Broadwater LNG Project
Statement of
On The
Broadwater LNG Project
Long Island Sound Energy Security
(Docket No. PF05-4)
Submitted To The
Cooperating Agencies:
U.S. Department of
Homeland Security
U.S. Environmental Protection Agency
U.S. Army Corps of Engineers
U.S. Department of Commerce
National Oceanic and Atmospheric Administration
National Marine Fisheries Service
U.S. Fish & Wildlife Service
New York State Department of Environmental Conservation
New York State Department of State
NOTICE OF INTENT TO PREPARE AN
ENVIRONMENTAL IMPACT STATEMENT
Joint Public Meetings:
Stony Brook, New York, September 13, 2005
Shoreham, New York, September 14, 2005
East Lyme, Connecticut, September 20, 2005
Branford, Connecticut, September 21, 2005
Introduction
My name is Norris McDonald and I am the founder and president of the African American Environmentalist Association (AAEA). This written statement is being submitted to express our support for liquefied natural gas (LNG) projects in general and the Broadwater LNG Project in particular. The African American Environmentalist Association (AAEA) supports LNG terminals because of the need for additional natural gas for electricity generation.
The African American Environmentalist Association was founded in 1985 and is a national, nonprofit organization dedicated to protecting the environment, promoting the efficient use of natural resources, enhancing human, animal and plant ecologies and increasing African American participation in the environmental movement. AAEA’s New York office is located in the Bronx, New York and our national headquarters is in the Washington, DC Metropolitan Area. We have chapters nationwide and members worldwide.
The Broadwater Liquefied Natural Gas Project will be a Floating Storage and Regasification Unit (FSRU) moored in Long Island Sound that will provide gas to New York and Connecticut via an underwater pipeline. The FSRU is a ship-like vessel about 1,200 feet long, 180 feet wide and 100 feet high. It will be built in a shipyard, towed to the proposed location in the Sound and attached to a mooring system. The FSRU will receive two LNG shipments per week, which would be stored, warmed and sent to New York and Connecticut via the existing Iroquois pipeline.
The Long Island Sound connects to the East River in New York and lies
between the coast of Connecticut to the north and Long Island, NY to the
south. It is one of the largest urban
estuaries in the United States and provides natural habitats to more than 1,200
invertebrates, 170 species of fish, and dozens of species of migratory birds.
This Atlantic Ocean estuary (where salt water from the ocean mixes with fresh
water from rivers) will not be negatively affected at all by the Broadwater LNG
Project. Westchester County, NY and the Bronx, NY bound it on the western end on
the north side. The Sound is 110 miles long and 21 miles wide at
its widest point. It has an average depth of 78 feet with the deepest point
being 300 feet. The volume of water in the Sound is 8 trillion gallons.
Including all islands, the Long Island Sound has a shoreline of 548 miles (882
km). (Wikipedia)
Environmental
Issues
Overall, the Broadwater Project will be environmentally benign and will have virtually no impacts to mitigate during construction, operation, maintenance and closure. The largest threat to Long Island Sound is polluted runoff. Polluted runoff includes sediment, fertilizers, pesticides, household cleaners, chemicals, heated water, degraded septic systems, motor oil and other poison runoff items. The Broadwater Project contributes virtually no effluent or runoff that will negatively impact the Sound.
One effort to restore the health of the Sound that was initiated in
1985 by EPA, New York, and Connecticut, was the Long Island Sound Study
(LISS). This study, produced by the New
England Interstate Water Pollution Control Commission, was implemented to
fulfill the goals of the 1972 federal Clean Water Act. It was conducted by a bi-state partnership
consisting of federal and state agencies, user groups, concerned organizations,
and individuals dedicated to restoring and protecting the Sound. They claim that investments in water
pollution control programs have led to measurable improvements in the water
quality of Long Island Sound.
In 1994, the LISS completed a Comprehensive Conservation and Management
Plan that identified seven issues of concern: (1) low dissolved oxygen
(hypoxia), (2) toxic contamination, (3) pathogen contamination, (4)
floatable debris, (5) living resources and habitat management, (6) land use and
development, and (7) public involvement and education. We do not believe the Broadwater Project
will have negative effects in any of these areas. The Broadwater Project will dump neither nitrogen nor toxic
chemicals. No pathogens will be
released and no floatable debris will be thrown or washed into the Sound by the
project. Living resources, habitat
management, land use and development will not be negatively influenced by this
project. The EIS process will increase
public involvement and education related to the Sound.
Construction, Operation, Maintenance, and Abandonment of the
Broadwater Project
Geology and Soils. The disturbance of the localized sediment will be minimal due to the installation of the Floating Storage and Regasification Unit (FSRU), yoke mooring system and submarine pipeline. The FSRU mooring tower will have a small footprint, about the size of a basketball court, and will have virtually no impact on the seafloor. The disturbance will be temporary and the ecology in the sound should return to a natural state soon after construction. The state-of-the-art cable embedment technologies and techniques will minimize impacts.
