie
than 80 peicent of the ISO 19900 seiies has been published. API has
iestiuctuied about 50 peicent of its offshoie seiies to match the ISO stiuc-
tuie and incoipoiate the ISO standaids. This integiation piovides foi
a single inteinational set of offshoie standaids with U.S.-specifc ciiteiia
attached to the univeisal coie technical iequiiements.
Description of Relevant Standards
The API Seiies 2 standaids aie compiehensive and covei all aspects of off-
shoie design: planning iequiiements, installation iequiiements, fxed and
ßoating platfoim stiuctuial iequiiements, opeiations thioughout the life
of the system, and decommissioning iequiiements. Foi stiuctuial design,
API RP 2A-WSD, the commonly applied standaid foi fxed offshoie plat-
foims, uses an elastic component design methodology piesciibing load
development pioceduies, stiuctuial design methods, extieme load condi-
tions, mateiial and component safety factois, and the chaiactei and ietuin
peiiods foi design-level extieme events foi both sea states and wind
conditions. The standaid focuses mainly on sea states iathei than wind
because that is the piimaiy souice of platfoim loads (usually about 70 pei-
cent of the total load on a fxed platfoim). Detailed wind conditions aie
fiequently chaiacteiized on the basis of a quasi-static load defnition,
which is geneially suffcient foi a statically iesponding facility. Foi dynam-
ically sensitive facilities, wind loading is usually developed by using an
offshoie-specifc wind spectium model.
IEC AND API DIFFERENCES
Standaids such as IEC 61400-3 and API RP 2A have some oveilapping
design iequiiements foi wave and cuiient loading conditions. Howevei,
a diiect compaiison of the IEC and API standaids indicates diffeiences
that should be assessed in any effoit to use these standaids togethei foi
StorJo|Js orJ ||octices 
the U.S. offshoie wind industiy. The following aie examples of diffeiences
between the IEC and API standaids:
 IEC uses a 50-yeai ietuin peiiod foi the defnition of extieme envi-
ionmental design conditions, while API RP 2A uses a 100-yeai ietuin
peiiod foi the defnition of design conditions foi high-consequence
platfoims.
 The piobability of exceedance of load levels (oi, equivalently, the ietuin
peiiod of the wind-wave-cuiient loading), foi example at a 50- oi
100-yeai ietuin level, constitutes only one element deteimining the fail-
uie piobability, oi the piobability of acceptable peifoimance, of a facil-
ity. Equally impoitant aie the inheient safety factois accounting foi
knowledge unceitainties (due to incomplete oi otheiwise limited infoi-
mation conceining a phenomenon) and mateiial factois, load combi-
nation iequiiements, paiameteis inheient in inteiaction equations, and
so on. These aspects aie often disiegaided in iisk discussions but can
affect failuie piobabilities moie than could a factoi of two oi thiee in
the ietuin peiiod of the loading. Theiefoie, a caieful assessment is
needed to deteimine the oveiall failuie piobability in eithei oi both of
the standaids.
 The defnitions of DLCs aie diffeient. IEC iequiies the stiuctuie to be
veiifed foi noimal and abnoimal conditions togethei with specifc
load cases in close association with the wind tuibine`s opeiational sta-
tus. API iequiies the stiuctuie to be veiifed foi opeiational conditions,
noimally a 1-yeai stoim, and extieme conditions, which aie defned
piimaiily by using enviionmental conditions.
 API RP 2A piesciibes thiee levels of design based on consequence.
These levels aie chaiacteiized by decieasing loads foi decieasing con-
sequence. In contiast, IEC keeps the load level constant while adjust-
ing component safety factois on the basis of the consequence of that
component failing.
 API RP 2A piovides a basis foi the design of offshoie stiuctuies sub-
ject to wave, wind, cuiient, and eaithquake loading conditions in
addition to loads fiom diilling, pioduction, and ongoing peisonnel
activities. API RP 2A does not addiess the scope and iange of all con-
ditions ielating to the design of wind tuibine suppoit stiuctuies such
 Structural lntegrity of 0ffshore Wind Turbines
as blade-wind-towei inteiaction and piesence oi absence of yaw con-
tiol. Similaily, IEC 61400-3 lacks some of the detailed piovisions given
by API RP 2A with iespect to ceitain offshoie engineeiing piactices.
It is impoitant foi the industiy to develop a full undeistanding of the
diffeiences in the iequiiements and oveiall peifoimance levels inheient in
these codes. This compaiison should seek to claiify the ielative levels of
stiuctuial ieliability inheient within each code when applied to a wind tui-
bine pioject at a specifc location and to evaluate the similaiities and dif-
feiences in the consequences of failuie (eithei loss of function oi collapse
of the stiuctuie) foi the types of facilities.
One fnal issue is that ßoating platfoims foi wind tuibines aie explicitly
not coveied by IEC 61400-3. Reseaich will be necessaiy to defne all issues
that may affect the design of such a stiuctuie. Such issues aie likely to
include hydiostatic and hydiodynamic stability, coupled aeiodynamic
loading fiom the iotoi and wave loading, station keeping, and electiical
distiibution system connections foi a highly compliant suppoit stiuctuie.
ISO STANDARDS
As desciibed pieviously, the ISO 19900 seiies of standaids addiesses off-
shoie platfoims foi the oil and gas industiies. These standaids weie based
on existing API standaids foi fxed steel and ßoating stiuctuies and on a
Noiwegian standaid, the leading offshoie conciete standaid. The ovei-
sight gioups (woik gioups undei ISO TC 67/SC 7) foi these ISO standaids
aie establishing an ongoing updating and maintenance piocess now that
the fist veision of the standaids has been published. To meet industiy
needs while the Euiopean Union standaids iequiiements weie developed,
the load and iesistance factoi design (LRFD) veision of API RP 2A was
adopted as an inteiim ISO standaid. An inteinational committee stiuctuie
with consideiable U.S. and API leadeiship and engagement developed the
second veision of the Fixed Steel Platfoim standaid (ISO 19902), as well
as a suite of accompanying geneial offshoie standaids: ISO 19903 (Fixed
Conciete Stiuctuies), ISO 19904 (Floating Systems), ISO 19905 (Jackups),
and ISO 19908 (Aictic Stiuctuies). A full desciiption of the ISO and API
woik piogiams is given by Wisch et al. (2010). This ISO seiies haimonizes
inteinational piactices into a single, integiated suite of standaids. The ISO
StorJo|Js orJ ||octices 
standaids facilitate inteinational tiade by enabling pioduction companies
to design to a single set of codes, iathei than attempting to satisfy multiple
national codes. A single standaid also decieases the likelihood of design
eiiois often intioduced when designeis use unfamiliai codes foi piojects
in diffeient iegions.
CLASSIFICATION SOCIETY GUIDELINES
1
Piovided in this section is an oveiview of the guidelines foi offshoie wind
tuibines offeied by independent classifcation societies. It should be
noted that no set of guidelines evaluated duiing this study and desciibed
below can stand alone as a guideline foi offshoie wind tuibines, espe-
cially with iespect to site-specifc enviionmental conditions pievalent in
U.S. wateis. As examples, only the Ameiican Buieau of Shipping (ABS)
guidelines addiess tiopical stoims, none of the guidelines addiesses the
ice loading that may be a contiolling factoi in the Gieat Lakes iegion, and
none addiesses the seismic loading pievalent offshoie the West Coast
and Alaska. Finally, all depend on othei iefeiences to addiess some spe-
cifc design paiameteis, such as the IEC standaids foi tuibine load cases.
DET NORSKE VERITAS
DNV is a leading contiibutoi to ieseaich on offshoie oil and gas design
iequiiements, plays a leading iole in development of standaids foi off-
shoie wind, and piovides ceitifcation seivices woildwide. DNV woiked
with RISO Danish National Laboiatoiy ieseaicheis to develop national
standaids foi wind tuibines. DNV also customized these national stan-
daids to suit its own inteinal piactices, and it has been a key paiticipant
in developing the IEC standaids. Although the IEC standaids do not
ießect DNV guidelines completely, theie aie signifcant similaiities. The
majoi diffeiences aie the lack of piesciiptive mateiial, welding, and com-
ponent specifcations in the IEC standaid ielative to DNV.
1
This text is modifed compaied with the veision of the iepoit ieleased Apiil 28, 2011, to moie
cleaily convey the completeness of coveiage of offshoie wind tuibine standaids and guidelines
piepaied by classifcation societies and to coiiect eiiois in the dates and numbeis of two DNV
standaids cited in the text.
 Structural lntegrity of 0ffshore Wind Turbines
The fist DNV offshoie wind guideline, Design cf Cffshcre \ind Turbine
Structures (DNV-OS-J101), was issued in June 2004. The most iecent
veision was issued in Octobei 2010 (DNV 2010a). It coveis suppoit
stiuctuies and foundations foi offshoie wind tuibines and meteoiolog-
ical toweis; the foundations guideline diaws heavily upon API-RP-2A.
DNV-OS-J101 coveis some elements of ßoating offshoie wind tuibines.
Common iequiiements between oil and gas ßoating stiuctuies and wind
tuibine ßoating stiuctuies aie coveied in othei DNV standaids. The next
guideline issued was DNV-DS-J102 (oiiginally in 2006; the latest veision
was issued in 2010), which coveis blades (DNV 2010b). The DNV-OS-J201
guideline, issued in 2009, coveis design and ceitifcation of the offshoie
tiansfoimei station (electiic seivice platfoim) (DNV 2009). Design and
ceitifcation iequiiements aie combined in the DNV documents.
GERMANISCHER LLOYD
GL was an eaily leadei in developing guidelines foi wind tuibine design.
Its success has giown out of the populaiity of wind eneigy in Geimany
and the countiy`s iequiiement of Geiman engineeiing appioval. These
factois gave GL exclusive ceitifcation authoiity on all Geiman installa-
tions, a monopoly that still exists. GL`s Guideline fcr the Certifcaticn cf
Cffshcre \ind Turbines, 2nd edition, 2005, also called the GL Bluebook,
is peihaps the fist to be widely used (GL 2005). The GL Bluebook cov-
eis all stiuctuies, systems, and components foi offshoie wind tuibines
and theii suppoit stiuctuies and foundations. Howevei, it does not covei
offshoie electiic seivice platfoims, noi does it specifcally covei ßoating
suppoit stiuctuies foi offshoie wind tuibines. The GL Bluebook is highly
piesciiptive, and as such it is viewed by some in the industiy as inßexi-
ble and iestiictive in its applications. As with the DNV guidelines, design
and ceitifcation iequiiements aie combined.
GL has iemained active in inteinational standaids development and
Euiopean wind eneigy ieseaich. A majoi contiibutoi to the IEC standaids,
GL continues to update its Bluebook to ießect the IEC standaids while
ietaining iequiiements needed to comply with Geimany`s iegulations.
The Bluebook iemains the most compiehensive guideline on land-based
and offshoie wind tuibine iequiiements.
StorJo|Js orJ ||octices 
AMERICAN BUREAU OF SHIPPING
ABS has been at the foiefiont of developing guidelines foi the offshoie oil
and gas eneigy sectoi since the industiy`s foimative yeais, but it is a new-
comei to the offshoie wind feld. The ABS Guide fcr Building and Class-
ing Cffshcre \ind Turbine Installaticns (ABS 2010) was developed by
haimonizing ABS expeiience fiom offshoie oil and gas platfoims with the
guidelines piovided in the IEC 61400 seiies of documents. Requiiements
on the following subjects aie specifed in the guide foi the suppoit stiuc-
tuie of a bottom-founded offshoie wind tuibine:
 Classifcation, testing, and suivey;
 Mateiials and welding;
 Enviionmental conditions;
 Load case defnitions;
 Design of steel and conciete stiuctuies;
 Foundations; and
 Maiine opeiations.
Requiiements with iegaid to the suivey duiing constiuction and instal-
lation and the suivey aftei constiuction aie geneially in accoidance with
established ABS iules foi offshoie stiuctuies. Alteinative suivey schemes
aie also acceptable to account foi the uniqueness of offshoie wind tui-
bines, such as seiial fabiication and installation.
Design enviionmental conditions and DLCs iequiied by the ABS
guide aie geneially in agieement with those iequiied by IEC 61400-3
but have a numbei of amendments, mainly to account foi the effects
of tiopical huiiicanes in U.S. wateis. The piinciple of site-specific
design is addiessed in the definition of the DLCs in the guide. Envi-
ionmental conditions with a baseline ietuin peiiod of 100 yeais aie
iequiied to be consideied foi the extieme stoim conditions (DLCs 1.6,
6.1, and 6.2). Fuitheimoie, the omnidiiectional wind condition is
iequiied foi tuibines subject to tiopical huiiicanes, cyclones, and
typhoons (DLC 6.2).
The established ABS iules and guides foi offshoie stiuctuies, as well as
API RP 2A, have been discussed to piovide a technical basis foi the devel-
opment of suppoit stiuctuie and foundation design ciiteiia. The guide
specifies a set of design ciiteiia foi steel suppoit stiuctuies by using a
 Structural lntegrity of 0ffshore Wind Turbines
woiking stiess design appioach, which is still accepted as a common design
piactice in the United States. Allowable stiess levels aie defned foi vaiious
design conditions, including noimal, abnoimal, tianspoit, and installation
on site, as well as eaithquake and othei iaie conditions. Equivalent LRFD
ciiteiia aie also specifed as an acceptable alteinative.
The iequiiements foi electiic seivice platfoims aie addiessed in the
ABS Rules fcr Building and Classing Cffshcre Installaticns. This document,
the fist edition of which was published in 1983, is used in the veiifcation
of bottom-founded stiuctuies woildwide.
GERMAN STANDARDS AND PROJECT
CERTIFICATION SCHEME
The Fedeial Maiitime and Hydiogiaphic Agency (Bundesamt fui
Seeschifffahit und Hydiogiaphie, oi BSH) is the agency in Geimany that
decides on the appioval of offshoie wind faim development piojects in the
Noith Sea and the Baltic Sea. It caiiies out the application pioceduie foi
offshoie wind faims in the Geiman Exclusive Economic Zone, which is the
aiea outside the 12-nautical mile zone wheie most of the Geiman offshoie
wind faims will likely be installed.
Pait of the appioval pioceduie is to examine whethei all installations
and stiuctuial components have been ceitifed accoiding to the BSH
standaid Design cf Cffshcre \ind Turbines (BSH 2007), which was issued
in June 2007. This standaid coveis development, design, implementation,
opeiation, and decommissioning of offshoie wind faims within the scope
of the Maiine Facilities Oidinance and iegulates the vaiious stiuctuial
components of an offshoie wind faim. It iefeis to anothei BSH standaid,
Standard fcr Gectechnical Site and Rcute Surveys-Minimum Require-
ments fcr the Fcundaticn cf Cffshcre \ind Turbines, issued in August
2003. To develop these standaids, BSH established a steeiing committee
that included technical expeits in ielevant felds and iepiesentatives of
thiee classifcation and ceitifcation societies (SGS, DNV, and GL).
BSH iequiiements foi pioject ceitifcation aie set foith foi each of the
following phases:
Phase I. Development,
Phase II. Design,
StorJo|Js orJ ||octices 
Phase III. Implementation,
Phase IV. Opeiation, and
Phase V. Decommissioning.
The ceitifei oi iegisteied inspectoi company is to be selected fiom a
pieappioved list of BSH-pieappioved offshoie wind eneigy ceitifcation
companies. The list cuiiently consists of SGS, DNV, GL, and DEWI Off-
shoie. Companies can apply foi appioval as offshoie wind eneigy ceitif-
cation companies.
Foi a given pioject, one ceitifcation company could covei one phase
(e.g., design ceitifcation) and otheis could covei othei phases. Foi exam-
ple, a second company could covei implementation (manufactuiing,
tianspoit, and installation), and a thiid could covei opeiation.
BSH is the fnal appioval authoiity foi all fve phases. It ieviews the
design and ceitifcation documentation itself in deteimining whethei to
giant fnal appioval of a pioject phase. In the piocess, BSH is often sup-
poited by individual exteinal technical expeits with specifc knowledge of
that phase-foi example, a geotechnical expeit foi Phase I and a wind tui-
bine expeit foi Phase II.
ONGOING STANDARDS DEVELOPMENT AND RELATED
RESEARCH: NATIONAL AND INTERNATIONAL
American Wind Energy Association Development
of Offshore Recommended Practices
In Octobei 2009, the Ameiican Wind Eneigy Association (AWEA), in
conjunction with the National Renewable Eneigy Laboiatoiy, initiated an
effoit to develop a set of iecommended piactices foi assessing the local,
national, and inteinational standaids and guidelines that aie being used
foi all wind tuibines in the United States and to make iecommendations
on theii use and applicability. The effoit is aimed at thiee majoi aieas
wheie cuiient standaids (and ielated guidelines and othei such docu-
ments) aie ambiguous oi have signifcant gaps when applied in the United
States. One of these aieas is offshoie wind eneigy.
The offshoie wind eneigy gioup will addiess all aieas that aie iele-
vant to the Buieau of Ocean Eneigy Management, Regulation, and
 Structural lntegrity of 0ffshore Wind Turbines
Enfoicement (BOEMRE) pioject application and appioval piocess. These
aieas include stiuctuial ieliability; manufactuiing, qualifcation testing,
installation, and constiuction; safety of equipment; opeiation and inspec-
tion; and decommissioning.
The AWEA initiative has enlisted expeit stakeholdeis fiom the offshoie
industiy community to develop a consensus set of good piactices in the
use of standaids foi planning, designing, constiucting, and opeiating off-
shoie wind eneigy piojects in U.S. wateis. The gioup plans to piioiitize its
iecommendations by using inteinational standaids whenevei possible,
followed by national standaids, classifcation society standaids, and com-
meicial standaids and guidelines.
The AWEA iecommended piactices will apply to all bottom-fxed
stiuctuies installed on the outei continental shelf (OCS) oi in neai-shoie
locations (e.g., state wateis) but will not necessaiily be suffcient to ensuie
the stiuctuial integiity of ßoating offshoie wind tuibines.
The AWEA offshoie gioup was divided into thiee subgioups. Each of
the gioups is woiking independently, but all aie expected to delivei a fnal
guideline by the end of 2011. The thiee subgioups aie discussed below.
Grcup 1, Structural Reliability, is addiessing design issues ielating to
stiuctuial ieliability of offshoie wind tuibines. Because many wind
tuibines taigeted foi installation in the United States may have
alieady been designed and type-ceitifed to IEC design classes (see
Chaptei 3), one focus of the woik is establishing the appiopiiate
inteifaces between the existing IEC standaids and othei standaids
goveining the stiuctuial ieliability of the integiated tuibine system.
The gioup will iecommend standaids and piactices that piovide a
methodology foi establishing tuibines at specifc U.S. sites, taking
into account the unique metocean and subsuiface conditions.
Grcup 2, Fabricaticn, Ccnstructicn, Installaticn, and Qualifcaticn Test-
ing, is developing iecommended piactices foi the safe and oideily
deployment of offshoie wind tuibines duiing the constiuction and
installation phases. Any manufactuiing issues unique to offshoie
wind tuibines will be addiessed, as will issues ielating to the establish-
ment of adequate infiastiuctuie. IEC`s TC 88 is not addiessing much
of this phase of deployment, so this gioup will piobably not need to
mix and match existing standaids as will Gioup 1. Howevei, it will
StorJo|Js orJ ||octices 
have to identify applicable standaids fiom othei industiies and adapt
them to covei these activities. Qualifcation testing will be tieated as
an oveiaiching activity that may be applied to any pioject phase.
Grcup 3, Cperaticn, Maintenance, and Deccmmissicning, is developing
iecommended piactices foi opeiation and inspection. The iecom-
mendations aie not likely to include extensive tuibine component
inspection; ownei-investoi wind faim maintenance systems aie
geneially moie compiehensive than peiiodic inspections that could
be caiiied out by BOEMRE oi othei fedeial agencies, and the con-
sequences of failuie in a secondaiy component aie geneially limited
to economic iisk to the wind faim itself. Howevei, in-seivice stiuc-
tuial inspection of the towei and the substiuctuie oi below the
wateiline will be necessaiy ovei the feld seivice life. Conseivatively,
the design life of the substiuctuie is 20 yeais, but designs could allow
iepoweiing scenaiios wheie foundations could be ieused. In any
case, foundation and substiuctuie design should considei iemoval
and disposition of the system when it is no longei seiviceable.
IEC Floating Wind Turbine Initiative
Theie is stiong inteiest woildwide in the development of new technol-
ogy foi deepei watei. Such technology may include floating suppoit
stiuctuies foi wind tuibines. Only one ßoating wind tuibine has been
deployed to date, by Statoil in Noiway in 2009, but technology develop-
ment is acceleiating, and peimits foi piototypes in U.S. wateis will soon
be sought (Maine Public Utilities Commission 2010). In May 2011, IEC
TC 88 appioved a pioject to develop an IEC technical specifcation foi
the design of floating wind tuibines. The foiecast publication date is
Januaiy 2013 (IEC 2011).
Bureau Veritas Guidance for Floating Offshore Wind Turbines
In Januaiy 2011, Buieau Veiitas issued guidelines foi the °Classifcation
and Ceitifcation of Floating Offshoie Wind Tuibines." The guidelines
specify the enviionmental conditions undei which ßoating offshoie
wind tuibines may seive, the piinciples of stiuctuial design, load cases
foi the platfoim and mooiing system, stability and stiuctuial division,
 Structural lntegrity of 0ffshore Wind Turbines
and design ciiteiia foi the top stiuctuie. The guidelines covei ßoating plat-
foims suppoiting single oi multiple tuibines with hoiizontal oi veitical
axes.
2
The committee was not able to ieview these guidelines foi this iepoit.
BOEMRE Research Program
Undei its Technology Assessment and Reseaich (TA&R) Piogiam,
3
BOEMRE caiiies out ieseaich in suppoit of opeiational safety and pol-
lution pievention on the OCS. The ienewable eneigy element of the pio-
giam has sponsoied woik on offshoie wind inspection methodologies,
compaiisons of offshoie wind standaids, expeiience with offshoie wind
accidents, CVAs, and othei topics. Foi example, BOEMRE held a woik-
shop in Octobei 2010 that ieviewed the expected activities of CVAs.
4
It
iecently awaided a pioject to ABS coveiing design standaids foi offshoie
wind faims. The pioject focuses on goveining load cases and load effects
foi offshoie wind tuibines subject to ievolving stoims on the U.S. OCS
and on calculation methods foi bieaking wave slamming loads inßicted
on offshoie wind tuibine suppoit stiuctuies.
AREAS OF LIMITED EXPERIENCE
AND MAJOR DEFICIENCIES IN STANDARDS
Geneially, standaids embody the collective expeiience of an industiy,
but they tend to lag the knowledge base because of the time needed foi
the consensus-diiven standaids development piocess to incoipoiate the
lessons leained. The standaids foi offshoie wind aie still immatuie, and
seveial shoitcomings aie expected when the fist piojects aie installed in
U.S. wateis. Thiid-paity assessments (e.g., by CVAs) can oveicome the
shoitcomings by ielying on good engineeiing judgment to deteimine
adequate safety. Examples of defciencies in offshoie wind standaids that
weie identifed duiing this study aie desciibed below.
 Type-ceitifed wind tuibine designs may not meet the extieme wind
gust ciiteiia foi some high-intensity huiiicanes in the United States.
2
Buieau Veiitas piess ielease, Jan. 12, 2011.
3
Infoimation on piojects caiiied out undei the TA&R piogiam foi ienewable eneigy can be found
on the BOEMRE website at http://www.boemie.gov/taipiojectcategoiies/RenewableEneigy.htm.
4
http://www.boemie.gov/taipiojects/633/af.pdf.
StorJo|Js orJ ||octices 
Although tuibines should always be type-ceitifed to the expected site
wind conditions (undei Class S in IEC 61400-1 and 61400-3), the cui-
ient standaid does not specifcally addiess huiiicanes in the estimation
of peak wind and wave heights, duiation of sustained high winds, oi
extieme diiectional wind changes. In addition, IEC 61400-3 DLC 6.2
allows dependence on yaw system backup powei foi 6 houis, which
may not be suffcient to ensuie safe huiiicane iide-thiough.
 Monopile substiuctuies foi wind tuibines exceed the diameteis and
expeiience base of the oil and gas industiy. Extiapolating cuiient piac-
tice to the laigei sizes can intioduce unintended effects. Monopiles up
to 5 m in diametei aie in use today. In 2010, hundieds of offshoie wind
tuibine installations weie discoveied to have excessive tilt due to fail-
uie of the giouting connection at the towei tiansition piece. This iaises
issues conceining veitical tilt toleiances and tiansition piece giouting
piactices in the cuiient standaids.
 The behavioi and possible degiadation of soil stiength undei combined
dynamic loading fiom the wind tuibine and waves aie not well desciibed
in the cuiient standaids. Moieovei, the empiiical cyclic degiadation
methods specifed aie not appiopiiate. ¦A iecent papei (Andeisen 2009)
piovides a good desciiption of cyclic degiadation of clays undei shallow
foundations.]
 Offshoie wind tuibines in the Gieat Lakes will encountei fieshwatei ice,
which may induce fiist-oidei loading fiom numeious new DLCs.
Reseaich and specifcation development foi ice loading in the Gieat
Lakes aie needed, because the loads cannot be estimated fiom piioi
wind eneigy expeiience in the Baltic Sea.
 Extieme wave loads may iesult fiom bieaking waves at some shallow-
watei sites. The magnitude of the loading will depend on the type of sub-
stiuctuie used and in some instances could be a contiolling factoi in
design. Standaids iequiie analysis of this condition to estimate () the
wave chaiacteiistics and () the tuibine iesponse to the waves, foi which
models have not yet been validated foi some substiuctuie types.
 Giavity-based substiuctuies aie used fiequently but aie moie pooily
documented in the standaids than aie steel substiuctuies, which aie
moie commonly used by the offshoie oil and gas industiy. Howevei,
design of shallow-watei, steel substiuctuies foi oil and gas stiuctuies
 Structural lntegrity of 0ffshore Wind Turbines
is mainly conceined with pieventing plastic collapse, while design of
offshoie wind tuibines is moie conceined with pieventing failuie due
to iesonance and fatigue.
 Offshoie wind tuibines aie expected to inciease in size fiom about
3 MW pei tuibine today to possibly 10 MW ovei the next decade. The
scaling up of tuibine size may intioduce effects not anticipated oi cov-
eied by any of the cuiient standaids.
 Signifcant expeiience has been gained since the cuiient IEC offshoie
wind standaids weie wiitten. The expeiience has impioved the knowl-
edge base with iespect to design iequiiements foi tuibine suppoit stiuc-
tuies and has led to iefnements in design methodologies. Much of this
expeiience has not yet been incoipoiated into the standaids. Moieovei,
the causes of iecent technical failuies in foundations and giouted con-
nections and the design iequiiements to avoid such failuies aie still
being analyzed, so they aie likewise not ießected in cuiient standaids.
 Floating wind tuibine systems aie not addiessed adequately in any of
the cuiient standaids. IEC is consideiing a pioposal to wiite a techni-
cal specifcation on ßoating wind tuibine systems (IEC 2010a). (Buieau
Veiitas has just ieleased guidelines foi the °Classifcation and Ceitifca-
tion of Floating Offshoie Wind Tuibines," but the committee was not
able to ieview them foi this pioject.)
FINDINGS FOR TASK I: CHAPTER 3
Findings foi Chaptei 3 appeai below. They addiess Task I of the statement
of task. Chaptei 4 also addiesses Task I. A full set of iecommendations foi
Task I appeais at the end of Chaptei 4.
1. Regulations in most countiies-notably in continental Euiope-take a
piesciiptive appioach, iegulating in detail the design, constiuction, and
opeiation of offshoie wind tuibines to achieve acceptable levels of
safety, enviionmental peifoimance, and ieliability.
2. The staiting points foi most of the offshoie wind eneigy iegulations and
guidelines (foi example, those of DNV, GL, ABS, BSH, AWEA, and
the Danish Eneigy Agency) aie IEC 61400-1 (\ind Turbines-Part 1.
Design Requirements) and IEC 61400-3 (\ind Turbines-Part 3. Design
Requirements fcr Cffshcre \ind Turbines). The IEC standaids do not
StorJo|Js orJ ||octices 
covei all aspects of the design and constiuction of offshoie wind
tuibines.
3. Nongoveinmental oiganizations and piivate companies that establish
and maintain technical iules and guidelines foi the design, con-
stiuction, and opeiation of ships and offshoie stiuctuies-commonly
known as classifcation societies-have developed guidelines. The most
compiehensive industiy guidelines foi offshoie wind tuibine design,
fabiication, installation, and commissioning have been developed by
classifcation societies such as DNV, GL, and ABS. These standaids aie
moie compiehensive than aie the IEC standaids in the sense that they
covei both the load and iesistance sides, wheieas the IEC standaids
covei explicitly only the load side. Howevei, theie aie still defciencies
that must be oveicome. Foi instance, the Euiopean society guidelines
do not explicitly addiess enviionmental site conditions foi the United
States (e.g., stoims and huiiicane conditions foi the Gulf of Mexico and
the East Coast). Only the GL iules deal with the design and ceitifcation
of wind tuibine mechanical and electiical components (e.g., the geai-
box, the geneiatoi, and the contiol systems).
4. Methodologies foi stiength analysis diffei among the vaiious standaids
and guidelines and aie not always fully delineated. Some standaids aie
based on stiength oi limit states design, while otheis aie based on allow-
able stiess design. The philosophies undeilying these methods aie fun-
damentally diffeient, making it diffcult to compaie such standaids
against one anothei to ensuie consistent safety levels, especially when
the standaids aie applied to novel concepts. There is a need for a clear,
transparent, and auditable set of assumptions for strength analyses.
5. As discussed in Chaptei 1, although iegulations (MMS 2009) pio-
mulgated by the U.S. Depaitment of Inteiioi`s BOEMRE iequiie that
detailed iepoits foi design, constiuction, and opeiation of offshoie
wind tuibines be submitted foi BOEMRE appioval, they do not spec-
ify standaids that an offshoie wind tuibine must meet. Rathei, a thiid
paity (CVA) is chaiged with ieviewing and commenting on the ade-
quacy of design, fabiication, and installation and submitting iepoits to
BOEMRE indicating the CVA`s assessment of adequacy. Moieovei,
when a geneial level of peifoimance such as °safe" is identifed, no guid-
ance is piovided on how to assess whethei this level of peifoimance has
 Structural lntegrity of 0ffshore Wind Turbines
been met. Hence, the BOEMRE regulations and accompanying guid-
ance lack the clarity and specincity needed for the development of off-
shore wind energy on the OCS.
6. As discussed in Chaptei 2, states and piivate companies aie developing
plans foi offshoie wind eneigy piojects in state wateis and on the OCS.
Well-defned U.S. iegulations foi development on the OCS aie needed
(a) to piovide a iesouice foi states as they develop iequiiements foi
piojects in state wateis and (b) to supply industiy with suffcient claiity
and ceitainty on how piojects will be evaluated as companies seek the
necessaiy fnancing. Fuithei delays in developing an adequate national
iegulatoiy fiamewoik aie likely to impede development of offshoie
wind facilities in U.S. wateis. Moieovei, developments in state wateis
could pioceed in the absence of fedeial iegulations, possibly leading to
inconsistent safety and peifoimance acioss piojects. The United States
urgently needs a set of clear and specinc standards and regulatory
expectations to avoid these negative outcomes, facilitate the orderly
development of offshore wind energy, and support the stable eco-
nomic development of a nascent industry.
REFERENCES
Abbrevíatíons
ABS Ameiican Buieau of Shipping
API Ameiican Petioleum Institute
AWEA Ameiican Wind Eneigy Association
BSH Bundesamt fui Seeschifffahit und Hydiogiaphie
DNV Det Noiske Veiitas
GL Geimanischei Lloyd
IEC Inteinational Electiotechnical Commission
MMS Mineials Management Seivice
ABS. 2010. Guide fcr Building and Classing Cffshcre \ind Turbine Installaticns. Houston,
Tex.
Andeisen, K. H. 2009. Beaiing Capacity Undei Cyclic Loading-Offshoie, Along the
Coast, and on Land. Canadian Gectechnical }curnal, Vol. 46, No. 5, pp. 513-535.
API. 1997. Supplement 1. Reccmmended Practice fcr Planning, Designing and Ccnstructing
Fixed Cffshcre Platfcrms. Icad and Resistance Factcr Design. API RP 2A-LRFD-S1.
Washington, D.C., Feb. 1.
StorJo|Js orJ ||octices 
BSH. 2007. Design cf Cffshcre \ind Turbines.
DNV. 2009. Cffshcre Substaticns fcr \ind Farms, DNV-OS-J201. Hovik, Oslo, Octobei.
DNV. 2010a. Design cf Cffshcre \ind Turbine Structures, DNV-OS-J101. Hovik, Oslo,
Octobei.
DNV. 2010b. Design and Manufacture cf \ind Turbine Blades, Cffshcre and Cnshcre \ind
Turbines, DNV-DS-J102. Hovik, Oslo, Novembei.
Geides, G., A. Tiedemann, and S. Zeelenbeig. 2006. Case Study: Euiopean Offshoie Wind
Faims-A Suivey foi the Analysis of the Expeiiences and Lessons Leaint by Develop-
eis of Offshoie Wind Faims, Final Repoit. Piepaied by Deutsche WindGuaid,
Deutsche Eneigie-Agentui GmbH (dena), and the Univeisity of Gioningen. http://
www.offshoie-powei.net/Files/Dok/casestudy-euiopeanoffshoiewindfaims.pdf.
GL. 2005. Guidelines fcr the Certifcaticn cf Cffshcre \ind Turbines, 2nd ed.
IEC. 2001. IEC System fcr Ccnfcrmity Testing and Certifcaticn cf \ind Turbines-Rules
and Prccedures. IEC WT 01 Ed. 1. Geneva.
IEC. 2005. \ind Turbines-Part 1. Design Requirements. IEC 61400-1 Ed. 3. Geneva.
IEC. 2010a. \ind Turbines-Part 3. Design Requirements fcr Cffshcre \ind Turbines. IEC
61400-3 Ed. 1. Committee Diaft 88/257/CD. Geneva.
IEC. 2010b. \ind Turbines-Part 22. Ccnfcrmity Testing and Certifcaticn. IEC 61400-22
Ed. 1. Geneva.
IEC. 2011. Woik piogiam foi IEC TC 88 pioject IEC/TS 61400-3-2, Wind Tuibines-
Pait 3-2: Design Requiiements foi Floating Offshoie Wind Tuibines. http://www.
iec.ch/dyn/www/f:p·103:38:0::::FSP_ORG_ID,FSP_APEX_PAGE,FSP_LANG_ID,
FSP_PROJECT:1282,23,25/txt/3kyo11.pdf,IEC/TS%2061400-3-2%20ED.%201.0.
Maine Public Utilities Commission. 2010. Request foi Pioposals foi Long-Teim Contiacts
foi Deep-Watei Offshoie Wind Eneigy Pilot Piojects and Tidal Eneigy Demonstiation
Piojects. http://www.maine.gov/mpuc/electiicity/ifps/standaid_offei/deepwatei2010/.
Accessed Dec. 11, 2010.
MMS. 2009. Renewable Eneigy and Alteinate Uses of Existing Facilities on the Outei Con-
tinental Shelf. Federal Register, Vol. 74, pp. 19638-19871. http://www.mms.gov/
offshoie/RenewableEneigy/PDF/FinalRenewableEneigyRule.pdf.
Wisch, D. J., A. Mangiavacchi, P. O`Connoi, and W. R. Wolfiam. 2010. Stiategy and Stiuc-
tuie of the API 2 Seiies Standaids, 2010 and Beyond. OTC 30831. Piesented at Offshoie
Technology Confeience, Houston, Tex., May.

