Monday, December 31, 2007

Dear Governor Spitzer: Reject Broadwater's Proposal for Long Island Sound (III)

Adrienne Esposito, executive director of Citizens Campaign for the Environment, has written an open letter to Governor Eliot Spitzer, explaining why Broadwater's proposal to put an LNG terminal in Long Island Sound, should be rejected:

Dear Governor Spitzer,

The Broadwater battle has never been about opposing energy infrastructure but rather it is a battle to protect Long Island Sound. The Broadwater monstrosity will be detrimental to the Sound. First, it will diminish the already-struggling lobster population. As the NYS Department of Conservation just confirmed in their December 21, 2007 letter, the Broadwater project will increase water temperatures resulting in lobster fatalities. The project will need approximately 28.2 million gallons of seawater per day, which will result in an estimated 274 million eggs and larvae being killed annually and in addition an unknown number of young and small adult fish will be lost. Many of these fish deaths will include the commercial and recreational valuable Winter Founder.

As you are aware, the NYS Department of State will soon release an evaluation of Broadwater’s conformity to the federal law, Coastal Zone Management Act (CZMA). This critical law requires the state to evaluate and assess potential impacts to the water dependent uses and public access of a waterway. If Broadwater were to be approved, it would set a new low standard for applying the CZMA and weaken protection for other waterways. The CZMA was designed and crafted to protect waterways and to allow them to continue to be used for traditional maritime purposes. Broadwater will need a 1.5 square mile security zone and another moving security zone around each and every LNG tanker entering the Sound. This would set a new, dangerous precedent for restricting public access in favor of corporate control of a waterway. The security zone would require a 24 hours per day armed surveillance, establishing the first “militarized zone” in the middle of one of NY’s waterways. This would be a national precedent for an estuary of national significance – one that future generations will regret.

CCE has long argued that alternative LNG technologies and alternative locations need to be fully explored and evaluated. We will not support energy infrastructure that causes severe environmental damage, such as Broadwater. However, we understand the need for energy, and encourage the development of a regional energy plan. This plan should seek to identify the least environmentally damaging energy infrastructure. To date, two other LNG alternatives for the tri-state area have been proposed, the Atlantic Sea Island and the BlueOcean Exxon proposal. In addition, there are other LNG proposals moving forward for the northeast such as the two sub sea pipelines approved off of Massachusetts. Each one of these LNG projects will provide 1 billion cubic feet of natural gas per day into the northeast market.

We understand that change is inevitable; however, change does not have to come at the cost of losing what it is that we love. The Long Island Sound is a special place and that’s why so many of us have fought long and hard to preserve and protect this water body. To so many, the Long Island Sound is our equivalent of Central Park. If you would deny an LNG facility from being place in the middle of Central Park then we are urging you to join with the 80,000 members of the public who oppose Broadwater. Thank you for your consideration to this important matter. We look forward to the state’s ruling.

Adrienne Esposito
Executive Director
Citizens Campaign for the Environment


Thursday, December 27, 2007

New York Tells Broadwater its Environmental Analysis Isn't Good Enough

The New York State Department of Environmental Conservation has written a tough letter detailing a number of problems it has with Broadwater’s proposal to put a liquefied natural gas terminal in the middle of Long Island Sound. The letter is dated December 21, 2007.

Coming just weeks before the state is scheduled to make a final decision on Broadwater’s application, the letter says that Broadwater’s analysis of the environmental impacts of its LNG terminal is inadequate, and its plans for mitigating some of the environmental problems the terminal would cause in the Sound are weak. And it concludes that even if mitigation methods are strengthened, it might not be good enough.

Citizens Campaign for the Environmental got a copy of the letter and distributed it and a press release late last night. Here are a couple of excerpts (I’ve posted the letter below):

We find that the application lacks details on applicable DEC and EPA requirements, requirements we had previously told Broadwater to address….

… Projected exceedences of the SO2 PSD increments and PM2.5 standard indicate that an air permit could not be granted at this time….

Regarding the seabed pipeline, the project proposes to leave the pipeline trench open, allowing it to backfill passively over time. The Department believes that cable and pipeline trenches do not fill in naturally in all locations, as field evidence increasingly indicates, and that these open trenches present unnecessary negative impacts to aquatic biota. Accordingly, the Department objects to the open trench proposal and reiterates its position that the trench should be backfilled after pipeline installation to restore pre construction bottom topography, and eliminate negative impacts. Before the Department can determine whether to issue a WQC it will be necessary for Broadwater to more thoroughly explore and evaluate the facts and science associated with trenching alternatives including backfilling techniques.

Last, the project as proposed presents significant adverse impacts to the Long Island Sound aquatic environment and fishery through the entrainment and impingement impacts of the FSRU and LNG carriers. There are design changes suggested below to reduce this impact, but even with these changes the project=s effect on the fishery will be significant. Further assessment and consideration must be given to additional changes and mitigation measures relative to this impact. …

Here’s how CCE characterizes the letter:

“The letter was fairly scathing of the Broadwater project with regards to not only the environmental impact but it indicates that Broadwater has been displaying corporate arrogance by disregarding New York States repeated requests for accurate information,” said Adrienne Esposito, Executive Director of Citizens Campaign for the Environment. “This letter is a terrific step in the right direction for our side. It illustrates the State is doing their due diligence and standing their ground to the corporate King Kong of Shell Oil. The Governor should be seeking advice from these state agencies and the DEC message is loud and clear.”

The issues identified in the letter are all issues that CCE has also identified over the last three years of the Broadwater battle. “The battle has never been about energy but rather about protecting the Long Island Sound,” Esposito concluded. Governor Spitzer and the New York State Department of State are due to release their decision no later than February 12, 2008.