Currently, the underwater Cross-Sound Cable
transmits electricity under the Long Island Sound and runs from New Haven in
western Connecticut to Brokhaven in central Long Island. This cable and the Iroquois natural gas
pipeline have had an insignificant effect on the Sound while providing great
benefits to New York and Connecticut..
Everyone wants the benefits of projects of this type, but
obstructionists complain about such projects for abstract and narcissistic
reasons.
Water Resources. No mitigation is necessary for water flows because the project will not have a significant impact on tidal driven currents and wave conditions. Water quality in the immediate area of the FSRU will not be threatened by water discharges, sewage wastewater treatment, storm water runoff and potential liquid natural gas spills. There will be little to no discharges, runoff and spills. Clearly, the massive discharges and runoff from land-based sources are the major concerns of water quality in the Sound.
Aquatic Resources. The Broadwater Project will not have a negative impact on aquatic resources. Neither streams and wetlands nor lands bordering these water bodies and the Sound will be impacted in any way by the project. The project will not cause soil erosion that could lead to oxygen depletion and habitat destruction. The laying of the pipeline will only have a temporary effect on very few benthos organisms and there will be no effect after natural sound bottom restores itself.
Long Island Sound is a rich fishery, but in recent
years the western part of the sound has become increasingly deficient of marine
life. The fishing and lobstering industries have encouraged efforts to identify
the cause of the dead water and have supported efforts to rectify the
problem. As described earlier, major
environmental problems currently affecting the Sound include hypoxia, toxic
substances and pathogen contamination, litter, and land-based development
activities. The Broadwater Project is
not a part of these problems and will not add to Sound stressors.
Vegetation and Wildlife. Virtually no mitigation is needed for the temporary disturbance of benthos invertebrates and shellfish due to laying the pipeline or from the vessels and other structures. We assume the applicant will consider providing additional mitigation measures: shellfish reseeding funding, notification of registered lobster fishermen, avoiding privately licensed shellfish areas, among others. There will be minimum disruption to and mortality of finfish, eggs and larvae. The project poses no threat to protected marine or terrestrial species. The project will have minimal impact on land and sea vegetation.
According to Stony Brook University’s Marine Sciences Research Center (MSRC), warmer water temperatures, low oxygen levels, “shell disease,” a bacterial infection, and related stresses are the likely reasons for a massive die-off of lobsters in Long Island Sound in 1999. The Broadwater Project will not contribute to any of these stressors to the Sound.
Threatened and Endangered Species. The project does not pose a threat to raptors or waterfowl. Collisions with the approximately 100 foot high tankers will kill a minimal number of birds; not enough to significantly affect populations of gulls, migrating birds or shorebirds. Ten federally listed endangered or threatened species occur within the Connecticut River watershed and the Broadwater Project will impact none of them. These include three birds, a fish, an insect, a mussel and four plants:
1. Piping plover (Charadrius melodus)Threatened
2. Peregrine falcon (Falco peregrinus)Endangered
3. Bald eagle (Haliaeetus leucocephalus)Threatened
.
4. Shortnose sturgeon (Acipenser brevirostrum)Endangered
5. Puritan tiger beetle (Cicindela puritana)Threatened
6. Dwarf wedge mussel (Alasmidonta heterodon)Endangered
7. Small whorled pogonia (Isotria medeoloides)Threatened
8. Jesup's milkvetch (Astragalus robbinsii var.
jesupi)Endangered
9. Robbin's cinquefoil (Potentilla robbinsiana) Endangered
10. Northeastern bulrush (Scirpus ancistrochaetus)Endangered
Source: U.S. Fish & Wildlife Service
Any potential interactions will be addressed with appropriate mitigation procedures and activities.
Land Use. The FSRU will be built in a shipyard. The construction of the facility in dry dock should eliminate or minimize any release to the environment. Since it is off shore it will not have any land use impacts.
Recreation. The Sound provides economic and recreational benefits to millions of people in Connecticut and New York and the Broadwater Project will have no negative impacts on these activities. Recreational boating should not be negatively influence by the FSRU or twice weekly shipments of LNG. The FSRU is a speck in the massive Sound and will have appropriate night lighting to eliminate any threat to recreational boaters. The pipeline will be in sediment under the Sound and will not affect swimming, boating or fishing. It will probably become a tourist and boater attraction.
Visual Resources
(Visibility). The FSRU will be barely visible from the shore because
it will be anchored 11 miles from East Haven and 18 miles from Long Island
Sound Ferry. Valuable wind power
projects are experiencing the same visual pollution objections that are being
used against the Broadwater Project.
Yet when industrial sites are proposed in minority communities, these
same people complaining about spoiled views are nowhere to be found. It is the ‘build absolutely nothing anywhere
near anything’ (BANANA), ‘not in my backyard’ (NIMBY) crowd that is putting
needed infrastructure at risk. Again,
‘anywhere’ does not seem to register with the gated community, shore visibility
protection crowd when impacting projects are proposed for minority communities.
And this project is not a polluting facility.