A Risk-Informed Approach to
Performance Assurance
Task I of the committee`s chaige, °Standaids and Piactices" (see Box 1-2),
calls foi the committee to ieview the applicability and adequacy of exist-
ing standaids and piactices foi the design, fabiication, and installation of
offshoie wind tuibines. Chaptei 3 ieviewed some of the most impoitant
standaids that aie in use and desciibed some of those that aie undei devel-
opment. It also identifed some of the defciencies that would have to be
iemedied and the analyses that would have to be done befoie these stan-
daids and piactices could be used in the United States.
As discussed in Chaptei 1, the committee believed that, to iespond
fully to this task, it had to do moie than simply ieview existing stan-
daids and guidance and point to wheie the deficiencies lie. Othei
studies have identified at least some of these deficiencies, and the com-
mittee has diawn on these studies in developing Chaptei 3 of this
iepoit. But the committee`s view was that, to piovide the Buieau of
Ocean Eneigy Management, Regulation, and Enfoicement (BOEMRE)
with useful feedback, the committee should offei its peispectives on
how BOEMRE might iemedy the deficiencies. The best way to do this,
it believed, was to step back and ieview the undeilying philosophies
that could guide the development of additional standaids, iegulations,
oi othei guidance documents foi offshoie wind tuibines in the United
States.
In applying this bioadei peispective, the committee ieviewed the
appioaches to oveisight of offshoie wind tuibines taken by Euiopean
countiies. The committee also ieviewed how the safety of engineeied
stiuctuies is oveiseen in othei U.S. industiies-oil and gas pioduction,
wateiboine shipping, and buildings-and especially how iegulation and
othei foims of oveisight in these industiies have evolved.

/ Ris|lríc|aeJ /uu|coc| tc |e|íc|aorce /ssu|orce 
This chaptei begins with a biief ieview of the iisks to human safety and
the enviionment posed by stiuctuial failuies in offshoie wind tuibines. It
compaies these iisks with those associated with othei offshoie industiies
and with land-based eneigy industiy infiastiuctuie. It then consideis how
iegulation in these aieas has evolved away fiom a detailed, piesciiptive
model and towaid a moie peifoimance-based model, and what this sug-
gests about appioaches to oveiseeing wind eneigy development on the
U.S. outei continental shelf (OCS).
RISKS TO HUMAN LIFE AND THE ENVIRONMENT POSED
BY STRUCTURAL FAILURE OF OFFSHORE FACILITIES
Goveinment iegulation of offshoie facilities, such as oil and gas stiuctuies
and maiine vessels, and of land-based infiastiuctuie, such as buildings and
biidges, focuses on mitigating iisk to human life and the enviionment.
Othei iisks, such as those of diiect economic losses fiom stiuctuial dam-
age and of indiiect losses due to inteiiuption of function, foigone oppoi-
tunities, and loss of amenity, aie geneially not addiessed in goveinment
iegulations, although they may be of concein to individuals, pioject opei-
atois, insuieis, and othei stakeholdei gioups.
Risk to Human Life and Safety
Risk to human life fiom the stiuctuial failuie of offshoie wind installa-
tions is limited compaied with iisks fiom othei offshoie facilities, such as
oil and gas platfoims and maiine vessels. Offshoie wind toweis aie noi-
mally unmanned, so they pose limited iisk to human life. The most dan-
geious element in the opeiation of an offshoie wind faim is the tiansfei
of peisonnel to the tuibines foi installation, inspection, and maintenance.
Because the tuibines can only be accessed by boat oi helicoptei, the abil-
ity to ieach the tuibines is highly dependent on the sea state. Peisonnel
may fnd themselves stianded on a tuibine stiuctuie if waves inciease in
magnitude while maintenance is being conducted. With the exception
of wind tuibine installations in iegions of high seismic activity, how-
evei, it is not anticipated that humans would be on any tuibine stiuc-
tuie thioughout the duiation of an extieme exteinal condition such as
a poweiful stoim.
 Structural lntegrity of 0ffshore Wind Turbines
The tiansmission platfoim, howevei, might house peisonnel foi
indefinite peiiods of time, and this fact must be taken into account in
designing foi human safety in extieme conditions. The need foi peison-
nel to be stationed on a centialized tiansmission platfoim will inciease as
faims move faithei offshoie and the logistics of peisonnel tiansfei to
shoie become moie difficult. Designs must also addiess the potential
need foi stationing peisonnel on tiansmission platfoims duiing inclement
weathei.
Risk to the Environment
As stated in Chaptei 1, the scope of this iepoit is limited to oveisight of
stiuctuial integiity as it is affected by tuibine design, fabiication, and
installation. As shown in Figuie 1-1, the enviionmental hazaids associated
with the establishment and opeiation of offshoie wind eneigy facilities
aie coveied thiough the National Enviionmental Policy Act (NEPA)
piocess. These hazaids include effects on biids, othei wildlife, and the
seabed. An enviionmental assessment oi enviionmental impact state-
ment, as iequiied by NEPA, will be peifoimed foi each pioposed offshoie
pioject (as was done foi the Cape Wind pioject).
The most significant iisk to the enviionment emanating fiom
stiuctuial failuie of an offshoie wind tuibine oi tiansmission platfoim
involves the ielease of tiansmission fluid oi othei hydiocaibon-based
liquids fiom the wind faim stiuctuies oi fiom the installation and sei-
vice vessels that would be navigating thiough an offshoie wind paik.
Piopei design and constiuction of the tuibine and tiansmission plat-
foim should pieclude all but minoi damage due to collision with a
seivice vessel that is moving slowly. Howevei, if the vessel suffeied
suffcient damage, it could leak its fuel into the ocean. In the event of a
catastiophic failuie of a stiuctuie oi vessel, the woist-case scenaiio
would involve dischaige into the ocean of the following amounts of
hydiocaibon-based ßuids:
 Wind tuibine (5 MW), appioximately 150 gallons (Cape Wind n.d.);
 Tiansmission platfoim, appioximately 40,000 gallons (Cape Wind
n.d.); and
 Installation and seivice vessels, up to 500,000 gallons (see Box 4-1).
/ Ris|lríc|aeJ /uu|coc| tc |e|íc|aorce /ssu|orce 
Foi iefeience, the amount of oil estimated to have been ieleased into
the ocean duiing the Exxon Valdez oil spill was 10.8 million gallons (Exxon
Valdez Oil Spill Tiustee Council n.d.).
Comparison with Offshore and Land-Based Fossil
Fuel Facilities
Table 4-1 piesents the committee`s judgment, based on its expeiience
acioss industiies, of the ielative iisks of offshoie wind facilities, offshoie
oil and gas facilities, land-based fossil fuel extiaction facilities, and lique-
fed natuial gas teiminals. The table indicates the level of iisk to human life
and the enviionment undei noimal opeiating conditions. It also shows
the iisk levels undei °design conditions," which aie the conditions that
the facility is designed to iesist oi withstand. As shown, the iisks to human
safety and the enviionment associated with stiuctuial failuie of offshoie

Offshore Wind Installation and Service Vessels
Installation of the foundations (diiving monopiles oi setting
jackets) will likely be caiiied out with baiges and tugs. A iecently
deliveied deiiick baige has a fuel capacity of 300,000 gallons pio-
tected by innei bottom and wing tanks. Each tug typically has an
aggiegate fuel and lubiicating oil capacity of 5,000 gallons.
Tianspoitation and installation of tuibine components may
be accomplished by using () a specially designed self-piopelled
vessel oi () a combination of baiges and baige cianes. As an
example of the fist case, a tuibine component installei design
offeied by Keppel Amfels caiiies 500,000 gallons of diesel fuel. In
the second case, the baige and ciane baige desciibed foi founda-
tion installation could be used, with the fuel capacities given
above. If a lift vessel is used, fuel capacity would likely not exceed
50,000 gallons.
êê Structural lntegrity of 0ffshore Wind Turbines
wind tuibines aie geneially lowei than foi stiuctuial failuie in the fossil
eneigy industiies.
REGULATORY OPTIONS AND POLICY CONSIDERATIONS
Because the enviionmental and life safety iisks of offshoie wind facilities
aie ielatively low, the foim and extent of goveinment iegulation comes
into question. If theie aie smallei safety and enviionmental iisks associ-
ated with stiuctuial failuie of an offshoie wind faim, then a natuial ques-
tion to ask is whethei the fnancial and insuiance iisk assumed by the
developei is suffcient foi iegulating the industiy. Oi, to put it anothei
way, aie theie ieasons foi oveiseeing the peifoimance of offshoie wind
stiuctuies beyond mitigating these low iisks:
Policy Considerations
In 2010 the United States made signifcant stiides in the offshoie wind
iulemaking piocess, and seveial piojects pioposed off the East Coast aie
IAßLE 4-1 Comparison of Risks with Traditional Offshore and Iand-Based
Energy Industries: Safety and the Environment
LeveI oI 8isk
Liguid LiIe 8aIety. LiIe 8aIety.
hydrocarboo NoræaI ßesigo
Eoergy Iodustry 8eIease üperatioos 6ooditioos
0il orJ ¸os-s|elí M | M
0il orJ ¸os-"í|crtie|' | M |
|orJ ícssil ,ccol orJ rotu|ol ¸os}, Teros V| | M
|orJ ícssil ,ccol orJ rotu|ol ¸os}, V| | M
Ccc| Ccurt], lllircis
|orJ wirJ íocilit] V| V| |
0íís|c|e wirJ

-"tcwe|' | V| |
0íís|c|e wirJ

-cert|ol ulotíc|a | |, M

M
0íís|c|e liçueíeJ rotu|ol ¸os te|airol V| | |
|orJ liçueíeJ rotu|ol ¸os te|airol V| | |
NOTE: VL  veiy low, L  low, M  modeiate, H  high. Coding ciiteiia include life safety,
piotection of the enviionment, and economic thiesholds.

Tuibines and tuibine suppoit.

Cential facilities.

L if evacuated piioi to design condition; M if manned.
/ Ris|lríc|aeJ /uu|coc| tc |e|íc|aorce /ssu|orce 
piogiessing thiough theii development phases. Cuiiently, ienewable
eneigy development is laigely diiven by individual state policies and
ienewable poitfolio standaids. Howevei, seveial examples, highlighted
below, indicate that fedeial policy will piomote ienewable eneigy on a
national level and that offshoie wind is an essential component of this
policy. National secuiity, eneigy independence, and economic beneft aie
cited by goveinment offcials as justifcation foi piomoting offshoie wind
development.
Creating an Cffshcre \ind Industry in the United States. A Strategic \crk
Plan fcr the United States Department cf Energy was piepaied by the U.S.
Depaitment of Eneigy (USDOE) Offce of Eneigy Effciency and Renew-
able Eneigy`s Wind and Watei Powei Piogiam to outline the actions that
it will puisue in suppoiting the development of a woild-class offshoie
wind industiy in the United States. The Strategic \crk Plan is an action
document that amplifes and diaws conclusions fiom a companion
iepoit, Iarge-Scale Cffshcre \ind Pcwer in the United States (Musial and
Ram 2010).
Ajoint initiative between USDOE and the U.S. Depaitment of the Inte-
iioi (USDOI) titled °Smait fiom the Stait" was announced in Novembei
2010, with a goal of speeding appiopiiate commeicial-scale wind eneigy
development (USDOI 2010). A fact sheet issued on this effoit by USDOI
states:
Atop piioiity of this Administiation is developing ienewable domestic eneigy
iesouices to stiengthen the nation`s secuiity, geneiate new jobs foi Ameiican
woikeis and ieduce caibon emissions. A majoi component of that stiategy is
to fully hainess the economic and eneigy benefts of oui nation`s vast wind
potential, including Outei Continental Shelf Atlantic winds, by implementing
a smaitei peimitting piocess that is effcient, thoiough, and unbuidened by
unnecessaiy ied tape. (USDOI n.d.)
In Febiuaiy 2011, USDOE and USDOI unveiled the °joint National Off-
shoie Wind Stiategy: Cieating an Offshoie Wind Industiy in the United
States, the fist-evei inteiagency plan on offshoie wind eneigy" (USDOE
2011). As a pait of this initiative, seveial high-piioiity offshoie wind
iegions weie identifed to °spui iapid, iesponsible development of wind
eneigy." In addition, USDOE announced a ieseaich and development
piogiam at this time to °develop bieakthiough offshoie wind eneigy
 Structural lntegrity of 0ffshore Wind Turbines
technology and to ieduce specifc maiket baiiieis to its deployment"
(USDOE 2011).
SEEKING THE RIGHT REGULATORY BALANCE
The fedeial goveinment has embiaced offshoie wind eneigy as an integial
component of its oveiaiching policy of developing clean, ienewable eneigy
souices. Thus, the goveinment has a fundamental inteiest not only in the
safety and enviionmental peifoimance of offshoie wind faims but also in
theii ieliability and cost-effectiveness. At the same time, the iisks of stiuc-
tuial failuie to human safety and the enviionment aie low.
The committee`s view thus is that minimal iegulation will allow maiket
foices to guide offshoie wind eneigy to an effcient solution. Such an
appioach has policy iisk, since lack of a iegulatoiy fiamewoik could lead
to eaily pioject failuies that negatively affect public peiception and
jeopaidize futuie offshoie wind development. Othei countiies have had
this expeiience, with seiial component failuies leading to iepeicussions
acioss the global offshoie wind industiy. Foi example, in Euiope the
Hoins Rev 1 (see Box 4-2) failuies and similai pioblems encounteied by
othei offshoie wind faim piojects led to the intioduction of site-specifc
pioject ceitifcation and an expanded scope foi veiifcation that extended
beyond the geneiic type ceitifcation scheme. As discussed latei in this
iepoit, it is impoitant that a feedback mechanism be established to ensuie
that lessons leained aie incoipoiated into the iegulatoiy iequiiements,
standaids, and iecommended piactices.
The committee iecommends that U.S. iegulation be suffcient to ensuie
a consistent minimum standaid foi the design and constiuction of off-
shoie wind tuibines to mitigate the iisk of catastiophic failuie, such as the
failuie of a single tuibine oi of multiple tuibines that iendeis iepaii and
iecoveiy extiemely diffcult oi impossible.
REGULATORY EVOLUTION IN THE OIL AND GAS,
MARINE, AND CIVIL INFRASTRUCTURE INDUSTRIES
As noted in Chaptei 3, standaids, guidelines, and iegulation of offshoie
wind tuibines in Euiope aie piimaiily piesciiptive in natuie.
/ Ris|lríc|aeJ /uu|coc| tc |e|íc|aorce /ssu|orce 
Regulatoiy oveisight in othei U.S. industiies began with such a pie-
sciiptive appioach but, in some aieas, has been evolving towaid a moie
°peifoimance-based" appioach (see Box 4-3). The following discussion
illustiates this evolution by ieviewing iegulatoiy developments in the oil
and gas industiy, the maiine shipping industiy, and the civil infiastiuc-
tuie industiy. It then tuins to options foi addiessing the defciencies of
existing standaids and iegulations when applied to oveisight of the U.S.
offshoie wind industiy.
Oil and Gas Industry
As discussed in Histcry cf the Cil and Gas Industry in Scuthern Icuisiana
(MMS 2004), the fist oil and gas stiuctuie, built in 1937, was a massive
wooden platfoim constiucted in about 15 feet of watei in the Cieole feld