9:50 a.m. update: The Suffolk Times has a story about the state's response, here.


New York State's Letter to Broadwater Detailing Inadequacies in the Environmental Analysis and Mitigation Plans for an LNG Terminal in the Sound

New York State Department of Environmental Conservation

Division of Environmental Permits, 4th Floor

625 Broadway, Albany, New York 12233-1750
Phone: (518) 402 9167 $ FAX: (518) 402 9168


December 21, 2007

Murray Sondergard
Broadwater Energy LLC
c/o Robert Allessi
LeBoeuf, Lamb, Greene & MacRae LLP
99 Washington Avenue, Suite 2020
Albany, NY 12210-2810

Re: Broadwater Energy Project
DEC No. 1-4799-0007/00001

Dear Mr. Sondergard:

The New York State Department of Environmental Conservation (the Department; DEC) has reviewed the permit applications and supporting documentation submitted on behalf of the Broadwater Energy Project. Applications examined include those for air, State Pollution Discharge Elimination System (SPDES), petroleum bulk storage, and hazardous substance bulk storage permits; and a Section 401 Water Quality Certificate. Comments on these applications are provided below.

Project Description

The Broadwater Energy Project is a joint venture between TransCanada and Shell US Gas and Power, and involves construction and operation of a marine liquified natural gas (LNG) terminal and underwater natural gas pipeline, both in Long Island Sound. The terminal and pipeline will be used to import, store, regasify and transport natural gas. The terminal will hold roughly eight billion cubic feet (bcf) of LNG with vaporization capabilities of 1 bcf per day and up to 1.25 bcf at peak.

The terminal will be a Floating Storage Regasification Unit (FSRU), the first such free-floating FSRU in the world. The terminal will be located in roughly 90 feet of water, approx. nine miles north of the Long Island coast and approx. 12 miles south of the shoreline of Connecticut. A 30 inch diameter pipe will be installed for 21.7 miles on the bottom of Long Island Sound, from the FSRU west to an underwater connection with an existing Iroquois Gas Terminal System pipeline.

The FSRU will be approx. 1,215 feet long, 200 feet wide and 100 feet high, with a 40-foot draft. The FSRU will be moored to a tower anchored to the bed of Long Island Sound. The mooring system will allow the FSRU to weathervane around the tower, and the tower base will be approximately 13,180 square feet on the Sound bottom.

Federal Jurisdiction

The Federal Energy Commission (FERC) must approve the pipeline and LNG handling, storage, and regasification on the FSRU. The US Coast Guard is responsible for the safety and security of the FSRU, and LNG carriers at berth and in transit. The US Army Corps of Engineers must approve the project under the Rivers and Harbors Act and the Clean Water Act. This requirement is also subject to federal regulations, known collectively as the General Conformity Rule. Pursuant to Section 176c of the Clean Air Act, FERC must find the project in conformity with New York=s State Implementation Plan. Under the National Environmental Policy Act LNG import facilities are Major Federal Actions, requiring an environmental impact statement (EIS). A Draft EIS was completed by FERC in November 2006.

Department of Environmental Conservation Jurisdiction

The project must be approved by DEC under Federally-delegated regulatory programs. Thus the project requires an air and SPDES permit, and a Section 401 Water Quality Certificate (WQC) from DEC. In addition, the Department must issue the project a Hazardous Substances Bulk Storage permit and a Petroleum Bulk Storage permit for the use and storage of hazardous substances and petroleum based substances, respectively. The Department will review the project=s General Conformity Applicability Analysis.

Applications have been received for all permits, and, with the exception of the SPDES permit application (received December 12 and under active review), are addressed by the comments below. Broadwater=s General Conformity Applicability Analysis, received December 6, is also under review and DEC=s comments on it, if any, are forthcoming.

The Department has reviewed these applications for consistency with the applicable statutes, implementing regulations, and Department policies and practices developed thereunder. If our analysis reveals insufficient information has been provided we will determine the applications incomplete, and, under our procedural regulations, all the applications must be complete simultaneously in order for the application procedure to move to the next stage of public review and decision-making.

Ultimately, if our review concludes the applications are in non-compliance with the applicable statutes and regulations we will be unable to approve permits for the project. DEC will disapprove any activity with the potential for a significant adverse environmental impact that is unmitigated or not offset by demonstrated social benefit or public need.

Review Summary

DEC=s review of the air application concentrated on the air impact analysis, and considered issues relative to the impact assessments. We find that the application lacks details on applicable DEC and EPA requirements, requirements we had previously told Broadwater to address. It contains a project overview and fragmented sections on aspects of the permit requirements and only a summary table of non applicable requirements.

Review of the air quality impact analysis has identified a number of significant issues which must be addressed before conclusions can be reached on projected impacts, and before we can determine the application to be complete. Projected exceedences of the SO2 PSD increments and PM2.5 standard indicate that an air permit could not be granted at this time. Because this review is iterative, the Department will await your response to the items listed below before conducting a full review of modeling results.

Regarding the seabed pipeline, the project proposes to leave the pipeline trench open, allowing it to backfill passively over time. The Department believes that cable and pipeline trenches do not fill in naturally in all locations, as field evidence increasingly indicates, and that these open trenches present unnecessary negative impacts to aquatic biota. Accordingly, the Department objects to the open trench proposal and reiterates its position that the trench should be backfilled after pipeline installation to restore pre construction bottom topography, and eliminate negative impacts. Before the Department can determine whether to issue a WQC it will be necessary for Broadwater to more thoroughly explore and evaluate the facts and science associated with trenching alternatives including backfilling techniques.

Last, the project as proposed presents significant adverse impacts to the Long Island Sound aquatic environment and fishery through the entrainment and impingement impacts of the FSRU and LNG carriers. There are design changes suggested below to reduce this impact, but even with these changes the project=s effect on the fishery will be significant. Further assessment and consideration must be given to additional changes and mitigation measures relative to this impact.

