US BOEM Carolina Long Bay ATLW-9 lease sale

US BOEM Carolina Long Bay Lease Sale ATLW-9 (May 2022)

1. At a glance

Sources (1 primary in local corpus): atlw9-fsn (145K chars, spider-fetched from BOEM landing page, covers the complete FSN including auction procedures, bidding credit mechanics, and lease stipulations).

2. What makes CLB structurally different from NY Bight

3. The bidding credit mechanics — the Axis 4 stress test

Per ATLW-9 FSN §VIII "Auction Procedures":

Under 30 CFR 585.220(a)(4) and 585.221(a)(6), BOEM will use a multiple-factor auction format, with a multiple-factor bidding system for this lease sale. The bidding system for this lease sale will be a multiple-factor combination of a monetary bid and a non-monetary factor.

3.1 What the credit is

A single 20% non-monetary bidding credit for workforce training programs for the offshore wind industry, development of a US domestic supply chain for the offshore wind energy industry, or both.

The bidding credit allows a bidder to receive a credit of 20 percent of its cash bid in exchange for committing to make a qualifying monetary contribution ("Contribution") to programs or initiatives that support workforce training programs for the offshore wind industry, development of a U.S. domestic supply chain for the offshore wind energy industry, or both.

3.2 How qualification works

1. Bidder opts in on BFF (Bidder's Financial Form) by checking the credit paragraph and including a conceptual strategy.
2. BOEM appoints a panel to review the non-monetary component before the auction.
3. BOEM notifies bidders if they qualify for the credit before the mock auction.
4. Bidders who don't qualify (or don't opt in) participate in the auction without the credit — their cash bid is their bid as-is.

3.3 How the credit affects winner determination

A qualifying bidder's cash bid is effectively increased by 20% in BOEM's winner-determination algorithm:

To qualify for the credit, the winning bidder is required to financially contribute at least 80 percent of the bidding credit value toward a workforce training program or the development of a domestic supply chain. For example, a winning bidder qualified for the bidding credit submitting a high bid of $100 million would receive a credit of $20 million, resulting in a total bid of $120 million for the purposes of the lease sale.

The bidder does NOT pay the extra 20% in cash — they pay only the cash bid. The credit is a nominal uplift that changes the ranking, not the payment. But the bidder is legally committed to contributing ≥80% of the credit value toward qualifying programmes.

3.4 Enforcement

If a lease is awarded pursuant to a winning bid that includes the bidding credit, the lessee will be required to provide documentation showing that the lessee has met the commitment and complied with the applicable bidding credit requirements no later than the submission to BOEM of the first Facility Design Report (FDR) for the Lease.

Enforcement is strong: per lease §7.2.4, if BOEM determines the bidding-credit commitment was not satisfied at the FDR stage, or if the lessee/assignee relinquishes or otherwise fails to develop the lease by the tenth anniversary of lease issuance, then the amount corresponding to the bidding credit awarded shall be immediately due and payable to ONRR, with interest from the date of lease execution. This means the credit is effectively a deferred cash obligation that crystallises on non-performance — not a soft commitment that BOEM "can assess penalties" for (my iter1 draft understated this).

3.5 Schema interpretation — Axis 4

CLB exercises Axis 4 with two entries:

1. Price dimension: cash bonus bid per lease, weight = ~83% of total bid value (since the 20% credit makes the effective total 120% of cash, the cash component is 100/120 ≈ 83.3% of the effective total), direction = higher-wins, evaluation = ascending-multi-round highest-bid.

2. Bidding credit dimension: workforce_training_or_supply_chain, weight = ~16.7% (= 20/120 of total), evaluation_method = bid_discount_on_binding_commitment per v0.3 R4, weight_interpretation = discount_on_price_dimension per v0.3 R4 — the credit operates as a 20% uplift on the cash bid rather than as a separate weighted score that sums with the price dimension.