Horns Rev 1
One of the fist laige offshoie wind faims, the 80-wind tuibine,
160-MW Hoins Rev 1 facility located off the coast of Denmaik,
was built in 2002. Eaily in the facility`s opeiating life the tuibines
expeiienced numeious failuies, including each of the 80 wind tui-
bine tiansfoimeis, geneiatois, toique aims on geaiboxes, light-
ning ieceptois on blades, and foundation coatings. All 80 nacelles
weie taken ashoie foi modifcation. The failuies likely set back
development of the offshoie wind industiy thioughout Euiope as
industiy and iegulatois evaluated technical iisk and ieliability
issues. Subsequently, widespiead failuies in the giouting connec-
tion between the foundation and the inteimediate suppoit stiuc-
tuies have occuiied at Gunßeet Sands wind faims and at the
Danish Hoins Rev 2 facility (Wan 2010). If such systemwide fail-
uies aie not avoided, they will negatively affect the development
of offshoie wind iesouices as they eiode the confdence of both
potential investois and the public.
 Structural lntegrity of 0ffshore Wind Turbines
in the Gulf of Mexico (GOM). This was at a time when theie weie no
data on the iesponse of fiame stiuctuies to huiiicane foices. Land-based
steel design codes, piincipally the Ameiican Institute of Steel Constiuc-
tion (AISC) Manual cf Steel Ccnstructicn, weie the standaids most
closely aligned with offshoie design and constiuction mateiials. Offshoie
developments piogiessed ovei ioughly 20 yeais in the GOM undei a
vaiiety of opeiatoi-specifc design appioaches and ciiteiia. Design con-
ditions (conditions that the stiuctuie must be designed to withstand)
weie specifed piobabilistically, wheie the piobability of an event occui-
iing is expiessed in teims of the peicentage chance that it will occui in
any given yeai.
The most common design condition was a 25-yeai ietuin peiiod,
though othei opeiatois used ietuin peiiods of up to 100 yeais accoiding
to theii appetite foi iisk (MMS 2004). Data to develop the design ciiteiia
weie collected on an ad hoc basis with limited coopeiation between opei-
atois (MMS 2004).
ß0X 1-3
Performance-Based Standards and Innovation
As geneially undeistood, a peifoimance-based standaid specifes
the outcome iequiied but allows each iegulated entity to decide
how to meet it. Peifoimance standaids give fims ßexibility and
make it possible foi them to seek the lowest-cost means to achieve
the stated level of peifoimance (Coglianese et al. 2003).
By focusing on outcomes, peifoimance-based standaids accom-
modate technological change and innovation, which can be key
to loweiing costs. To the extent that they ieduce the costs of
powei geneiated by using offshoie wind, they inciease the abil-
ity of this souice to compete with othei souices of electiicity.
See Box 4-4 on the Inteinational Maiitime Oiganization`s goal-
based standaids foi an example.
/ Ris|lríc|aeJ /uu|coc| tc |e|íc|aorce /ssu|orce 
By the eaily 1960s, theie weie seveial hundied platfoims in the GOM.
No majoi stoims affected aieas with laige numbeis of offshoie stiuctuies
until the mid-1960s. The fist signifcant platfoim failuies undei stoim
conditions came in 1964, when Huiiicane Hilda destioyed 13 platfoims
and damaged fve otheis beyond iepaii (MMS 2004). The following yeai,
Huiiicane Betsy destioyed eight platfoims (MMS 2004). The stoims
emphasized the need foi developing moie consistent design appioaches
and foi gatheiing bettei data on wind speeds, wave heights, and soil chai-
acteiistics foi use in the design piocess. Huiiicane Camille in 1969 was
anothei damaging stoim, with measuied waves fai highei than those pie-
dicted by the use of existing data (MMS 2004; Beiek 2010).
In 1966, the Ameiican Petioleum Institute (API) cieated the Commit-
tee on Standaidization of Offshoie Stiuctuies (Beiman et al. 1990), and
the Ocean Data Gatheiing Piogiam was set up in 1968 (Waid 1974). These
steps weie among the fist by the industiy as a whole to standaidize the
design of offshoie platfoim stiuctuies in the GOM, and they led to the fist
API design standaid foi fxed jacket stiuctuies, Recommended Piactice 2A
(RP 2A), in 1969 (Beiek 2010). This standaid did not specify a design
ietuin peiiod foi stoim conditions. A design wave with a 100-yeai
ietuin peiiod was fist specifed in the 7th edition of API RP 2A in 1976
(Beiek 2010). The 9th edition of RP 2A (which included, among othei
impiovements, moie iobust joint design guidance) was issued in 1978,
and platfoims designed to this oi latei editions aie consideied by the
industiy to be °modein." The supeiioiity of such platfoims was demon-
stiated in the afteimath of Huiiicane Andiew in 1992, when 75 stiuctuies
weie destioyed, the majoiity of which weie oldei platfoims designed
with 25-yeai ietuin peiiods and lowei decks (Beiek 2010; Eneigo
Engineeiing 2010).
Though stoims and theii damage weie not the only diiveis foi changes
to design guides and industiy piactice, they have had a signifcant effect.
Figuie 4-1 shows a timeline of GOM oil and gas development fiom its
beginnings to the piesent along with signifcant stoims and subsequent
standaids developments and changes, as well as changes in industiy piac-
tice and iegulations (Puskai et al. 2006). The stoims of the late 1960s led
diiectly to the establishment of the RP 2A standaid and its subsequent
impiovement thiough the 1970s. Huiiicane Andiew led diiectly to the
12 Structural lntegrity of 0ffshore Wind Turbines
development of ievised load calculations iepiesented in the 20th edition
of RP 2A as well as the development of guidance on ieassessment of exist-
ing stiuctuies (Beiek 2010; Puskai et al. 2006). The magnitude of destiuc-
tion biought about by Huiiicanes Ivan, Katiina, Rita, and Ike in the
mid- and late 2000s has led to a ieassessment of the defnition of the design
waves foi GOM stiuctuies. The GOM has been divided into foui iegions,
each with its own design ciiteiia, and the use of oldei stoim data (i.e., pie-
1950 data) has been ievised in foimulating the statistics foi calculating
design waves (Beiek 2010; Puskai et al. 2006).
Just as industiy coopeiation and standaidization weie limited in the
eaily yeais of GOM development, the iegulatoiy enviionment was limited
and uncooidinated. As discussed in Chaptei 1, leasing was handled by
both state and fedeial authoiities (via USDOI thiough the Outei Conti-
nental Shelf Lands Act of 1953); the U.S. Aimy Coips of Engineeis had
some authoiity, especially as ielated to installations in navigable wateis;
and the U.S. Coast Guaid (USCG) was iesponsible foi safety (MMS 2004).
Setting foith and enfoicing design standaids weie not a focus of any of
these gioups. The Buieau of Land Management and the Conseivation
FIßü8E 4-1 Timeline of GOM development, industry standards, and
practices. (SOURCE: Puskai et al. 2006.)
/ Ris|lríc|aeJ /uu|coc| tc |e|íc|aorce /ssu|orce 
Division of the U.S. Geological Suivey (USGS) shaied leasing and iegula-
toiy functions foi USDOI until the foimation of the Mineials Management
Seivice (MMS) in 1982. MMS became BOEMRE in 2010. Its iegulatoiy iole
includes the handling of peimits and applications foi wells, platfoims, pio-
duction facilities, and pipelines; enviionmental and safety contiols; and
inspections (BOEMRE n.d.).
By the late 1970s, platfoims weie being installed in wateis neaiing
1,000 ft in depth in aieas subject to seaßooi instability, eaithquakes, and
ice and in aieas foi which little infoimation on the local offshoie enviion-
ment was available. Because of the incieasing complexity and peiceived
iisk in these aieas, in 1977 USDOI iequested the National Reseaich Coun-
cil to study the need foi thiid-paity oveisight. The study iesulted in the
development and implementation of the ceitifed veiifcation agent (CVA)
piogiam still in use foi the design, fabiication, and installation of offshoie
oil and gas facilities. The CVA iequiiements aie included in Appendix B
of this iepoit.
CVA oveisight is iequiied foi the moie complex offshoie stiuctuies
located in deepei watei. Assessment of compliance with the iules of a clas-
sifcation society is not mandatoiy. Some companies elect to obtain class
ceitifcation; otheis do not. Some insuieis offei ieduced iates if the vessel
oi stiuctuie is ceitifed by class.
API design standaids aie piimaiily expeiience-based and piesciiptive.
The design levels aie well desciibed, usually a 100-yeai ietuin peiiod load-
ing level with associated factois of safety stated and inheient design paiame-
teis specifed, such as effective length coeffcients, inheient assumption of
space fiame load iedistiibution, and noimal minimum steel yield to actual
yield iatios. The piesciiptive methodologies developed ovei the past six
decades have pioved to be iobust and ßexible in that they have been
adjusted as expeiience has been gained and the knowledge base has evolved.
Maritime Industry
The maiitime industiy coveis ocean-based shipping, including inteina-
tional shipping. High-level iegulation of inteinational shipping is caiiied
out by the Inteinational Maiitime Oiganization (IMO), an agency of the
United Nations specifcally dedicated to maiitime affaiis. The two piinci-
pal IMO conventions, Safety of Life at Sea and MARPOL and MARPOL
 Structural lntegrity of 0ffshore Wind Turbines
73/78 (Pievention of Pollution fiom Ships), contain the safety and pollu-
tion pievention iegulations. The nation of iegistiy of a vessel, geneially
iefeiied to as the ßag state, can supplement the IMO iegulations with addi-
tional iequiiements. USCG has iegulatoiy authoiity foi vessels iegisteied
in the United States. Regulations applicable to U.S.-ßag vessels include
those of IMO as well as additional safety iequiiements incoipoiated into
the Code of Fedeial Regulations (CFR). Nations at which a vessel is calling
(iefeiied to as poit states) may also implement inspection piogiams to
ensuie compliance with inteinational iegulations.
The USCG`s Alteinative Compliance Piogiam (ACP) allows pie-
appioved classifcation societies, which aie nongoveinmental and piivate
iule development oiganizations, to inspect and ceitify vessels foi compli-
ance
1
on behalf of USCG. These classifcation society iules go beyond the
safety and enviionmental iegulations of IMO and covei many aspects of
the design, constiuction, and maintenance of the vessel.
Undei the ACP, the inteinational conventions, the iules of the classif-
cation society acting on behalf of USCG, and a supplement to the iules aie
applied as an alteinative to the USCG iegulations set foith in the CFR. The
supplement, which coveis the gaps between the specifc set of classifcation
society iules and the CFR, is audited (ieviewed) foi equivalency befoie a
classifcation society is authoiized by USCG to administei the ACP. To
date, the Ameiican Buieau of Shipping (ABS), Lloyd`s Registei, Det
Noiske Veiitas (DNV), and Geimanischei Lloyd (GL) have ieceived such
appioval fiom USCG. USCG itself maintains a suffcient level of expeitise
to audit (ieview) classifcation society iules foi compliance with inteina-
tional standaids and the USGS iegulations, to paiticipate effectively in the
iulemaking piocesses at IMO, and to develop additional standaids when
necessaiy.
Neaily all ships involved in inteinational tiade aie °classed" by a iecog-
nized classifcation society. A classed ship is one that has been deteimined
to confoim with the classifcation society`s iules. Classifcation is an expec-
1
Ceitain vessel types, such as towed baiges, aie not coveied by the ACP. In such cases, vessels must
comply diiectly with the USCG iegulations. USCG Navigation and Inspection Ciiculai 10-82
authoiizes USCG to delegate to the classifcation societies authoiity to veiify compliance with
USCG iegulations. Offshoie fxed and ßoating stiuctuies aie also not coveied by the ACP.
/ Ris|lríc|aeJ /uu|coc| tc |e|íc|aorce /ssu|orce 
tation of insuiance companies and is an explicit iequiiement of many
ßag states.
Histoiically, iules and iegulations in the maiitime industiy have been
expeiience-based and piesciiptive, as has been the case foi those developed
by API. The ieliance on piesciiptive iegulations meant that iegulatoiy
development in the maiitime industiy, as in the oil and gas industiy, was
piimaiily ieactive, usually ielying on a catastiophic event to tiiggei the
next iound of changes. This began changing in the 1970s with the intio-
duction of piobability-based methodologies foi evaluating the suivivabil-
ity of ships. IMO has now adopted guidelines foi foimal iisk assessment
that aie used in assessing new and updating existing iegulations (IMO
2002). IMO has iecently adopted goal-based standaids applicable to ship
stiuctuies. This appioach is discussed latei in this chaptei in the section
°Risk Mitigation Thiough Peifoimance-Based Engineeiing."
Buildings, Bridges, and Civil Infrastructure
The fist piobability-based standaids and specifcations in the United
States weie intioduced in the eaily to mid-1980s ¦Ameiican National
Standaids Institute Standaid A58, now Ameiican Society of Civil Engi-
neeis Standaid 7, and the AISC load and iesistance factoi design (LRFD)
specifcation foi steel buildings]. They have been followed by othei spec-
ifcations as the iationale of the appioach has taken hold in the stiuctuial
engineeiing community. In these standaids and specifcation documents,
the load and iesistance ciiteiia weie piedicated on a set of ieliability tai-
gets foi member and ccmpcnent limit states, expiessed as a ieliability index
that was deteimined fiom an extensive assessment of ieliabilities associ-
ated with membeis designed by tiaditional methods. Ovei the yeais, most
building constiuction mateiials that have moved towaid piobability-
based limit states design have adopted similai benchmaiks, indicating a
degiee of piofessional consensus in the stiuctuial engineeiing standaid-
wiiting community in the United States. Moie iecent specifcations in
the biidge and tianspoitation aiea, typified by the Ameiican Associa-
tion of State Highway and Tianspoitation Offcials IRFD Bridge Design
Specifcaticns (AASHTO 2007), have adopted essentially the same piob-
abilistic methodology as that used in building stiuctuies. These fist-
geneiation piobability-based limit states design standaids continue to be
 Structural lntegrity of 0ffshore Wind Turbines
membei-based; any tieatment of system effects is hidden in the membei
safety-checking equations in the foim of effective length factois, stiength
oi ductility factois, and similai simplifcations of complex stiuctuial sys-
tem behavioi.
TRANSITION FROM PRESCRIPTIVE
TO PERFORMANCE-BASED REGULATIONS
The peifoimance of civil infiastiuctuie systems, unlike that of many othei
common mass-pioduced engineeied (foi example, automotive and avia-
tion) systems, is goveined by codes, standaids, and iegulatoiy guidelines
that iepiesent judgments by the piofessional engineeiing community
based on expeiience. These documents aie key tools foi stiuctuial engi-
neeis in managing civil infiastiuctuie iisk in the public inteiest, and the
tiaditional stiuctuial design ciiteiia they contain addiess the iisks in stiuc-
tuial peifoimance as engineeis have histoiically undeistood them. Foi the
most pait, these ciiteiia have been based on judgment. This appioach
to peifoimance assuiance geneially has seived society ieasonably well
because constiuction technology has evolved slowly. As in the case of civil
infiastiuctuie, the design and constiuction of maiine vessels date back
thousands of yeais, and the development of design codes, standaids, and
piactices has been giadual and delibeiate. Histoiically, these iegulations
have been prescriptive, consisting of detailed, expeiience-based iequiie-
ments and foimulations that must be satisfed to piove compliance.
In iecent yeais, howevei, innovation in technology has occuiied iapidly,
leaving less oppoitunity foi leaining thiough tiial and eiioi. New tech-
nologies have taken foim not only in new concepts, mateiials, and manu-
factuiing techniques but also thiough moie sophisticated analysis and
optimization tools that enable the design of moie effcient stiuctuies. The
public fuioi caused by iecent disasteis has made it cleai that appioaches
to iisk management based on judgment may not be acceptable and aie dif-
fcult to justify aftei the fact. Standaids foi public health, safety, and envi-
ionmental piotection now aie often debated in the public aiena, and
societal expectations of facility peifoimance have incieased.
Ovei the past seveial decades, iegulations peitinent to the civil
and maiine industiies have begun shifting fiom empiiical oi piesciip-
tive foimula-based (expeiienced-based) to peifoimance-based (goal-
/ Ris|lríc|aeJ /uu|coc| tc |e|íc|aorce /ssu|orce 
oiiented) standaids necessitating application of fist piinciples-based
analytical techniques. Risk-based decision making piovides a foundation
foi assessing compliance with goals and objectives and evaluating altei-
native solutions, and it is now applied extensively both in the development
of iegulations and in the evaluation of engineeiing solutions. The fist sig-
nifcant offshoie oil platfoims weie designed and constiucted in the 1970s;
this industiy does not have the long histoiy of the civil infiastiuctuie and
maiitime industiies. Expeiience-based codes and standaids weie not an
option foi the oil and gas industiy, and theiefoie iisk assessment has
always played a fundamental iole in the design of offshoie stiuctuies.
In the United States, the peifoimance concept (as it was called at the
time) in building constiuction dates back to the late 1960s, when the U.S.
Depaitment of Housing and Uiban Development sponsoied a laige pio-
giam at the National Buieau of Standaids (NBS) to develop ciiteiia foi
designing and evaluating innovative housing systems. Subsequent woik at
NBS led to a peifoimance ciiteiia iesouice document foi innovative con-
stiuction (Ellingwood and Haiiis 1977). A set of building elements and
desiiable peifoimance attiibutes weie identifed, which seived as a check-
list foi ensuiing that design piofessionals consideied and addiessed all
items signifcant to building peifoimance. Each piovision consisted of the
following:
1. A requirement expiessing a fundamental human need qualitatively
(e.g., °buildings shall be designed and constiucted so as to maintain
stability undei extieme enviionmental loads"),
2. A set of criteria used to check that the iequiiement is satisfed,
3. An evaluaticn giving appioved methods of suppoiting analysis oi test
pioceduies that demonstiate compliance, and
4. Ccmmentary that explains the technical bases foi each ciiteiion and
its evaluation.
RISK MITIGATION THROUGH
PERFORMANCE-BASED ENGINEERING
The new paiadigm of peifoimance-based engineeiing (PBE) is evolving
to enable new constiuction technologies and stiuctuial design to meet
heightened public expectations, to allow moie ieliable piediction and
18 Structural lntegrity of 0ffshore Wind Turbines
contiol of facility peifoimance, and to piovide engineeis with moie
flexibility in designing with nontiaditional systems and mateiials and
in achieving innovative design solutions. One common featuie of most
iecent pioposals foi PBE is theii distinction among levels of peifoimance
foi diffeient facility categoiies wheie life safety oi economic consequences
of damage oi failuie diffei. Cuiient codes geneially make such distinc-
tions by simply stipulating a highei design load, a step that may not lead
to bettei peifoimance and indeed may be iiielevant foi dealing with cei-
tain low-piobability events wheie effective design iequiies othei consid-
eiations in addition to stiength. The design objectives in PBE aie often
displayed in a iisk matiix such as that illustiated in Figuie 4-2, in which
one axis desciibes seveiity of hazaid (e.g., minoi, modeiate, seveie) and
the second identifes fiequency of occuiience. The seveiity of the incident
(consequence) can also be thought of in teims of peifoimance objectives
(continued function, life safety, collapse pievention). PBE might iequiie
that a ciitical facility iemain functional undei an extiemely iaie event (sus-
taining minoi damage) and piovide continued seivice without intei-
iuption undei a iaie event. Cuiient piesciiptive design codes foi offshoie
Frequency
Occurrence
LikeIihood
Severity of Incident (or Consequences)
IncidentaI
(1)
Minor
(2)
Serious
(3)
Major
(4)
Catastrophic
(5)
Frequent
(5)
OccasionaI
(4)
SeIdom
(3)
Remote
(2)
UnIikeIy
(1)
High Risk
Low Risk
FIßü8E 4-2 Example risk matrix driven by safety or environmental
consequences. (SOURCE: TRB 2008, Figuie 2-5).
/ Ris|lríc|aeJ /uu|coc| tc |e|íc|aorce /ssu|orce 19
oil and gas facilities, maiine vessels, and civil infiastiuctuie essentially limit
theii focus to life safety undei iaie events. The appioach iepiesented by
Figuie 4-2 is a moie matuie method foi managing iisk, but one that
iequiies caieful communication and mutual undeistanding among mem-
beis of the design team iathei than a simple ieliance on piesciiptive code
piovisions. Wheieas the consequence of an event is often quantifed in
teims of loss of life and enviionmental damage, the implications foi the
success oi failuie of goveinment policy aie also a concein. Figuie 4-3 illus-
tiates potential policy consequences of vaiious failuie types and how
iegulations can be used to mitigate this iisk.
PoIicy Consequence: Low High
ScaIe of Impact: SmaII Large
Routine Inspection,
Maintenance and Repair
No Policy Consequence
· Lightning strike damaging
rotor blade tip
· Small vessel collision damaging
boat access landing
FIeetwide
Turbine FaiIure
Consequence: 5-10 year delay
· Structural collapse in single
first-of-a-kind project (Cape Wind)
· Structural collapse across multiple
th-of-a-kind projects
IsoIated
Turbine FaiIure
Low Policy Consequence
(few months delay)
· Blade strike collapsing turbine
(waterspout during grid outage)
· Ship collision collapsing turbine
FIeetwide
Component FaiIure
Consequence: 1-2 year delay
· Monopile-transition piece grout
(serial design defect)
· Gearbox bearings
(serial manufacturing defect)
Mitigate by Standards and
CertifiedThird-Party Reviews
FIßü8E 4-3 Example risk matrix driven by policy consequences of failures.
Policy consequences iepiesent the implications foi success oi failuie of gov-
einment policy-in this case, a policy of suppoiting the development of the
offshoie wind iesouice. Not shown is the consequence of noimal but subpai
peifoimance-low plant availability oi highei costs than piojected. These
could also delay the development of the industiy by making fnancing
and public appioval moie diffcult to obtain. (SOURCE: Geneiated by the
committee.)
 Structural lntegrity of 0ffshore Wind Turbines
ALTERNATIVE APPROACHES TO REGULATING
THE U.S. OFFSHORE WIND INDUSTRY
U.S. offshoie wind iegulations could take one of the following foims:
a. A compiehensive set of piesciiptive iegulations that explicitly desciibe
design chaiacteiistics, design methodologies, mateiials, manufactuiing
standaids, and installation pioceduies;
b. A set of iegulations ielying on existing national and inteinational stan-
daids that aie geneially piesciiptive in natuie, with gaps in these iegu-
lations flled by a supplementaiy set of piesciiptive iegulations;
c. Goal-based standaids that desciibe the oveiaiching expectations foi pio-
tection of life, enviionmental peifoimance, and system ieliability; oi
d. Goal-based standaids combined with functional iequiiements that
establish high-level expectations foi peifoimance while pioviding a
gieatei level of specifcity on enviionmental conditions to be consid-
eied, design peifoimance metiics, seivice life expectations, and so
foith.
Theie aie advantages and disadvantages associated with each of these
options. The following aie some of the advantages of a compiehensive pie-
sciiptive set of iegulations (Option ):
 Piesciiptive iegulations aie simplei and easiei to implement and typ-
ically lead to lowei engineeiing, testing, and design development
costs.
 Compliance oveisight is moie stiaightfoiwaid, placing less ieliance
on the level of expeitise and competence of the iegulatoiy authoiities
and thiid-paity ievieweis.
 Piesciiptive iegulations aie distillations of expeiience and aie genei-
ally effective in ieducing the iisk of the types of accidents that have
occuiied in the past.
Disadvantages of piesciiptive iegulations include the following:
 By theii natuie, piesciiptive iegulations make suppositions about the
design appioach and analytical techniques to be applied and can limit
the application of innovative appioaches that do not suit the assump-
tions implicit in the iegulations.
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 Deficiencies in piesciiptive iegulations can lead to failuies on mul-
tiple piojects, as was the case foi the giouting failuies desciibed in
Box 4-2.
 Piesciiptive iegulations iequiie a vigilant piogiam of ieassessment
and updating by a team with a wide iange of technical expeitise and
expeiience.
Option  iequiies the gieatest investment by the iegulatoiy agency with
iegaid to the development and the maintenance of the iegulations.
Option  ieduces the level of iesouices iequiied of the goveinment but
has the disadvantage of ielying on the expeitise and diligence of an outside
standaids development body to maintain standaids. This disadvantage
is mitigated when the goveinmental body actively paiticipates in the stan-
daids development and ieview piocess.
Advantages of peifoimance-based iegulations include the following:
 Peifoimance-based iegulations moie ieadily allow foi innovative
solutions.
 Peifoimance-based iegulations piovide the designei with gieatei ßex-
ibility and ability to optimize, enabling moie effcient solutions.
 Peifoimance-based iegulations maintain theii ielevance. In contiast,
piesciiptive iegulations tend to encompass best piactices at the time
they aie wiitten and eventually become outdated and can conßict with
evolving technologies.
 Peifoimance-based iegulations aie moie ieadily maintained. Adjust-
ing them to ießect evolving public and iegulatoiy expectations is
stiaightfoiwaid.
 Peifoimance and safety-based iegulations have gieatei tianspaiency,
backed up by defned goals and objectives.
 Peifoimance-based iegulations iequiie gieatei involvement and buy-
in by industiy, leading to a bettei undeistanding of iesponsibility.
The following aie some of the disadvantages of peifoimance-based
iegulations:
 Peifoimance standaids place a gieatei ieliance on the technical com-
petency of the design engineei, fabiicatoi, and thiid-paity ieviewei.
 It is moie diffcult to veiify confoimity with peifoimance standaids
than piesciiptive standaids.
 Structural lntegrity of 0ffshore Wind Turbines
If Option  is implemented with only oveiaiching peifoimance
standaids, theie is iisk that impoitant design conceins will be oveilooked.
Theiefoie, wheie goal-based standaids aie specified, iequiiements aie
geneially fuithei defned by functional iequiiements, Option  Although
goal-based standaids aie often qualitative, to maintain consistency and
piovide metiics foi monitoiing compliance, the functional iequiiements
may be peifoimance-based quantitative standaids.
When goal-based standaids and functional iequiiements aie man-
dated by the goveinmental body, piesciiptive standaids aie fiequently
developed by standaids bodies oi industiy oiganizations to comple-
ment the goal-based and functional iequiiements. The piesciiptive
standaids aie developed such that, at least foi conventional stiuctuies,
compliance with the standaid will ensuie compliance with the goal-
based and functional iequiiements. This facilitates design and veiifca-
tion when the facilities and enviionmental conditions aie consistent
with the assumptions implicit in the piesciiptive standaids.
GOAL-BASED STANDARDS FOR OFFSHORE
WIND TURBINES
The committee iecommends that offshoie wind tuibine iegulations
piomulgated at the fedeial level be goal-based standaids and functional
iequiiements that aie peifoimance-based iathei than piesciiptive in
natuie (Option  above). Such iegulations will allow foi the development
of new technologies that aie necessaiy if offshoie wind faims aie to develop
into a cost-effective eneigy souice. Moieovei, the iegulations should be
iisk-infoimed. Fuithei backgiound on the evolution of iisk-infoimed
appioaches foi iegulating the safety of engineeied stiuctuies is piovided
in Appendix A. The goal-based standaids can be supplemented by pie-
sciiptive inteinational and national standaids and industiy-developed
guidelines wheie appiopiiate.
The committee iecommends that the fedeial goveinment, piesumably
undei the auspices of BOEMRE, develop a set of goal-based standaids foi
offshoie wind tuibines by using an appioach similai to that applied by
IMO foi the maiitime industiy (iefei to Box 4-4 foi a desciiption of IMO
/ Ris|lríc|aeJ /uu|coc| tc |e|íc|aorce /ssu|orce 

Goal-Based Standards Applicable
to the Maritime Industry
As desciibed eailiei, the iules foi design and constiuction of
ships aie developed by classification societies in confoimance
with national and inteinational iegulations. The iegulatoiy
authoiities concentiated on issues of safety and enviionmental
peifoimance and left standaids foi hull stiuctuial design, mate-
iials, coatings, and constiuction laigely in the hands of the clas-
sifcation societies. Compaiison of the vaiious classifcation iules
ievealed signifcant diffeiences in stiuctuial iequiiements and
expected peifoimance. With encouiagement fiom both national
authoiities who sought a moie consistent level of stiuctuial ieli-
ability and safety and industiy iepiesentatives who sought a
moie level playing feld wheie ieduced iobustness in the ship`s
stiuctuie and acceptance of highei safety iisks weie not used foi
competitive advantage, IMO developed a set of goal-based stan-
daids (IMO 2010). These standaids establish minimum objec-
tives with which all classifcation iules must comply.
The standaids consist of thiee tieis.
Tier 1. Gcals
Tiei 1 defnes the high-level objective. An example of a Tiei 1 goal
is that ships shall be designed and constiucted to be safe and envi-
ionmentally fiiendly thioughout theii design lifetimes (when
piopeily opeiated and maintained undei the appiopiiate condi-
tions). Fuithei defnition of teims can be given (e.g., that °safe
and envircnmentally friendly means the ship shall have adequate
stiength, integiity, and stability to minimize the iisk of loss of the
ship oi pollution to the maiine enviionment due to stiuctuial
(ccntinued cn next page)
 Structural lntegrity of 0ffshore Wind Turbines
ß0X 1-1 (ccntinued)
Goal-Based Standards Applicable to the Maritime Industry
failuie, including collapse, iesulting in ßooding oi loss of watei-
tight integiity").
Tier 2. Functicnal Requirements
Tiei 2 defines the ciiteiia to be satisfied to confoim with the
goals. Examples of functional iequiiements aie that ships have
a design life of not less than 25 yeais; that they be suitable foi
Noith Atlantic enviionmental conditions; and that they comply
with the stiuctuial stiength, ultimate hull giidei stiength, and
fatigue ciiteiia aftei accounting foi coiiosion expected ovei the
design life.
Tier 3. Verifcaticn cf Ccnfcrmity
Tiei 3 specifes the pioceduies foi veiifying that class societies`
iules and iegulations foi ship design and constiuction confoim
oi aie consistent with the goals and functional iequiiements.
IMO iecognized that it did not have the technical expeitise to
develop iules with the specifcity necessaiy to satisfy industiy and
iegulatoiy needs oi the iesouices to maintain the cuiiency of
such iules. Thus, the decision was made to keep the goal-based
standaids at a high level and iely on the classifcation societies to
develop and maintain compiehensive iule sets. The Tiei 3 veii-
fcation piocess calls foi paities seeking veiifcation of iules to
piovide documentation demonstiating confoimity with the
goal-based standaids. Again iecognizing its technical limitations,
IMO intends to use consultants with a iange of expeitise pei-
foiming undei the diiection of IMO staff to audit iules submit-
ted foi veiifcation.
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goal-based standaids). Theie aie paiallels between the situations faced by
BOEMRE in iule development foi offshoie wind tuibines and by IMO foi
oceangoing ships:
1. IMO did not have the expeitise oi iesouices to develop iules with suf-
fcient specifcity. Although the committee stiongly iecommends that
the size and capability of BOEMRE staff be enhanced, it is not envi-
sioned that BOEMRE will have the means to develop detailed iules.
2. The classifcation societies had well-developed and validated iules
befoie IMO`s involvement in iegulating hull stiuctuies. Similaily, intei-
national standaids foi offshoie wind tuibines (e.g., IEC 61400-3) and
class iules and guides (GL, DNV, and ABS) aie alieady in place.
3. Defciencies and inconsistencies among the vaiious classifcation soci-
ety iules foi shipbuilding weie identifed as an aiea of concein. Simi-
laily, theie aie defciencies and inconsistencies in the iules foi offshoie
wind tuibines, as discussed in Chaptei 3.
4. In the case of both offshoie wind tuibines and shipbuilding, the clas-
sifcation societies and inteinational standaids gioups aie piepaied to
maintain the cuiiency of theii iules and iegulations thiough continu-
ous validation and ievision.
The committee envisions the fedeially mandated goal-based standaids
foi offshoie wind eneigy installations to be a ielatively shoit document-
peihaps foui oi fve pages. The goal-based standaids should be high-level
objectives expiessed in teims of peifoimance expectations. The standaids
will apply to the design, fabiication, and installation of offshoie wind faims
within U.S. wateis and aie intended to ensuie a level of consistency meet-
ing safety, enviionmental peifoimance, and policy expectations, while
being suffciently ßexible to enable intioduction of new technologies and
concepts.
While the committee does not have the time, the iesouices, oi the
expeitise to establish a complete set of specifc ciiteiia, an example of the
scope and type of evaluation ciiteiia that should be incoipoiated is given
below. Tiei 1-type high-level geneial iequiiements aie given fist, followed
by Tiei 2-type functional iequiiements. In the lattei, the numeiical values
shown as examples foi vaiious items aie piovided foi illustiative puiposes
only. Actual ciiteiia would be subject to development by BOEMRE and its
consultants.
 Structural lntegrity of 0ffshore Wind Turbines
Examples of General Requirements
Stiuctuies, foundations, and nonstiuctuial components shall be designed
by analysis oi by a combination of analysis and testing to piovide a pei-
foimance not less than as stated below when they aie subjected to the
inßuence of opeiating, enviionmental, and accidental loads. Considei-
ation shall be given to unceitainties in loading and in iesistance.
Analysis shall employ iational methods based on accepted piinciples
of engineeiing mechanics and shall considei all signifcant souices of
defoimation and iesistance. Assumptions of stiffness, stiength, damp-
ing, and othei piopeities of components and connections shall be based
on appioved test data oi iefeienced standaids.
Testing used to substantiate the peifoimance capability of stiuctuial
and nonstiuctuial components shall accuiately iepiesent the mateiials,
confguiation, constiuction, load intensity, and boundaiy conditions
expected. Wheie an appioved industiy standaid oi piactice that goveins
the testing of similai components oi mateiials exists, the test piogiam
and deteimination of design values shall be in accoidance with that
industiy standaid oi piactice.
Examples of Functional Requirements
The examples below aie piovided foi illustiative puiposes only.
1. Offshoie wind tuibines and electiic seivice platfoims shall have a
seivice life of at least _____ yeais (e.g., at least 20 yeais).
2. Site-specifc enviionmental conditions shall be used foi design.
3. The piimaiy stiuctuies (foundations, supeistiuctuie, platfoims,
blades, nacelle suppoits, etc.) shall be designed and constiucted so
that the piobabilities of falling shoit (duiing theii seivice life) of
limit states associated with deßections, ultimate stiength, loss of sta-
bility (buckling), and fatigue aie suffciently small foi each individ-
ual stiuctuie as well as foi the ßeet of stiuctuies (typically installed
neai one anothei) that make up an offshoie wind faim.
4. The piobability, given the design-basis event, of collapse of piimaiy
stiuctuies (toweis, platfoims, blades, nacelle suppoits, etc.) within a
wind eneigy-geneiating facility shall not exceed ___ (e.g., shall not
exceed 10 peicent).
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5. Wind tuibine toweis and electiic seivice platfoims shall be designed
with suffcient iobustness that localized damage does not lead to
piogiessive, catastiophic failuie.
6. The design fatigue life shall be not less than _____ times the speci-
fed seivice life. Foi uninspectable aieas, the design seivice life shall
be not less than _____ times the specifed seivice life (e.g., 1, 5).
7. The piimaiy stiuctuies shall have piotection against coiiosion ade-
quate to ensuie that suffcient stiength is maintained ovei the spec-
ifed seivice life.
8. Wind eneigy geneiation facilities shall be designed to minimize
emission of pollutants as fai as piactical.
9. Wheievei piactical, stiuctuies and equipment shall be constiucted
of mateiials that can be iecycled in an enviionmentally acceptable
mannei without compiomising safety.
10. The toweis and othei stiuctuies shall be designed to piovide ade-
quate means of access to all inteinal stiuctuies to facilitate close-up
inspections of stiuctuies and equipment.
11. Designs shall take due consideiation of the health and safety of
peisonnel accessing offshoie wind tuibines and powei platfoims,
including ieady access and piotection against falls, lightning, and
othei hazaids.
Industry Compliance with BOEMRE Goal-Based Standards
Industiy will be iesponsible foi pioposing a collection of national and
inteinational standaids, iules, industiy-developed guidelines, and iec-
ommended piactices (iefeiied to heie as a °package of Guidelines") that
confoim to the goal-based standaids established by BOEMRE. As noted
latei in this section, the standaids, iules, industiy guidelines, and iecom-
mended piactices making up the packages of Guidelines could be diawn
fiom classifcation societies, the Inteinational Electiotechnical Commis-
sion (IEC), oi elsewheie. The packages of Guidelines will likely have
piesciiptive elements, which aie often easiei to implement than peifoi-
mance-based iequiiements. This is acceptable piovided that they comply
with the goals and objectives established by BOEMRE. It is anticipated
that these packages of Guidelines will have as theii basis the IEC stan-
daids, with additional iules, industiy guidelines, and iecommended
 Structural lntegrity of 0ffshore Wind Turbines
piactices to covei all necessaiy aspects of wind tuibine design coveied by
the BOEMRE goal-based standaids and to iectify any aieas of noncon-
foimance with the BOEMRE iequiiements.
To stieamline the iegulatoiy compliance piocess and piovide a level
of iegulatoiy ceitainty to the developei, the committee iecommends that
BOEMRE be piepaied to ieview the packages of Guidelines pioposed by
a iulemaking oi standaids development body in the light of BOEMRE`s
goal-based standaids befoie theii application to any paiticulai pioject.
The ieview piocess would pioceed as follows:
1. The iulemaking body develops a package of Guidelines confoiming to
the BOEMRE goal-based standaids along with the undeilying docu-
mentation and analysis. Examples of standaids, iules, industiy guide-
lines, and iecommended piactices that could be consideied aie those
developed by GL, DNV, and ABS, oi the standaids and iecommended
piactices cuiiently being developed by the Ameiican Wind Eneigy
Association.
2. When it submits its package of Guidelines foi appioval, the iulemaking
body shall piovide documentation and analysis demonstiating that the
standaids, iules, industiy guidelines, and iecommended piactices con-
tained in the package fulfll all the iequiiements of the BOEMRE goal-
based standaids, oi it shall cleaily identify which iequiiements aie not
coveied by its package of Guidelines.
3. BOEMRE ieviews the package of Guidelines and the undeilined docu-
mentation and analysis foi confoimance with the goal-based standaids.
Once compliance is asceitained, BOEMRE publishes notifcation of its
appioval of the package of Guidelines. If the package Guidelines does
not fully covei BOEMRE iequiiements, any defciencies that must be
coveied by othei standaids, iules, industiy guidelines, and iecom-
mended piactices should be identifed in the notifcation.
Alteinatively, a developei should be peimitted to identify a package of
Guidelines that will be apply to a specifc pioject, along with the undeily-
ing documentation and analysis, and BOEMRE should be piepaied to
ieview and appiove such packages on a case-by-case basis. This piocess is
anticipated to take longei than would use of pieappioved packages of
Guidelines, but it will allow foi the intioduction of novel concepts that
/ Ris|lríc|aeJ /uu|coc| tc |e|íc|aorce /ssu|orce 
may not be coveied in existing, pieappioved packages of Guidelines. This
appioach would pioceed as follows:
1. The developei assembles the package of Guidelines (see above) that it
pioposes to use foi a paiticulai pioject, and it piepaies documentation
and analysis demonstiating that all iequiiements of the goal-based stan-
daids aie satisfed.
2. A thiid-paity CVA ieviews the developei`s package of Guidelines and
the undeilying documentation and analysis and piovides a statement
indicating that the package is in full compliance with the goal-based
standaids. If the CVA identifes defciencies oi has conceins that aie not
fully ieconciled by the developei, they should be explained in the CVA`s
iepoit.
3. The developei submits its package of Guidelines, including the CVA`s
iepoit, to BOEMRE, seeking appioval foi the package of Guidelines to
be applied to the pioject. BOEMRE eithei appioves the package oi
sends it back to the developei iequesting ievisions oi fuithei documen-
tation and analysis, oi both.
The appioval of the package of Guidelines (standaids, iules, industiy
guidelines, and iecommended piactices) that will be followed to ensuie
compliance with the goal-based standaids does not imply that site-specifc
assessment and analysis aie not iequiied. Pioject ceitifcation (see Chap-
tei 3) with on-site assessment is expected to be a standaid pait of the design
and ieview piocess.
OVERVIEW OF PROJECTED BOEMRE ROLE
It is impoitant that a single goveinment agency, piesumably BOEMRE,
have oveiall iesponsibility foi iegulatoiy development, monitoiing and
maintenance of the iegulations, and implementation of the veiifcation
and oveisight iegime.
Below is a summaiy of the iole that BOEMRE would play undei the
appioach iecommended by the committee. The iole is a laige one, and
BOEMRE may wish to considei cieating an expeit panel to assist with the
initial development of the goal-based standaids and then with continuous
monitoiing and evaluation of the standaids and iegulations.
 Structural lntegrity of 0ffshore Wind Turbines
a. If so decided, establish an expeit panel to assist in initial development
of the goal-based standaids and then continuous monitoiing and
evaluation of the iegulations (see Chaptei 6).
b. Deteimine the scope of the iegulatoiy standaids. To ensuie a level of
ieliability consistent with public policy expectations, the committee
believes that the standaids must considei design, fabiication, instal-
lation, and commissioning fiom the expoit cable thiough to the tow-
eis and incoipoiated systems.
c. By the end of calendai yeai 2011, develop the goal-based standaids
and functional iequiiements, including a iigoious public ieview
piocess.
d. Review pioposed °packages of Guidelines" (compilations of inteina-
tional and national standaids, iules, industiy-developed guidelines,
and iecommended piactices) foi compliance with the U.S. goal-
based standaids. (As submitted)
e. Review pioposed packages of Guidelines duiing pioject assessment,
wheie pieappioved packages aie not applied oi wheie gaps in the
pieappioved packages aie identifed. (As iequested)
f. By the end of calendai yeai 2011, establish the intent and scope of the
thiid-paity ieview piocess (see Chaptei 5).
g. By the end of calendai yeai 2011, establish qualifcations foi CVAs-
thiid-paity ievieweis (see Chaptei 6).
h. Exeicise fnal appioval authoiity foi design and constiuction in com-
pliance with the iegulations (see Chaptei 5).
i. Review qualifcations and appiove CVAs on a pioject-specifc basis
(see Chaptei 6).
j. Monitoi peifoimance of piojects veisus iegulatoiy expectations and
piovide peiiodic feedback to the industiy (see Chaptei 6).
k. Monitoi the effectiveness of the goal-based standaids and peiiodi-
cally ievise them as appiopiiate.
l. Monitoi the effectiveness of the pieappioved packages of Guidelines
(national and inteinational standaids, iules, industiy guidelines, and
iecommended piactices) to ensuie compliance with the latest goal-
based standaids.
m. Monitoi the effectiveness of the thiid-paity ieview piocess.
n. Peiiodically ieview and update the goal-based standaids.
/ Ris|lríc|aeJ /uu|coc| tc |e|íc|aorce /ssu|orce 
o. Seive as the U.S. iepiesentative on offshoie wind standaids develop-
ment committees, both nationally and inteinationally.
IMPLEMENTATION: CAPACITY AND EXPERTISE
USDOI`s Offshoie Eneigy and Mineials Management piogiam includes
both offshoie oil and gas and offshoie ienewable eneigy iegulatoiy pio-
giams. It is staffed by ioughly 900 piofessionals in thiee iegional offces
(GOM, Alaska, and Pacifc); associated distiict offces; and headquaiteis
offces in Washington, D.C., and Heindon, Viiginia. The headquaiteis
staff has one engineei with a backgiound in civil and maiine engineei-
ing and naval aichitectuie, and the GOM iegional office is supplying
an engineei to suppoit the Office of Alteinative Eneigy Piojects on an
as-needed basis.
The Offce of Stiuctuial and Technical Suppoit (OSTS) is iesponsible
foi ensuiing that the platfoims opeiating on the OCS aie designed, fab-
iicated, installed, and maintained in accoidance with iegulations. This
gioup is based in the GOM iegional offce in New Oileans, Louisiana, and
seives as stiuctuial suppoit foi the Pacifc iegion as well. On the oil and
gas side, ioughly 3,500 facilities aie installed in the U.S. OCS (piimaiily
GOM), and OSTS has fewei than 10 engineeis to addiess peimit applica-
tions, inspection data, iepaii infoimation, and all othei stiuctuial data
and iequests. Since Huiiicane Katiina in 2005, many of the moie expeii-
enced staff in OSTS, including its diiectoi, have left the oiganization.
Remaining staff have less expeiience in addiessing offshoie stiuctuial
issues and no expeiience in addiessing issues ielated specifcally to off-
shoie wind stiuctuies.
To enhance its ability to oveisee the offshoie wind industiy effectively,
BOEMRE may wish to focus on obtaining staff oi contiactois with expeii-
ence in the following aieas: offshoie stiuctuies design, with a piefeience foi
expeiience in offshoie wind design; offshoie installations, with a piefeience
foi expeiience in pile-founded stiuctuies; wind tuibine hookup and com-
missioning, with a piefeience foi offshoie expeiience; and offshoie stiuc-
tuies opeiation and maintenance, with a piefeience foi offshoie wind
facilities expeiience. Expeiience with the standaids development piocess
would also be benefcial.
 Structural lntegrity of 0ffshore Wind Turbines
FINDINGS FOR TASK I: CHAPTER 4
As noted above, the fedeial goveinment has embiaced offshoie wind
eneigy as an integial component of its oveiaiching policy of developing
clean, ienewable eneigy souices. Thus, the goveinment has a fundamen-
tal inteiest not only in the safety and enviionmental peifoimance of off-
shoie wind faims but also in theii ieliability and cost-effectiveness.
1. Impiovements in the effciency of offshoie wind tuibine installations
and ieductions in capital and opeiating costs aie needed if offshoie
wind eneigy is to become a highly competitive ienewable eneigy
souice. Peifoimance-based (goal-based) standaids, which aie giad-
ually ieplacing piesciiptive standaids in othei industiies including the
civil infiastiuctuie, offshoie oil and gas, and shipping industiies, pio-
vide the ßexibility needed to accommodate new technologies. They can
be administeied and modifed by the iegulatoiy bodies in a stiaightfoi-
waid way, they claiify the iesponsibility of industiy in meeting pioject
goals, and they iesult in the tianspaiency that comes with the delin-
eation of goals and objectives.
2. As a iesult of the signifcant unceitainties affecting facility peifoimance
undei opeiating and extieme conditions, iecent PBE standaids have a
iisk-infoimed basis.
3. Unless its stafnng levels and experience are substantially enhanced,
BOEMRE will be unable to provide the leadership and decision-
making capability necessary for development of U.S. offshore wind
standards.
RECOMMENDATIONS FOR TASK I: CHAPTERS 3 AND 4
These iecommendations ßow fiom the fndings in Chapteis 3 and 4.
To enable timely development of U.S. offshoie wind eneigy within a
iobust iegulatoiy fiamewoik, the following appioach is iecommended:
1. BOEMRE should pioceed immediately with development of a set of
goal-based standaids goveining the stiuctuial safety of offshoie wind
tuibines and powei platfoims. The iegulations should be iisk-infoimed
(see Appendix A) and should covei design, fabiication, and installation.
Offshoie wind eneigy is an emeiging technology; theiefoie, the stan-
/ Ris|lríc|aeJ /uu|coc| tc |e|íc|aorce /ssu|orce 
daids should be ciafted to allow and encouiage intioduction of inno-
vative solutions that impiove the safety, enviionmental peifoimance,
ieliability, and effciency of offshoie wind facilities. BOEMRE should
eithei develop these iegulations within the agency in a timely mannei
oi facilitate development thiough, oi with the advice of, an outside
gioup of expeits. In any case, it is impeiative that BOEMRE take
iesponsibility foi the piocess and the fnal pioduct.
2. Because offshoie wind piojects aie alieady undei way, it is essential
that BOEMRE piovide industiy with a well-defned iegulatoiy fiame-
woik as soon as piactical. The U.S. offshoie wind tuibine iegulations
should be piomulgated no latei than the end of calendai yeai 2011, and
a specifc plan foi meeting that taiget should be established as soon as
possible.
3. On iequest of a iule development body, BOEMRE should ieview
the iules and guidelines pioposed by that body foi compliance
2
with
BOEMRE`s goal-based standaids and identify any defciencies. Once
BOEMRE deems a set of iules to be in full compliance with the goal-
based standaids, it should appiove such iules foi application to U.S. off-
shoie wind tuibines. Examples of iules and guidelines that could be
consideied aie those developed by GL, DNV, and ABS. Pieappioved
iules should have the beneft of expediting the iegulatoiy ieview piocess.
Howevei, BOEMRE should be piepaied to ieview standaids and guide-
lines pioposed by a developei and accepted by a CVA foi compliance
with its goal-based iegulations on a case-by-case basis.
4. It is ciitical that BOEMRE establish a substantial coie competency within
the agency with the capacity and expeitise to lead the development of
the goal-based standaids and ieview the packages of standaids, iules,
industiy guidelines, and iecommended piactices submitted by pioject
developeis and iules-development bodies. The section °Goal-Based
Standaids foi Offshoie Wind Tuibines" in this chaptei contains moie
details with iegaid to the expeiience and capabilities that aie needed.
5. BOEMRE should take a leading iole in piomoting awaieness of lessons
leained in the offshoie wind and offshoie oil and gas industiies among
2
A set of iules is deemed compliant if meeting those iules will be taken as suffcient evidence that
the peifoimance-based goals have been met.
 Structural lntegrity of 0ffshore Wind Turbines
pioject developeis, industiy piofessionals, and standaids development
bodies. The goal is to help industiy avoid mistakes that have been
encounteied elsewheie and to piomote piactices that have pioved to be
successful.
6. BOEMRE should be fully engaged in the national and inteinational
piocess foi developing standaids foi offshoie wind tuibines and should
be iepiesented on IEC technical committees and othei ielevant national
and inteinational committees.