Review Comments

1. Application Form

a. The applications fail to properly identify the permit applicant. The applicant is identified as Broadwater Energy LLC, and the person signing the application is titled Project Director. No address is given for the company, nor is the Project Director identified as a company employee, representative or agent. At minimum, an address for the company must be provided and a duly designated officer or principal of the company must sign the applications.

b. The application lists Broadwater Energy LLC as the owner. The underwater land on which the project will be undertaken (the bed of Long Island Sound) is owned by the State of New York. The Department requires that the owner identified in the application hold title to the land, facility, easement or right-of-way on which the project will be undertaken. If someone other than the owner is the applicant, written consent of the owner to use the property or facility must accompany the application. Broadwater must demonstrate that the NYS Office of General Services will provide it with the appropriate leasehold to site the facility as proposed.

2. Air Application

a. Section 1 of the Air Quality Modeling Report (Attachment 3d of the application) states that, per NYSDEC guidance, the emissions from the docked LNG carriers are included in the impact analysis. Section 3.1 notes that only the boiler emissions associated with LNG pumping were included as required for EPA's PSD applicability determination. However, DEC consistently noted in its comments during the protocol review that all "stationary" source emissions must be included in the impact analysis, in addition to those on the FSRU, independent of any applicability determinations. Thus, emissions during ship hoteling noted on page 3 7 and any other emissions from the carriers or any anticipated tugs while stationary next to the FSRU must be modeled.

Page 3 7 also notes that, per NYSDEC guidance, the short term emissions have not been scaled for the hours with zero emissions in a 24 -hour period. This change should also be reflected in footnote 1 of Table 4 in Attachment B (Emissions Workbook) of the modeling section, and in other locations.

b. Section 3.3 notes two sizes for carriers that will supply LNG to the FSRU: 140,000 and 250,000 m3 vessels. For the smaller carriers, the oil sulfur content is 4.5% maximum and 2.7% average for the short term and annual impacts, respectively, based on data reported by an international convention. For the larger 250,000 m3 carriers, the modeling is based on 1.5% sulfur content which it said to be the anticipated convention limit. Broadwater must provide an acceptable demonstration process, and permitting should reflect the means by which both these limits will be achieved by the carriers that will supply the FSRU. Otherwise, the maximum available sulfur content fuel should be used in the modeling analysis.

In addition, Attachment 3c of the application notes that the PM10 and PM2.5 emissions for the FSRU components reflect the factors from AP42, which includes the condensible fraction of particulates. It is not clear if condensible particulate form is also reflected in the carrier emissions per noted Reference 13. If not, these should be included in the modeling results.

c) Section 3.4 discusses how building downwash considerations are addressed in the modeling and references Appendix B for the FSRU and carrier dimensions. The only diagrams we can find are in Appendix E, but these do not provide plot plans detailed enough to confirm whether the BPIP PRIME input dimensions are proper. Thus, more detailed vertical and horizontal plot plans should be provided.

d) The impacts of short term emissions due to startup and shutdown conditions are incorporated in the modeling by scaling the hourly emission rates. In previous comments to Broadwater on the protocol DEC requested a separate assessment of the short term impacts of pollutants affected by these conditions. The request was based on the potential lower stack temperatures and velocities associated with start up and shut down periods. Although the modeled hourly emission rates used by Broadwater have accounted for these conditions, the corresponding effects of lower stack parameters must also be addressed.

e) Pages 2 3 of Section 2 incorrectly note that our August 31, 2007 comments on the modeling protocol stated we were satisfied that the safety zone can be used as the fence line for the purposes of defining ambient receptors. Our review letter only noted that we did not need further information from Broadwater at the time because we were awaiting EPA's decision on where ambient receptors should be placed. That determination was made by EPA in an October 9, 2007 letter. Thus, section 2 and Section 3.6 discussions on receptor placement should reflect EPA's determination that the safety zone can be the starting distance of the receptors, including the determination that the carriers are considered to be under the control of Broadwater and can be excluded from the definition of ambient air.

f) Section 4 of Attachment 3d presents the results of the modeling of the FSRU with and without the carriers at berth (at two sizes noted above) using the OCD and AERMOD models approved for use as per the modeling protocol review for specific conditions. The results are presented in Tables 8 to 10 for the OCD model and are separated by on water and on shore receptors, while Tables 11 13 present results of AERMOD that simulated downwash effects using more recent methodologies than in OCD on near field receptors(i.e. over water only). To the extent that these results will be affected by comments 1 and 2 above, a revised set of Tables will need to be provided. These tables should also be revised to include PM10 annual impacts since the PM10 standards and PSD increments are still applicable in New York for source permitting purposes.

The results presented indicate that for each of the pollutants modeled, there is at least one scenario under which the corresponding EPA significant impact levels (SILs) are exceeded. We request that the distance to which the SILs are exceeded (i.e. the Significant Impact areas, SIAs) be provided in all these instances, as well as the locations at which the maxima occur for each of the tabulated results. EPA and DEC policy requires that when a SIL is exceeded, a cumulative impact analysis be conducted to assure that the proposed facility does not contribute to a modeled standards violation. The modeling protocol (Appendix A, page 3 19) notes that under these circumstances, NYSDEC procedures in DAR 10 and Air Guide 36 are used to assess whether and which nearby sources need to be explicitly modeled in a cumulative analysis, in addition to the use of regional background levels to represent other source contributions.