Cultural Resources. The offshore location of the facility and the pipeline means there will be virtually no impacts on cultural resources. To the extent that the Sound itself is a cultural resource, the small footprint and small scale of the commercial activity at the facility means there will be virtually no impact on this historical water body.
Socioeconomics: Environmental Justice. Assuming that the DEIS will state that there are no environmental justice issues, it should state that there are no environmental injustice issues. The project will not formally trigger thresholds requiring environmental justice analysis. The important point from an environmental justice perspective is that the Broadwater LNG Project will provide the least polluting fossil fuel for generating electricity. Thus, operation of the project will be beneficial to human health. To the extent that natural gas is provided to the long-haul natural gas pipeline system, the project positively affects minority communities east of the Rocky Mountains that are disproportionately impacted by pollution sites, particularly air pollution sites.
If opponents are successful in killing this project by delaying it through litigation, they are saying that it s not good if it is in their backyard. They must take the view that it should be built in Harlem, South Bronx, Queens or other low-income, minority communities in New York. AAEA has a big problem with this type of environmental elitism.
Marine Transportation. The auto and passenger ferries will not be
inconvenienced because the LNG carriers will only offload their cargo into the
FSRU about two to three times per week. Ferries provide service between Long Island and Connecticut, notably
between Port Jefferson, NY and Bridgeport, Conn, and Orient Point, NY and New
London, Conn.
Air Quality. The FSRU will be required to get a clean air permit, but will not contribute significant new amounts of air pollution to the atmosphere. The project will be beneficial to regional air quality to the extent that it replaces coal as an electricity generating fuel.
Noise. The noise impacts of
the FSRU will be minimal because it will sit in the middle of a 120 mile Sound
ten miles from either shore. There will
be no ongoing pile driving or any other type of industrial noise from this
project. Noise from small and powerful
motor boats will be far louder than any minor noise emanating from the FSRU.
Cumulative Impacts. I served on a peer consultation panel that reviewed the Draft Framework for Cumulative Risk Assessment for the U.S. Environmental Protection Agency. Cumulative risk assessment is a valuable analytical tool. Risk Assessment is a complicated undertaking. Cumulative Risk Assessment can become unmanageable if limitations are not placed on the input parameters. It becomes a case of “too much information in, nothing useful can come out.” Paradoxically, cumulative risk assessment becomes useless if enough inputs are not included. In the case of Broadwater, cumulative risk assessment would conclude that the rewards far outweigh the risks.
Aeronautical. There are no adverse aeronautical impacts. The Broadwater Project will be lighted with Federal Aviation Administration-approved flashing lights. The FSRU might even serve as a watermark for pilots because flight over water at night can be disorienting. The FSRU adds one more point of reference for helicopter and small craft pilots.
Commercial Fishing, Recreational Boating and Recreational Fishing. The applicant is not requesting any restrictions on commercial fishing, so there should be no adverse impacts on this sector. Recreational boating and fishing should not be adversely impacted because of the extremely small footprint of the facility and the infrequent deliveries of LNG.
Alternatives. There isn’t a reasonable alternative to building the FSRU in the current location and connecting to the current pipeline. The no-build alternative will lead to more pollution in the New York-Connecticut environments via more air pollution from coal-fired electricity generating plants.
Energy
Issues
The reality of electricity generation in America today is that natural gas power plants are the only facilities that can be approved for construction in today’s ‘Not-In-My-Backyard’ (NIMBY) climate. Although coal provides fifty percent of electricity generation and nuclear provides another twenty percent, public opposition is significantly limiting the use of these fuels. Natural gas provides about twenty-one percent of the fuels used to generate electricity in the U.S. but it is the cleanest burning fossil fuel. For this reason, it is the fossil fuel of choice for utilities, environmental groups, regulators and the general public. Unfortunately, New York and Connecticut do not have sufficient local supply and domestic and Canadian supplies are in high demand all over the country. Limited supplies and increasing demand are leading to price volatility. The solution is to import LNG from nations with abundant supplies of natural gas. If capacity is not increased by importing more gas, building larger pipelines and exploring for additional sources of natural gas, America will continue to demand gas, put pressure on the supply side and continue to drive up the price of natural gas.
In its vaporized state, natural gas is
voluminous and therefore the rate of energy transferred moves rather slowly
through high-pressurized pipelines, especially when compared to oil. To get
LNG, natural gas is cooled to a temperature of minus 260 degrees
Fahrenheit until it becomes liquid and occupies 1/600 of its gaseous volume.
Large tankers are then used to ship the LNG to major markets. A typical
liquefying plant costs about $1 billion, tankers are priced at $250 million a
piece and a terminal to store the LNG and to "regasify" runs between
$300 million and $500 million.
Electricity In Connecticut
Connecticut is at a
crossroads in terms of providing its citizens with reliable electricity. Connecticut is not sure about nuclear
power. It cannot afford to continue to
use oil to produce electricity. Natural
gas supplies are tight, which is leading to price volatility. The state does
not use much coal to produce electricity and Clean Air Act regulations and
climate change considerations probably rule out significant additional
use. Wind and photovoltaic power have
to be backed-up with a reliable source of electricity. And the state is using about as much
hydropower as is available for use.