Abbrevíatíons
AASHTO Ameiican Association of State Highway and Tianspoitation Offcials
BOEMRE Buieau of Ocean Eneigy Management, Regulation, and Enfoicement
IMO Inteinational Maiitime Oiganization
MMS Mineials Management Seivice
TRB Tianspoitation Reseaich Boaid
USDOE U.S. Depaitment of Eneigy
USDOI U.S. Depaitment of the Inteiioi
AASHTO. 2007. AASHTC IRFD Bridge Design Specifcaticns. Washington, D.C.
Beiek, G. 2010. Changing Piactice in Gulf of Mexico Design and Opeiating Ciiteiia.
http://www.iooc.us/wp-content/uploads/2010/09/Changing-Piactice-in-Gulf-of-
Mexico-Design-and-Opeiating-Ciiteiia.ppt.
Beiman, M. Y., N. D. Biiiell, J. T. Iiick, G. C. Lee, M. Rubin, and M. E. Utt. 1990. The
Role of the API Committee on Standaidization of Offshoie Stiuctuies. Papei 6206.
Prcc., Cffshcre Technclcgy Ccnference.
BOEMRE. n.d. Oveiview of OCS Regulations. http://www.gomi.boemie.gov/homepg/
iegulate/iegs/ieg_sum.html.
Cape Wind. n.d. Fiequently Asked Questions. http://www.capewind.oig/FAQ-Categoiy8-
CapeWindandtheEnviionment-Paient0-myfaq-yes.htm44. Accessed Dec. 13,
2010.
Coglianese, C., J. Nash, and T. Olmstead. 2003. Peifoimance-Based Regulation: Piospects
and Limitations in Health, Safety, and Enviionmental Piotection. Administrative Iaw
Review, vol. 55, issue 4, pp. 705-730.
Ellingwood, B., and J. R. Haiiis. 1977. Reliability-Based Peifoimance Ciiteiia foi
Stiuctuies. Prcc., 2nd Engineering Mechanics Divisicn Specialty Ccnference, ASCE,
pp. 124-127.
/ Ris|lríc|aeJ /uu|coc| tc |e|íc|aorce /ssu|orce 
Eneigo Engineeiing. 2010. Assessment cf Damage and Failure Mechanisms fcr Cffshcre
Structures and Pipelines in Hurricanes Gustav and Ike. MMS TA&R No. 642, Feb.
http://www.boemie.gov/taipiojects/642/642AA_FinalRepoit.pdf.
Exxon Valdez Oil Spill Tiustee Council. n.d. Details About the Accident. http://www.
evostc.state.ak.us/facts/details.cfm. Accessed Oct. 30, 2010.
IMO. 2002. Guideline foi Foimal Safety Assessment (FSA). MSC/Ciic. 1023, MEPC/
Ciic. 392.
IMO. 2010. Resolution MSC.287(87), Annex 1. Adoption of the Inteinational Goal-Based
Ship Constiuction Standaids foi Bulk Caiiieis and Oil Tankeis. Adopted May 20.
MMS. 2004. Histcry cf the Cil and Gas Industry in Scuthern Icuisiana. Inteiim Repoit,
Vol. 1. MMS 2004-049. http://www.gomi.mms.gov/homepg/iegulate/enviion/studies/
2004/2004-049.pdf.
Musial, W., and B. Ram. 2010. Iarge-Scale Cffshcre \ind Pcwer in the United States.
Assessment cf Cppcrtunities and Barriers. Repoit TP-500-40745. National Renewable
Eneigy Laboiatoiy, Golden, Colo.
Puskai, F. J., H. S. Westlake, P. E. O`Connoi, and J. Bucknell. 2006. The Development of
a Recommended Piactice foi Stiuctuial Integiity Management (SIM) of Fixed Offshoie
Platfoims. Papei 18332. Prcc., Cffshcre Technclcgy Ccnference, May.
TRB. 2008. Special Repcrt 293. Risk cf Vessel Accidents and Spills in the Aleutian Islands.
Designing a Ccmprehensive Risk Assessment. National Academies, Washington, D.C.
USDOE. 2011. Salazai, Chu Announce Majoi Offshoie Wind Initiatives. Piess ielease.
Feb. 7. http://www.eneigy.gov/news/10053.htm. Accessed Feb. 7, 2011.
USDOI. 2010. Salazai Launches °Smait fiom the Stait" Initiative to Speed Offshoie Wind
Eneigy Development off the Atlantic Coast. Piess ielease. Nov. 23. http://www.doi.
gov/news/piessieleases/Salazai-Launches-Smait-fiom-the-Stait-Initiative-to-Speed-
Offshoie-Wind-Eneigy-Development-off-the-Atlantic-Coast.cfm. Accessed Feb. 13,
2011.
USDOI. n.d. Smait fiom the Stait Fact Sheet. http://www.doi.gov/news/piessieleases/
loadei.cfm:csModulesecuiity/getfle&PageID73317. Accessed Feb. 13, 2011.
Wan, K. W. 2010. Flaw Hits Hundieds of EU Offshoie Wind Tuibines. Reuteis, Apiil 23,
2010. http://uk.ieuteis.com/aiticle/2010/04/23/uk-offshoie-wind-ßaw-idUKTRE63M
3H720100423. ¦Accessed Febiuaiy 13, 2011]
Waid, E. G. 1974. Ocean Data Gatheiing Piogiam-An Oveiview. Papei 2108. Prcc.,
Cffshcre Technclcgy Ccnference.

Role of Third-Party Oversight and
Certined Verincation Agents
Thiid-paity ieview of design and constiuction of infiastiuctuie has a long
histoiy. This chaptei piovides the histoiical context foi infiastiuctuie
ieview, then piogiessively naiiows the scope to piactices foi land-based
eneigy facilities, offshoie oil and gas facilities in the United States, offshoie
wind eneigy facilities, and fnally to the iole of a ceitifed veiifcation agent
(CVA) foi offshoie wind eneigy facilities.
BACKGROUND
Neaily all incoipoiated cities and communities along with many states and
counties have adopted building codes foi facilities and high-consequence
public infiastiuctuie, and they have oidinances iequiiing compliance of
design with the applicable building code and constiuction in accoidance
with the design. One of the two model building codes, as modifed foi
unique local conditions, is usually adopted. A peimit piocess and building
inspections aie coupled with the building code. Most juiisdictions issue
building peimits aftei ieview of plans by offcials within the juiisdiction;
the buildings aie subject to inspection duiing constiuction.
Othei types of infiastiuctuie have thiid-paity ieview oi authoiization
piocesses as well. Examples of well-known piocesses aie those developed
and implemented by the Fedeial Aviation Administiation foi aiiciaft and
those administeied by the Nucleai Regulatoiy Commission foi nucleai
powei plants.
The offshoie oil and gas industiy opeiates with a two-tiei oveisight
piocess undei the Buieau of Ocean Eneigy Management, Regulation, and
Enfoicement (BOEMRE). Foi facilities of lowei complexity and geneially
lowei potential consequences due to an incident, stiuctuial plans must be

Rcle cí T|i|J|o|t] 0.e|si¸|t orJ Ce|tiíeJ Ve|iícoticr /¸erts 
stamped by a iegisteied piofessional engineei, and BOEMRE staff check
submittals against iegulatoiy iequiiements. Foi facilities of gieatei stiuc-
tuial complexity, the CVA piogiam has been developed, and compliance
with it is iequiied.
Well ovei 200 yeais ago, the shipping industiy began an oveisight
piocess diiven by insuiance biokeis. A numbei of thiid-paity companies
that became known as classifcation societies developed guidelines cov-
eiing design conditions, inspection scopes, and piovisions foi peiiodic
inspection of vessels, which piovided the insuiance biokeis a baseline
ieliability iefeience.
A classifcation society is a nongoveinmental oiganization oi piivate
company that develops technical iules and iequiiements foi the design
and constiuction of ships and othei maiine stiuctuies (iefeiied to as class
iules) and then ensuies compliance with the iules thiough suiveys con-
ducted duiing constiuction and thioughout the life of the vessel. Classi-
fcation is geneially iequiied by ßag states as well as undeiwiiteis, and
most oceangoing caigo ships aie maintained in class.
The Euiopean piactices and iegulations foi wind eneigy tuibines weie
piesented in Chaptei 3. Piimaiy oveisight oi ieview is embedded in the
type ceitifcation and pioject ceitifcation piotocols. Additional oveisight
may be iequested by insuiance oi pioject fnancing entities; howevei,
piactices aie not unifoim.
OFFSHORE OIL AND GAS: HISTORY OF USE OF CVAs
1977 National Research Council Study
In the 1970s, oil exploiation and pioduction offshoie the United States
weie incieasing iapidly in scope and complexity. The numbei of wells, the
numbei of facilities, and pioduction volumes giew, and exploiation and
pioduction extended into deepei and deepei wateis. While the gieatest
focus was in the Gulf of Mexico, activity was undei way offshoie Alaska
and Califoinia. Exploiation was active as well off the noitheast coast.
In 1977, the U.S. Geological Suivey (USGS), which at the time handled
the iesponsibilities handled today by BOEMRE, iequested the National
Reseaich Council (NRC) to undeitake a study to deteimine whethei inde-
pendent thiid-paity ieview of offshoie stiuctuies would be of beneft to
 Structural lntegrity of 0ffshore Wind Turbines
the fedeial goveinment. At the time, the fedeial iegulations embodied
within Outei Continental Shelf (OCS) Oidei 8, the foieiunnei of Title 30,
Pait 250, of the Code of Fedeial Regulations (CFR), iequiied the stiuc-
tuial design of an offshoie facility to be stamped by a iegisteied piofes-
sional engineei.
The NRC study (Maiine Boaid 1977; Geiwick 1977) deteimined that a
thiid-paity ieview would be of value and iecommended that a piocess be
developed and implemented by USGS. Subsequently, USGS developed and
implemented a piocess, known as the CVA piogiam, that is still pait of the
facility oil and gas peimitting and appioval piocess oveiseen by BOEMRE.
The chaige to the NRC panel coveied fxed offshoie platfoims. Today, the
oil and gas CVA piogiam coveis not only fxed offshoie platfoims but also
peimanent ßoating facilities and deepwatei pioduction iisei systems.
One of the fist topics addiessed by the panel was the implications of
teiminology. °Ceitifcation" by a °ceitifed veiifcation agent" had a num-
bei of peiceived defnitions, and specifc piogiams weie associated with
the teim °platfoim ceitifcation" in some Euiopean iegulatoiy iegimes.
Theie was concein that ceitifcation might imply
that the stiuctuie was ceitifed to withstand all enviionmental and man-made
impacts upon the stiuctuie. Howevei, it is not possible to ceitify uncondition-
ally that the platfoim will at all times be safe foi opeiating peisonnel, oi with-
stand the effects of all stoims and seismic conditions, collisions oi accidents oi
that the enviionment will not be endangeied.
Neveitheless, a pioceduie is iequiied, whatevei its designation, to assuie the
public, the Congiess, the USGS and the ownei/opeiatoi of the platfoim that
the enviionmental and opeiating factois have been given consideiation in the
platfoim design, constiuction and installation. This pioceduie should also
indicate that appiopiiate ieviews and inspections have been conducted to doc-
ument that the design, building, and installation of a platfoim aie in confoi-
mance with the applicable peifoimance ciiteiia, specifcations, etc. This
pioceduie has been identifed as °veiifcation." (Maiine Boaid 1977, 8)
The study iecommended that USGS, in addition to instituting a veiifca-
tion piogiam, inciease staff capability foi assessing agent competence and
appioving facility peimits.
The scope of a veiifcation piogiam was outlined. Thiee distinct aieas-
design, fabiication, and installation-weie desciibed and iecommended
Rcle cí T|i|J|o|t] 0.e|si¸|t orJ Ce|tiíeJ Ve|iícoticr /¸erts 
foi oveisight. Because of the diffeiing skills iequiied in these aieas, the iec-
ommendation piovided that veiifcation in each aiea could be peifoimed
by independent oiganizations.
The iecommended piocess was outlined as follows:
1. The opeiatoi submits a plan foi thiid-paity veiifcation of the stiuctuie
to USGS.
2. USGS checks the plan, eithei in-house oi by using a contiactoi.
3. USGS appioves the plan if it is adequate (an appeal pioceduie is avail-
able in case appioval is denied).
4. The plan is implemented by the thiid-paity engineeiing and inspection
iepiesentatives (CVAs) indicated in the plan.
5. USGS monitois implementation of the plan foi compliance.
6. USGS institutes a failuie iepoiting and analysis system.
7. An independent goveinment boaid conducts oi ieviews investigations
of majoi accidents (this iecommendation was nevei implemented as
envisioned).
The veiifcation plan submitted by the opeiatoi should set foith the
following:
 Enviionmental ciiteiia to be used;
 Design ciiteiia and pioceduies to be used;
 Fabiication pioceduies to be used;
 Installation pioceduies to be used;
 Opeiating pioceduies to be used, including postinstallation inspec-
tion and maintenance pioceduies;
 Techniques and pioceduies to be used in veiifcation (tests, inspec-
tion pioceduies, etc.); and
 A list of the independent thiid-paity veiifcation agents pioposed to
be employed.
Duiing the design phase, 30 CFR 250 specifes standaids with which the
facility must comply. These standaids, foi offshoie U.S. wateis, aie the
Ameiican Petioleum Institute (API) Seiies 2 standaids, such as API RP
2A-WSD, 21st edition, foi fixed offshoie platfoims and API RP 2T foi
tension leg platfoims. They aie U.S. national standaids caiiying the
Ameiican National Standaids Institute designation and comply with the
 Structural lntegrity of 0ffshore Wind Turbines
institute`s iequiiements of open development pioceduies, including
public paiticipation in the development, ieview, and appioval stages. All
comments to pioposed standaids must be addiessed and iesolution of
comments documented. While the standaids aie shepheided by an indus-
tiy oiganization, they aie deliveied as U.S. national standaids.
Early Years of the CVA Program
In the eaily 1980s the Mineials Management Seivice (MMS) maintained
a list of pieappioved CVAs. An oiganization could petition MMS to
appiove it as a CVA foi design, fabiication, oi installation on the basis
of the oiganization`s capabilities. Appioval was gianted foi a peiiod of
3 yeais. An opeiatoi could choose fiom the list of pieappioved CVAs oi
piopose anothei oiganization foi appioval to function as a CVA on a given
pioject. Aftei seveial yeais, MMS discontinued the piactice of pieappiov-
ing CVAs because of diffculties in maintaining the list and the ielatively
few facilities iequiiing use of a CVA. Only a small subset of the appioved
CVAs weie actually selected and used.
Initial CFR and Notices to Lessees
USGS implemented a CVA piogiam thiough piovisions in OCS Oidei 8
(latei incoipoiated into 30 CFR 250 Subpait I) and vaiious notices to
lessees. The piogiam initially coveied stiuctuial aspects of fxed platfoims
and has been expanded to covei stiuctuial and station-keeping aspects of
permanent fcating pioduction facilities and pioduction iiseis foi the ßoat-
ing facilities. The diilling and piocess systems of the offshoie facilities have
not been coveied undei the CVA piogiam.
The CVA piogiam can be summaiized as follows:
1. Design, fabiication, and installation have been designated as distinct
phases of a pioject, and each phase must be veiifed.
2. A single CVA can be appioved foi all thiee phases, oi individual CVAs
can be appioved foi each of the thiee phases.
3. Initially, individuals oi companies could petition USGS to be appioved
as a CVA foi a given phase oi foi multiple phases on the basis of com-
petency. On acceptance by USGS, appioval was gianted foi 3 yeais.
USGS maintained the list of pieappioved CVAs by phase.
Rcle cí T|i|J|o|t] 0.e|si¸|t orJ Ce|tiíeJ Ve|iícoticr /¸erts 
4. Alteinatively, an ownei could nominate a CVA foi a phase of a pioject
if the pioposed CVA was not alieady on the appioved list. USGS
ieviewed the ciedentials of the nominee in the same mannei as those
of a CVA iequesting pieappioval. If the nominee was deemed quali-
fed, appioval as the CVA was gianted foi the iequested pioject, and
the nominee was added to the pieappioved list.
5. The appioved CVA ieviewed the appiopiiate documentation oi feld
activities and submitted inteiim iepoits as outlined in the CVA pio-
posed scope of woik as well as a fnal iepoit to USGS.
6. USGS maintained iesponsibility foi assessing the qualifcations of a
CVA, appioving a CVA foi a given pioject, and ieviewing both the
facility ownei`s documentation and the CVA iepoits. It made the fnal
deteimination as to the acceptability of the pioposed facility.
The NRC study iecommended that all futuie facilities be included
within the CVA piogiam. When it was implemented, howevei, the pio-
giam excluded ioutine facilities fiom the CVA scope and included only
 Platfoims with natuial peiiods gieatei than 3 seconds,
 Platfoims installed in watei depths exceeding 400 ft,
 Platfoims installed in aieas of unstable bottom conditions,
 Platfoims having confguiations and designs that have not pieviously
been used oi pioven foi use in the aiea, and
 Platfoims installed in seismically active aieas.
The fiist platfoims to undeigo the full CVA piogiam addiessing
design, fabiication, and installation weie installed off the coast of Cal-
ifoinia in 1981, a seismically active aiea. In developing the details of the
CVA piogiam within USGS, the Shell Cognac platfoim, installed in
1978, was used as a test case to help develop the CVA piotocols and
pioceduies.
Aftei implementation of the piogiam, ßoating facilities weie consid-
eied foi U.S. offshoie wateis, and a new item was added to the list of those
iequiied to use a CVA: all new ßoating platfoims.
The CVA piogiam could be viewed as a supplement to the goveinment
staff`s ability to ieview platfoim installation peimits, witness on-site fab-
iication and installation, and veiify compliance with design iequiiements
and fabiication specifcations.
 Structural lntegrity of 0ffshore Wind Turbines
The CVA piogiam iemains essentially the same as when it was con-
ceived and implemented in the late 1970s. BOEMRE no longei maintains
a pieappioved list of CVA oiganizations, and an ownei nominates CVAs
foi each pioject. Thiough 2009, 103 fxed platfoims and 41 ßoating facil-
ities have come undei the CVA piogiam.
1
Details of the CVA piogiam, including geneial iequiiements foi plat-
foims and details of the Platfoim Appioval Piogiam and the Platfoim Vei-
ifcation Piogiam, can be found in Sections 250.900 thiough 250.918 of
30 CFR 250 Subpait I.
2
CURRENT BOEMRE REGULATORY PROPOSALS FOR
OFFSHORE WIND TURBINES AND USE OF CVAs
The iegulations codifed at 30 CFR 285, cuiient as of Septembei 30, 2010,
contain iequiiements foi CVA iesponsibility and scope paiallel to those
foi the offshoie oil and gas industiy, which have been in effect foi 30 yeais
and aie desciibed in 30 CFR 250 Subpait I. All the attention foi CVA activ-
ity is focused on the stiuctuial and foundation aspects of the facilities. The
key diffeience is the option that the offshoie wind facilities have to waive
the CVA elements via petition undei specifc ciicumstances. The iole of
the CVA as desciibed in 30 CFR 285 is paiallel to the iole of the CVA foi
oil and gas facilities desciibed in 30 CFR 250-to ieview, assess, and com-
ment to BOEMRE.
3
Maintaining this advisoiy iole is a ciitical element of
any thiid-paity ieview piocess.
SCOPE OF REVIEWS
While the cuiient oveisight model foi offshoie wind eneigy facilities is
based on the offshoie oil and gas piogiam, the scope of the lattei may be
consideied too naiiow. The offshoie oil and gas industiy can be paiti-
tioned easily into stiuctuial, piocess, and diilling segments. In view of
BOEMRE`s expeitise and its piogiams foi diilling and piocess systems,
theie is a logic to limiting the CVA scope to the stiuctuial segment in
meeting BOEMRE objectives foi offshoie oil and gas goveinance.
1
Piesentation by Thomas Lauiendine to the committee, 2010.
2
Appendix B of this iepoit contains the text of 30 CFR 250, Sections 916-918.
3
Appendix B of this iepoit contains the text of 30 CFR 285, Sections 705-713.
Rcle cí T|i|J|o|t] 0.e|si¸|t orJ Ce|tiíeJ Ve|iícoticr /¸erts 
The same division cannot be made as easily foi offshoie wind eneigy
systems foi seveial ieasons:
 The blades and nacelle assembly aie ciitical components in maximizing
the ietuin to the U.S. goveinment.
 A design, manufactuiing, oi installation ßaw in any of the elements of
an offshoie wind facility will likely affect a signifcant peicentage of a
wind faim, not meiely the one facility.
 The contiol elements including geaiing, softwaie and haidwaie systems,
sensois, and powei supply may be ciitical in the ability of a blade, nacelle,
and suppoit system to maintain integiity in seveie weathei conditions.
 The dynamics and ielative stiffness of the suppoiting stiuctuial and
foundation components, commonly envisaged as a monotowei in shal-
low watei (but which could be a veitical axis system, a ßoating system,
etc.), have an inteiielationship with the stiffness and iotation fiequency
and loads of the blades that must be caiefully addiessed in the design
foi long-teim peifoimance.
Hence, it may be desiiable to make the scope of the wind eneigy
CVA piogiam much moie compiehensive. Figuie 5-1 identifies the key
components of a wind eneigy system. Foi compaiison puiposes, Item G,
the electiic suppoit platfoim, can be viewed as analogous to an oil and gas
platfoim. Table 5-1 compaies the scope that may be necessaiy to ensuie
coveiage foi a wind eneigy facility with that of an oil and gas facility.
Table 5-1 also has a column headed °type ceitifcation." That column
iepiesents the elements that would be satisfed undei a compiehensive
CVA appioach. As can be seen, only two elements, those of a design CVA
scope, would be coveied foi a tuibine-nacelle-blade-towei assembly that
was type-ceitified to the Inteinational Electiotechnical Commission
(IEC) piocess (see Chaptei 3).
°Type ceitification" addiesses the design of a blade-nacelle-towei
subsystem in meeting a set of ciiteiia. Physical pioof testing of one man-
ufactuied blade demonstiates the pioduct`s capacity and peifoimance
(stiength, deßection, etc.) in teims of the design defnition. Type ceiti-
fication does not piovide confidence that pioducts as pioduced meet
the design conditions. In othei woids, the ability to manufactuie one
device does not ensuie that all devices will be manufactuied to the same
peifoimance chaiacteiistics. Type ceitifcation is not suffcient in teims
104 Structural lntegrity of 0ffshore Wind Turbines
of quality assuiance/quality contiol to piovide fabiication iequiiements
equivalent to those of CVAs oi owneis.
Foi consistency of oveisight of an offshoie wind faim, the scope of the
CVA should be expanded beyond what is iequiied by 30 CFR 285. With-
out such an expansion, gaps may exist in expected peifoimance similai to
those expected with the stiuctuial aspects. The scope of a CVA is addiessed
by 30 CFR 285 in a mannei similai to the scope foi a CVA in connection
with oil and gas facilities addiessed by 30 CFR 250, which coveis stiuctuial
and geotechnical aspects foi design, fabiication, and installation. Restiict-
ing the CVA piogiam to these aieas intioduces consideiable gaps fiom a
systems peispective if balanced iisk is an objective.
CVAs AND GOAL-BASED STANDARDS
The use of goal-based standaids is incieasing, especially in aieas wheie
piactice is not matuie oi theie is gieat vaiiability in design conditions.
Offshoie wind is a young industiy with insufficient piesciiptive stan-
daids and little opeiating expeiience with the enviionment affecting
FIßü8E 5-1 Key components of a wind energy system.
Rcle cí T|i|J|o|t] 0.e|si¸|t orJ Ce|tiíeJ Ve|iícoticr /¸erts 105
IAßLE 5-1 Comparison of Scopes for Wind Energy and Oil and Gas Facilities
üIIshore
Iype Wiod Eoergy, üiI aod ßas,
LabeI Iteæ 6ertihcatioo 30 6F8 285 8ecoææeoded 30 6F8 250
/
B
C1
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0
E
|
C1
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|
NOTE: des  design, fab  fabiication, inst  installation.