On the other hand, the application improperly argues that nearby sources need to be modeled primarily if the proposed source is on land and if its SIAs overlap "permanent" receptors (i.e. not over water). Significantly, this argument is only presented for the AERMOD results wherein receptors have been confined to the near field (over water locations) and this limitation translates to there being no nearby major sources within the 15km distance to the shoreline at Long Island. Thus, the results from the project are added to only the regional background levels for comparison to standards in Tables 11 13.

Not only are the supporting arguments provided in the application unjustified, but also it should be noted that the OCD results in Tables 8 to 10 indicate that the short term SILs for SO2 are exceeded at the shoreline receptors, in addition to numerous exceedences at over water receptors. Thus, a cumulative analysis is necessary for the project to demonstrate that it does not contribute to standards violations. That analysis must follow the procedures in NYSDEC DAR 10 and Air Guide 36 as well as in EPA's New Source Review Workshop Manual. Since the protocol did not detail how such an analysis might be performed, Broadwater should submit a proposal for DEC review and approval before undertaking the analysis.

The starting point would be to define the SIAs for each pollutant and request a source inventory from New York and/or Connecticut (once it identifies on which shoreline the SILs are exceeded) out to 50km from the largest SIA. Furthermore, the cumulative analysis should remedy the limited receptors placement in the application to only along the shorelines (page 3 19), while the protocol noted that a grid of receptors would be placed to capture near and on shore impacts. That grid should be refined to assure maximum impacts are defined for the cumulative analysis.

g) The AERMOD results in Table 12 indicate that the project is predicted to exceed the 3 and 24 hour SO2 PSD increments with the 140,000 m3 LNG carriers at berth. Whether other pollutants or scenarios also might be projected to have similar exceedences will depend on responses to comments above on carrier emissions. We had indicated in our 8/31/07 protocol review letter that the PSD regulations require an increment consumption analysis for minor sources, even if these are not PSD applicable, pursuant to 40 CFR 51.166(b)(13)(ii)(b). These exceedences mean that the project as proposed cannot be permitted without mitigation of the increment violations. The resolution can include either a project modification or impact offsets per guidance in EPA's New Source Review Manual (Section C.IV.E).

h) The application discusses the impacts of the project on PM2.5 levels in the context of Commissioner's policy Commissioner=s Policy 33 (CP-33. Assessing and Mitigating Impacts of Fine Particulate Matter Emissions. 12/29/2003) on pages 4 8 to 4 10. It concludes that even though these impacts are above the thresholds in CP 33 that would require an environmental impact statement, such a Draft EIS has been submitted to FERC. We previously commented on this analysis and do not know yet FERC=s conclusions in the Final EIS. However, it is seen from Tables 11 to 13 that the impacts from AERMOD predictions are above the 24 hour PM2.5 standard of 35 ug/m3 with and without the carriers next to the FSRU, when the maximum regional background level from the protocol is added to the project impacts. If this background level is used for the OCD model results in Tables 8 to 10, the same standards violations would result. As noted previously, these results do not account for comments 1 and 2 above which could increase the level of impacts.

These projected violations are unacceptable for inclusion in the FERC EIS, and for DEC permitting purposes. Broadwater can revisit the background levels, which they note to be conservative, using procedures allowed in EPA's Modeling Guidelines. In addition, the application (and FEIS) should discuss all measures which Broadwater can take to minimize the impacts of PM2.5 not only to meet CP 33 requirements, but also because the location of the project can be deemed to be in the PM2.5 nonattainment area.

i) Section 3g of the application discusses the nonattainment requirements of Subpart 231 with respect to an alternative site and size analysis using the "three prong" test previously determined by the Commissioner as a necessary component for major source review in nonattainment areas. Aspects of this alternatives analysis need to be revised or augmented. With respect to the first prong addressed in Section 3.1, the discussions fail to address the projected PM2.5 standards violations (and increment exceedences) noted above in demonstrating that the potential adverse effects have been avoided to the maximum extent possible.

With respect to the third prong, the application discussions rely on their alternative sites analysis in the FERC DEIS and claim FERC has accepted these assessments. However, the requirements of Section 231 2.4(a)(2)(ii) are independent of what information FERC might accept or require to reach its determinations. Thus, the application's claim that they need only look at sites they own or control is inappropriate within the context of Subpart 231, and is especially since they do not own or control the underwater lands of the proposed site. Furthermore, most of the discussions appear to summarily dismiss all Atlantic Ocean sites and address either onshore or Sound sites, while ocean sites are noted in terms of sites in New England or Gulf of Mexico. The only site on the Atlantic side of Long Island mentioned is the Safe Harbor project which is noted to be in initial stages of proposal without any discussion of relevant environmental impacts. There is also a brief discussion of the pipeline sites suggested by NYSDOS for consideration, as presented in Section 5 of the application.

These discussions of alternative sites fall short of the requirements of Subpart 231 2 for the Broadwater proposal. Sites which are distinctly different from the proposal should be assessed in detail with respect to the air quality aspects, and whether they offer more environmental benefit without unduly curtailing the project benefits.

3. General Conformity

As stated above, Broadwater=s General Conformity Applicability Analysis was received by the Department on December 6. It is under review and DEC=s comments on it, if any, will be provided as soon as possible, but no later than February 8, 2008.

4. Section 401 Water Quality Certificate

a. The application proposes to leave the pipeline trench open, allowing it to backfill naturally over time. DEC believes there is strong evidence that portions of exposed trenches remain open years after construction, and that an open trench may have a negative impact on the movement and survival of lobsters and other aquatic organisms. Backfilling with native substrate to restore the pre construction topography will allow for more rapid re colonization by benthic organisms. In addition, backfilling will minimize the potential for thermal impacts on NY's already stressed lobster resources.

Temperature increases in the vicinity of the pipeline can exceed 20 degrees F above ambient temperatures. Such an increase would be detrimental or fatal to lobsters during summer months when ambient temperatures in Long Island Sound approach the maximum tolerated by lobsters.

