The Court agrees with defendants that Congress never intended that . . . a management program . . . provide a zoning map which would inflexibly commit the state in advance of receiving specific proposals to permitting particular activities in specific areas. Nor did Congress intend . . . to require that such programs establish such detailed criteria that private users be able to rely on them as predictive devices for determining the fate of projects without interaction between the relevant state agencies and the user.
Am. Petroleum Inst. v. Knecht, 456 F. Supp. 889, 919 (C.D. Cal. 1978), affd, 609 F.2d 1306, 1315 (9th Cir. 1979). The court concluded that the national interest in siting offshore energy facilities, even as strengthened by the 1976 CZMA amendments, did not require state coastal plans to address national energy objectives more precisely. Id. at 919, 926.
[A]n offshore wind farm is a new concept. However, other coastal developments, such as oil and gas platforms, have been around for decades. . . . Offshore wind farms and oil/gas platforms are similar in that both (a) are energy-related activities, (b) require the installation of structures in U.S. navigable waters, (c) are potentially visible from the shoreline, and (d) may affect the coastal zone.