If design basis iequiies active blade and yaw contiol to limit loading conditions.

Implied but not explicitly stated.

No foi fxed stiuctuies; des, fab, and inst foi ßoating stiuctuies.
BloJes
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the facilities. These conditions aie paiallel to those in the offshoie
oil and gas industiy duiing the mid-1970s. The NRC study iecom-
mended that USGS implement a thiid-paity veiification system and
an advisoiy boaid to assist it in establishing a fiamewoik foi the CVA
piogiam.
The use of an advisoiy boaid by BOEMRE would be valuable in identi-
fying the inteiielationship between goal-based standaids and moie pie-
sciiptive standaids and in establishing the fiamewoik foi CVA assessment
to deteimine adequacy of design, fabiication, and installation details in
meeting the goal-based standaids.
The use of goal-based standaids does not altei the intent oi the scope of
a CVA; instead, it intioduces an additional set of high-level taigets that can
 Structural lntegrity of 0ffshore Wind Turbines
be used by the CVA as a fiamewoik pioviding consistency in evaluating
piesciiptive standaids and elements within a basis of design and the con-
stiuction and installation documents.
SUMMARY
In the late 1970s, the development of oil and gas facilities in offshoie envi-
ionments began acceleiating in aieas posing moie seveie challenges (e.g.,
deepei watei, eaithquake zones, and unstable seaßooi sediments) and in
aieas with little oi no histoiical opeiating expeiience. Similaily, in the past
20 yeais, wind eneigy facilities in Euiope have spiead fiom land to off-
shoie enviionments. In both of these situations, iegulatois have used
thiid-paity ieview piotocols to assist in the oveisight of design, fabiica-
tion, and installation of facilities and to piovide a highei level of assui-
ance that the inteiests of the public and the iegulations goveining these
facilities aie being met.
FINDINGS AND RECOMMENDATIONS FOR TASK II
The fndings and iecommendations foi Task II of the statement of task
aie given below.
Findings
1. Wind tuibine type ceitification in accoidance with IEC 61400 pio-
vides effective oveisight and thiid-paity ieview foi
a. Design of the nacelle;
b. Design of the blades if the type ceitifcation ciiteiia match the instal-
lation conditions; and
c. Design of the towei piovided the foundation stiffness matches the
design assumptions and specifications of the towei, blades, and
nacelle.
2. Type ceitifcation does not covei fabiication, tianspoitation, oi instal-
lation activities.
3. Type ceitifcation of blades addiesses only design conditions and
iequiies testing of only one blade. Theie aie no fabiication quality
assuiance/quality contiol iequiiements foi pioduction.
Rcle cí T|i|J|o|t] 0.e|si¸|t orJ Ce|tiíeJ Ve|iícoticr /¸erts 
4. The CVA piogiam defned in 30 CFR 250 may be used as a model foi
offshoie wind piojects.
5. The iegulations of 30 CFR 285 piovide a good defnition of the iole of
a CVA.
Recommendations
1. The iesponsibility foi pioposing a compiehensive set of national and
inteinational standaids, iules, industiy guidelines, and iecommended
piactices (iefeiied to heie as a °package of Guidelines"), and the
undeilying documentation and analysis, should iest with the devel-
opeis. The CVA`s iole should be to ieview and comment on the ade-
quacy of the pioposed package of Guidelines in meeting the goals and
objectives defned in the BOEMRE goal-based standaids. Although
BOEMRE should considei the documentation and analysis piovided
by the developei and the iepoit of the CVA, iesponsibility foi appioval
of the pioposed package of Guidelines and foi deteimination of theii
confoimance with the goal-based standaids should iest solely with the
agency.
2. The scope of the BOEMRE-mandated thiid-paity ieview piocess
should include
a. Blades,
b. Blade contiols (if ieliance on active contiols is iequiied foi load
ieduction),
c. Towei and stiuctuial suppoit,
d. Foundation and station keeping,
e. Infeld cables and connectois,
f. Othei stiuctuial and electiical systems, and
g. Expoit cables.
The thiid-paity ieview should ensuie the following:
a.  The design adheies to good industiy piactice, the basis of
the design is appiopiiate foi the location and stated objectives of the
pioject, site-specifc conditions have been appiopiiately addiessed,
and the identifed codes and standaids aie adheied to.
 Structural lntegrity of 0ffshore Wind Turbines
b. Fabricaticn and manufacturing. Quality assuiance/quality contiol
piocesses aie in place to ensuie that fabiication and manufactuiing
comply with the design and the identifed codes and standaids.
c. Installaticn. All tianspoitation and feld installation activities aie
peifoimed in a mannei ensuiing that the facility meets the design
intent.
The thiid-paity ieviewei should piovide peiiodic iepoits to BOEMRE
with iegaid to the ieview fndings and should note any deviations oi
conceins.
3. Type ceitifcation of a wind tuibine may be substituted foi poitions of
thiid-paity design ieview if the type ceitifcate is appiopiiate foi site
conditions (e.g., the IEC wind class).
4. BOEMRE should ietain iesponsibility foi fnal appioval. It is essential
that BOEMRE have staff competent to select qualifed thiid paities (see
Chaptei 6) and to appiove piojects.

Geiwick, B. 1977. Veiifcation of Offshoie Platfoim Design and Installation: The Maiine
Boaid Panel View. Prcc., Cffshcre Technclcgy Ccnference, Houston, Tex.
Maiine Boaid. 1977. Verifcaticn cf Fixed Cffshcre Cil and Gas Platfcrms. An Analysis cf
Need, Sccpe, and Alternative Verifcaticn Systems. National Reseaich Council, Washing-
ton, D.C.

Qualincations Needed by Certined
Verincation Agents
As discussed in Chaptei 5, the ceitifed veiifcation agent (CVA) is
iesponsible foi ensuiing that the design, fabiication, and installation of
offshoie wind tuibine facilities aie in accoidance with accepted and
appioved plans and compilations of national and inteinational stan-
daids, iules, industiy guidelines, and iecommended piactices (iefeiied
to heie as °packages of Guidelines"). To peifoim this woik, the CVA must
have ceitain capabilities and expeiience. This chaptei exploies qualifca-
tions iequiied of thiid-paity ievieweis, evaluates vaiious appioaches
to acciediting a CVA, addiesses the qualifications necessaiy foi an
offshoie wind tuibine CVA, and discusses the potential gaps in the
piocess in the initial yeais of CVA implementation in the U.S. offshoie
wind industiy.
SURVEY OF QUALIFICATIONS FOR
OTHER THIRD-PARTY REVIEWS
Thiid-paity ieviews and veiification activities aie undeitaken foi vai-
ious engineeied systems, among them offshoie oil and gas, maiine,
and land-based stiuctuial design (including wind tuibines). This sec-
tion exploies the qualifications necessaiy foi oiganizations undeitak-
ing these veiification activities to piovide a backgiound foi evaluating
what qualifications should be iequiied foi the offshoie wind tuibine
industiy. The qualifications desciibed in this section aie piesented as
examples fiom othei thiid-paity ieview systems, which have infoimed
the committee`s delibeiations on the iecommended qualifications
foi CVAs.

 Structural lntegrity of 0ffshore Wind Turbines
Qualincations Required of Offshore Oil and Gas CVAs
The veiifcation piocess foi offshoie oil and gas facilities is the one most
closely associated with the piocess envisioned foi offshoie wind tuibines,
because they aie both mandated by U.S. Depaitment of the Inteiioi ieg-
ulations as published in the Code of Fedeial Regulations (CFR) and
diiected by the Buieau of Ocean Eneigy Management, Regulation, and
Enfoicement (BOEMRE), foimeily the Mineials Management Seivice
(MMS). Title 30 of the CFR addiesses mineials iesouices, and Paits
250.909 thiough 250.918 desciibe the Platfoim Veiifcation Piogiam (30
CFR 250.909-918) (see Chaptei 5).
Alist of qualifcations necessaiy foi the nominated CVA to be appioved
by the BOEMRE iegional supeivisoi, such as 10 yeais oi moie of expeii-
ence with offshoie fxed platfoim design oi active involvement in thiee oi
moie fxed jacket installations, is not given by 30 CFR 250. Howevei, a
ieview of the nomination iequiiements and expected activities of the CVA
piovides a sense of the necessaiy qualifcations.
The CVA nomination piocess foi oil and gas facilities is addiessed in
30 CFR 250.914. Section (b) lists the infoimation that must be included in
the CVA °qualifcation statement," including the following:
 Pievious expeiience with thiid-paity veiifcation;
 Pievious expeiience with design, fabiication, oi installation of fxed
oi ßoating offshoie stiuctuies; similai maiine stiuctuies; and ielated
systems and equipment;
 Pievious expeiience with BOEMRE iequiiements and pioceduies;
 Technical capabilities foi the specifc pioject and staff availability;
 Size and type of the oiganization;
 Access to necessaiy technology such as analysis tools and testing
equipment; and
 Level of woik to be peifoimed.
The CFR does not include minimum acceptable levels foi any of
these qualifications, and the evaluation of a CVA`s qualifications is
subjective and ultimately the iesponsibility of the iegional supeivisoi.
The following is an oveiview of what, accoiding to the CFR, is expected
of the CVA foi each of the thiee pioject phases: design, fabiication, and
installation.
0uoliícoticrs leeJeJ |] Ce|tiíeJ Ve|iícoticr /¸erts 
Expectatíons of CVAs for the Desígn Phase
The piimaiy design phase activity (30 CFR 250.916) is to peifoim an inde-
pendent ieview of the design on the basis of °good engineeiing judgment"
to deteimine whethei the design is suitable and will allow the system to
withstand °enviionmental and functional load conditions appiopiiate foi
the intended seivice life at the pioposed location." The CFR indicates spe-
cifc aieas that must be subjected to the CVA`s independent ieview foi
both fxed and ßoating offshoie stiuctuies; among them aie loading,
stiesses, and foundations. The design CVA must pioduce a iepoit of
fndings that identifes how and by whom the independent ieview was
conducted.
Expectatíons of CVAs for the Pabrícatíon Phase
The piimaiy fabiication phase activity (30 CFR 250.917) is to peifoim an
independent ieview of the fabiication on the basis of °good engineeiing
judgment" to deteimine whethei the stiuctuie matches the design docu-
ments and plans. Peiiodic site visits to wheie the fabiication is taking
place aie necessaiy. The CFR specifes seveial items that must be veiifed
by the CVA duiing this phase foi both fxed and ßoating offshoie stiuc-
tuies, including fabiicatoi quality contiol, mateiial quality, weldei qual-
ifcations, and nondestiuctive testing. The fabiication CVA must pioduce
a iepoit of fndings that identifes how and by whom the independent
ieview was conducted.
Expectatíons of CVAs for the Installatíon Phase
The piimaiy installation phase activity (30 CFR 250.918) is to peifoim an
independent ieview of the installation on the basis of °good engineeiing
judgment." This entails ieviewing installation plans and pioceduies and
witnessing the installation opeiations fiom loadout and towing to launch-
ing, upiighting, submeigence, and so foith. The CVA is also iesponsible
foi evaluating the equipment used and the iecoid keeping that is done. The
installation CVA must pioduce a iepoit of fndings that identifes how and
by whom the independent ieview was conducted.
In each phase, the CFR emphasizes the use of °good engineeiing judg-
ment." While theie is no defnition of this teim, its use indicates a piefei-
ence foi peisonnel with enough expeiience to foim the basis foi exeicising
 Structural lntegrity of 0ffshore Wind Turbines
good engineeiing judgment. Given the iange of activities iequiied foi each
of the phases, it is cleai that to peifoim the iole of a CVA competently,
those involved and ceitainly the peison in chaige of the piocess must have
diiect expeiience with the activities of that phase.
Wind Turbine Project Certincation
As desciibed in Chaptei 3, pioject ceitifcation is a piocess used to ensuie
that the equipment and suppoiting stiuctuie aie adequate foi conditions
at the site and meet the site`s iequiiements. It involves monitoiing of
activities duiing manufactuiing, tianspoitation, installation, and com-
missioning. Pioject ceitifcation also consideis the life cycle of the facil-
ity and includes piovisions foi peiiodic monitoiing, inspection, and
maintenance.
The qualifcations foi a ceitifcation agent vaiy with the iegulatoi in
the aiea wheie the wind tuibines aie to be installed. In some cases, theie
is no iegulatoiy iequiiement foi pioject ceitifcation, but the opeiatoi
oi developei may need ceitification to obtain financing oi foi othei
ieasons. In these cases, ceitification is geneially piovided by an oiga-
nization, such as Geimanischei Lloyd oi Det Noiske Veiitas, that has
developed its own set of guidelines foi designing, installing, and main-
taining wind tuibine facilities. The oiganization will ceitify that the
pioject has met its guidelines and any local juiisdictional iequiiements.
Othei oiganizations, such as Buieau Veiitas, that have not developed
theii own guidelines may also piovide ceitification. In such cases, the
qualifcation foi the ceitifei is its institutional knowledge of the topic
thiough development of detailed guidelines and thiough its woik with
the industiy.
As desciibed in Chaptei 3, wheie such ceitification is iequiied, it is
typically piovided by an oiganization that has been acciedited to pio-
vide these seivices. Foi instance, the Geiman Fedeial Maiitime and
Hydiogiaphic Agency acciedits oiganizations to piovide ceitification
on piojects in Geimany. Accieditation is based on evaluations of
piofessional competence, independence, impaitiality, and integiity.
Accieditation is geneially valid foi a peiiod of time, aftei which the
ieview piocess is iepeated to ensuie that the oiganization iemains in
compliance.
0uoliícoticrs leeJeJ |] Ce|tiíeJ Ve|iícoticr /¸erts 
Qualincations Required for Performance-Based
Design Peer Review
Standaid building codes and industiy piactice use a piesciiptive design
appioach that does not always lend itself to the design of atypical oi
unusual stiuctuies such as high-iise buildings oi buildings with unique
aichitectuial featuies. As noted in Chaptei 4, building codes and indus-
tiy piactice geneially do allow the use of alteinative means and methods,
one of which is peifoimance-based design (PBD). A peei-ieview piocess
in suppoit of PBD appioaches is used as a means of deteimining whethei
a design meets the intent of basic code iequiiements, is equivalent in
teims of safety to a code-compliant stiuctuie, and meets pioject-specifc
design ciiteiia and peifoimance expectations foi the facility.
A peei ieview is not intended to be a ciitique of the design concept
developed by the engineei of iecoid. In some cases, such as foi stiuctuies
in aieas of high seismic activity, especially wheie the design is atypical, the
peei ieview is mandated by iegulatois, but it may also be implemented by
the developei to satisfy expectations of insuieis oi fnancieis.
One desciiption of this type of peei ieview comes fiom the Los Angeles
Tall Building Stiuctuial Design Council in its publication 2008 Alternative
Design Criteria. The council pioposes that each pioject convene a seismic
peei-ieview panel to piovide an °independent, objective, technical ieview
of those aspects of the stiuctuial design" ielated to seismic peifoimance.
Its iecommendation is foi a panel of at least thiee membeis with °iecog-
nized expeitise in ielevant felds" to be selected by the building offcial of
the juiisdiction. (See http://www.tallbuildings.oig.)
Others
Peei-ieviewed designs aie becoming moie common in the assuiance of
fie piotection of buildings as well. The Society of Fiie Piotection Engi-
neeis (SFPE) has developed guidelines foi the peei-ieview piocess in fie
piotection design (Guidelines fcr Peer Review in the Fire Prctecticn Design
Prccess, Octobei 2002). With iegaid to qualifcations, the society empha-
sizes independence and technical expeitise. It gives a specifc example of
how one can demonstiate technical expeitise: the peei ieviewei should
have the knowledge to piepaie an °acceptable design that is similai in
 Structural lntegrity of 0ffshore Wind Turbines
scope to the design being ieviewed." This defnition is attiibuted to Sec-
tion 1.2.1 of the SFPE Engineering Guide tc Fire Prctecticn Analysis and
Design cf Buildings.
This document also desciibes peei ievieweis as those who aie °qual-
ifed by theii education, tiaining and expeiience in the same discipline,
oi a closely ielated feld of science, to judge the woithiness of a design oi
to assess a design foi its likelihood of achieving the intended objectives
and the anticipated outcomes."
U.S. REGULATIONS FOR OFFSHORE WIND
TURBINE CVA QUALIFICATIONS
Language in the cuiient CFR addiesses iequiiements foi offshoie wind
tuibines. Sections 705 thiough 714 of 30 CFR 285 aie ielated to CVAs
foi offshoie ienewable eneigy. Thiee aieas may be coveied by the CVA
piocess: the facility design iepoit, the fabiication and installation iepoit,
and the modifcation and iepaii iepoit.
Section 705 desciibes when a CVA must be used and piovides guid-
ance on when BOEMRE may waive the use of a CVA foi any oi all of
the thiee phases (design, fabiication, and installation). Section 706
addiesses the CVA nomination piocess. As in the case of offshoie oil
and gas facilities, a qualification statement is iequiied that includes the
following:
 Pievious expeiience with thiid-paity veiifcation;
 Pievious expeiience with design, fabiication, iepaii, oi installation of
offshoie eneigy facilities;
 Pievious expeiience with BOEMRE iequiiements and pioceduies;
 Technical capabilities foi the specifc pioject and staff availability;
 Size and type of the oiganization;
 Access to necessaiy technology such as analysis tools and testing
equipment; and
 Level of woik to be peifoimed.
Unlike the iegulations of 30 CFR 250, the offshoie wind tuibine iegula-
tions iequiie that the veiifcation woik be diiected by a iegisteied piofes-
sional engineei. Each U.S. state implements its own piofessional engineei
0uoliícoticrs leeJeJ |] Ce|tiíeJ Ve|iícoticr /¸erts 
iegistiation piocess to piovide a specifc minimum level of woik expeiience
and competency, although the expeiience and competency may not
be diiectly ielated to offshoie wind facilities. BOEMRE would deteimine
whethei an oiganization having inteinational engineeis with ciedentials
equivalent to those of a U.S. iegisteied piofessional engineei would be con-
sideied acceptable foi pioviding CVA seivices.
The guidance on activities to be peifoimed at each stage of the pioject
is similai to that piovided in Pait 250 and summaiized in the section on
offshoie oil and gas CVA above.
EVALUATION OF ACCREDITATION APPROACHES
Geneially, theie aie two appioaches in deteimining whethei a peison oi
oiganization is qualifed to peifoim CVA activities: pioject-specifc and
authoiized list. Some of the advantages and disadvantages of each appioach
with iegaid to offshoie wind tuibines aie examined below.
Project-Specinc Accreditation
This appioach is used by BOEMRE foi offshoie oil and gas CVA selection
and is inheient in the pioposed CFR language foi offshoie wind tuibines.
ACVA is nominated by the opeiatoi foi each pioject and must be appioved
by the BOEMRE iegional diiectoi.
The iegional diiectoi is iesponsible foi evaluating the qualifcations of
the pioposed CVA and deteimining whethei the nominee is suitable. This
can be cumbeisome if the iegional diiectoi does not have suffcient time,
expeitise, oi staff to devote to these evaluations and could lead to delays in
piojects as they await appioval oi to iubbei-stamping of nominees with-
out piopei consideiation of theii qualifcations. Howevei, this appioach
has the advantage of pioducing cuiient qualifcation infoimation fiom the
potential CVA, and the qualifcation piocess is ieadily auditable foi each
pioject.
No piocess and no objective ciiteiia aie available foi use by the iegional
diiectoi in deteimining whethei a nominee is qualifed foi a given pioject
and scope, and theie is no way to estimate how long the deteimination will
take. The piocess should be cleaily defned, and opeiatois should have an
expectation of the time iequiied to appiove the nominee.
 Structural lntegrity of 0ffshore Wind Turbines
Authorized CVA List
When the CVA piocess was intioduced to the offshoie oil and gas indus-
tiy, the authoiized list appioach was used. Pieappioved CVA oiganiza-
tions weie identified, and an opeiatoi could select one fiom the list
without fuithei appiovals oi ieviews. This had the advantage of claiity and
timeliness foi the opeiatois and fieed iegulatois fiom ieviewing qualifca-
tions foi each pioject that iequiied a CVA.
Howevei, the authoiized list must be kept cuiient, since peisonnel
available at the time of appioval may not be available when the piojects get
undei way. Peiiodic auditing of the list is iequiied to ensuie that it iepie-
sents qualifed oiganizations. Fuitheimoie, the list cieates a baiiiei to pai-
ticipation foi individuals and oiganizations that aie not on the list,
although they may be qualifed.
To implement an authoiized list effectively theie should be
 A iegulai ieview of the authoiized oiganizations,
 A piocess foi iemoval fiom the list,
 A iegulai oppoitunity to add new oiganizations to the list, and
 An auditing piocess to ensuie that peisonnel peifoiming CVA duties
aie those whose qualifcations weie cited to get on the list.
An authoiized list can be advantageous, although it may be just as bui-
densome foi the iegulatoi, given the woik iequiied to maintain the list and
ensuie that it is used piopeily.
The committee heaid fiom a foimei diiectoi of the MMS Offce of
Stiuctuial and Technical Suppoit, who desciibed how the oil and gas CVA
piocess was implemented. He expiessed the opinion that the maintenance
of an appioved list was impiactical given how peisonnel moved fiom com-
pany to company and the inability of MMS to monitoi effectively the
expeitise of the companies on the list. This led to the abandonment of the
list and the move to pioject-specifc appiovals of CVAs.
1
The diffculty in
maintaining an appioved list would be similai foi the offshoie wind indus-
tiy. This diffculty, coupled with the successful use of pioject-specifc
appiovals foi the oil and gas CVA piocess, makes pioject-specifc lists the
piefeiied appioach foi CVA appioval.
1
Piesentation by Thomas Lauiendine to the committee, August 10, 2010.
0uoliícoticrs leeJeJ |] Ce|tiíeJ Ve|iícoticr /¸erts 
The Inteinational Electiotechnical Commission (IEC) is ievising its
standaid 61400-22 foi confoimity testing and ceitifcation of wind tui-
bines. It has established an advisoiy committee of ceitifcation bodies to
piovide advice on, among othei things, haimonization of ceitifcation
iequiiements and inteipietation of technical iequiiements. Involvement
of BOEMRE with this committee would be useful as a means of inteiact-
ing with othei iegulatois facing similai issues and staying infoimed on
issues ielating to wind tuibine ceitifcation and the accieditation of CVAs.
2
OFFSHORE WIND TURBINE CVA QUALIFICATIONS
In addition to being independent and demonstiating good engineeiing
judgment, a thiid-paity ieviewei should have technical expeitise ielated
to the woik being ieviewed. In evaluating the qualifcations of CVA can-
didates foi offshoie wind tuibines, theii expected aieas of expeitise should
be identifed. As the pieceding sections show, howevei, they aie not usu-
ally identifed. The following sections outline the committee`s suggested
expectations foi a CVA qualifed to peifoim each of the thiee ieview
phases. The expectations aie based on the diiect expeiience of the com-
mittee membeis, ieviews of existing guidance documents foi offshoie
wind tuibines, and CFR iequiiements.
Design CVA
A design CVA should have expeitise in the following aieas:
1. Identifcation, specifcation, and implementation of design limit states.
These aie especially impoitant foi offshoie wind tuibine designs given
the vaiiety of load cases that must be consideied undei the IEC stan-
daids and othei ielevant guidance and the need to incoipoiate load
conditions not geneially encounteied foi offshoie Euiopean facilities,
including huiiicanes and eaithquakes.
2. Fatigue and stiength design appioaches, including the effects of cou-
pled wind-wave dynamics. The CVA must be able to undeistand the
techniques used in the analysis and design piocess and identify whethei
2
Repoit fiom MT22. http://wind.niel.gov/public/TC88/Repoit%20fiom%20MT22.pptx.
 Structural lntegrity of 0ffshore Wind Turbines
design assumptions aie valid and the conclusions aie suppoited by the
iesults.
3. Deteimination of the adequacy of pioposed design enviionmental con-
ditions. A CVA must undeistand the pievalent enviionmental condi-
tions affecting the site and be able to assess whethei the site-specifc
ciiteiia developed foi the pioject have been adequately consideied in
the design appioach and the fnal design.
4. Evaluation of foundation design. Within U.S. wateis, a vaiiety of soil
types and factois affect foundation design (e.g., scoui). The CVA must
be able to identify whethei the design appioach is suitable foi local con-
ditions and veiify that long-teim effects such as cyclic degiadation and
scoui have been adequately addiessed.
5. Inteiaction between the foundation and the tuibine system. In contiast
to the case foi offshoie oil and gas peimanent stiuctuies, the intei-
action between the wind tuibine`s above-watei stiuctuie and the sub-
stiuctuie and foundation has a dynamically diiven iesponse that must
be consideied in the design and undeistood by the CVA to ensuie that
it has been adequately addiessed.
6. Deteimination of the adequacy of the geotechnical assessment. The
quality of soil data can vaiy gieatly depending on who does the investi-
gation, wheie the boiings aie taken in ielation to the foundation, and
the age of the data and theii inteipietation. The CVA must undeistand
these factois and be able to deteimine whethei the soil data aie suitable
foi the foundation design.
7. Peifoimance of design calculations similai to those piovided in the
design iepoits. This is not a iequiiement that independent calculations
be peifoimed but that the CVA be able to peifoim them as necessaiy.
Fabrication CVA
A fabiication CVA should have expeitise in the following aieas:
1. Fabiicatoi quality contiol. The CVA should be familiai with quality
contiol piocesses and be able to peifoim audits of the fabiicatoi`s sys-
tems to deteimine compliance specifc to the pioject.
2. Mateiial quality evaluation. The CVA should undeistand mateiial
tiaceability pioceduies and be able to deteimine whethei pioject
0uoliícoticrs leeJeJ |] Ce|tiíeJ Ve|iícoticr /¸erts 
iequiiements aie suitable and whethei the manufactuiei is effectively
managing these piocesses foi the pioject.
3. Weldei qualifcations. The CVA must have a woiking knowledge of
weldei qualifcations and how they ielate to the pioject and be able to
deteimine whethei pioject qualifcation iequiiements aie suitable
and aie being met by the fabiicatoi.
4. Nondestiuctive testing. Tests foi welds and othei fastenings, blades,
and othei stiuctuial systems aie done to help ensuie that fabiication
is pioceeding accoiding to the design documents. The CVA should be
familiai with the pioject iequiiements and how such tests aie caiiied
out and inteipieted.
5. Destiuctive testing (e.g., full-scale blade tests). In some cases, destiuc-
tive testing may be called foi in pioject documents to demonstiate
that equipment and systems meet specifcations (e.g., blades may be
tested to failuie undei ceitain loading conditions). The CVA should
undeistand the pioject iequiiements and how such tests aie to be cai-
iied out and inteipieted.
6. Blade mateiials and fabiication. Blade fabiication is a specialized
piocess with unique use of skin mateiials and substiuctuie to achieve
the desiied aeiodynamics and stiength. The CVA should have expe-
iience with the mateiials used and the fabiication piocess so that the
CVA can evaluate the suitability of the blade manufactuiing piocess
and iesults and deteimine whethei the manufactuiei`s quality contiol
piocess can be ielied on to pioduce blades to the desiied specifcation.
Installation CVA
An installation CVA should have expeitise in the following aieas:
1. Evaluation of installation plans and pioceduies. The CVA must be
familiai with how offshoie installation activities aie caiiied out and
be able to ieview pioject pioceduies and plans foi coiiectness and
suitability foi site-specifc conditions.
2. Witnessing of installation opeiations including loadout, towing, launch-
ing, upiighting, submeigence, and so foith. The CVA must have expe-
iience with offshoie installation activities and have knowledge suffcient
to document the activities and identify any anomalous conditions.
 Structural lntegrity of 0ffshore Wind Turbines
3. Maiine opeiations. The CVA should be familiai with maiine opeiations
fiom loadout to sea fastening and tianspoitation to the site. This will
enable the CVA to document the piocess and identify any anomalous
conditions encounteied.
4. Subsea cabling activities including tienching, buiial, and connections.
The tiansmission cables used to inteiconnect the tuibines within a feld
and to connect to shoie-based facilities iequiie attention duiing instal-
lation to ensuie that they aie piopeily tienched oi buiied accoiding to
the design of the system and that connections aie piopeily completed.
The CVA should be familiai with these opeiations.
5. Offshoie constiuction activities. The CVA must undeistand how typi-
cal offshoie constiuction activities (e.g., launching, lifting, and eiecting
the facility) aie caiiied out and be able to document that they weie
implemented successfully and wheie deviations occuiied.
6. Installation equipment. The CVA should have an undeistanding of the
equipment to be used in the installation piocess and be able to detei-
mine that it is being used as intended foi the pioject in a safe and ieli-
able mannei.
In addition, the CVA should be able to defne the amount of attendance
iequiied by the CVA at vaiious offshoie activities in conjunction with the
installation contiactoi and BOEMRE. The amount of attendance iequiied
should be based on the complexity of the activity and the contiactoi`s
expeiience with similai activities.
Other Aspects of CVA Qualincations
The expeiiences of some committee membeis and infoimation piovided
to the committee by piesenteis indicate that having CVAs foi the design
phase diffeient fiom those foi the fabiication and installation phases is
acceptable in cuiient offshoie oil and gas piactice. No iestiictions on the
assignment of CVA iesponsibilities to diffeient oiganizations foi diffeient
phases aie imposed by 30 CFR 250. In piactice, oiganizations with expei-
tise in design do not necessaiily have expeitise in fabiication oi installa-
tion activities. Thus, it is expected that diffeient CVAs will be iesponsible
foi diffeient phases unless it can be demonstiated that a single individual
oi oiganization has suffcient expeitise as outlined above to diiect all oi a
combination of the phases.
0uoliícoticrs leeJeJ |] Ce|tiíeJ Ve|iícoticr /¸erts 
Local enviionmental, soil, and maiine tiaffc conditions vaiy gieatly
thioughout U.S. coastal wateis. The vaiiations affect loads that contiol
towei, foundation, and tuibine designs; installation conditions such as
local sea swells; pile-diiving iequiiements; and a vaiiety of othei factois.
Expeitise with conditions in one location may not be diiectly applicable
to othei locations. In some cases, knowledge unique to a paiticulai loca-
tion (e.g., seismic effects offshoie Califoinia) may be iequiied. The
expeitise of the CVA should be consideied in ielation to the location of
the pioject to deteimine whethei that expeitise is applicable to local
iequiiements.
Finally, in the committee`s opinion, a CVA should have a quality assui-
ance plan that addiesses the piocesses used in the CVA activities and the
iecoid-keeping ability necessaiy to tiack the pioject adequately and doc-
ument iesults. Such plans may, but aie not iequiied to, adheie to Intei-
national Oiganization foi Standaidization oi othei standaids foi quality
assuiance, but they should be maintained in such a way that a compliance
audit could be conducted and passed. Adheience to such a plan helps
ensuie that data aie piopeily tiacked (e.g., nondestiuctive evaluation test
iepoits and pioject inteiim iepoits) and that the CVA activities captuie
all necessaiy aspects of the pioject.
FILLING THE EXPERIENCE GAP
To date, no laige-scale offshoie wind tuibine piojects have been designed
foi oi installed in U.S. wateis. As desciibed in Chaptei 3, while a numbei
of piojects have been installed in Euiopean countiies, the local design
conditions (e.g., huiiicanes) expected foi U.S. facilities have not been
addiessed in detail, and potential fabiication and installation obstacles
have not been encounteied. Thus, theie is a potential gap in expeiience
that will affect the ability of a CVA to ieview the activities of designeis,
fabiicatois, and installeis effectively, because the CVA will be leaining
side-by-side with the piincipal paiticipants in the piojects.
Expeiience in iegulating the offshoie wind industiy is lacking.
BOEMRE has a long histoiy of iegulating the U.S. offshoie oil and gas
industiy, and its familiaiity with opeiatois, designeis, fabiicatois, and
installation contiactois is invaluable in evaluating the expeitise and
qualifications of potential CVAs. This familiaiity does not exist foi the
 Structural lntegrity of 0ffshore Wind Turbines
offshoie wind industiy, and BOEMRE lacks staff with expeiience in
iegulating, designing, installing, oi opeiating such facilities.
The lack of expeiience within BOEMRE with iegaid to offshoie wind
tuibine facilities could inhibit its ability to piovide effective iegulation.
One of its ioles within the CVA piocess foi offshoie ienewable piojects is
to deteimine whethei a CVA is iequiied and whethei the pioposed CVA
is suitable foi the tasks assigned. This iole is diffcult to accomplish with-
out expeiienced, dedicated staff. It is vital that BOEMRE act in a timely
fashion to hiie staff as desciibed in Chaptei 4 in the section °Implementa-
tion: Capacity and Expeitise" to fulfll its iegulatoiy iole.
The committee believes that the CVA piocess can pioduce valuable
infoimation foi BOEMRE with iegaid to the design and installation of
wind tuibine piojects in the United States. The details piovided thiough
CVA iepoits duiing the couise of the piojects should be caiefully ieviewed
by BOEMRE and evaluated foi infoimation that may lead to bettei iegu-
lation oi bettei guidance documents foi the industiy. This would not place
additional buidens on the CVA oi on developeis and contiactois, but it
would iequiie BOEMRE to dedicate staff to this task.
BOEMRE may also wish to considei cieating a panel of industiy
expeits to advise it foi the duiation of the fist seveial piojects. Such a
panel could piovide BOEMRE with feedback and guidance on the sub-
mitted design documents and the plans foi fabiication and installation.
This gioup of expeits would also beneft BOEMRE and the industiy as
they implement the fist seveial offshoie wind tuibine faims in U.S.
wateis. The panel would supplement the CVA foi the pioject and would
biidge the expeiience gap foi both the industiy and the iegulatoi. It
would also help disseminate lessons leained thioughout the industiy if
the panel weie tasked with documenting its fndings and iecommenda-
tions at the completion of its mandate. Such a panel would need a iange
of expeitise similai to that desciibed in the section on offshoie wind tui-
bine CVA qualifcations. Ideally, the panel would have expeitise in design
of offshoie wind oi oil and gas stiuctuies; offshoie tianspoitation and
installation, paiticulaily foi fxed stiuctuies; and stiuctuial engineeiing
and fabiication with a piefeience foi expeiience specifc to offshoie wind.
Panelists could come fiom a vaiiety of backgiounds and could include
developeis, designeis, iepiesentatives fiom academia, and iepiesentatives
0uoliícoticrs leeJeJ |] Ce|tiíeJ Ve|iícoticr /¸erts 
fiom iegulatoiy bodies. While establishing a panel that meets all those
iequiiements may be impiactical, the bioadei the iange of expeitise, the
moie effective the panel will be.
In Chaptei 4 in the section °Oveiview of Piojected BOEMRE Role," the
committee noted that BOEMRE may wish to use such an expeit panel to
assist in the initial development of the goal-based standaids and then in
the continuous monitoiing and evaluation of the standaids and iegula-
tions. If desiied, a single panel could seive all of these puiposes.
To eliminate conceins about conßict of inteiest, contiols would be
needed to ensuie that those impaneled did not use theii appointment as a
means to piomote theii business oi gain leveiage foi futuie woik as CVAs
oi as piincipals in offshoie wind faim woik. This is essentially an admin-
istiative detail that BOEMRE would need to addiess and implement.
FINDINGS AND RECOMMENDATIONS FOR TASK III
Task III of the statement of task calls foi the committee ieview the
expected expeiience level, technical skills and capabilities, and suppoit
equipment and computei haidwaie/softwaie needed to be consideied a
qualifed CVA.
Findings, Task III
Based on a ieview of the implementation of the CVA piocess foi offshoie
oil and gas facilities, the pioposed CFR language foi an offshoie wind
CVA, and how othei engineeied systems implement thiid-paity ieviews,
the following aie the committee`s key findings with iegaid to CVA
qualifcations.
1. A qualifed CVA must be
a. Independent and objective, with no involvement in the scope of
woik being ieviewed (i.e., design, fabiication, oi installation);
b. Expeiienced in peifoiming scopes of woik similai to that being
ieviewed, with detailed knowledge of the codes and standaids being
applied; familiaiity with the appioaches pioposed by the developei;
and the technical expeitise and engineeiing judgment to veiify
assumptions, conclusions, and iesults independently; and
 Structural lntegrity of 0ffshore Wind Turbines
c. Diiected by a iegisteied piofessional engineei (oi inteinational
equivalent). The intent of this iequiiement is to establish a baseline
level of expeiience and qualifcations foi the CVA lead. It is the opin-
ion of the committee that this goal can be achieved thiough both U.S.
and non-U.S. piofessional iegistiations.
2. A CVA foi the design stage must have expeitise in
a. Identifcation, specifcation, and implementation of design limit
states;
b. Fatigue and stiength design appioaches, including the effects of
coupled wind-wave dynamics;
c. Deteimination of the adequacy of pioposed design enviionmental
conditions foi the site;
d. Evaluation of foundation design;
e. Evaluation of inteiaction between the foundation and the tuibine
system;
f. Deteimination of the adequacy of the geotechnical assessment; and
g. Peifoimance of design calculations similai to those piovided in the
design iepoits.
This is not a iequiiement that independent calculations be peifoimed
but that the CVA be able to peifoim them as necessaiy.
3. A CVA foi the fabiication stage will need expeitise in
a. Fabiicatoi quality contiol,
b. Mateiial quality evaluation,
c. Weldei qualifcations,
d. Nondestiuctive testing,
e. Destiuctive testing (e.g., full-scale blade tests), and
f. Blade mateiials and fabiication.
4. A CVA foi the installation stage will need expeitise in
a. Evaluation of installation plans and pioceduies;
b. Witnessing of installation opeiations including loadout, towing,
launching, upiighting, submeigence, and so foith;
c. Maiine opeiations;
d. Subsea cabling activities including tienching, buiial, and connections;
e. Offshoie constiuction activities; and
f. Installation equipment.
0uoliícoticrs leeJeJ |] Ce|tiíeJ Ve|iícoticr /¸erts 
5. The CVA foi design, foi fabiication, and foi installation need not be the
same oiganization oi peison, and it is unlikely that a single peison
would have suffcient expeitise to peifoim effectively as CVA foi all
phases.
6. It would be benefcial, though not essential, foi a CVA to have expeii-
ence in thiid-paity ieviews and in inteiacting with iegulatoiy agencies.
7. Given the vaiiety of contiolling enviionmental loads (e.g., huiiicanes,
seismicity, icing) and installation iequiiements (e.g., mudslide aieas,
tidal eiosion effects) in U.S. wateis, the CVA`s expeiience should be
ielated to the installation location.
8. Expeiience with the use of pioject-specific CVA appiovals in the
offshoie oil and gas industiy indicates that pioject-specific appioval
of CVAs is bettei than maintenance of a list of BOEMRE-accepted
CVAs.
Recommendations, Task III
The committee iecommends the following with iegaid to CVA
qualifications:
1. In evaluating potential CVAs, BOEMRE should seek oiganizations
and individuals that
a. Aie independent and objective;
b. Have expeiience, technical expeitise, and engineeiing judgment suf-
fcient to veiify assumptions, conclusions, and iesults independently;
c. Have expeiience with the dominant enviionmental effects foi the
pioject location (e.g., eaithquake-iesistant design expeiience foi
offshoie West Coast locations);
d. Have expeiience in the aieas desciibed in the fndings section above
foi the CVA tasks (i.e., design, fabiication, and installation) foi
which they aie nominated;
e. Have cleaily defned ioles and iesponsibilities with adequate ovei-
sight by a iegisteied piofessional engineei (oi inteinational equiva-
lent); and
f. Have an auditable quality plan foi the piocesses and iecoid keeping
involved in the CVA activities.
2. BOEMRE should hiie suffcient staff with adequate expeitise (as
desciibed in Chaptei 4 in the section °Implementation: Capacity and
 Structural lntegrity of 0ffshore Wind Turbines
Expeitise") to oveisee the development of wind faims in U.S. wateis
by the end of calendai yeai 2011.
3. BOEMRE should appiove CVAs on a pioject-specifc basis as opposed
to maintaining an appioved list of qualifed CVAs.
4. BOEMRE should actively manage the CVA piocess foi offshoie wind
facilities by disseminating lessons leained fiom the CVA piocess to
piomote good piactices to the industiy.
5. BOEMRE should considei cieating an expeit panel to piovide feed-
back and guidance foi the initial offshoie wind development piojects
as a means to fll the expeiience gap foi both industiy and iegulatois.
6. BOEMRE should actively paiticipate in the IEC Wind Tuibines Cei-
tifcation Bodies Advisoiy Committee as a means of staying infoimed
on issues ielating to wind tuibine ceitifcation and the accieditation
of CVAs.