Connecticut has to make up its mind now to assure dependable electricity
ten years from now.
Historically,
Connecticut Light & Power (CL&P) and United Illuminating (UI), were the
only two companies making and selling electricity in Connecticut. In 1998, the
Connecticut Legislature passed a law that opened the electric generation market
to retail competition, effective Jan. 1, 2000. Several generators now provide
electricity.
In 2001, the fuel mix for Connecticut’s electricity
generating facilities is approximately:
·
43 percent oil/gas,
·
9 percent coal,
·
3 percent refuse/tires,
·
32 percent nuclear,
·
2 percent hydro, and
·
11 percent gas/oil.
Connecticut currently has two operational nuclear electric
generating units contributing a total of 2,017 MW (summer rating),
approximately 32 percent of the state’s capacity. Nuclear capacity, which
formerly accounted for 45 percent of the state’s operating capacity, has
already been reduced by the retirement of the Connecticut Yankee and Millstone
Unit 1 facilities in December 1996 and July 1998, respectively. Millstone
Unit 2, which was reactivated in the spring of 1999, is scheduled to retire in
2015.
Connecticut currently has 46 oil-fired electric generating
facilities, some of which can also burn natural gas, contributing a total of
2,706 MW, approximately 43 percent of the state’s current capacity. New
generation fueled solely on oil has been largely ruled out for future new
supply due in part to the historic and potential volatility of the crude oil
market.
Connecticut currently has 53 natural gas-fired electric generating units, some of which can burn oil, contributing a total of 724 MW, approximately eleven percent of the state’s current capacity. Natural gas is expected to be the fuel of choice to be used for electric generation to meet sulfur dioxide standards and other limitations set by the Clean Air Act. Natural gas electric generating facilities are currently preferred primarily because of the available technology, high efficiency, cleaner emissions, and the relatively low capital cost per kWh produced. The Connecticut State Energy Plan forecasts that natural gas for electric generation will nearly double from 24% in 2002 to 47% by 2011. (Connecticut Siting Council)
Connecticut Renewables Portfolio. Connecticut's
renewables portfolio standard (RPS) requires electricity suppliers and
electric-distribution companies to use renewable resources to generate 10% of
all retail electricity sales by 2010.
[Also
see: Attachment 1: Connecticut Electricity Sales by Utility, 2000; Attachment
2: Connecticut Electricity Generation by Operator, 2000; Attachment 3: Ten
Largest Plants by Generating Capability, 1999; Attachment 4: Electric Power
Industry Generating Capability by Primary Energy Source, 1990, 1994, and 1999]
Climate Change. Connecticut
has finalized a series of on-going and recommended actions developed by the
Governor’s Steering Committee on Climate Change and supported actions that will
reduce the pollution that causes global warming. The recommended actions in the
plan, entitled Connecticut Climate Change Action Plan 2005, is designed
to put Connecticut on target to reduce greenhouse gas emissions to 1990 levels
by 2010 and to 10% below 1990 levels by 2020. (See Attachment 6)
Unfortunately,
the recommendations are not realistic because the electricity generation
component is unrealistic. One of the major elements in the plan is to increase
the amount of renewable energy supplied to the electricity grid. In spring
2005, Connecticut electric consumers will be able to choose a clean energy
option to supply their electric needs.
These options are simply not available. Wind projects are being opposed
and it is an intermittent source of electricity that has to be backed-up by
fossil fuels or nuclear power. Thus,
hydro power is the only source for this electricity and there is not enough
hydro capacity to satisfy Connecticut’s electricity growth requirements.
Absent other options, it is a good thing that on a Btu basis, natural gas combustion
generates about half as much carbon dioxide, or CO2, as coal, less particulate
matter, and very little sulfur dioxide or toxic air emissions. It is also fortunate for the state’s
climate change plans that nuclear energy supplies 32 percent of the electricity
generated in Connecticut. Nuclear
energy supplies 29.8 percent
of the electricity generated in New York.
(Nuclear Energy Institute)
Electricity in New York
If approved, the Broadwater project would
begin receiving LNG in 2010. This
timetable should be accelerated if possible because New York is vulnerable to
electricity shortages. It will be
difficult to get new coal or nuclear power plants approved in New York. Wind projects are also encountering
significant resistance, even when they are proposed offshore. Photovoltaic
projects that could provide electricity to significant numbers of the
population in New York and Connecticut are not being proposed. Hydro is being utilized at about its maximum
and proposals for additional hydro capacity would encounter environmental group
opposition. Low-head hydro is an
impediment to fish migration.
According to the New
York State Energy Plan, natural gas demand in the state is expected to grow
nearly 38% by 2020 from 2002 levels.
This growth will be driven largely by electricity generation, which is
forecasted to grow approximately 23% by 2020.