Accordingly, to avoid these impacts the Department strongly supports the FERC proposal in its Draft EIS to actively backfill the trench and strongly recommends that the project be redesigned to backfill the trench immediately after pipeline installation, in order to restore pre construction bottom topography, and is unlikely to authorize a pipeline construction that does otherwise. Any WQC issued for the pipeline would require post construction monitoring to ensure that the natural topography is restored and maintained.

b. Although the application provides no construction schedule for the pipeline, if the project is approved the Department will likely impose seasonal construction restrictions to protect aquatic resources.

5. SPDES Permit Application

a. As state above, a revised SPDES application was received by the Department December 12 and review is ongoing. The Department will provide comments on the application, if any, as soon as possible, but no later than February 8, 2008.

6. Seawater Withdrawal

According to application documents, the project (the FSRU and LNG carriers) will withdraw a total of approx. 28.2 million gallons per day (MGD) of seawater. This will result in an estimated 274 million eggs and larvae being entrained annually, and, in addition, an unknown number of young-of-the-year (YOY) and small adult fish.

Of that total, the FSRU will withdrawal 6.6 MGD to support all FSRU operations. This will result in the annual entrainment and death of 64 million eggs and larvae and, again, an unknown number of YOY and small adult fish. The estimated 130 carriers per year will potentially entrain 210 million eggs and larvae (approx. 1.6 million per vessel), and an additional unknown number of YOY and small adult fish.

The Department believes that the destruction of over 270 million eggs and larvae, and more YOY and young adult fish, annually, is a significant adverse impact to the aquatic environment and fishery of the Long Island Sound.

Relative to the FSRU, the current design of the intake screening in the sea chests calls for cleaning the sea chests periodically, not continuously. As a consequence, most (likely all) impinged organisms will die. In addition, current designs call for adding chlorine before the screen. This will ensure that any organisms that may survive the physical stress of being impinged on the screen will be killed by being exposed to the chlorine.

Therefore, the Department strongly recommends that the intake structure use a wedgewire screen with a mesh size of 2mm or less, equipped with a "air burst" cleaning system. This will significantly reduce impingement and entrainment mortality from the FSRU=s intake. It is also strongly recommended that the intake be redesigned to prevent fish mortality from exposure to chlorine.

Even with these design changes, however, the project will result in the death of approx. 210 million eggs and larvae and an unknown number of YOY and small adult fish, through entrainment in the LNG carriers= intake systems. The Department believes this is a significant adverse impact to the LIS aquatic environment and fishery, caused as a direct result of the project=s operations. The application documents must fully assess the impact and propose alternatives which seek to eliminate, minimize or mitigate this significant adverse environmental impact.

7. Hazardous Substance Bulk Storage Registration Application

a. The application is overly generic and provides little information on specific design of the three chemical bulk storage tanks ranging in size from 4,000 to 19,800 gallons. The relative location of the tanks are depicted on a general vessel plan, but the plan does not include the location of piping. Further, the FSRU is proposed to have three SCR skids. These will be required to have some form of containment as well. Review of the application revealed that many sections were not addressed, such as leak detection, high level alarms, gauges, etc.

b. Two of the three chemical bulk storage tanks will require internal inspections approved by a licensed Professional Engineer every five years (the 19,800 gallon ammonia tank and 13,200 gallon mercaptan tank).

c. The application included a generic SPCC plan. However, pursuant to 6NYCRR Part 598.1(k), a site specific Spill Prevention Report (SPR) will have to be provided prior to commencement of operations.

7. Petroleum Bulk Storage Registration Application

a. There will be nine tanks ranging in size from 2,100 gallons to 310,000 gallons for a total storage capacity of 645,182 gallons. Because the total storage capacity exceeds 400,000 gallons the facility is considered a Major Oil Storage Facility (MOSF). Broadwater must complete a MOSF application (available on-line at the Department=s website) and must provide the actual date of installation or construction.

b. Because the vessel has not been built yet, the Spill Prevention, Containment and Countermeasure (SPCC) Plan submitted with the application is generic and many sections are blank. However, the application acknowledges that a site-specific SPCC must be developed prior to commencement of operations. DEC would prefer to review the SPCC prior to operations to ensure compliance.

c. The FSRU will have a double bottom. However, the application must provide more specificity on construction of the tanks. The PBS application has many sections which were not properly coded, including leak detection and spill prevention (i.e. high level alarms, etc.).

d. Figure 2-2, FSRU Hull Cross-section, indicates the 310,000 gallon diesel tanks will share a bulkhead with the water ballast tanks. Although the application describes the FSRU as having a double floor, it is unclear how a diesel leak into the water ballast tank would be detected. The application must identify the leak detection methodology to be employed.

As stated above and indicated in these comments the Department finds the applications to be incomplete at this time. In addition, please be aware that the Department will only issue a notice of complete application when all applications are complete. To continue the application review procedure Broadwater must respond to these comments.

In addition, the Department=s reviews of the SPDES application and Broadwater=s General Conformity Applicability Analysis are ongoing and comments on these applications will be forthcoming. Finally, please be aware that, consistent with 6NYCRR '621.14(b), at any time during the application review the Department may request additional information as necessary to make the mandated decisions, findings or determinations.

If you wish to discuss the comments or have any other questions please contact me at the above telephone.

Very truly yours,

John J. Ferguson
Project Review Coordinator

cc: Sara Allen-Mochrie, Ecology & Environment, Inc.
Steven Riva, USEPA
Annamaria Coulter, USEPA
Eric Tomasi, FERC Office of Energy Projects
James Martin, FERC Office of Energy Projects
Andrew Kasius, NYS DOS Division of Coastal Resources
Alan Bauder, NYS Office of General Services


Ghost-fishing for Blackfish

Norwalk Harbor seems to be littered with unattended fish traps -- maybe 100, maybe 1,000: no one really knows -- that serve, as one observer put it, as "self-perpetuating fish-killing machines."

