Revolution Wind Is Now Fully Built and Selling Power. Washington Is Still Trying to Reopen Its Permit File.

Ørsted's Q3 2026 interim report, published on 5 November, records that the 704 MW Revolution Wind offshore wind farm reached commercial operations in October under its offtake contracts with Rhode Island and Connecticut utilities. The last of 65 Siemens Gamesa SG 11.0-200 DD turbines went in during September, twenty-five months after the first unit was installed.

That sentence in a results announcement is, in practical terms, the end of a construction project that was repeatedly ordered to stop, and the beginning of a different kind of exposure. On 9 October the US Department of Justice and the Department of the Interior asked the federal district court in Washington to vacate and remand the project's 2023 construction and operations plan (COP) approval so that Interior can reconsider its Outer Continental Shelf Lands Act analysis. The target is a wind farm that is finished and generating.

What actually got built

Revolution Wind sits on lease OCS-A 0486 about 15 miles south of the Rhode Island coast and 32 miles southeast of Connecticut, in the shared ISO New England market. It is owned 50/50 by Ørsted and Skyborn Renewables (the offshore platform formerly held by Global Infrastructure Partners) through Revolution Wind, LLC.

One commercial detail worth flagging: the state-level split obscures the fact that Connecticut's 304 MW is divided between two utilities, not held by one counterparty. That matters for anyone modelling the project's revenue concentration, and it is why Skyborn's project documentation lists three offtakers rather than two.

The schedule is the story

Monopile installation ran from 10 May to 22 August 2024 — 52 turbine foundations in roughly fifteen weeks, an unremarkable but competent campaign. Then the schedule broke. Between the first turbine in September 2024 and the last in September 2026, the project absorbed two federal suspension orders: one from BOEM's acting director in August 2025, issued when the project was around 80% complete and lifted by a court the following month, and a second in December 2025 on national-security grounds, blocked in January 2026.

Neither order stopped the project permanently, but together they explain why a 704 MW farm took two years between first and last turbine instead of the single season that the build rate would otherwise imply. The cost of that idle time sits in Ørsted's numbers rather than in a headline figure: the company booked DKK 5,979m of impairments over the first nine months of 2026, attributing the hit mainly to non-cash interest-rate effects on its US projects. The Revolution Wind delay is not the direct cause of those impairments, but it is part of the same US risk register. Against that, Ørsted reported 9M 2026 EBITDA excluding new partnerships and cancellation fees of DKK 20.2bn, up 19% year on year — a reminder that the group's problems have been balance-sheet and permitting problems, not operational ones.

Why a remand request against a finished wind farm matters

The October filing does not revoke anything. A remand would send the COP approval back to Interior, where the agency would run a fresh OCSLA analysis with an administration that has already shown it will issue stop-work orders. The practical question is what an agency could lawfully do to an operating 704 MW generator whose power is contracted to two states and three utilities under 20-year PPAs approved by state regulators.

That is where the industry's attention should sit. The legal theory and the commercial consequence are very different things here:

• Contractual protection is substantial. The offtake is not a federal instrument. Connecticut's 304 MW was selected in a 2018 state solicitation and its PPA was filed with and approved by PURA; Rhode Island's 400 MW runs through Rhode Island Energy under a state contract. A federal permit reversal does not automatically touch either.
• Operational leverage is what remains. A suspended or modified COP could constrain how the project is operated or maintained rather than whether it runs — a far weaker tool against a commissioned asset than against one still driving piles, and one that invites immediate injunctive relief.
• Precedent is the real product of the case. Whatever happens to Revolution Wind specifically, the filing tells developers how the current administration intends to treat approvals it inherited. That signal propagates directly into the cost of capital for every US offshore project that has not yet reached financial close.

Readers should treat the outcome as genuinely uncertain. Ørsted's own reporting treats the project as operating and contracted; the litigation is reported by trade press and Bloomberg Law (9 October filing) but no court ruling on the remand request had been issued.

Sunrise Wind is the next test

The more consequential disclosure in the same results may be the Sunrise Wind update. The 924 MW project off New York — wholly owned by Ørsted, 84 Siemens Gamesa 11 MW turbines — has now completed installation of all turbine foundations. Turbine and inter-array cable installation are underway, offshore converter station commissioning has started, and Ørsted expects turbine commissioning around the end of 2026 with full commissioning in the second half of 2027.

Sunrise is larger than Revolution Wind and sits entirely on Ørsted's own balance sheet, without a 50/50 partner to share construction and political risk. If Revolution Wind establishes that a completed, contracted project can be pushed back into permit review, the exposure at Sunrise — which will spend most of 2027 in exactly the vulnerable window between "built" and "fully commissioned" — is materially larger.

What to watch

Three things will determine whether this is an isolated nuisance or a structural change in US offshore risk pricing. First, whether the district court grants remand at all, and on what terms. Second, whether any fresh Interior review produces conditions that touch operations rather than paperwork. Third, whether the 2026–27 construction window at Sunrise passes without a suspension order. Until those resolve, the correct reading of Revolution Wind's commissioning is that the steel is finished and the legal risk is not.

Figures for capacity, offtake, turbine counts and installation dates are as reported by Ørsted's Q3 2026 announcement and Skyborn Renewables; the interpretation of legal and commercial exposure is the author's analysis. Note that BOEM's 2023 record of decision cited "nearly 250,000 homes" for the project while project documentation uses "more than 350,000" — differing conversion assumptions, not differing capacity.