Data collected and analyzed by the Northeast Power Coordinating Council
(NPCC) shows that electricity capacity growth will be satisfied by the
following fuel sources by 2008:
2008 Projected Fuel Mix
To Produce Electricity in the Northeast
|
Natural Gas |
51% |
|
Oil |
15% |
|
Hydro |
10% |
|
Nuclear |
9% |
|
Coal |
7% |
|
Other |
8% |
See also Attachment 5 Natural Gas Capacity and Consumption Rates for New England.
According to the DOE EIA (see chart below), the fuels mix in 2000 for generating electricity shows that natural gas is the fuel used most often to generate electricity in New York.
Electricity Fuel Source, 2000
New York Fuel Mix
|
Fuel |
Percent |
|
Nuclear |
23 |
|
Coal |
18 |
|
Petroleum |
11 |
|
Natural Gas |
28 |
|
Hydro |
18 |
|
Renewables |
2 |
See also Attachment 11 for a comparison between New York and national use.
Article X. The NY Power Authority (NYPA) recently installed ten new 79.9 MW natural gas turbines to generate electricity during peak hours. These were installed without environmental review (which is triggered at 80 MW) and are primarily located in poorer communities of color. Long Island and New York City commercial consumers may be paid to run their backup diesel generators during the day to further reduce demand, but at a cost of skyrocketing pollutant emissions. Watt for watt, diesel generators produce more than 50 times the pollution of a new, natural gas plant.
New York State Department of Environmental Conservation (DEC) issued air pollution control permits in 2001 to the New York Power Authority (NYPA) to allow the construction and operation of six new electric generating facilities in three New York City boroughs and Brentwood, Suffolk County. Although touted as a hedge against blackouts, local communities claimed environmental racism, particularly in the South Bronx.
Permits, known as State Facility permits, have been issued for new facilities in the following locations:
1. Harlem River Yard Plant - East 132nd Street, Bronx, 2 turbines;
2. Hell Gate - East 132nd to East 134th streets and Locust Avenue, Bronx, 2 turbines;
3. North 1st Street Plant - North 1st Street and River Street, Brooklyn, 1 turbine;
4. 23rd and 3rd Plant - 23rd and 3rd avenues, Brooklyn, 2 turbines;
5. Vernon Boulevard Plant - 42-30 Vernon Boulevard, Queens, 2 turbines; and
6. Brentwood - at the former Pilgrim State Hospital, Brentwood, Suffolk County, turbine.
The permits, which are valid for three years, limit generating capacity at the facilities with two turbines to 79.9 megawatts. Facilities using one turbine will be limited to 47 megawatts. Under the permits, NYPA will install natural gas-fired, simple-cycle combustion turbines at each location.
Article X of the New York
State Public Service Law sets forth a review process
in New York State (NYS) for consideration of any application to construct and
operate an electric generating facility with a capacity of 80 megawatts or
more.
An applicant must meet Article X requirements to obtain the Certificate of
Environmental Compatibility and Public Need (Certificate) that is needed before
construction of such a facility.
Article X of the Public Service Law was enacted in 1992 and expired on January 1, 2003. The law has not been reauthorized so New York is without an electricity power plant licensing statute.
Climate Change. New York City and eight States (California, Connecticut, Iowa, New Jersey, New York, Rhode Island, Vermont
and Wisconsin) filed a
lawsuit in Federal District Court in Manhattan in 2004 against utilities (American Electric Power, Cinergy, the Southern
Company, the Tennessee Valley Authority and Xcel Energy) alleging that, as
the country's largest emitters of the heat-trapping, global warming gas carbon
dioxide, they are harming the health of citizens. A federal judge dismissed the lawsuit in
September 2005. The judge noted that in asking the court to set CO2 reductions,
the states want the judiciary to craft wide-ranging environmental policies that
would affect the economy, national security, foreign policy and that such
political decisions should properly be considered by the president and Congress
The plaintiffs were not
seeking financial penalties but are demanding "substantial cuts" in
the emissions, which they say "pose serious threats to our
health, economy and environment.'' The defendants operate a
total of 174 fossil fuel-fired power plants that emit 646 million tons of
carbon dioxide a year, or 10 percent of the national total.
The suit was the first state
legal action taken directly against companies that discharge carbon dioxide, an
unavoidable byproduct of burning coal, oil and other fossil fuels. The
plaintiffs based the suit on federal common law of public nuisance. The common
law provides a right of action to curb air and water pollution emanating from
sources in other states. (AP, various
news services)
Mirant reported to the Securities and Exchange Commission (SEC) via its annual report that it intends to shut down the Lovett Generating Station in 2007, which produces most of Rockland County's electricity. It plans to close one unit in 2007 and the other in 2008. Mirant had the choice of spending at least $100 million to upgrade the plant with scrubbers or convert to natural gas. The utility concluded that the facility did not merit the investment.
New York began its
deregulation of utilities in 1996 in order to have competitive generation
services and open access to the transmission system. Some highlights of deregulation include:
·
The PSC supported the
development of the New York Independent System Operator (NYISO), which is
charged with providing open access while coordinating the daily operation and
ensuring the reliability of the New York bulk power system.
