Today, Green America filed the following comments with the Federal Energy Regulatory Commission (FERC) in regards to a proposed natural gas export facility in Oregon, Jordan Cove. Like the many other gas export facilities proposed around the US, Jordan Cove will contribute to increased climate change and fracking, and will endanger the local community.
Natural gas is not a bridge fuel (its growth impedes the growth of true clean energy), and when we frack for natural gas and then export it abroad, we are damaging our communities and risking our future for energy that Americans are not even using.
February 12, 2015
Chairman Cheryl A. LaFleur, Commissioner Philip D. Moeller,
Commissioner Tony Clark, Commissioner Norman C. Bay,
Commissioner Colette D. Honorable
Federal Energy Regulatory Commission
888 First Street, NE
Washington, DC 20426
Re: Jordan Cove Liquefaction and Pacific Connector Pipeline Projects (Docket Nos. CP13-483-000 and CP13-492-000)
Green America is a national non-profit organization with 180,000 individual members and 3,500 business members nationwide, and several thousand individual members and over 100 businesses in Oregon. Our green business network is the largest network of certified green business in the United States. Green America is also a member of the American Sustainable Business Council, which represents over 150,000 businesses nationwide.
On behalf of our members, we are expressing concerns about the possible environmental impacts of the proposed Jordon Cove Liquefaction and Pacific Connector Pipeline Projects. We are also concerned that FERC’s Draft Environmental Impact Statement (EIS) underestimates the impacts and risks associated with this project.
In particular, we have concerns about the following:
Climate Change Impacts. The Draft EIS fails to take account of the climate change impacts of Jordan Cove and the Pacific Connector Pipeline Project. Jordan Cove would likely become the largest greenhouse gas emitting project in Oregon within the next decade. The project would release an estimated 2.1 million metric tons of carbon dioxide and equivalents. Oregon has set aggressive goals for limiting greenhouse gas emissions, and Jordan Cove would work to undermine them.
The power plants used to liquefy natural gas would operate with a capacity of 420 megawatts, which is enough energy to power 400,000 homes. In addition, the venting of natural gas will also significantly increase emissions, and there will be methane leaks from the pipeline and at the plant. Methane has heat trapping properties 87 times as great as carbon dioxide.
Green America requests that FERC more fully research the greenhouse gas emissions of the projects and their impacts on Oregon and its greenhouse gas reduction targets.
Increased Fracking. Jordan Cove and other LNG shipping facilities are accelerating US exploration of natural gas, much of it through fracking. Research is increasingly highlighting the negative environmental impacts of fracking on local communities. Fracking is tied to water and air pollution, significantly increased seismic activity, and degraded infrastructure. Jordan Cove would work to increase these impacts in order to ship natural gas overseas. Thus, the natural gas in question would not even benefit US communities, and shipping natural gas overseas could also contribute to an increase in the price of natural gas for US consumers.
Green America requests that FERC better account for the impact of the Jordan Cove project on communities impacted by fracking.
The danger to the community surrounding Jordan Cove. In FERC’s draft EIS, the agency states that it believes “the facility design proposed by Jordan Cove includes acceptable layers of protection or safeguards which would reduce the risk of a potentially hazardous scenario from developing into an even that could impact the off-site public.” However, two well-recognized scientific experts, Jerry Havens, of the University of Arkansas, and James Venart, emeritus professor at the University of New Brunswick, have called FERC’s assessment into question. The two scientists point out that the use of propane and ethylene, two highly flammable gases, create a risk for explosion and that the 40 foot impermeable barriers around the proposed plant could actually retain vapor leaks contributing to an increased hazard in the event of an explosion.
The risks are not theoretical. Explosions in the last decade in Algeria and more recently in Washington State have left environmentalists, emergency responders, and citizens living near proposed LNG facilities in the U.S. understandably concerned.
LNG can vaporize and form highly explosive clouds in pipelines and other parts of the facility if its container leaks. In a phenomenon called rapid phase transition, the heat transfer from spilling enough water at room temperature on the subzero LNG can cause a tremendous “cold explosion.”
FERC should more thoroughly evaluate the risk of explosion at Jordan Cove and the potentially catastrophic impact on local communities.
Based on the known climate change impacts and increased fracking impacts, combined with the potential for catastrophic explosions, Green America believes that a complete and rigorous assessment of the costs versus benefits of Jordan Cove would result in a recommendation that the project be terminated.
We would be happy to discuss any of the above concerns with FERC Commissioners and we thank you in advance for your attention to these comments.
Corporate Responsibility Division Director