On first read I thought it was a mistake. Fish traps? Lobster traps, perhaps, but whoever heard of fish traps in Long Island Sound?

The proliferation of traps was driven by two events, Backer said: the demise of lobsters in 1999 and the rise in the value of blackfish in New York City's live fish markets. Both changed blackfishing in the last two decades, Backer said.

"A lot of old-timers used to set up traps, catch a couple dozen blackfish and fillet them for the winter," Backer said. "But the confluence of events that drove up the value of blackfish made people more willing to exploit them."

So, as Terry Backer implies further on in this Stamford Advocate article (published on Christmas), it's good news that fish from the Sound are being caught and sold locally (or relatively locally). That's a sustainable use of the Sound. But it's irresponsible to leave traps out there and to not check them regularly. The Connecticut DEP, by the way, says there's not much it can do about the problem.

Nice work by Tim Stelloh, who also dug up this story, about the potential implications of an application by a Southport resident, Stuart Bell, on publicly-owned shellfish beds in the Sound.

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Wednesday, December 26, 2007

Terry Backer: No to Broadwater, But Then What?

When I asked Tom Baptist and Sam Wells to write open letters (here and here) to Governor Spitzer stating the case against Broadwater’s LNG proposal for Long Island Sound, they made compelling arguments (Leah Schmalz and Adrienne Esposito have promised they’d send me their arguments too). When I asked Terry Backer, he said he’s against Broadwater but then added that it’s a bit more complicated than just before for or against. Terry has been the Long Island Soundkeeper for 20 years; he’s also a member of the Connecticut General Assembly and co-chairman of its peak oil caucus. Here’s what he wrote:

When it comes to energy, for every option we rule out, the list of available fuels and locations grow smaller and more complex. The options grow ever more onerous for the types of fuel available when viewed realistically and with knowledge. If you are a serious student of the ever-constricting global fossil fuel supply (liquids) you understand where we are headed and the implications. Our society, our economy and a modern life style relies almost 100% on those fossilized solar power fuels.

The New York and Connecticut regions lie at the end of almost all global distribution for fuels. Natural gas production peaked in the United States some time ago and it appears to have peaked in Canada as we speak. The National Energy Board of Canada announced in October of this year that 30% cuts in natural gas exports to the United States will happen incrementally between now and 2015. Natural gas from the Gulf of Mexico and Alberta are distant sources with many consumers in line for a contracting supply before it reaches us.

Global oil production has been flat for a few years but demand has increased. New discoveries and production aren’t keeping up with declining mature oil fields. New discoveries of oil are in more complex geological formations in water that reaches depths of 10,000 feet and 28,000 under the earth. This means higher recovery cost, poor return on energy invested and slow production. Explosive growth in Asia is sucking in every drop of oil it can get with no relief in sight. We are headed quickly to an oil and gas crunch that will have heavy handed impacts on our economy. And we are not ready.

This brings us to liquefied natural gas. The US Department of Energy's Energy Information Administration has calculated that the region will need a 70% increase in LNG in the next decade to compensate for declining natural gas production. LNG will be needed to fill the oil and native natural gas gap. Mind you, EIA assessments of natural gas recourses are notoriously optimistic and they have over-estimated its supply for years. So it reasons even more LNG will be needed sooner. Our backs are up against it and most of us have no idea.

We have not yet seen the impact of oil over $75 a barrel let alone $90 for any prolonged time frame. The negative savings rate of Americans in general means the embedded cost of energy in all products and services is going on credit cards and home equity loans as people try to cover bases while not knowing what's causing it. They will demand cheaper energy, and that means coal. And coal isn't that clean yet. It also means 5 to 10 years of crippling cost while plants are built. Global climate change is a big focus of mine but peak oil is, more than likely, here now.

LNG will be needed and even then its sources are not the most dependable. We will need a supply of cleaner bridge fuel that can be used in existing machinery while the massive infrastructure is converted to something else. And that's a zinger as well we since don't know what something else is. Does this mean we have to have Broadwater? No it doesn't. It does mean we have to have someplace to land this fuel and no one seems to want it. It gets pretty cold here in January.

Alternatives are not even off the ground yet and conservation isn't keeping up with demand increases. Alternatives barely provide us 2 percent of our energy needs and almost no transportation fuel. Most people do not have the slightest idea of the scale we need in alternatives. It could easily take 100 years to build out and we don't have 100 years. We are talking about a contraction in energy that will do significant harm to the economy and to the bulk of the middle class and working poor, and demand more government social services.

We are no longer at a time where we can only say what we don't want. We need to be part of an aggressive plan to usher in a new energy regime. I urge the environmental community to join me in educating the public on energy realities and an all-out effort to get our leaders to lead us on a conservation and renewable energy policy. Conservation by the truck load, energy efficient transportation, and a slow-down in sprawl development may buy us enough time to make the transition to less abundant and dramatically more expensive fuel supply with less pain, but it won't come close to being pain free. Even then we will still need more LNG in the region as a stopgap fuel for as long as we can get it.

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Sunday, December 23, 2007

Kemp's Ridleys are Still Washing Up on Long Island's Shores

Chris Zurcher’s summary of daily news headlines (subscribe here) pointed me to this story, in the Times Long Island section, about Kemp’s ridley sea turtles being cold-stunned on the east end of the island. Twenty four have been found this year (about twice as many as usual); 12 were dead, eight are behing rehabilitated. One of the odd things is that while they clearly spend time in Long Island Sound, they wash up only on Long Island beaches, never in Connecticut.