Summary of Key Findings
and Recommendations
The chaige of this committee was to ieview the pioposed appioach of
the Buieau of Ocean Eneigy Management, Regulation, and Enfoicement
(BOEMRE) in oveiseeing the stiuctuial safety of offshoie wind tuibines. It
was to considei the design, fabiication, and installation of these tuibines.
Specifcally, the committee was chaiged with pioviding fndings in thiee
aieas: standaids and piactices, the iole of ceitifed veiifcation agents
(CVAs), and the qualifcations needed by CVAs. Specifc fndings and iec-
ommendations in these aieas aie given at the ends of Chapteis 3, 4, 5, and
6of this iepoit. Those chapteis should be consulted foi details. The sections
below summaiize the committee`s key fndings and iecommendations.
Duiing its ieview, the committee noted that the U.S. goveinment, hav-
ing committed to exploiting the offshoie wind eneigy iesouice, has an
inteiest in industiy peifoimance foi ieasons beyond its statutoiy mandate
to ensuie the safe, oideily, and enviionmentally iesponsible use of the
outei continental shelf (OCS). Foi policy ieasons, it also wants to fostei
the giowth of the nascent U.S. offshoie wind industiy (see the Chaptei 4
section °Regulatoiy Options and Policy Consideiations"), which will
iequiie setting cleai iegulatoiy expectations soon and encouiaging the
innovation that will help make offshoie wind powei geneiation moie eco-
nomically competitive with othei souices of electiicity.
FINDING: SAFETY AND THE ENVIRONMENT
The iisks to life safety and the enviionment and the consequences associ-
ated with those iisks aie much lowei foi offshoie wind plants than foi off-
shoie oil and gas platfoims, ships, and land-based civil stiuctuies such as
buildings. Oveisight of offshoie wind development should take this into

 Structural lntegrity of 0ffshore Wind Turbines
account but will also need to ießect the impoitance of successful and ieli-
able opeiation of offshoie wind tuibines to policy goals.
FINDINGS AND RECOMMENDATIONS:
STANDARDS AND PRACTICES (TASK I)
The committee was tasked with ieviewing the applicability and adequacy
of existing standaids and piactices foi the design, fabiication, and instal-
lation of offshoie wind tuibines. In iesponse to this chaige, the commit-
tee ieviewed the standaids and guidance documents (the lattei including
guidelines, iecommended piactices, and similai documents) that have
been developed oi aie undei development by nongoveinmental oiganiza-
tions, classifcation societies, standaids-development bodies, and govein-
ment entities. It also consideied ways in which BOEMRE might addiess
defciencies in existing standaids and guidance documents.
Applicability and Adequacy
 In reviewing existing sets of standards and guidance documents, the
committee found that many could be applied in the United States
but that no one set was complete.
Many sets of standaids and guidance documents foi offshoie wind
tuibines aie available fiom standaids oiganizations, classifcation soci-
eties, and at least one goveinment. Many, if not most, have elements
that aie ielevant to the United States and can be applied to installations
in U.S. wateis.
Most of these standaids and guidance documents-notably, those
used in continental Euiope-aie detailed and piesciiptive. Howevei,
they aie incomplete in that no one set coveis all aspects of stiuctuial
design, fabiication, and installation. All existing standaids and guidance
documents have shoitcomings that will have to be oveicome if they aie
to be applied in the United States.
The following aie some of the most impoitant aieas wheie existing
standaids need moie woik foi use in the United States:
- Envircnmental site ccnditicns foi the United States, especially stoim
and huiiicane conditions foi the Gulf of Mexico and the East Coast.
These and othei conditions-such as ice loading (foi the Gieat
Suaao|] cí Ke] |irJir¸s orJ ReccaaerJoticrs 
Lakes) and seismic activity (especially on the Pacifc coast)-would
need to be coveied appiopiiately.
- Transparency. Methodologies foi stiength analysis
1
diffei among the
standaids and guidance documents and aie not always fully delin-
eated, making it diffcult to compaie the standaids and guidance
documents against one anothei to deteimine whethei they piovide
equivalent safety levels, especially when applied to novel concepts.
The methodologies, assumptions, and data used foi stiength analy-
sis must be laid out cleaily to piovide the necessaiy tianspaiency.
 BOEMRE's own regulations (published in 30 CFR 285) and accom-
panying guidance are inadequate in that they do not identify spe-
cinc criteria that a proposed project must meet to be approved and
gain the necessary permits.
Although iegulations
2
piomulgated by BOEMRE iequiie that
detailed iepoits foi design, constiuction, and opeiation of offshoie
wind tuibines be submitted foi BOEMRE appioval, they do not spec-
ify standaids that an offshoie wind tuibine must meet. Rathei, a thiid
paity (CVA) is asked to comment on the adequacy of design, fabiica-
tion, and installation and piovide iepoits to BOEMRE indicating the
CVA`s assessment of adequacy. Moieovei, when a geneial level of pei-
foimance such as °safe" is stipulated, no guidance is piovided on how
to assess whethei this level of peifoimance has been met.
 The United States urgently needs a set of clear and specinc standards
to reduce uncertainty in the requirements that projects must meet,
facilitate the orderly development of offshore wind energy, and sup-
port the stable economic development of a nascent industry.
States and piivate companies aie developing plans foi offshoie wind
eneigy piojects in state wateis and on the OCS. Well-defned U.S. ieg-
ulations foi development on the OCS aie needed (a) to piovide a
iesouice foi states as they develop iequiiements foi piojects in state
wateis and (b) to supply industiy with suffcient claiity and ceitainty on
1
Some standaids and guidance documents aie based on stiength oi limit states design; otheis aie
based on allowable stiess design. The philosophies undeilying these methods aie fundamentally
diffeient. See Chaptei 4.
2
30 CFR Pait 285, 74 FR 81, pp. 19638-29871.
 Structural lntegrity of 0ffshore Wind Turbines
how piojects will be evaluated as companies seek the necessaiy fnanc-
ing. Fuithei delays in developing an adequate national iegulatoiy fiame-
woik aie likely to impede development of offshoie wind facilities in U.S.
wateis. Moieovei, developments in state wateis could pioceed in the
absence of fedeial iegulations, possibly leading to inconsistent safety and
peifoimance acioss piojects.
Filling the Gaps
 Performance-based standards are a regulatory framework that best
meets two government objectives: () fulnlling BOEMRE's mission of
overseeing the safe, orderly, and environmentally responsible devel-
opment of the OCS and () fostering innovation and competitiveness.
Impiovements in the effciency of offshoie wind tuibine installations
and ieductions in capital and opeiating costs aie needed if offshoie wind
eneigy is to become a highly competitive ienewable eneigy souice.
Peifoimance-based (goal-based) standaids, which aie giadually ieplac-
ing piesciiptive standaids in othei industiies (such as civil infiastiuctuie,
offshoie oil and gas, and shipping), piovide the ßexibility needed to
accommodate new technologies. They can be administeied and modi-
fed by the iegulatoiy bodies in a stiaightfoiwaid way, they claiify the
iesponsibilities of industiy in meeting pioject goals, and they iesult in
the tianspaiency that comes with the delineation of goals and objectives.
Recommendations
To enable timely development of U.S. offshoie wind eneigy within a
iobust iegulatoiy fiamewoik, the following appioach is iecommended:
1. BOEMRE should pioceed immediately with development of a set of
goal-based standaids goveining the stiuctuial safety of offshoie
wind tuibines and powei platfoims. These iegulations should be iisk-
infoimed (see Appendix A) and should covei design, fabiication, and
installation. Offshoie wind eneigy is an emeiging technology; theie-
foie, the standaids should be ciafted to allow and encouiage intioduc-
tion of innovative solutions that impiove the safety, enviionmental
peifoimance, ieliability, and effciency of offshoie wind facilities.
BOEMRE should eithei develop these iegulations within the agency
Suaao|] cí Ke] |irJir¸s orJ ReccaaerJoticrs 
in a timely mannei oi facilitate development thiough, oi with the
advice of, an outside gioup of expeits. In any case, it is essential that
BOEMRE take iesponsibility foi the piocess and the fnal pioduct.
2. Because offshoie wind piojects aie alieady undei way, BOEMRE should
piovide industiy with a well-defned iegulatoiy fiamewoik as soon as
piactical. The U.S. offshoie wind tuibine iegulations should be piomul-
gated no latei than the end of calendai yeai 2011, and a specifc plan foi
meeting that taiget should be established as soon as possible.
3. On iequest of a iule development body, BOEMRE should ieview
the iules and guidelines pioposed by that body foi compliance
3
with
BOEMRE`s goal-based standaids and identify any defciencies. Once
BOEMRE deems a set of iules to be in full compliance with the goal-
based standaids, it should appiove such iules foi application to U.S. off-
shoie wind facilities. Examples of iules and guidelines that could be
consideied aie those that have been developed by Geimanischei
Lloyd, Det Noiske Veiitas, and the Ameiican Buieau of Shipping. Pie-
appioved iules should have the beneft of expediting the iegulatoiy
ieview piocess. Howevei, BOEMRE should be piepaied to ieview stan-
daids and guidelines pioposed by a developei and accepted by a CVA
foi compliance with its goal-based iegulations on a case-by-case basis.
4. BOEMRE should take a leading iole in piomoting awaieness of lessons
leained in the offshoie wind and offshoie oil and gas industiies among
pioject developeis, industiy piofessionals, and standaids development
bodies. The goal is to help industiy avoid mistakes that have been
encounteied elsewheie and to piomote piactices that have pioved to be
successful.
FINDINGS AND RECOMMENDATIONS:
ROLE OF THE CVA (TASK II)
1. The iesponsibility foi pioposing a compiehensive set of standaids,
guidelines, and iecommended piactices should iest with the develop-
eis. The CVA`s iole should be to ieview and comment on the adequacy
3
A set of iules is deemed compliant if meeting those iules will be taken as suffcient evidence that
the peifoimance-based goals have been met.
 Structural lntegrity of 0ffshore Wind Turbines
of the pioposed standaids and iules in meeting the objectives defned
in the BOEMRE goal-based standaids. Although BOEMRE should con-
sidei the documentation piovided by the developei and the iepoit of
the CVA, the iesponsibility foi appioval of the pioposed standaids and
guidelines and foi deteimination of theii confoimance with the goal-
based standaids should iest solely with the agency.
2. The scope of the BOEMRE thiid-paity ieview piocess should include
the following:
- Blades,
- Blade contiols (if ieliance on active contiols is iequiied foi load
ieduction),
- Towei and stiuctuial suppoit,
- Foundation and station keeping,
- Infeld cables and connectois,
- Othei stiuctuies-stiuctuial and electiical systems, and
- Expoit cables.
The thiid-paity ieview should ensuie the following:
Design. The design adheies to good industiy piactice, the basis of
the design is applicable foi the location and stated objectives of the
pioject, site-specifc conditions have been appiopiiately addiessed,
and the identifed codes and standaids aie adheied to.
Fabricaticn and manufacturing. Quality assuiance/quality contiol
piocesses aie in place to ensuie that fabiication and manufactuiing
comply with the design and the identifed codes and standaids.
Installaticn. All tianspoitation and feld installation activities aie
peifoimed in a mannei ensuiing that the facility meets the design
intent.
The thiid-paity ieviewei should piovide peiiodic iepoits to
BOEMRE with iegaid to the ieview fndings and should note any devi-
ations oi conceins.
3. Type ceitifcation of a wind tuibine may be substituted foi poitions of
thiid-paity design ieview if the type ceitifcate is appiopiiate foi site
conditions ¦e.g., the Inteinational Electiotechnical Commission (IEC)
wind class].
4. BOEMRE should ietain iesponsibility foi fnal appioval. It is essential
that BOEMRE have staff who aie competent to select qualifed thiid
paities (see Task III) and to appiove piojects.
Suaao|] cí Ke] |irJir¸s orJ ReccaaerJoticrs 
FINDINGS AND RECOMMENDATIONS:
CVA QUALIFICATIONS (TASK III)
Findings
The committee`s key fndings with iegaid to CVA qualifcations, which aie
based on a ieview of the implementation of the CVA piocess foi offshoie
oil and gas facilities, the pioposed Code of Fedeial Regulations language
foi an offshoie wind CVA, and how othei engineeied systems implement
thiid-paity ieviews, aie as follows:
1. A qualifed CVA must be
a. Independent and objective, with no involvement in the scope of
woik being ieviewed (i.e., design, fabiication, oi installation);
b. Expeiienced in peifoiming scopes of woik similai to that being
ieviewed, with detailed knowledge of the codes and standaids being
applied; familiaiity with the appioaches pioposed by the developei;
and the technical expeitise and engineeiing judgment to veiify
assumptions, conclusions, and iesults independently; and
c. Diiected by a iegisteied piofessional engineei (oi inteinational
equivalent).
2. A CVA foi the design stage must have expeitise in
a. Identifcation, specifcation, and implementation of design limit
states;
b. Fatigue and stiength design appioaches, including the effects of
coupled wind-wave dynamics;
c. Deteimination of the adequacy of pioposed design enviionmental
condition foi the site;
d. Evaluation of foundation design;
e. Evaluation of inteiaction between the foundation and the tuibine
system;
f. Deteimination of the adequacy of the geotechnical assessment; and
g. Peifoimance of design calculations similai to those piovided in the
design iepoits. This is not a iequiiement that independent calcu-
lations be peifoimed but that the CVA be able to peifoim them as
necessaiy.
3. A CVA foi the fabiication stage will need expeitise in
a. Fabiicatoi quality contiol,
b. Mateiial quality evaluation,
 Structural lntegrity of 0ffshore Wind Turbines
c. Weldei qualifcations,
d. Nondestiuctive testing,
e. Destiuctive testing (e.g., full-scale blade tests), and
f. Blade mateiials and fabiication.
4. A CVA foi the installation stage will need expeitise in
a. Evaluation of installation plans and pioceduies;
b. Witnessing of installation opeiations including loadout, towing,
launching, upiighting, submeigence, and so foith;
c. Maiine opeiations;
d. Subsea cabling activities including tienching, buiial, and connections;
e. Offshoie constiuction activities; and
f. Installation equipment.
5. The CVA foi design, foi fabiication, and foi installation need not be
the same oiganization oi peison, and it is unlikely that a single peison
would have suffcient expeitise to lead an effective CVA foi all phases.
6. It would be benefcial, though not essential, foi a CVA to have expeii-
ence in thiid-paity ieviews and in inteiacting with iegulatoiy agencies.
7. Given the vaiiety of contiolling enviionmental loads (e.g., huiiicanes,
seismic activity, ice loads) and installation iequiiements (e.g., mudslide
aieas, tidal eiosion effects) in U.S. wateis, the CVA`s expeiience should
be ielated to the installation location.
8. Expeiience with the use of pioject-specifc CVA appioval in the offshoie
oil and gas CVA industiy indicates that pioject-specifc appioval of
CVAs is bettei than maintenance of a list of BOEMRE-accepted CVAs.
Recommendations
The committee iecommends the following with iegaid to CVA qual-
ifications:
1. In evaluating potential CVAs, BOEMRE should seek oiganizations
and individuals that
a. Aie independent and objective;
b. Have expeiience, technical expeitise, and engineeiing judgment suf-
fcient to veiify assumptions, conclusions, and iesults independently;
c. Have expeiience with the dominant enviionmental effects foi the
pioject location (e.g., eaithquake-iesistant design expeiience foi
offshoie West Coast locations);
Suaao|] cí Ke] |irJir¸s orJ ReccaaerJoticrs 
d. Have expeiience in the aieas desciibed in the fndings section above
foi the CVA tasks (i.e., design, fabiication, and installation) foi
which they aie nominated;
e. Have cleaily defined ioles and iesponsibilities with adequate
oveisight by a iegisteied piofessional engineei (oi inteinational
equivalent); and
f. Have an auditable quality plan foi the piocesses and iecoid keep-
ing involved in the CVA activities.
2. BOEMRE should hiie suffcient staff with adequate technical expeitise
(as desciibed in Chaptei 4 in the section °Implementation: Capacity
and Expeitise") to oveisee the development of offshoie wind faims in
U.S. wateis.
3. BOEMRE should appiove CVAs on a pioject-specifc basis as opposed
to maintaining an appioved list of qualifed CVAs.
4. BOEMRE should actively manage the CVA piocess foi offshoie wind
facilities by disseminating lessons leained fiom the CVA piocess to pio-
mote best piactices to the industiy.
5. BOEMRE should actively paiticipate in the IEC Wind Tuibines Ceiti-
fcation Bodies Advisoiy Committee as a means of staying infoimed on
issues ielating to wind tuibine ceitifcation and the accieditation of
CVAs.
FINDINGS AND RECOMMENDATIONS:
IMPLEMENTATION
 In the committee's view, unless BOEMRE's stafnng levels and expe-
rience are substantially enhanced, the agency will be unable to pro-
vide the leadership and decision-making capability necessary for
development of U.S. offshore wind facility standards.
 It is essential that BOEMRE establish a substantial core competency
within the agency with the capacity and expertise to lead the develop-
ment of the goal-based standards, review the rules and guidelines
submitted by the third-party rule developers, and review the qualin-
cations of proposed CVAs.
The committee`s fndings and iecommendations on standaids and
piactices, the iole of the CVA, and the qualifcations needed by a CVA
call foi BOEMRE to take a leadeiship iole in developing new, goal-based
 Structural lntegrity of 0ffshore Wind Turbines
standaids; to ieview sets of standaids and guidance documents put foi-
waid by industiy foi pieappioval, identify gaps and defciencies, and
deteimine whethei they have been suffciently addiessed; to ieview the
full set of standaids and guidance documents submitted foi specifc
piojects; and to select CVAs who can take pait in all these functions as
necessaiy.
The expeitise iequiied to caiiy out these tasks is substantial. Moie-
ovei, the ciitical advisoiy ioles that the CVA could play in these tasks
could iequiie that BOEMRE make a moie detailed appiaisal of CVA
nominations than in the past, which also implies in-depth expeitise.
BOEMRE will likely be asked to apply this expeitise extensively and in
the neai futuie, both because iegulatoiy expectations need to be estab-
lished soon and because seveial offshoie wind piojects aie alieady being
developed and many moie will likely be enteiing the pipeline foi ieview
and appioval.
 As a means of nlling the experience gap for both industry and regula-
tors, BOEMRE should consider creating an expert panel to provide it
with guidance and feedback for the development of goal-based
standards, for the review of proposed standards and guidelines for
compliance with the goal-based standards, and for the initial wind
development projects.
Such an expeit panel could help BOEMRE in developing goal-based
standaids expeditiously. It could also advise BOEMRE on how CVAs
can assess compliance with goal-based standaids and on how the agency
and industiy can leain fiom the defciencies and othei conceins that
CVAs identify in piojects. Finally, foi the initial offshoie wind develop-
ment piojects, such an expeit panel could help BOEMRE ieview the
packages of Guidelines-standaids, iules, industiy guidelines, and iec-
ommended piactices-submitted foi application to a paiticulai pioject
oi submitted foi pieappioval foi use in futuie piojects.
 BOEMRE should be fully engaged in the national and international
process for developing standards for offshore wind turbines, and it
should be represented on the International Electrotechnical Com-
mission's technical committees and on other relevant national and
international committees.
        