·
In 1997, the New York
Power Pool filed a proposal with the Federal Energy Regulatory Commission
(FERC) that dissolved the currently existing New York Power Pool and replaced
it with the NYISO.
·
Consolidated Edison (ConEd)
sold most of its power plants and now relies on long-term contracts and the
spot market operated by NYISO for its power requirements to serve its 3 million
customers in New York City.
·
Customers in the state
paid an average of 14.2 cents per kilowatt-hour in 2000, up from 13.3 cents in
1999, 13.7 in 1998 and 14.1 in 1997.
Factors contributing to the increase include
rising natural gas prices, the primary fuel used for generation in New York,
and the effect on markets of imbalances between supply and demand.
The New York State
control area has three major transmission constraint paths that show consistent
pricing congestion. Two of them are the interface of the transmission service
into New York City and then into Long Island. Transmission congestion into New
York City increases prices for electricity in the eastern part of the State,
including the City and Long Island.
One transmission
interface of concern is the Sprain Brook/Dunwoodie Interface, which consists of
the underground and submarine extra high voltage cables from Westchester County
into the New York City and Long Island load zones. This interface may limit the
total electricity it can transfer into these zones from upstate New York to
approximately 4,500 MW. Another interface of concern is the PJM-New York
Interface. The New York import capability from PJM under emergency conditions
is 2,400-2,900 MW, depending on regulatory controls on the PJM/New York
Interface.
In March 2001, the
NYISO issued a report entitled, "Power Alert: New York's Energy
Crossroads." The report brought attention to the possibility of an
impending electricity crisis in New York and made recommendations to alleviate
a growing imbalance in the supply and demand of electricity in New York.
The New York
Electric Reliability Council (a member of the North American Electric
Reliability Council) recommends maintaining a reserve margin of 18 percent of
peak load to ensure a reliable and continuous power supply. Since 1999, in
order to meet this reserve requirement, it has been necessary to rely more each
year on out-of-state generators. See also: Attachment 7: New York
Electricity Sales by Utility, 2000; Attachment 8: New York Electricity Generation by Operator, 2000;
Attachment 9: Ten Largest Plants by Generating Capability, 1999; and Attachment
10: Five Largest Utilities by Retail Sales within the State, 1999.
New York's electric
power system is comprised of four parts: upstate east and west, New York City,
and Long Island. New York City and Long Island are load pockets, areas where
the majority of capacity to serve the load must be locally installed due to
existing transmission limitations. These areas have additional location
reliability requirements. In the city, to meet peak demand with adequate
reserves, 80 percent of the peak demand capacity must be located physically
"in-city." Long Island requires 98 percent of peak load capacity be
located "on-island."
(DOE-EIA)
New York Renewables
Portfolio. On September 24, 2004, the
New York Public Service Commission issued its "Order Approving
Renewable Portfolio Standard Policy." That Order identified the
Commission's renewable energy policy and provided definitions and targets for
carrying out the policy. The policy calls for an increase in renewable energy
used in the State from its current level of about 19% to 25% by the year 2013.
In his 2003 State of the State Address, Governor George Pataki proposed standards that would ensure at least 25 percent of the electricity purchased in New York by 2013 is generated from renewable sources such as wind power. In 2001, Pataki issued an executive order that requires state agencies to use renewables for 10 percent of their electricity by 2005 and 20 percent by 2010. The New York Power Authority (NYPA) has announced it will purchase up to 50 megawatts of electricity from two wind projects. Excluding hydro sources, wind and solar currently make up less than 2 percent of the generation mix.
The ISO projects that New York's 2005 peak demand will be 31,962 MW (megawatts), an increase of 162 MW over last summer. Add to that another 5,753 MW of reserve power that is needed to provide a cushion in case of severe hot weather or equipment failures, and New York's total electricity capacity need is 37,715 MW.
Domestic LNG Facilities
There are approximately 113 LNG facilities in the U.S. Currently, there are only four import terminals and one export terminal, which is located in Alaska. Two percent of the natural gas used by homes and businesses comes from liquefied natural gas. The gas is chilled to 260 below zero to be stored and transported in insulated tankers and then reheated into gaseous form at terminals such as Cove Point before being piped to customers.
Liquefied Natural
Gas (LNG) is increasing market share because of increased use of natural gas at
electric utility plants. Today, LNG makes up about 2 percent of all gas
consumed in this country but if the projects now under consideration become
real, then LNG imports could supply 15 percent of the nation's gas demand by
2025, according to the U.S. Energy Information Administration.
Right now, only
four LNG receiving terminals exist in the United States and are located in 1) Georgia, 2) Louisiana, 3) Maryland and 4) Massachusetts. One of the
largest facilities, owned by Dominion
Resources, is located about 40 miles from Washington, DC
- - Cove Point terminal on the Chesapeake Bay in southern Maryland. Tankers
deliver the frozen LNG from the dock through two 31-inch diameter pipes
to storage domes a mile from shore. Imports of liquefied natural
gas are expected to increase. In addition to Cove Point, Maryland, the
nation's other three liquefied natural gas facilities - at Elba Island, Ga.,
Lake Charles, La. and Everett, Mass. - also have proposed expanding
and new terminals are being proposed on both coasts.