Kemp’s ridleys are the rarest of the world’s sea turtles and two decades ago were considered doomed. My buddy Sam Wells puts in some volunteer time at the sea turtle rescue center (which I think is this place), on South Padre Island in Texas, and I’m hoping that when he gets a minute he might update us on the status of the Kemp’s ridley. I wrote a long chapter about Kemp’s ridleys for my book but then cut it. It’s here, for those interested in more background.

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Needless Destruction of Beautiful Places: An Old, Sad Story

My reaction to this column, written for the Courant by a novelist named Luanne Rice, about the destruction of a cherished place on Long Island Sound in Old Lyme, is twofold and contradictory:

1. Welcome to the real world, Luanne. Those of us is our late 40s and early 50s have spent a lifetime watching cherished places be destroyed by greedy landowners.

2. This is heartbreaking in a way that I and others of our generation have had our hearts broken many times.

Friday, December 21, 2007

Dear Governor Spitzer: Reject Broadwater's Proposal for Long Island Sound (II)

Tom Baptist, vice president and executive director of Audubon Connecticut, has written an open letter to Governor Eliot Spitzer, explaining why Broadwater's proposal to put an LNG terminal in Long Island Sound, should be rejected:

Dear Governor Spitzer:

I recently received a letter from Broadwater Energy that began “Dear Small Business Owner.”

Broadwater had written to me to obtain my support for the construction of a massive liquefied natural gas (LNG) facility in the middle of Long Island Sound. Their letter contended the proposed LNG facility would “have limited adverse environmental impacts” while saving the average homeowner “$300 per year” by providing more natural gas - - “an additional 25% of what we use right now”.

Unfortunately, Broadwater’s calculations don’t add up. They ignore the $5.5 billion contributed annually to Connecticut/New York economy by Long Island Sound. Any potential negative environmental impact to this Estuary of National Significance would jeopardize this economic engine and the revenue it provides.

The potential for environmental impacts is real. Dozens of experts have concluded that the Broadwater proposal understates or ignores the potential for environmental damage from the project. There is no shortage of testimony to this effect: the Federal Energy Regulatory Commission records contain hundreds of pages contesting Broadwater’s claims. These potential impacts include significant disruptions to fish and bird habitats, and the impairment of recreational and other commercial uses of the Sound such as fishing and lobstering.

Broadwater assumes – wrongly I believe – that small business owners will be willing to sell off Long Island Sound, our state’s most important open space and natural resource, for a vague promise of $300 in annual savings that may never materialize.

Governor Jodi Rell recently requested a Congressional investigation into the possible manipulation of natural gas prices. In her letter to federal officials, the Governor cites the fact that according to federal data natural gas prices for residential users increased 169% from June 2002 to June 2007. The record is even worse for business users. Over the same period, natural gas prices for commercial users increased 175% and for industrial users 207%.

So how does Broadwater with its massive construction project propose to generate the promised $300 in annual savings? By slowing the rate of increase in the price of natural gas, that’s how. And the savings promised are only for residential consumers. No such figure is promised for commercial or industrial users – presumably the very small business owners whose support the company is seeking in their letter.

Perhaps most importantly, Broadwater ignores energy conservation and increased efficiency as viable alternatives to its project. Taking steps to conserve energy and to improve efficiency will put money directly into the pockets of small owners faster than any promised reduction in the rate of increase offered by Broadwater. Given the conservation potential in Connecticut and New York, this LNG facility might not be needed at all if we implemented conservation measures statewide. For those small businesses interested in realizing savings through conservation and increased energy efficiency, the Connecticut Energy Efficiency Fund offers information on available conservation programs at

Broadwater wants us to put the Long Island Sound ecosystem at serious risk and forever restrict public access and commercial use of the vast area consumed by their facility, all for the promise of $300 in annual savings that may never materialize when simple energy conservation can guarantee that amount of savings or more. Connecticut small business owners should not be fooled.

Thomas R. Baptist
Vice President and Executive Director
Audubon Connecticut

Audubon Connecticut, the state organization of the National Audubon Society with more than 13,000 members statewide, works to protect birds, other wildlife, and their habitats using education, science and conservation, and legislative advocacy for the benefit of people and the earth’s biological diversity. Through our network of three nature education centers, more than 4,500 acres of protected wildlife sanctuary lands, and11 local volunteer Chapters, we seek to connect people with nature and inspire the next generation of conservationists.


Thursday, December 20, 2007

Saving Gas

Global climate change isn't particularly my topic here but nevertheless there's a post on Gristmill today that starts with the words, "This never fails to fascinate me," and indeed it fascinated and amazed me.

If we want to reduce gasoline use, we can make a huge gain by concentrating first on vehicles that get very low mileage. Obvious. The amazing thing is that low mileage vehicles don't have to be traded in for high mileage vehicles to get the huge gain; trading in an SUV that gets 16 mpg for one that gets 23 mpg saves twice as much gas as trading in a car that gets 32 for a hybrid that gets 47 (of course, trading in a 16 for a 42 would be even better). Read it
here and look at the graph. (Update: Read through the comments on Gristmill for more good stuff.)

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Wednesday, December 19, 2007

Dear Governor Spitzer, Reject Broadwater's Proposal for Long Island Sound

Sam Wells, a marine biologist who grew up in Clinton, Connecticut, and now lives on South Padre Island, Texas, has written a short open letter to Governor Eliot Spitzer, explaining why he thinks the Broadwater LNG proposal should be rejected:

In addressing whether the proposed Broadwater LNG project should be approved by the State of New York, I would like to address one final point that perhaps you might have missed. Simply stated, for all the reams of paper, testimony, analysis, and comments, we really don’t know what the risks are from completing such a project. If the proposed terminal site was located in the open Atlantic Ocean where good transport and flushing occurs due to wind, tides, and current, it would be far easier to measure the risks. However, located in a partly closed embayment system, Long Island Sound, we won’t know the long-term impacts for many years.