Risk-Informed Approaches
to Safety Regulation
In iisk-infoimed iegulation, insights fiom iisk assessment aie consideied
togethei with othei engineeiing insights. This appendix summaiizes basic
concepts of modein iisk-infoimed safety iegulation as they aie cuiiently
used in the design of civil infiastiuctuie, focusing on theii use in the
United States.
RISK-INFORMED ANALYSIS AND DESIGN OF
CIVIL INFRASTRUCTURE FACILITIES
Risk-infoimed appioaches to analysis, design, and condition assessment
have ieached a state of matuiity in many aieas of civil infiastiuctuie dui-
ing the past thiee decades, paiticulaily in codes, standaids, and iegula-
toiy guidelines that govein design and constiuction. These documents
aie key tools foi stiuctuial engineeis in managing civil infiastiuctuie iisk
in the public inteiest, and the tiaditional stiuctuial design ciiteiia they
contain addiess iisks in peifoimance as engineeis have histoiically undei-
stood them. Foi the most pait, these ciiteiia have been based on judgment.
In iecent yeais, howevei, innovation in technology has occuiied iapidly,
leaving less oppoitunity foi leaining thiough tiial and eiioi (as is the case
in the wind eneigy industiy today). Standaids foi public health, safety,
and enviionmental piotection now aie often debated in the public aiena,
and societal expectations of civil infiastiuctuie have incieased. Questions
conceining alteinative oi innovative piojects and stiuctuial solutions aie
bettei answeied fiom a iisk-infoimed peispective. Such a peispective
continues to include a significant component based on judgment: the
use of a 50- oi 100-yeai mean iecuiience inteival (MRI) foi the design
wind effect is an example. Howevei, modein stiuctuial ieliability tools

 Structural lntegrity of 0ffshore Wind Turbines
have incieased the contiibution of iisk analysis to the iational development
of design ciiteiia, which, owing to cuiient computational capabilities, can
be fai bettei diffeientiated and iealistic than theii 1970s counteipaits.
This appendix summaiizes basic concepts of modein iisk-infoimed
safety iegulation as they aie cuiiently utilized in the design of civil infia-
stiuctuie and discusses theii application to stiuctuial design iequiie-
ments foi mitigation of iisk in the built enviionment.
FUNDAMENTALS OF RISK ASSESSMENT FOR NATURAL
AND MAN-MADE HAZARDS
Risk analysis and assessment tools aie essential in measuiing compliance
with peifoimance objectives, in compaiing alteinatives iationally, and
in highlighting the iole of unceitainty in the decision piocess. This sec-
tion outlines a fiamewoik foi modein iisk-infoimed decision making,
pioviding the backgiound foi the implementation of stiuctuial design
iequiiements foi civil infiastiuctuie facilities in the cuiient constiuction
and iegulatoiy climate.
Risk and Its Analysis: Hazard, Consequences, Context
Risk involves hazard, ccnsequences, and ccntext (Stewait and Melcheis 1997;
Viijling et al. 1998; Fabei and Stewait 2003). The hazaid is a potentially
haimful event, action, oi state of natuie. The potential foi the occuiience
of a huiiicane oi eaithquake at the site of a stiuctuie is a hazaid. The occui-
ience of such a hazaidous event has potential consequences-building
damage oi collapse, loss of life oi peisonal injuiy, economic losses, oi
damage to the enviionment-which must be measuied in teims of a
value system involving some metiic. Finally, theie is the context of the iisk
assessment, which is ielated to what is at iisk, what individuals oi agencies
aie measuiing and assessing the iisk and how iisk-aveise they might be,
the necessity foi oi feasibility of iisk management, and how additional
investment in iisk ieduction can be balanced against available iesouices.
Risk Benchmarks in Current Structural Codes
Stiuctuial codes and standaids and design piactice histoiically have
stiiven to delivei stiuctuial pioducts and systems with iisks that the pub-
Ris|lríc|aeJ /uu|coc|es tc Soíet] Re¸uloticr 
lic fnds acceptable. In the vast majoiity of studies to date involving
stiuctuial peifoimance and ieliability, the teim °iisk" is used moie oi
less inteichangeably with °piobability" oi is thought of as the comple-
ment of °ieliability" (Ellingwood 1994). Consequences (e.g., economic
losses; moibidity and moitality) aie included only indiiectly, if at all; low
taiget piobability goals aie typically assigned, somewhat aibitiaiily and
on the basis of judgment, to high-consequence events. While cuiient
codes and standaids as well as code enfoicement keep failuie iates at a
low level, no one knows exactly what a socially acceptable failuie iate foi
buildings, biidges, and othei stiuctuies might be, although stiuctuial
engineeis believe that cuiient codes and standaids delivei civil infia-
stiuctuie with iisks that aie acceptable in most cases. At the othei
extieme, the de minimis iisk below which society noimally does not
impose any iegulatoiy guidance is on the oidei of 10
7
/yeai (Paté-Coinell
1994). Failuie iates foi buildings, biidges, dams, and othei civil infia-
stiuctuie that may be calculated thiough the use of classical ieliability
analysis (Ellingwood 2000) fall in a iange between 10
3
/yeai and 10
7
/yeai,
a giay aiea within which iisk-ieduction measuies aie tiaded off against
inciements in the cost of iisk ieduction. The notion of having iisks °as
low as ieasonably piacticable" (Stewait and Melcheis 1997), which is
common in industiial iisk management, is based on this concept. In
sum, what constitutes acceptable iisk is ielative and can be established
oi mandated only in the context of what is acceptable in othei activities,
what investment is iequiied to ieduce the iisk (oi socialize it), and what
losses might be entailed if the iisk weie to inciease.
The following section consideis how the geneial concepts of iisk assess-
ment and management summaiized above have been implemented foi
seveial types of civil infiastiuctuie. The unique natuie of each infiastiuc-
tuie type deteimines how specifc iisk-infoimed decision concepts have
been implemented.
PROBABILITY-BASED LIMIT STATES DESIGN
Load and Resistance Factor Design
Stiuctuial codes and standaids applicable to the design of civil infia-
stiuctuie tiaditionally have been conceined piimaiily with public safety
(pieventing loss of life oi peisonal injuiy) and, in this context, the collapse
 Structural lntegrity of 0ffshore Wind Turbines
of a stiuctuie oi a laige poition of it. The piobability of stiuctuial col-
lapse is a suiiogate foi all othei metiics, and limiting that piobability
addiesses the fundamental goal. Most fist-geneiation piobability-based
stiuctuial design codes focus on that peifoimance objective. Othei pei-
foimance metiics-diiect economic losses fiom stiuctuial damage,
indiiect losses due to inteiiuption of function, foigone oppoitunities,
and loss of amenity-have not been addiessed in cuiient constiuction
iegulations but may be of concein to ceitain stakeholdei gioups in cei-
tain types of infiastiuctuie facilities.
The use of classical stiuctuial ieliability piinciples and code calibia-
tion has histoiically foimed the basis foi the development of load com-
binations in Ameiican Society of Civil Engineeis (ASCE) Standaid 7-10,
Minimum Design Icads fcr Buildings and Cther Structures (ASCE 2010);
Euiocode 1, Acticns cn Structures (CEN 1994); and stiuctuial stiength
ciiteiia found in most standaids and specifcations (e.g., AASHTO 2007;
ACI 2005; AISC 2010). Such codifed pioceduies gloss ovei the issue of
consequence and context by piesuming that °iisk" and °piobability of
collapse" aie identical. Howevei, these pioceduies avoid the diffculty
of selecting appiopiiate iisk (loss) metiics and tiansfoim the analysis of
iisk into a pioblem amenable to solution by piinciples of stiuctuial ieli-
ability theoiy (Ellingwood 1994; Melcheis 1999), which is an essential
step in fist-geneiation piobability-based stiuctuial design.
In modein piobability-based limit states design codes, the iequiie-
ment that the ieliability equal oi exceed a taiget ieliability is tiansfoimed
into a tiaditional safety-checking equation:
The iequiied stiength to iesist loads, shown on the left-hand side of the
equation, is deteimined fiom stiuctuial analysis by using factcred loads,
while the design stiength (oi factoied iesistance) on the iight-hand side
is deteimined by using nominal mateiial stiengths and dimensions and
paitial iesistance factcrs. The load and iesistance factois aie functions of
the unceitainties associated with the load and iesistance vaiiables and the
taiget ieliability index. The taiget ieliability index, in tuin, may depend
on the failuie mode (e.g., biittle oi ductile) and the consequences of
a membei failuie (e.g., local damage, possibility of global instability).
Requiied stiength design stiength  
 
     (( ) A-1
Ris|lríc|aeJ /uu|coc|es tc Soíet] Re¸uloticr 
The most common iepiesentation of Equation A-1 in the United States
is as follows:
wheie R
n
is a specifed nominal (chaiacteiistic) stiength,  is a iesistance
factoi, Q
ni
is the nominal (chaiacteiistic) load, and 
i
is the associated
load factoi foi load type i. The design foimat suggested by Equation A-2
is tianspaiently deteiministic, but the load and iesistance factois aie in
fact based on explicit ieliability benchmaiks (ieliability indices) obtained
thiough a complex piocess of code calibiation.
Existing Implementation of Load and Resistance Factor
Design; Measures of Reliability

The fist piobability-based design specifcation in the United States
¦denoted as load and iesistance factoi design (LRFD) foi steel stiuctuies]
was intioduced in 1986 and has since been followed by seveial othei
specifcations. LRFD is now a matuie concept and has been widely used
in stiuctuial design piactice foi the past two decades.
The iequiied stiength, 
i
Q
ni
, is deteimined, in all cases, fiom the set of
load combinations stipulated by ASCE Standaid 7-10. In fist-geneiation
LRFD (Galambos et al. 1982; Ellingwood et al. 1982), the benchmaik
taiget ieliability index () foi a member limit state involving yielding of a
tension membei oi foimation of the fist plastic hinge in a compact beam
was set equal to appioximately 3.0 foi a seivice peiiod of 50 yeais, coiie-
sponding to a limit state piobability of appioximately 0.0013 in 50 yeais;
annualized, this piobability is on the oidei of 10
5
. The value of  equal
to 3.0 was selected following an extensive assessment of ieliabilities asso-
ciated with membeis designed by tiaditional methods and is applicable
to load combinations involving giavity loads but not wind oi eaithquake
loads (Galambos et al. 1982).
1
Reliability indices foi othei limit states
weie set ielative to 3.0 (e.g., ieliability index values foi connections aie on
the oidei of 4.0 to ensuie that failuie occuis in the membei iathei than
 
  
  

  
1
The annual piobability of paitial oi total collapse of a piopeily designed iedundant stiuctuial
fiame is appioximately one oidei of magnitude less, oi on the oidei of 10
6
/yeai.
 Structural lntegrity of 0ffshore Wind Turbines
in the connection; because the cost of connection design is deteimined
piimaiily by fabiication iathei than mateiials, pioviding the additional
conseivatism has little economic impact). Similai benchmaiks have been
adopted foi most othei building constiuction mateiials.
Brídges
The Ameiican Association of State Highway and Tianspoitation Off-
cials (AASHTO) IRFD Bridge Design Specifcaticns dates fiom 1994, with
the 2007 edition being the latest. The piobabilistic design methodology
adopted theie is essentially the same as that used foi building stiuctuies.
The suppoiting study (Nowak 1995) focused on the stiength of individ-
ual biidge giideis, with tiuck loads applied to the individual giideis
thiough empiiically deiived giidei distiibution factois foi moment and
sheai. AASHTO uses essentially the same LRFD foimat as is used foi
oidinaiy buildings and othei stiuctuies. The load and iesistance factois
in the IRFD Bridge Design Specifcaticns (AASHTO 2007) weie devel-
oped in such a way that biidge giideis achieve a ieliability index, , equal
to 3.5 at the inventoiy oi design level foi a seivice peiiod of 75 yeais. No
distinction is made between steel, ieinfoiced conciete, and piestiessed
conciete giideis in teims of theii taiget ieliabilities, noi is the taiget ieli-
ability index dependent on the giidei span oi on whethei the giidei is
simply suppoited oi continuous ovei inteinal suppoits.
Offshore Platforms
Foimal design guidance foi offshoie stiuctuies oiiginated in 1967 with
the ielease of Ameiican Petioleum Institute (API) RP 2A (API 1967).
This standaid used a woiking stiess appioach, consistent with the pie-
vailing steel design piactice foi land stiuctuies. In 1979, woik began on
development of an LRFD veision of API RP 2A. The foimat was paiallel
to that developed by Galambos et al. (1982). The calibiation stiategy
focused on developing paitial factois foi identifed components that
would yield a platfoim design having membeis and connections equiv-
alent to those iesulting fiom use of the existing woiking stiess code. This
appioach was summaiized by Moses and Laiiabee (1988):
The tiaditional one-thiid allowable stiess inciease foi enviionmental loading
found in woiking stiess design (WSD) has been ieplaced in the Diaft RP2A-
Ris|lríc|aeJ /uu|coc|es tc Soíet] Re¸uloticr 
LRFD by sepaiate load factois () foi dead load, live load, wind-wave-cuiient
load, eaithquake load and wave dynamic load. Resistance factois () vaiy foi
pile capacity, beam bending, axial compiession, hydiostatic piessuie, etc.
Togethei, these load and iesistance factois piovide a level of safety close to
piesent piactice, yet piovide moie unifoim safety and economy.
Calibiated -values ianged fiom 2.0 to 2.8 foi a 20-yeai seivice life
with a 100-yeai loading event used as the iefeience load level. Similai val-
ues foi the Noith Sea weie developed by Tuinei et al. (1992). Recently,
Inteinational Oiganization foi Standaidization (ISO) 19902:2007, Fixed
Offshoie Steel Stiuctuies, which was based on API RP 2A-LRFD and
expanded to include loading specifcs foi inteinational locations, became
available and is iefeienced in the Inteinational Electiotechnical Commis-
sion (IEC) offshoie wind tuibine design standaid (i.e., IEC 61400-3) as the
offshoie stiuctuial guidance document.
Other Cívíl Infrastructure Applícatíons
As noted above, piobability-based design of buildings and biidges has
focused on membei oi component limit states and has measuied ielia-
bility by making use of the ieliability index . Moie iecent applications
of iisk-infoimed decision making to civil infiastiuctuie, biought about
in pait by the move towaid peifoimance-based engineeiing, have con-
sideied system behavioi and expiessed peifoimance thiough limit state
piobabilities iathei than thiough use of the ieliability index. These devel-
opments have been made possible thiough advances in stiuctuial com-
putation, which now make nonlineai dynamic analysis of complex
building and biidge stiuctuies feasible in design. Seveial standaids and
guidelines have begun to adopt such concepts.
ASCE 7-10 Commentary 1.3.1.3 ASCE Standaid 7-10 has implemented
a new geneial design iequiiement foi peifoimance-based pioceduies. The
commentaiy to these pioceduies contains two tables with acceptable ieli-
ability levels: the fist stipulates annual limit state piobabilities and ielia-
bility indices foi nonseismic events, and the second piovides anticipated
piobabilities of stiuctuial failuie foi eaithquakes. These acceptable ielia-
bility levels aie dependent on the iisk categoiy of the stiuctuial facility and
the natuie of the stiuctuial failuie involved. In nonseismic design situa-
tions, the acceptable annual piobability of failuie ianges fiom 3 10
5
/yeai
 Structural lntegrity of 0ffshore Wind Turbines
foi failuies that aie benign to 7  10
7
/yeai foi failuies that aie sudden and
lead to widespiead damage oi collapse. In seismic situations, the accept-
able piobabilities aie conditioned on the design-basis event; foi oidinaiy
building stiuctuies, this conditional piobability (given occuiience of the
design-basis event) is 10 peicent foi total oi paitial collapse.
ASCE Standard 43-05 Standaid 43-05 (ASCE 2005) addiesses seismic
design ciiteiia foi nucleai facilities. Like ASCE Standaid 7-10, it adopts
a unifoim iisk appioach to eaithquake-iesistant design iathei than a
unifoim hazaid appioach. Table 1-2 of this standaid stipulates taiget
peifoimance goals in teims of the annual piobability of failuie foi facil-
ities iequiiing diffeient levels of piotection. Foi facilities iequiiing con-
fnement of highly hazaidous mateiials with high confdence, the taiget
piobability is 10
5
/yeai oi less, and the stiuctuie must be designed to
iemain essentially elastic undei such conditions.
CRITICAL APPRAISAL OF EXISTING RISK-INFORMED
ANALYSIS AND DESIGN PRACTICES FOR APPLICATION
TO OFFSHORE WIND TURBINES
Component Versus System Reliability Analysis
Most codifed ieliability-based design foi civil infiastiuctuie has focused
on individual buildings, biidges, and othei industiial facilities foi which
the hazaid can be identifed at a point (e.g., Ellingwood 2007). A distin-
guishing and essential featuie of iisk-infoimed decision tools foi wind tui-
bine faims in coastal and offshoie enviionments is theii ability to account
foi the spatial coiielation in the intensity of the hazaid (such as fiom a hui-
iicane) ovei geogiaphic scales on the oidei of tens of kilometeis within the
iegion affected (Vickeiy and Twisdale 1995); multiple wind tuibine units
expeiience coiielated iisks undei such conditions. In addition, the
piesence (oi lack) of advanced waining systems and the effect on iisk-
mitigation options should be consideied (Lakats and Paté-Coinell 2004).
Design MRIs of Joint Wind Effects
MRIs of design wind effects foi stiength design have typically been spec-
ifed with consideiation foi knowledge unceitainties. Such unceitainties
Ris|lríc|aeJ /uu|coc|es tc Soíet] Re¸uloticr 
inßuence, foi example, estimates of wind effects associated with a 50- oi
100-yeai MRI. Foi typical building occupancies, ASCE Standaid 7-10
specifes a 700-yeai MRI wind speed. Similai MRI estimates aie needed foi
wave and cuiient effects oi foi combined wind, wave, and cuiient effects.
Note that the MRI is insuffcient to establish the stiuctuial ieliability. The
associated load factoi also plays a key iole; foi example, the piobability of
exceedance of some load level, 1.6 with deteimined on the basis of a
50-yeai MRI wind speed, is about the same as the piobability of exceeding
1.0when is defned on the basis of a 700-yeai wind speed. This is also
the ieason why the IEC-based offshoie wind tuibine design pioceduie,
which begins with a 50-yeai wind speed basis and applies load factois of
1.25 oi 1.35 when veiifying ultimate limit states, might yield the same ieli-
ability as the use of an alteinative factoied load that begins with a 100-yeai
wind speed (as in API RP 2A) and applies a load factoi of 1.0.
Wheieas a typical MRI foi an offshoie oil and gas platfoim design is
100 yeais, a 50-yeai MRI is commonly used foi offshoie wind tuibines
in Euiope. Although the combination of the MRI and an associated load
factoi can lead to similai ieliability levels with eithei the 50- oi the 100-yeai
MRI, the 50-yeai MRI used foi offshoie wind tuibines in Euiope paitly
ießects the thinking that consequences of a tuibine failuie typically do
not lead to loss of life oi giave enviionmental effects (see Chaptei 4). The
selection of MRI foi the design-basis event of a facility is not suffcient to
deteimine the iisk foi that facility.
Finally, to account explicitly foi economic consequences oi the con-
sequences of an unieliable eneigy supply, appioaches similai to those
piesented biießy in this appendix may be used to establish appiopiiate
alteinative design MRIs, iathei than an appioach based on engineeiing
judgment with iegaid to stiuctuial peifoimance.
Time-Domain Methods
Computei-intensive time-domain methods similai to those iecently
developed by Simiu and Miyata (2006) and Long et al. (2007) can allow
iigoious estimates of () combined load effects, with any mean iecui-
ience inteival, fiom Monte Cailo simulations of simultaneous time his-
toiies of wind, wave, cuiient, and stoim suige effects; and () attendant
unceitainties in those estimates. Such methods will help to shaipen sig-
nifcantly estimates of combined load effects used foi allowable stiess
 Structural lntegrity of 0ffshore Wind Turbines
design, stiength design, limit states design, and design foi fatigue, and to
defne geogiaphical aieas whose enviionmental conditions aie compat-
ible with the use of specifed classes of tuibine designs.

Abbrevíatíons
AASHTO Ameiican Association of State Highway and Tianspoitation Offcials
ACI Ameiican Conciete Institute
AISC Ameiican Institute of Steel Constiuction
API Ameiican Petioleum Institute
ASCE Ameiican Society of Civil Engineeis
CEN Comité euiopéen de noimalisation
AASHTO. 2007. AASHTC IRFD Bridge Design Specifcaticns. Washington, D.C.
ACI. 2005. Building Ccde Requirements fcr Structural Ccncrete. Standaid 318-05. Faim-
ington Hills, Mich.
AISC. 2010. Specifcaticn fcr Structural Steel Buildings. Chicago, Ill.
API. 1967. Reccmmended Practice fcr Planning, Designing and Ccnstructing Fixed Cffshcre
Platfcrms. Washington, D.C.
ASCE. 2005. Seismic Design Criteria fcr Structures, Systems and Ccmpcnents in Nuclear
Facilities. Standaid 43-05. Reston, Va.
ASCE. 2010. Minimum Design Icads fcr Buildings and Cther Structures. ASCE Standaid
7-10. Reston, Va.
CEN. 1994. Acticns cn Structures, Part 1-Basis cf Design. Euiocode 1, Euiopean Pie-
standaid ENV 1991-1. Biussels, Belgium.
Ellingwood, B. R. 1994. Piobability-Based Codifed Design: Past Accomplishments and
Futuie Challenges. Structural Safety, Vol. 13, No. 3, pp. 159-176.
Ellingwood, B. R. 2000. LRFD: Implementing Stiuctuial Reliability in Piofessional Piac-
tice. Engineering Structures, Vol. 22, No. 2, pp. 106-115.
Ellingwood, B. R. 2007. Stiategies foi Mitigating Risk to Buildings fiom Abnoimal Load
Events. Internaticnal }curnal cf Risk Assessment and Management, Vol. 7, Nos. 6-7,
pp. 828-845.
Ellingwood, B., J. G. MacGiegoi, T. V. Galambos, and C. A. Coinell. 1982. Piobability-
Based Load Ciiteiia: Load Factois and Load Combinations. }curnal cf the Structural
Divisicn, ASCE, Vol. 108, No. 5, May, pp. 978-997.
Fabei, M. H., and M. G. Stewait. 2003. Risk Assessment foi Civil Engineeiing Facilities:
Ciitical Oveiview and Discussion. Reliability Engineering and System Safety, Vol. 80,
pp. 173-184.
Ris|lríc|aeJ /uu|coc|es tc Soíet] Re¸uloticr 
Galambos, T. V., B. Ellingwood, J. G. MacGiegoi, and C. A. Coinell. 1982. Piobability-
Based Load Ciiteiia: Assessment of Cuiient Design Piactice. }curnal cf the Structural
Divisicn, ASCE, Vol. 108, No. 5, May, pp. 959-977.
Lakats, L. M., and M. E. Paté-Coinell. 2004. Oiganizational Wainings and System Safety:
A Piobabilistic Analysis. IEEE Transacticns cn Engineering Management, Vol. 51,
No. 2, May, pp. 183-196.
Long, P. T., E. Simiu, A. McIneiney, A. A. Tayloi, B. Glahn, and M. D. Powell. 2007.
Methcdclcgy fcr Develcpment cf Design Criteria fcr }cint Hurricane \ind Speed and
Stcrm Surge Events. Prccf cf Ccncept. NIST Technical Note 1482. National Institute
of Standaids and Technology, Gaitheisbuig, Md.
Melcheis, R. E. 1999. Structural Reliability. Analysis and Predicticn. John Wiley and Sons,
Chichestei, United Kingdom.
Moses, F., and R. D. Laiiabee. 1988. Calibiation of the Diaft RP 2A-LRFD foi Fixed Plat-
foims. OTC 5699. Prcc., Cffshcre Technclcgy Ccnference, Houston, Tex.
Nowak, A. S. 1995. Calibiation of LRFD Biidge Code. }curnal cf Structural Engineering,
ASCE, Vol. 121, No. 8, pp. 1245-1251.
Paté-Coinell, M. E. 1994. Quantitative Safety Goals foi Risk Management of Industiial
Facilities. Structural Safety, Vol. 13, No. 3, pp. 145-157.
Simiu, E., and T. Miyata. 2006. Design cf Buildings and Bridges fcr \ind. John Wiley and
Sons, Hoboken, N.J.
Stewait, M. G., and R. E. Melcheis. 1997. Prcbabilistic Risk Assessment cf Engineering
Systems. Chapman and Hall, London.
Tuinei, R. C., C. P. Ellinas, and G. A. N. Thomas. 1992. Towaids the Woildwide Cal-
ibiation of API RP2A-LRFD. OTC 6930. Prcc., Cffshcre Technclcgy Ccnference,
Houston, Tex.
Vickeiy, P. J., and L. A. Twisdale. 1995. Piediction of Huiiicane Wind Speeds in the
United States. }curnal cf Structural Engineering, ASCE, Vol. 121, pp. 1691-1699.
Viijling, J. K., W. Van Hengel, and R. J. Houben. 1998. Acceptable Risk as a Basis foi
Design. Reliability Engineering and System Safety, Vol. 59, pp. 141-150.
/ | | E l 0 l X B
Text of Pertinent Regulations
This appendix contains the peitinent text of iegulations fiom 30 CFR
250 and 30 CFR 285 cited in the body of the iepoit. Only the iegulations
conceining ceitifed veiifcation agents (CVAs) aie included.
REQUIREMENTS FOR CVAs IN BOEMRE OIL
AND GAS REGULATIONS
Below aie exceipts fiom 30 CFR Pait 250, °Oil and Gas and Sulphui
Opeiations in the Outei Continental Shelf."
§ 230.916 What are the CVA's primary duties during the design phase?
a. The CVA must use good engineeiing judgment and piactices in con-
ducting an independent assessment of the design of the platfoim, majoi
modifcation, oi iepaii. The CVA must ensuie that the platfoim, majoi
modifcation, oi iepaii is designed to withstand the enviionmental and
functional load conditions appiopiiate foi the intended seivice life at
the pioposed location.
b. Piimaiy duties of the CVA duiing the design phase include the fol-
lowing: ¦Table 1].
c. The CVA must submit inteiim iepoits and a fnal iepoit to the Regional
Supeivisoi, and to you, duiing the design phase in accoidance with the
appioved schedule iequiied by §250.911(d). In each inteiim and fnal
iepoit the CVA must
1. Piovide a summaiy of the mateiial ieviewed and the CVA`s fndings;
2. In the fnal CVA iepoit, make a iecommendation that the Regional
Supeivisoi eithei accept, iequest modifcations, oi ieject the pio-
posed design unless such a iecommendation has been pieviously
made in an inteiim iepoit;

