The Problem With FERC's Environmental Review of Broadwater? "Quarrying marble in Long Island Sound"

Ralph Lewis, who used to be the Connecticut State Geologist and is now a geology professor at UConn, got a fair amount of attention early last month when he compared the geology section of FERC’s Broadwater environmental impact statement to a bad term paper.

Save the Sound got a copy of the transcripts of Lewis’s remarks (he and three other scientists were testifying before Connecticut’s LNG task force, in Hartford) and submitted them to FERC, as part of their comments on the EIS (click here and then enter "Broadwater" in the 'text search' box, near the bottom, then look for the Connecticut Fund for the Environment's filings). I read through Lewis’s section this morning and was amazed at his critique and its implications for the environmental analysis that FERC will base its Broadwater decision on.

Lewis makes two main points. One is that the analysis in the environmental impact statement of the Sound’s geology is barely competent, but in general it doesn’t make any blunders that would lead him to believe the moorings for the LNG terminal, or the pipeline that would transport LNG, would be unsafe. Her gave on example, for instance, of an assertion about the Sound's geology that sort of makes you scratch your head:

… they're talking about quarrying marble in Long Island Sound, which doesn't even exist in Long Island Sound. It only exists in the northwestern part of the state.

That’s a mistake but on its own it’s irrelevant to whether the floating gas terminal would be safe.

Here’s another mistake, more serious but still, I think, one that can be solved by Broadwater spending more money on engineering than it originally thought it would have to. The issue is the clay that forms the basin of Long Island Sound, how deep those clay deposits are before they hit bedrock, and what would happen if there were an earthquake, which, as Lewis notes, happens about once a year in New England. The environmental impact statement asserts that you have to go through about 165 feet of clay before you hit bedrock; Lewis, who published a lot of original research on these kinds of questions, says it’s more like 400 to 500 feet:

If there's an earthquake, they're worried about shaking. … what would be a good example that I could give you? If you had a bowl filled with concrete and a bowl filled with Jell-O, and you wrapped those two bowls in exactly the same amount of energy, which one would shake more? The Jell-O.

Well, the lake clay is like Jell-O. The bedrock is like the concrete. So there's a thing called intensity. An earthquake can only have one magnitude, X number of sticks of dynamite goes off, and it releases one amount of energy. But what that energy is passing through determines how much damage there is, so there's a thing called modified mercali intensity, which, what that basically says is that you could have one earthquake go off, but you can have a variety of amounts of damage. Buildings sitting on bedrock and buildings sitting on made land or lake clay or something like that, there'd be much more damage over the lake clay, and you can predict that.

So they're worried a little bit about the fact that the lake clay would be susceptible to shaking, and what they propose to do is put pilings in, and they mentioned 165 feet, I believe, in the report. That may not be, if they want to found those pilings in bedrock, they may have to go much deeper than that in some places because there are places in Long Island Sound where the lake clay is 400 or 500 feet thick. So I just bring that up as a concern that they didn't really understand the distribution of the lake clay when they mentioned that.

These kinds of mistakes (and Lewis describes a number of others) lead to his second point – that the basic research about Long Island Sound’s geology is easy for a competent geologist to find and to understand, so if FERC did a poor job finding it and understanding it, we probably should assume FERC did a poor job finding and understanding the other research and issues the environmental study covers. Here's what he says:

… the approach I took was that what I was expecting to see would be something probably at the level of a graduate student or a young professional who was either submitting the first draft of a thesis or dissertation or submitting to me a draft for my review of a paper to be published. So that was the level of expectation that I had for, you know, the background that I would be supplied to see if they had supported their argument or not.

I'm not taking any sides as to whether this is a good idea or a bad idea. I just tried to review the material that was there, and give you some idea of what I thought. My finding is that probably this is at the level of maybe an undergraduate, reasonably bright undergraduate, who's taken some geology courses … who had some insights but probably went to the library the afternoon before the paper was due, grabbed what was there, and pulled an all-nighter and wrote the paper, first draft.

And I base that on my first read. I haven't really spent a lot of time with it, but that was my first impression. So they certainly didn't meet the level of expectation that I would have, and I would call that sloppy in my terminology. If I were talking to a student, I'd say that was a pretty sloppy first effort, so that's the terminology I'll use. So what I have to say is, overall, it's a fairly sloppy general overview of the geology of Long Island Sound by people who either didn't have the knowledge or didn't take enough time to seek out the best reference material in support of their arguments. And what I feel is, they've used old references that have been superseded by better information.

A good example of that is the Williams 1981 reference that they use in the first paragraph of their opening argument. It's over 35 years old, and I think a careful researcher would realize that that's probably been superseded.

So in summary of what I think, in the case of the geologic setting hazardous section, the sloppiness did not result in any great misunderstandings of the general state of affairs. My concern though is, that if they were this sort of sloppy with the geology sections, if they were equally sloppy elsewhere, there may be some place where that really did make a huge difference.