The increase in gas
prices has opened the door to LNG. Gas inventories needed for the winter
are still way below normal. The gas has to come from somewhere other than the
terrestrial Lower 48 because domestic supplies cannot keep up with
demand. San Diego's Sempra
Energy is building a $700 million LNG terminal in Louisiana and
has applied for permission to build a terminal in northern Baja California,
Mexico. ChevronTexaco's
is planning an LNG facility in the Gulf of Mexico, 36 miles from shore, which
will import 1.5 billion cubic feet per day of natural gas by
2007. ChevronTexaco’s proposed Pelican LNG terminal in the Gulf would be
the delivery destination for a huge gas production and LNG processing plant
planned for Angola. (EIA, Sempra, ChevronTexaco)
Texas LNG Facility Approved. The Federal Energy Regulatory Commission (FERC)
approved a $500 million liquefied natural gas (LNG) complex in 2004 owned by a
three-company consortium that will be located in Quintana Island,
Texas. Freeport LNG Investments, Cheniere LNG and Contango Oil and Gas
will build the facility 70 miles south of Houston, Texas, which will have the
capability to unload 200 ships a year of LNG. The Freeport LNG venture will be partially financed by
ConocoPhillip oil company in exchange for a portion of the gas. Dow
Chemical will also receive a large portion of the gas. (FERC)
Sempra, parent of
Southern California Gas and San Diego Gas & electric, also faces a need for
natural gas to supply three power plants being built in Bakersfield, Phoenix
and Mexicali, Mexico. (Sempra)
A single tanker
carries enough LNG to supply the daily energy needs of more than 10 million
homes. LNG, chilled to minus 260 degrees Fahrenheit, expands 600 times when
warmed to its normal vapor state. Chicago Bridge & Iron Company is
the world's largest builder of the cryogenic tanks that hold LNG in its liquid
state. Fluor Corporation of Aliso Viejo, and the Houston based Brown &
Root, a division of Halliburton, Inc build liquefaction and regasification
facilities.
The first LNG plant
built in the U.S. was built in Alaska in 1969 and is still operating.
Foreign LNG Facilities & Suppliers
There are
approximately 240 LNG facilities worldwide.
In 2002, 12 exporting countries shipped approximately 5.4 Tcf of natural
gas to 12 importing countries.
Natural gas
resources are plentiful all over the world. In addition to the U.S., there are
huge reserves in Indonesia, the Persian Gulf states of Qatar and Oman, as well
as in Russia and several West African countries. In ascending
order, the countries controlling the largest reserves of natural gas are the United Arab Emirates, Qatar, Saudi Arabia, Iran and Russia.
ExxonMobil Corp,
the world's largest energy company, is building a $12 billion LNG system
in Qatar. It will deliver 2 billion cubic feel a day of natural gas to
the U.S. starting in 2008. This unprecedented project will supply 2% of total
U.S. natural gas. Norway's biggest oil
and gas company, Statoil ASA, has signed a letter of intent with Dominion to
provide gas for the additional storage at the Cove Point terminal.
And Australian Company is
proposing an LNG port off the coast of California. BHP Billiton, an Australia-based company submitted a
license application in 2004 to construct a $500-million floating
deep-water liquefied natural gas port terminal off the Ventura County
coast. The Cabrillo Deepwater Port, which would act as a receiving point for
shipments of California-bound natural gas, would be the first such floating terminal
on the West Coast. Stored liquefied natural gas would be converted to vapor
through a heat exchange system and transported by an undersea pipeline to
existing onshore natural gas facilities. The project would be built about 20
miles off the coast of Oxnard. BHP has stated that the terminal would also be
placed outside shipping lanes and marine mammal migratory routes, as well as
away from the Point Mugu Navy base and the Channel Islands National Marine
Sanctuary.
Shipbuilders
LNG Tanker Contract. According to officials in Qatar, Hyundai Heavy Industries, Daewoo Shipbuilding
and Marine and Samsung Heavy Industries Company
have won a $3.2 billion contract to build eight of the world's largest tankers
for shipping liquefied natural gas, with an option for eight more.
The Overseas Shipbuilding Group, a tanker owner listed in the U.S., and
Pronav Ship Management (no website) of Germany ordered the ships. (Bloomberg
News)
BP & Sempra Energy LNG
Contract. In 2004, BP, Europe's
biggest oil company, and partners in Indonesia's Tangguh LNG project announced
they will start to deliver as much as 3.7 million metric tons of the fuel to
Sempra Energy in Mexico in 2008, Indonesia's oil and gas regulator said. BP and San Diego-based Sempra have signed a
20-year sales contract. The LNG will be delivered to Sempra's planned terminal
near Ensenada in Baja California. There, the LNG will be returned to gas form
for use in power plants.