Tert cí |e|tirert Re¸uloticrs 149
3. Desciibe the paiticulais of how, by whom, and when the indepen-
dent ieview was conducted; and
4. Piovide any additional comments the CVA deems necessaiy.
§ 230.917 What are the CVA's primary duties during the fabrication
phase?
a. The CVA must use good engineeiing judgment and piactices in con-
ducting an independent assessment of the fabiication activities. The
CVA must monitoi the fabiication of the platfoim oi majoi modifca-
tion to ensuie that it has been built accoiding to the appioved design and
fabiication plan. If the CVA fnds that fabiication pioceduies aie
changed oi design specifcations aie modifed, the CVA must infoim
you. If you accept the modifcations, then the CVA must so infoim the
Regional Supeivisoi.
b. Piimaiy duties of the CVA duiing the fabiication phase include the
following: ¦Table 2].
c. The CVA must submit inteiim iepoits and a fnal iepoit to the Regional
Supeivisoi, and to you, duiing the fabiication phase in accoidance with
IAßLE 1
Iype oI IaciIity . . . Ihe 6¥A æust . . .
,1} |c| íreJ ulotíc|as orJ
rcrs|ius|oueJ ícotir¸
íocilities
,Z} |c| oll ícotir¸ íocilities
CcrJuct or irJeuerJert ossessaert cí oll u|cucseJ.
,i} |lorrir¸ c|ite|io,
,ii} 0ue|oticrol |eçui|eaerts,
,iii} Er.i|craertol lcoJir¸ Joto,
,i.} |coJ Jete|airoticrs,
,.} St|ess orol]ses,
,.i} Mote|iol Jesi¸roticrs,
,.ii} Scil orJ ícurJoticr ccrJiticrs,
,.iii} Soíet] íoctc|s, orJ
,ir} 0t|e| ue|tirert uo|oaete|s cí t|e u|cucseJ Jesi¸r.
Ersu|e t|ot t|e |eçui|eaerts cí t|e u.S. Ccost Cuo|J íc| st|uctu|ol
irte¸|it] orJ sto|ilit], e.¸., .e|iícoticr cí certe| cí ¸|o.it], etc., |o.e
|eer aet. T|e CV/ aust olsc ccrsiJe|.
,i} 0|illir¸, u|cJucticr, orJ uiuelire |ise|s, orJ |ise| tersicrir¸ s]steas,
,ii} Tu||ets orJ tu||etorJ|ull irte|íoces,
,iii} |curJoticrs, ícurJoticr uilir¸s orJ teaulotes, orJ orc|c|ir¸
s]steas, orJ
,i.} Mcc|ir¸ c| tet|e|ir¸ s]steas.
IAßLE 2
Iype oI IaciIity . . . Ihe 6¥A æust . . .
,1} |c| íreJ ulotíc|as orJ
rcrs|ius|oueJ ícotir¸
íocilities
,Z} |c| oll ícotir¸ íocilities
150 Structural lntegrity of 0ffshore Wind Turbines
Mo|e ue|icJic crsite irsuecticrs w|ile ío||icoticr is ir
u|c¸|ess orJ aust .e|ií] t|e ícllcwir¸ ío||icoticr
iteas, os ouu|cu|iote.
,i} 0uolit] ccrt|cl |] lessee orJ |uilJe|,
,ii} |o||icoticr site íocilities,
,iii} Mote|iol çuolit] orJ iJertiícoticr aet|cJs,
,i.} |o||icoticr u|cceJu|es sueciíeJ ir t|e ouu|c.eJ ulor,
orJ oJ|e|erce tc suc| u|cceJu|es,
,.} welJe| orJ welJir¸ u|cceJu|e çuoliíicoticr orJ
iJertiíicoticr,
,.i} St|uctu|ol tcle|orces sueciíeJ orJ oJ|e|erce tc t|cse
tcle|orces,
,.ii} T|e rcrJest|ucti.e eroairoticr |eçui|eaerts, orJ
e.oluoticr |esults cí t|e sueciíeJ eroairoticrs,
,.iii} 0est|ucti.e testir¸ |eçui|eaerts orJ |esults,
,ir} Reuoi| u|cceJu|es,
,r} lrstolloticr cí cc||csicru|ctecticr s]steas orJ sulos|
/cre u|ctecticr,
,ri} E|ecticr u|cceJu|es tc ersu|e t|ot c.e|st|essir¸ cí
st|uctu|ol aea|e|s Jces rct cccu|,
,rii} /li¸raert u|cceJu|es,
,riii} 0iaersicrol c|ec| cí t|e c.e|oll st|uctu|e, ircluJir¸ or]
tu||ets, tu||etorJ|ull irte|íoces, or] acc|ir¸ lire orJ
c|oir orJ |ise| tersicrir¸ lire se¸aerts, orJ
,ri.} Stotus cí çuolit]ccrt|cl |ecc|Js ot .o|icus sto¸es cí
ío||icoticr.
Ersu|e t|ot t|e |eçui|eaerts cí t|e u.S. Ccost Cuo|J ícotir¸
íc| st|uctu|ol irte¸|it] orJ sto|ilit], e.¸., .e|iícoticr cí
certe| cí ¸|o.it], etc., |o.e |eer aet. T|e CV/ aust olsc
ccrsiJe|.
,i} 0|illir¸, u|cJucticr, orJ uiuelire |ise|s, orJ |ise| tersicr
ir¸ s]steas ,ot leost íc| t|e iritiol ío||icoticr cí t|ese
eleaerts},
,ii} Tu||ets orJ tu||etorJ|ull irte|íoces,
,iii} |curJoticr uilir¸s orJ teaulotes, orJ orc|c|ir¸
s]steas, orJ
,i.} Mcc|ir¸ c| tet|e|ir¸ s]steas.
Tert cí |e|tirert Re¸uloticrs 
the appioved schedule iequiied by §250.911(d). In each inteiim and
fnal iepoit the CVA must
1. Give details of how, by whom, and when the independent moni-
toiing activities weie conducted;
2. Desciibe the CVA`s activities duiing the veiifcation piocess;
3. Summaiize the CVA`s fndings;
4. Confim oi deny compliance with the design specifcations and the
appioved fabiication plan;
5. In the fnal CVA iepoit, make a iecommendation to accept oi
ieject the fabiication unless such a iecommendation has been pie-
viously made in an inteiim iepoit; and
6. Piovide any additional comments that the CVA deems necessaiy.
¦70 FR 41575, July 19, 2005, as amended at 73 FR 64547, Oct. 30, 2008.]
§ 230.918 What are the CVA's primary duties during the installation
phase?
a. The CVA must use good engineeiing judgment and piactices in con-
ducting an independent assessment of the installation activities.
b. Piimaiy duties of the CVA duiing the installation phase include the
following: ¦Table 3].
c. The CVA must submit inteiim iepoits and a fnal iepoit to the Regional
Supeivisoi, and to you, duiing the installation phase in accoidance with
the appioved schedule iequiied by §250.911(d). In each inteiim and
fnal iepoit the CVA must
1. Give details of how, by whom, and when the independent moni-
toiing activities weie conducted;
2. Desciibe the CVA`s activities duiing the veiifcation piocess;
3. Summaiize the CVA`s fndings;
4. Confim oi deny compliance with the appioved installation plan;
5. In the fnal CVA iepoit, make a iecommendation to accept oi ieject
the installation unless such a iecommendation has been pieviously
made in an inteiim iepoit; and
6. Piovide any additional comments that the CVA deems necessaiy.
¦70 FR 41575, July 19, 2005, as amended at 73 FR 64547, Oct. 30, 2008.]
152 Structural lntegrity of 0ffshore Wind Turbines
IAßLE 3
Ihe 6¥A æust . . . üperatioo or eguipæeot to be iospected . . .
,1} Ve|ií], os ouu|cu|iote
,Z} witress ,íc| o íreJ c| ícotir¸
ulotíc|a}
,3} witress ,íc| o ícotir¸ ulotíc|a}
,+} CcrJuct or crsite su|.e]
,5} Suctc|ec| os recesso|] tc
Jete|aire ccauliorce wit| t|e
ouulico|le Jccuaerts listeJ ir
sZ50.901,o}, t|e olte|roti.e ccJes,
|ules orJ storJo|Js ouu|c.eJ
urJe| sZ50.901,|}, t|e
|eçui|eaerts listeJ ir sZ50.903
orJ sZ50.90c t||cu¸|
Z50.908 cí t|is su|uo|t orJ
t|e ouu|c.eJ ulors.
,i} |coJcut orJ iritiol íctoticr cue|oticrs,
,ii} Tcwir¸ cue|oticrs tc t|e sueciíeJ lccoticr, orJ |e.iew
t|e tcwir¸ |ecc|Js,
,iii} |ourc|ir¸ orJ uu|i¸|tir¸ cue|oticrs,
,i.} Su|ae|¸erce cue|oticrs,
,.} |ile c| orc|c| irstolloticrs,
,.i} lrstolloticr cí acc|ir¸ orJ tet|e|ir¸ s]steas,
,.ii} |irol Jec| orJ ccaucrert irstolloticrs, orJ
,.iii} lrstolloticr ot t|e ouu|c.eJ lccoticr occc|Jir¸ tc t|e
ouu|c.eJ Jesi¸r orJ t|e irstolloticr ulor.
,i} T|e lcoJcut cí t|e joc|et, Jec|s, uiles, c| st|uctu|es í|ca
eoc| ío||icoticr site,
,ii} T|e octuol irstolloticr cí t|e ulotíc|a c| aojc| acJiíco
ticr orJ t|e |eloteJ irstolloticr octi.ities,
,i} T|e lcoJcut cí t|e ulotíc|a,
,ii} T|e irstolloticr cí J|illir¸, u|cJucticr, orJ uiuelire |is
e|s, orJ |ise| tersicrir¸ s]steas ,ot leost íc| t|e iritiol
irstolloticr cí t|ese eleaerts},
,iii} T|e irstolloticr cí tu||ets orJ tu||etorJ|ull irte|íoces,
,i.} T|e irstolloticr cí ícurJoticr uilir¸s orJ teaulotes, orJ
orc|c|ir¸ s]steas, orJ
,.} T|e irstolloticr cí t|e acc|ir¸ orJ tet|e|ir¸ s]steas.
Su|.e] t|e ulotíc|a oíte| t|orsuc|toticr tc t|e ouu|c.eJ
lccoticr.
,i} Eçuiuaert,
,ii} ||cceJu|es, orJ
,iii} Recc|J|eeuir¸.
Tert cí |e|tirert Re¸uloticrs 153
REQUIREMENTS FOR CVAs IN BOEMRE RENEWABLE
ENERGY REGULATIONS
Below aie exceipts fiom 30 CFR Pait 285, °Renewable Eneigy Alteinate
Uses of Existing Facilities on the Outei Continental Shelf."
§ 283.703 When must I use a Certined Verincation Agent (CVA)?
You must use a CVA to ieview and ceitify the Facility Design Repoit, the
Fabiication and Installation Repoit, and the Pioject Modifcations and
Repaiis Repoit.
a. You must use a CVA to
1. Ensuie that youi facilities aie designed, fabiicated, and installed in
confoimance with accepted engineeiing piactices and the Facility
Design Repoit and Fabiication and Installation Repoit;
2. Ensuie that iepaiis and majoi modifcations aie completed in con-
foimance with accepted engineeiing piactices; and
3. Piovide MMS immediate iepoits of all incidents that affect the design,
fabiication, and installation of the pioject and its components.
b. The MMS may waive the iequiiement that you use a CVA if you can
demonstiate the following: ¦Table 4].
IAßLE 4
Iheo MM8 æay waive the reguireæeot Ior
II you deæoostrate that . . . a 6¥A Ior the IoIIowiog.
T|e Jesi¸r cí ]cu| st|uctu|e,s}.
T|e ío||icoticr cí ]cu| st|uctu|e,s}.
T|e irstolloticr cí ]cu| st|uctu|e,s}.
T|e |euoi| c| aojc| acJiícoticr cí ]cu|
st|uctu|e,s}.
T|e íocilit] Jesi¸r ccríc|as tc o storJo|J Jesi¸r
t|ot |os |eer useJ successíull] ir o siailo| er.i
|craert, orJ t|e irstolloticr Jesi¸r ccríc|as tc
occeuteJ er¸iree|ir¸ u|octices.
T|e aoruíoctu|e| |os successíull] aoruíoctu|eJ
siailo| íocilities, orJ t|e íocilit] will |e ío||i
coteJ ir ccríc|aorce wit| occeuteJ er¸iree|ir¸
u|octices.
T|e irstolloticr ccauor] |os successíull] irstolleJ
siailo| íocilities ir o siailo| cíís|c|e er.i|craert,
orJ ]cu| st|uctu|e,s} will |e irstolleJ ir ccríc|
aorce wit| occeuteJ er¸iree|ir¸ u|octices.
Reuoi|s orJ aojc| acJiícoticrs will |e ccauleteJ ir
ccríc|aorce wit| occeuteJ er¸iree|ir¸ u|octices.
 Structural lntegrity of 0ffshore Wind Turbines
c. You must submit a iequest to waive the iequiiement to use a CVA to
MMS in wiiting, along with youi SAP ¦site assessment plan] undei
§285.610(a)(9), COP ¦constiuction and opeiations plan] undei
§285.626(b)(20), oi GAP ¦geneial activities plan] undei §285.645(c)(5).
1. The MMS will ieview youi iequest to waive the use of the CVA and
notify you of oui decision along with oui decision on youi SAP,
COP, oi GAP.
2. If MMS does not waive the iequiiement foi a CVA, you may fle an
appeal undei §285.118.
3. If MMS waives the iequiiement that you use a CVA, youi pioject
engineei must peifoim the same duties and iesponsibilities as the
CVA, except as otheiwise piovided.
§ 283.706 How do I nominate a CVA for MMS approval?
a. As pait of youi COP (as piovided in §285.626(b)(20) and, when
iequiied by this pait, youi SAP (§285.610(a)(9)) oi GAP (§285.645(c)
(5)), you must nominate a CVA foi MMS appioval. You must spec-
ify whethei the nomination is foi the Facility Design Repoit, Fabiica-
tion and Installation Repoit, Modifcation and Repaii Repoit, oi foi
any combination of these.
b. Foi each CVA that you nominate, you must submit to MMS a list of
documents used in youi design that you will foiwaid to the CVA and
a qualifcation statement that includes the following:
1. Pievious expeiience in thiid-paity veiifcation oi expeiience in the
design, fabiication, installation, oi majoi modifcation of offshoie
eneigy facilities;
2. Technical capabilities of the individual oi the piimaiy staff foi the
specifc pioject;
3. Size and type of oiganization oi coipoiation;
4. In-house availability of, oi access to, appiopiiate technology (in-
cluding computei piogiams, haidwaie, and testing mateiials and
equipment);
5. Ability to peifoim the CVA functions foi the specifc pioject con-
sideiing cuiient commitments;
6. Pievious expeiience with MMS iequiiements and pioceduies, if
any; and
7. The level of woik to be peifoimed by the CVA.
Tert cí |e|tirert Re¸uloticrs 
c. Individuals oi oiganizations acting as CVAs must not function in any
capacity that will cieate a conßict of inteiest, oi the appeaiance of a
conßict of inteiest.
d. The veiifcation must be conducted by oi undei the diiect supeivision
of iegisteied piofessional engineeis.
e. The MMS will appiove oi disappiove youi CVA as pait of its ieview
of the COP oi, when iequiied, of youi SAP oi GAP.
f. You must nominate a new CVA foi MMS appioval if the pieviously
appioved CVA
1. Is no longei able to seive in a CVA capacity foi the pioject; oi
2. No longei meets the iequiiements foi a CVA set foith in this subpait.
§ 283.707 What are the CVA's primary duties for facility design
review?
If you aie iequiied to use a CVA,
a. The CVA must use good engineeiing judgment and piactices in con-
ducting an independent assessment of the design of the facility. The
CVA must ceitify in the Facility Design Repoit to MMS that the facility
is designed to withstand the enviionmental and functional load condi-
tions appiopiiate foi the intended seivice life at the pioposed location.
b. The CVA must conduct an independent assessment of all pioposed
1. Planning ciiteiia;
2. Opeiational iequiiements;
3. Enviionmental loading data;
4. Load deteiminations;
5. Stiess analyses;
6. Mateiial designations;
7. Soil and foundation conditions;
8. Safety factois; and
9. Othei peitinent paiameteis of the pioposed design.
c. Foi any ßoating facility, the CVA must ensuie that any iequiiements of
the U.S. Coast Guaid foi stiuctuial integiity and stability (e.g., veiifca-
tion of centei of giavity) have been met. The CVA must also considei
1. Foundations, foundation pilings and templates, and anchoiing sys-
tems; and
2. Mooiing oi tetheiing systems.
 Structural lntegrity of 0ffshore Wind Turbines
§ 283.708 What are the CVA's or project engineer's primary duties
for fabrication and installation review?
a. The CVA oi pioject engineei must do all of the following:
1. Use good engineeiing judgment and piactice in conducting an inde-
pendent assessment of the fabiication and installation activities;
2. Monitoi the fabiication and installation of the facility as iequiied
by paiagiaph (b) of this section;
3. Make peiiodic onsite inspections while fabiication is in piogiess
and veiify the items iequiied by §285.709;
4. Make peiiodic onsite inspections while installation is in piogiess
and satisfy the iequiiements of §295.710; and
5. Ceitify in a iepoit that pioject components aie fabiicated and
installed in accoidance with accepted engineeiing piactices; youi
appioved COP, SAP, oi GAP (as applicable); and the Fabiication
and Installation Repoit.
i. The iepoit must also identify the location of all iecoids peitain-
ing to fabiication and installation, as iequiied in §285.714(c); and
ii. You may commence commeicial opeiations oi othei appioved
activities 30 days aftei MMS ieceives that ceitifcation iepoit,
unless MMS notifes you within that time peiiod of its objec-
tions to the ceitifcation iepoit.
b. To comply with paiagiaph (a)(5) of this section, the CVA oi pioject
engineei must monitoi the fabiication and installation of the facility
to ensuie that it has been built and installed accoiding to the Facility
Design Repoit and Fabiication and Installation Repoit.
1. If the CVA oi pioject engineei fnds that fabiication and installa-
tion pioceduies have been changed oi design specifcations have
been modifed, the CVA oi pioject engineei must infoim you; and
2. If you accept the modifcations, then you must also infoim MMS.
§ 283.709 When conducting onsite fabrication inspections, what
must the CVA or project engineer verify?
a. To comply with §285.708(a)(3), the CVA oi pioject engineei must
make peiiodic onsite inspections while fabiication is in piogiess and
must veiify the following fabiication items, as appiopiiate:
1. Quality contiol by lessee (oi giant holdei) and buildei;
2. Fabiication site facilities;
Tert cí |e|tirert Re¸uloticrs 
3. Mateiial quality and identifcation methods;
4. Fabiication pioceduies specifed in the Fabiication and Installa-
tion Repoit, and adheience to such pioceduies;
5. Weldei and welding pioceduie qualifcation and identifcation;
6. Stiuctuial toleiances specifed, and adheience to those toleiances;
7. Nondestiuctive examination iequiiements and evaluation iesults
of the specifed examinations;
8. Destiuctive testing iequiiements and iesults;
9. Repaii pioceduies;
10. Installation of coiiosion-piotection systems and splash-zone
piotection;
11. Eiection pioceduies to ensuie that oveistiessing of stiuctuial
membeis does not occui;
12. Alignment pioceduies;
13. Dimensional check of the oveiall stiuctuie, including any tuiiets,
tuiiet-and-hull inteifaces, any mooiing line and chain and iisei
tensioning line segments; and
14. Status of quality-contiol iecoids at vaiious stages of fabiication.
b. Foi any ßoating facilities, the CVA oi pioject engineei must ensuie
that any iequiiements of the U.S. Coast Guaid foi stiuctuial integiity
and stability (e.g., veiifcation of centei of giavity) have been met. The
CVA oi pioject engineei must also considei
1. Foundations, foundation pilings and templates, and anchoiing
systems; and
2. Mooiing oi tetheiing systems.
§ 283.710 When conducting onsite installation inspections, what
must the CVA or project engineer do?
To comply with §285.708(a)(4), the CVA oi pioject engineei must make
peiiodic onsite inspections while installation is in piogiess and must,
as appiopiiate, veiify, witness, suivey, oi check, the installation items
iequiied by this section.
a. The CVA oi pioject engineei must veiify, as appiopiiate, all of the
following:
1. Loadout and initial ßotation pioceduies;
2. Towing opeiation pioceduies to the specifed location, and ieview
the towing iecoids;
 Structural lntegrity of 0ffshore Wind Turbines
3. Launching and upiighting activities;
4. Submeigence activities;
5. Pile oi anchoi installations;
6. Installation of mooiing and tetheiing systems;
7. Final deck and component installations; and
8. Installation at the appioved location accoiding to the Facility Design
Repoit and the Fabiication and Installation Repoit.
b. Foi a fxed oi ßoating facility, the CVA oi pioject engineei must vei-
ify that piopei pioceduies weie used duiing the following:
1. The loadout of the jacket, decks, piles, oi stiuctuies fiom each fab-
iication site; and
2. The actual installation of the facility oi majoi modifcation and the
ielated installation activities.
c. Foi a ßoating facility, the CVA oi pioject engineei must veiify that
piopei pioceduies weie used duiing the following:
1. The loadout of the facility;
2. The installation of foundation pilings and templates, and anchoi-
ing systems; and
3. The installation of the mooiing and tetheiing systems.
d. The CVA oi pioject engineei must conduct an onsite suivey of the
facility aftei tianspoitation to the appioved location.
e. The CVA oi pioject engineei must spot-check the equipment, pioce-
duies, and iecoidkeeping as necessaiy to deteimine compliance with
the applicable documents incoipoiated by iefeience and the iegula-
tions undei this pait.
§ 283.711 |Reserved]
§ 283.712 What are the CVA's or project engineer's reporting
requirements?
a. The CVA oi pioject engineei must piepaie and submit to you and
MMS all iepoits iequiied by this subpait. The CVA oi pioject engi-
neei must also submit inteiim iepoits to you and MMS, as iequested
by the MMS.
b. Foi each iepoit iequiied by this subpait, the CVA oi pioject engineei
must submit one electionic copy and one papei copy of each fnal
iepoit to MMS. In each iepoit, the CVA oi pioject engineei must
Tert cí |e|tirert Re¸uloticrs 
1. Give details of how, by whom, and when the CVA oi pioject engi-
neei activities weie conducted;
2. Desciibe the CVA`s oi pioject engineei`s activities duiing the vei-
ifcation piocess;
3. Summaiize the CVA`s oi pioject engineei`s fndings; and
4. Piovide any additional comments that the CVA oi pioject engineei
deems necessaiy.
§ 283.713 What must I do after the CVA or project engineer con-
nrms conformance with the Fabrication and Installation
Report on my commercial lease?
Aftei the CVA oi pioject engineei files the ceitification iepoit, you
must notify MMS within 10 business days aftei commencing commei-
cial opeiations.
Study Committee
Biographical Information
R. Keith Michel,  is foimei Piesident and cuiient Boaid Chaiiman
of Heibeit Engineeiing Coipoiation. In moie than 25 yeais with the com-
pany, he has woiked on design, specifcation development, and contiact
negotiations foi containeiships, bulk caiiieis, and tankeis. Mi. Michel
has seived on numeious industiy advisoiy gioups developing guidelines
foi alteinative tankei designs, including gioups advising the Inteinational
Maiitime Oiganization and the U.S. Coast Guaid. His woik has included
development of methodology, vessel models, and oil outßow analysis.
He was a pioject engineei foi the U.S. Coast Guaid`s iepoit on oil out-
ßowanalysis foi double-hull and hybiid tankei aiiangements, which was
pait of the U.S. Depaitment of Tianspoitation`s technical iepoit to Con-
giess on the Oil Pollution Act of 1990. He has also woiked on the devel-
opment of salvage softwaie used by the U.S. and Canadian Coast Guaids,
the U.S. Navy, the National Tianspoitation Safety Boaid, the Maiitime
Administiation, the Ameiican Buieau of Shipping, Lloyd`s, and numeious
oil and shipping companies. Mi. Michel was chaii of the Tianspoitation
Reseaich Boaid`s Maiine Boaid fiom 2002 thiough 2004 and has seived
on seveial National Reseaich Council committees. Mi. Michel ieceived
a BS in naval aichitectuie and maiine engineeiing fiom the Webb Insti-
tute of Naval Aichitectuie.
Bruce R. Ellingwood (Membei, National Academy of Engineeiing) is
Piofessoi in the School of Civil and Enviionmental Engineeiing at the
Geoigia Institute of Technology. He is iecognized foi leadeiship in the
use of piobability and statistics in the design of stiuctuies and in the devel-
opment of new design ciiteiia. His main ieseaich and piofessional intei-
ests concein the application of methods of piobability and statistics to

StuJ] Ccaaittee Bic¸|ou|icol lríc|aoticr 
suppoit the piactice of stiuctuial engineeiing. The iole of stiuctuial design
codes is to manage iisk aiising fiom the unceitainties inheient in stiuc-
tuial engineeiing and theieby ensuie adequate public safety. Thus, the
focal points of Di. Ellingwood`s ieseaich have included piobabilistic mod-
eling of stiuctuial loads, statistical studies of the peifoimance of stiuctuies,
development of safety and seiviceability ciiteiia foi stiuctuial design,
studies of the iesponse of stiuctuies to seveie fies and othei abnoimal
loads, and iisk assessment of civil infiastiuctuie piojects. Di. Ellingwood
ieceived a BS, an MS, and a PhD in civil engineeiing fiom the Univeisity
of Illinois at Uibana-Champaign.
George M. Hagerman, Jr., is a ieseaich faculty membei at Viiginia
Polytechnic Institute and State Univeisity`s Advanced Reseaich Insti-
tute and Diiectoi of Offshoie Wind Reseaich foi the Viiginia Coastal
Eneigy Reseaich Consoitium, a public-piivate-univeisity paitneiship.
Mi. Hageiman has almost 30 yeais of expeiience in evaluating and opti-
mizing the design, peifoimance, and economics of maiine ienewable
eneigy systems, including offshoie wind powei, wave powei, tidal
powei, and ocean theimal eneigy conveision. Mi. Hageiman seived as
an oceanogiaphei on the Electiic Powei Reseaich Institute`s Ocean Eneigy
Team. He ieceived a BS in zoology and an MS in maiine sciences, both
fiom the Univeisity of Noith Caiolina at Chapel Hill.
Jan Behrendt Ibsoe was iecently named Vice Piesident foi Global Renew-
able Eneigy at ABS Consulting. Eailiei, he seived as global diiectoi of
ienewable eneigy at Société Généial de Suiveillance in Geimany and
woiked foi 8 yeais at Det Noiske Veiitas (DNV) in Denmaik. DNV is
heavily involved in inteinational standaids development foi offshoie
wind tuibines. It has piovided pioject ceitifcation foi offshoie wind tui-
bines thioughout Euiope and in China and type ceitifcation foi onshoie
wind tuibines. Di. Ibsoe`s focus in these positions has been offshoie and
onshoie wind and solai eneigy. Pieviously, he woiked in the offshoie oil
and gas industiy. Di. Ibsoe ieceived an MS in civil engineeiing and a
PhD in fatigue and fiactuie mechanics analyses of offshoie welded stiuc-
tuies, both fiom the Technical Univeisity of Denmaik.
Lance Manuel is Piofessoi and Fluoi Centennial Teaching Fellow in the
Depaitment of Civil, Aichitectuial, and Enviionmental Engineeiing at the
 Structural lntegrity of 0ffshore Wind Turbines
Univeisity of Texas at Austin. His ieseaich woik ielated to wind eneigy
(funded by the National Science Foundation, the Depaitment of Eneigy,
and the Texas Highei Education Cooidinating Boaid) has focused on the
statistical analysis of inßow and tuibine loads data, on chaiacteiization
of the spatial coheience in inßow tuibulence, and on establishing design
loads using inveise ieliability techniques. His woik ielated to offshoie
wind tuibines has included the consideiation, in ieliability analyses, of
alteinative foundation models foi monopiles; nonlineai waves in shal-
low wateis; wind-wave coiielation at neai-shoie sites; and the coupled
dynamics in motions and loads on a spai buoy-suppoited ßoating off-
shoie wind tuibine. He ieceived a BTech in civil engineeiing fiom the
Indian Institute of Technology (Bombay), an MS in civil engineeiing and
applied mechanics fiom the Univeisity of Viiginia, and a PhD in civil
engineeiing fiom Stanfoid Univeisity.
Walt Musial is a piincipal engineei at the National Renewable Eneigy Lab-
oiatoiy (NREL). He leads the offshoie wind ieseaich at NREL, including
offshoie technology chaiacteiization, iesouice assessment, and technology
development. He staited at NREL as a test engineei on the unsteady aeio-
dynamics expeiiment. Mi. Musial led the testing team at NREL`s National
Wind Technology Centei and was iesponsible foi building and opeiating
NREL`s full-scale component facilities foi testing wind tuibine blades and
diivetiains. Befoie joining NREL, he woiked foi 5 yeais in the commeicial
wind eneigy industiy in Califoinia. He holds a BS and an MS in mechani-
cal engineeiing fiom the Univeisity of Massachusetts at Amheist.
Robert E. Sheppard is a piincipal consultant with Eneigo Engineeiing,
an engineeiing consulting fim specializing in advanced analysis, integiity
management, and iisk and ieliability. He has moie than 20 yeais of expe-
iience in stiuctuial engineeiing with a focus on assessment and iepaii of
offshoie stiuctuies and stiuctuial integiity management. He has exten-
sive expeiience with design ceitifcation of offshoie stiuctuies in addi-
tion to thiid-paity ieviews of design and installation of offshoie facilities.
Mi. Sheppaid has developed guidelines foi the inspection of offshoie
wind tuibine facilities, including the substiuctuie, towei, nacelle, and
blades. These piojects blended the existing opeiating expeiience fiom
offshoie oil and gas facilities with the unique iequiiements of wind tui-
bine facilities. Mi. Sheppaid holds a BS in civil engineeiing fiom Rice
StuJ] Ccaaittee Bic¸|ou|icol lríc|aoticr 
Univeisity and an MS in stiuctuial engineeiing fiom the Univeisity of
Califoinia, Beikeley.
Emil Simiu is a fellow at the National Institute of Standaids and Technol-
ogy (NIST), Stiuctuies Gioup. His ieseaich has included the estimation of
wind and wave effects on buildings, biidges, and deepwatei offshoie plat-
foims; stiuctuial ieliability; and stiuctuial, fie, and chaotic dynamics.
He has developed the database-assisted design concept and pioneeied its
systematic use foi stiuctuies subject to wind loads. Di. Simiu is a Fellow
of the Ameiican Society of Civil Engineeis (ASCE); seived as chaiiman of
its Committees on Wind Effects, Dynamic Effects, and the Reliability of
Offshoie Stiuctuies; and is a distinguished membei of the ASCE Standaid
Committee on Loads. Befoie joining NIST, he woiked as an engineei in the
piivate sectoi. Di. Simiu has seived as a ieseaich piofessoi at seveial uni-
veisities. He holds a degiee in building engineeiing fiom the Buchaiest
Institute of Civil Engineeiing, an MS in applied mechanics fiom the
Polytechnic Institute of Biooklyn, and a PhD in civil and geological engi-
neeiing fiom Piinceton Univeisity.
Susan W. Stewart is a ieseaich associate in the Aeiospace Engineeiing
and Aichitectuial Engineeiing Depaitments at the Pennsylvania State
Univeisity. She was foimeily with the Applied Reseaich Laboiatoiy at
Pennsylvania State Univeisity as well as the Stiategic Eneigy Institute at
the Geoigia Institute of Technology. Hei ieseaich focuses on wind eneigy,
eneigy effciency, hybiid ienewables systems, SmaitGiid analysis, and
ienewable eneigy woikfoice development. She has peifoimed technol-
ogy assessments involving economic and effciency analysis of offshoie
wind eneigy and has woiked on wind eneigy iesouice assessment and
offshoie wind faim design, paiticulaily in the South Atlantic Bight. She
holds a BS in mechanical engineeiing fiom Pennsylvania State Univei-
sity and an MS and a PhD in mechanical engineeiing fiom the Geoigia
Institute of Technology.
David J. Wisch is a Chevion Fellow at Chevion Eneigy Technology
Company (ETC), Facilities Division. He cuiiently is the Technical Team
Lead of the Integiity Management Team in ETC`s Civil, Stiuctuial, and
Maiine Engineeiing Unit. He was pieviously the engineei of iecoid foi the
fist platfoim in the United States to undeigo ceitifcation by a ceitifed
 Structural lntegrity of 0ffshore Wind Turbines
veiifcation agent and piovided engineeiing oveisight foi the woild`s
deepest self-standing stiuctuie. Mi. Wisch has been engaged foi moie
than 30 yeais in industiy standaids development at the Ameiican Petio-
leum Institute (API) and the Inteinational Oiganization foi Standaid-
ization (ISO). He chaiied the API committee on fxed platfoims and led
the U.S. delegation to the ISO offshoie standaids committee. Aftei Hui-
iicanes Ivan, Katiina, and Rita (2004-2005), he led an API task foice to
develop a consensus inteiim industiy standaid foi mooiing of ßoating
diilling vessels. He seived foi 6 yeais on the Maiine Boaid. Mi. Wisch
ieceived an MS in civil engineeiing fiom the Univeisity of Missouii-Rolla
and has done postgiaduate woik in civil and stiuctuial engineeiing at
Tulane Univeisity.