IMPORTANT CORRECTION: The v0.3-v0.5 sketch descriptions repeatedly said "Carolina Long Bay offered three stackable 5% bidding credits for workforce / supply chain / underserved communities." This is WRONG per the ATLW-9 FSN primary source. CLB offered a SINGLE 20% credit for workforce training OR supply chain development (or both). There is no separate "underserved community" credit in CLB. The "three stacking 5% credits" description may come from a secondary analysis or from a later BOEM auction (possibly California PACW-1 or Gulf of Maine), but it does NOT describe ATLW-9. The v0.6 sketch must be corrected.

4. Auction results

Per trade press (coastalreview.org, WFAE, Bloomberg — 11 May 2022):

Per BOEM's North/South Carolina Activities pages: TotalEnergies bid $160M for OCS-A 0545 and Duke Energy bid $155M for OCS-A 0546. Whether both winners had qualified for the bidding credit is not stated in the sources I've accessed — the California PACW-1 FSN Response to Comments notes that "in the Carolina Long Bay auction, all participant bidders qualified for all bidding credits", suggesting all CLB bidders did qualify.

5. Post-award status

Both CLB leases are affected by the January 2025 Trump temporary withdrawal memorandum (same as NY Bight). As of April 2026:

• OCS-A 0545 (TotalEnergies): assigned to TotalEnergies Carolina Long Bay, LLC in August 2023. Site assessment activities were reported as underway pre-pause. Post-pause status uncertain.
• OCS-A 0546 (Duke Energy): Duke Energy Renewables Wind, LLC retains the lease. Limited public reporting on development progress.

Neither project has submitted a Construction and Operations Plan to BOEM as of April 2026.

6. Schema implications — what CLB adds beyond the six existing pilots

6.1 The ACTUAL Axis 4 multi-entry case

CLB is the first and only pilot where Axis 4 genuinely has two types of entry: a price dimension and a non-monetary bidding-credit dimension. The six earlier pilots are all single-entry (pure-price or pure-option-fee). The schema needs to cleanly express:

• The price dimension's role as the primary competitive variable (ascending multi-round)
• The bidding credit's role as a multiplier on the price dimension (not a separate weighted score summing alongside price)
• The qualification process (BOEM panel review pre-auction, opt-in on BFF)
• The enforcement mechanism (commitment to contribute ≥80% of credit value before first FDR)

6.2 Correction to v0.3/v0.5 R4/R11

The sketch's R4 evaluation method (bid_discount_on_binding_commitment) is correct in kind but wrong in the specific description. The v0.5 Axis 4 text says:

"The motivating example is BOEM Carolina Long Bay (ATLW-9, 2022) — where BOEM offered three stackable 5% bidding credits"

This is WRONG. CLB offered a single 20% credit for workforce training OR supply chain development. There is no three-credit stacking mechanism in ATLW-9. The v0.6 sketch correction R11 must be re-corrected at v0.7 to say:

"The motivating example is BOEM Carolina Long Bay (ATLW-9, 2022) — the first US BOEM lease sale to use a multiple-factor format, offering a single 20% non-monetary bidding credit for workforce training or domestic supply chain development."

6.3 Weight interpretation

CLB's bidding credit is a multiplicative uplift on the cash bid (cash × 1.20 for the winner-determination calculation), not an additive score that sums with the cash bid. This is exactly the discount_on_price_dimension weight interpretation from v0.3 R4, but the mechanism is an uplift rather than a discount — the credit INCREASES the effective bid. The schema should express this as weight_interpretation: uplift_on_price_dimension or discount_on_price_dimension with direction reversed. Either works; the key point is that it's a multiplicative factor on the price, not an independent weighted score.

6.4 Confirmed: CLB validates the v0.3 R4 evaluation method

Despite the wrong credit-count, the bid_discount_on_binding_commitment evaluation_method from v0.3 R4 is exactly what CLB uses: a binding commitment to a non-monetary programme translates into a percentage uplift on the monetary bid in the winner-determination algorithm, with the commitment becoming an enforceable lease obligation (documentation required before first FDR). This confirms the evaluation method's design — it just needs the correct description and the correct example citation.