Security,
Safety and Health
Security
AAEA believes the FSRU will be as secure as any other commercial or industrial facility in the United States. Environmental critics and Not-In-My-Backyard (NIMBY) practitioners have seized on the terrorism issue and are using it to further their opposition to needed projects. Whether it is a uranium fueled power plant or an LNG facility, the threat of a terrorist attack is now being used to try to prevent needed infrastructure from being built.
Terrorists and Airplanes. We do not believe the United States should base its future development on the threat of terrorist attacks. To the extent that critics promote the notion that terrorists will use airplanes as missiles to destroy American facilities, they are calling for the shutdown of the airlines. Why should the proposed Broadwater Project be responsible for the misuse of another company’s product? Anyone stating that airplanes from Newark, JFK and LaGuardia airports could be used to destroy an LNG tanker or the FSRU is calling for the shutdown of the offending airline and airport. If it comes from another airport, then they are calling for the shutdown of that airport and associated airline. Of course if the Transportation Security Administration (TSA) and the U.S. Defense Department cannot protect American assets from terrorists, then maybe we should just free Saddam Hussein and put him in charge of our country. Of course, I do not hold this position and we do not hide in the closet afraid that the terrorists will kill us. We believe that America, New York and Connecticut should develop our country in a way that responsibly serves the needs of our citizens.
Security Zone. The selected location for the FSRU is brilliant. The Broadwater Project planners should be commended for figuring this out. The security zone established by the U.S. Coast Guard will enhance the security of the FSRU. Because the Coast Guard has established a 500-yard safety zone at other locations, we can assume that will be the safety zone for the Broadwater Project. Such a zone provides adequate security from most reasonable threats. The 120-mile long and 20 mile wide Long Island Sound represents another layer of security. It will be possible to see any water threat coming from miles away.
Safety
The FSRU will be safe because it will be in the middle of the Long Island Sound that is 120 miles long and 20 miles wide. We will get the maximum amount of safety from a minimum amount of safety zone space. The 500 square yards of safety zone space around the 1,200 foot long, 180-foot wide facility is virtually nothing in a 120 mile long by 20-mile wide Sound. At the same time, we get the buffer of the facility being 10 miles from the closest shore. Virtually none of the population will be at risk. Moreover, concerns about a flammable vapor cloud are diminished because of the ten miles such a cloud would have to travel, in concentration, to threaten anyone.
Due to the slow flame speed associated with combusting natural gas, in unconfined surroundings, an explosion would not occur and the fire would burn back to the source. It could not be any safer for residents of Long Island and Connecticut. Although some rural area in both locations might be close to being totally unpopulated, the middle of the Sound is definitely unpopulated by humans. We also believe that any accident in the middle of the Sound would probably kill fewer animals and plants than in an isolated rural area.
The FSRU will receive two LNG shipments per week, which will be stored, warmed and sent to New York and Connecticut via the existing Iroquois pipeline. AAEA is confident that we can protect shipments of LNG through the Sound to the FSRU. Our security is second to none.
Although there have been some deaths related to LNG facilities, it is not significantly greater than other industrial projects. Electrical transmission line repairmen are killed maintaining our power lines, but we do not want to eliminate that service. Airplanes crash and kill many more people in one crash than have died in the entire history of the LNG industry. Thousands of people still fly on thousands of airplanes every day. In any cumulative risk assessment, LNG would come out as a very safe fuel for commercial use.
Dangers from pool fires are minimal. The vapor will only burn if the concentration of gas-in-air is greater than 5% and less than 15%. For mixtures less than 5% gas there is not enough fuel to support combustion; with a mixture of greater than 15%, there is not enough oxygen to support combustion. (Broadwater Project Description)
Health
There will not be any unusual occupational health hazards that would be different for workers at a similar facility, such as an offshore oil platform. Actually, workers will have great views and a great fishing location. There should not be any negative health effects to residents of New York or Connecticut. There should be minimal to no leakage of gas that would affect human health. The pipeline will have no human health effects because it is underwater and under Sound bottom sediment.
Conclusion
LNG is an excellent fuel
for electricity generation. We need a
mix of energy sources to produce electricity.
New York and Connecticut cannot continue to oppose new generation and
expect economic growth to continue without disruptions. In today’s environmental climate, natural
gas will be one of the primary fuels used for electricity generation. To the extent that plants are built to
utilize this fossil fuel, it needs to be available in quantities sufficient to
meet local demand. We
cannot NMBY anytime and anywhere and expect to have electricity all the time
and everywhere.
It appears that the only real obstacle to its application in the Long Island Sound is ‘Not-In-My-Back-Yard’ (NIMBY) scenic elitists. And you can barely see it from the shores. Of course, their sensitivities should not be belittled or minimized. However, the reason most industrial and pollution sites end up in poor and minority neighborhoods is because power elites can afford to keep them out of their backyards. There should be some sensitivity to the fact that many Americans are sacrificing their health for industrial activity while others do not even want to barely see a remnant of a benign, environmentally friendly facility on their horizon.
The Broadwater Project will have minimal, if any, negative safety, security or health effects.
Attachment
1
Connecticut
Electricity Sales by Utility, 2000
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