2017 Jordan Cove LNG Export Proposal
Ideas & Procedure for Submitting Scoping Comments to FERC
The Federal Energy Regulatory Commission (FERC) is the federal agency responsible for approving or denying energy projects in the US. When an energy company applies to build a project, a Draft Environmental Impact Statement (DEIS) must be developed assessing the environmental and health impacts from the project. Scoping comments are designed to identify for FERC what concerned individuals think should be explored in developing that Environmental Impact Statement. This is the best way that the public can voice concerns about the project. One measure that will likely be used in determining which issues should be considered is the number of submissions identifying the issues.
FERC has allotted a 30 day comment period that ends on Monday, July 10 with three public scoping hearings related to the project. The hearings were scheduled as follows:
- Tuesday June 27, 4pm – 7pm in Coos Bay
- Wednesday June 28, 4pm – 7pm in Roseburg
- Thursday June 29, 4pm – 7pm in Klamath Falls
- NO hearing was scheduled in Jackson County! (FERC claims they have limited resources and a pretty good idea of how Jackson County “feels” about this project already.)
It is important to get as many substantive comments into FERC urging upon them a broad scope for their environmental and health assessment. This is an important opportunity for all of us, including YOU, to speak up!
Writing scoping comments is easy; you don’t have to be a professional.
- We suggest that you write your comments and save them as a word doc on your computer and proofread them (the FERC limit is 6,000 words). Please write in your own words, so submissions don’t appear as mere copy and paste repetitions from an orchestrated campaign and thus become discounted. Here are some points that you might include (in your own words):
- FERC must not rely on outdated data from previous iterations of the Jordan Cove and Pacific Connector projects proposals and assessments: (this includes wildlife or plant surveys that may no longer accurately reflect current on-the-ground conditions.
- FERC must consider alternatives to the project as a whole (including ‘no project’). FERC must also consider alternative designs to avoid potential impacts from the project.
- FERC must spell out specific mitigation measures and modification suggestions that are relied upon to draw conclusions about the impacts of the projects.
- FERC should weigh heavily on the negative impacts on private landowners from the Pacific Connector Pipeline, which would harm private property rights though the potential use of eminent domain.
- FERC should address the full impacts of the projects on water quality for each stream and wetland impacted. FERC should require Pacific Connector to rely on current and site-specific information to evaluate the impacts of the proposals.
- FERC should consider the direct, indirect and cumulative effects on fish and wildlife that will be impacted by the proposed LNG terminal and Pacific Connector pipeline, including threatened and endangered salmon, steelhead, and other rare and endangered wildlife.
- FERC must consider the climate-changing pollution that would be generated by all aspects of this project. FERC must consider the direct, indirect, and cumulative impact of fracked and conventional gas extraction, processing, transport, liquefaction, and end use combustion, including the contribution of leaked methane gas to the overall greenhouse gas emissions (climate pollution) from these proposals.
- FERC must undertake a detailed analysis of the public safety risks associated with the terminal and pipeline. In past reviews, FERC has failed to adequately address fire and emergency response risks along the pipeline route. Further, FERC must take a realistic look at a worst-case scenario LNG leak and fire near the terminal.
- FERC must consider whether fair compensation is even possible when granting the power of eminent domain to a multi-national corporation. Appropriate compensation from the company is unlikely with eminent domain as a last resort tool to confiscating private property.
- FERC must consider the negative impacts of pushing high pressure gas through rural Oregon that is susceptible to frequent wildland fire. Parts of the pipeline are above ground in the block valves. FERC must analyze how to protect above-ground sections of pipe in rural areas from wildland fire.
- FERC should consider the safety impacts to rural families along the pipeline route under a class 1 pipeline safety standard.
- FERC must consider the impacts of large populations of temporary, out-of-state work force along the pipeline route and in Coos Bay. Historic impacts from these types of work force communities include increases in housing/rental prices, drug and alcohol use, crime, prostitution, domestic violence and more causing stress on the permanent community and its resources.
- FERC must consider the impacts of putting a highly explosive LNG export plant in a seismic, Cascadia subduction zone and a tsunami evacuation area. FERC must get an unbiased peer-review of the proposed earthquake mitigations from scientists familiar with our unique coastal Oregon situation.
- FERC should extend the comment period past July 10th. 30 days is not enough time for the public to submit meaningful comments on hundreds of pages of resource reports that were not available to the public on time. 90-120 days would be sufficient.
- FERC should include scoping meeting in Jackson County and Portland to give the public the best opportunities to comment
- After you have written your comments go to: https://ferconline.ferc.gov/QuickComment.aspx and fill out the form. You will be emailed a link where you will go to comment on a new page.
- Go to your email and click the link from FERC. In the new page, enter docket number PF17-4 (no spaces) and hit “Search”. The project will appear. Select the Jordan Cove docket by clicking the blue “Select” cross.
- Copy and paste your comments from your word document into the textbox and hit “Send comment”.
- You should receive an acknowledgement that your comments have been received. These are public record so anyone can read them.
You are done! Thank you and please help spread the word!
This document is based closely upon materials provided by Rogue Riverkeeper.
In addition to requesting a deadline extension, a Jackson County Hearing, and an open hearing format, SOCAN has submitted the following:
3 – Letter to Senator Arnie Roblan and other state representatives who submitted a letter to FERC in support of the project – also submitted to FERC.
4 – The Roblan et al. letter to FERC to which item 3 is a SOCAN response.