Could Broadwater prove to be adverse from ecological, environmental, and cultural points of view? Would it contribute to eutrophication of Long Island Sound waters, such as increasing hypoxia? There is no computer model or risk assessment tool that can really tell you that. All we do know is that there does not seem to be any ecological, environmental, or cultural benefits from the project, other than to provide natural gas to consumers. Indeed, even the air quality impacts from the LNG ships and the terminal could be regionally significant, and possibly add to greenhouse gas emissions as well.

I suppose if the Broadwater owners had a binding agreement to offset and mitigate all the chief concerns, including a long term monitoring program, the project might pass the test. For example, if the project is expected to release “x” amount of greenhouse gasses a year, it would have to reduce that much elsewhere in New York. But that option does not appear to be on the table; one must accept or reject Broadwater as it is proposed in its current form. That documentation says that while there indeed are adverse impacts, they are within the realm of being insignificant and are within an acceptable level of risk. As a concerned scientist, I am always aware that there may be unexplained processes that are not so easily measured – for example scientists knew of warming in the Arctic but simply could not model the dramatic loss of sea ice. Did this mean that Climate Change was somehow invalidated? Not in the least. I would argue that Broadwater is simply not consistent with coastal zone plans for what is an already-threatened and nationally-recognized body of water, and that its operation will not improve on the situation one single iota. By virtue of tipping points and feedback loops, it could degrade it much faster than originally intended.


Chinese Mitten Crabs

Another Chinese mitten crab was found in the Hudson River, this one up near Cold Spring. The Hudson River Almanac has details, and characterizes the find rather dramatically: “…it casts an ominous cloud on the estuary.” (That must be one big crab.) Here’s what the Almanac says:

It was announced this week that a second Chinese mitten crab, this one an immature female, was recently found along the Hudson. Coupled with the first recovery this past June, it casts an ominous cloud on the estuary (see 12/9 Cold Spring). …

12/9 - Cold Spring, HRM 54: This past October 29, a second Chinese mitten crab was found at the Cold Spring Boat Club boat launch (see 6/3 Nyack for the first mitten crab, an adult male). It was confirmed as an immature female, 30 mm carapace width. The juvenile female mitten crab was brought to the Smithsonian Environmental Research Center in Edgewater, Maryland, in early November. Although we now have 11 confirmed mitten crabs from the Mid-Atlantic region, this is the first appearance of a juvenile. Yet, we still cannot confirm a self sustaining population. Continued monitoring is needed to establish a better understanding of the population.
- Carin D. Ferrante, Amanda Higgs

[The Chinese mitten crab (Eriocheir sinensis) is native to the estuaries of China where it is highly regarded in the market. Mitten crabs are catadromous, meaning that they spend much of their life in freshwater, then return to higher salinities in the lower estuary (15-20 parts-per-thousand salt) to reproduce. The salinity gradients of east coast estuarine systems like the Chesapeake Bay, Delaware Bay, and the Hudson River are nearly ideal for them. Adult mitten crabs have a carapace width of about 3", but six of its 8 legs are almost twice as long, giving them an almost "spider crab" look. Unlike the native blue crab, a swimming crab, mitten crabs are burrowing crabs, similar to our mud crabs only many times larger. They have a generalist diet, varied in prey, and their potential ecological impact on east coast estuaries is still unknown.

Chinese mitten crabs were inadvertently introduced to Europe in the 1930s and are now widespread. The first U.S. mitten crab was caught in San Francisco Bay in 1993, though they may have been there earlier. They first appeared along the Atlantic coast in Chesapeake Bay in 2005. One more followed in 2006, and another this year. Already, 4 mitten crabs have been collected from Delaware Bay this year. All 7 of these crabs, plus the earlier one from the Hudson, have been males.

Chinese mitten crabs have been an invasive species in Europe for a decade or more. The Marine Invasions Lab at the Smithsonian Environmental Research Center in Edgewater, Maryland, is working with U.S. Fish and Wildlife Service, NOAA, and the Maryland Department of Natural Resources in monitoring their presence. It is illegal to import mitten crabs into the United States, but there is genetic evidence that the east coast mitten crabs arrived here from Europe via commercial traffic, much like zebra mussel in 1988.

If you encounter a mitten crab in New York State, please notify Leslie Surprenant, NYSDEC Invasive Species Management Coordinator (518) 402-8980, (, and Carin D. Ferrante, Smithsonian Mitten Crab Coordinator ( Do not release them alive! If you take photos, make certain that you take both dorsal and ventral - top and bottom - views so we can determine its sex. Leslie Surprenant.]

Compiled by Tom Lake, Hudson River Estuary Program Naturalist New York State Department of Environmental Conservation.

And here’s more info about the Almanac itself, which is a great thing and should be duplicated on Long Island Sound:

The Hudson River E-Almanac is compiled and edited by Tom Lake and emailed weekly by DEC's Hudson River Estuary Program. To sign up to receive the E-Almanac (or to unsubscribe), send an email message to and write E-Almanac in the subject line.

Weekly issues are archived at

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Tuesday, December 18, 2007

A Reason to Reject Broadwater's LNG Proposal for Long Island Sound

We're probably just a matter of a few weeks away from decisions by the Federal Energy Regulatory Commission and New York State about whether Shell and TransCanada should be allowed to build a huge liquefied natural gas plant in the middle of Long Island Sound.

In anticipation, I want to reiterate the argument that allowing Broadwater to use the Sound amounts to an unacceptable public subsidy of industry.

The Long Island Sound region used to be heavily industrialized, and while the local wealth created by manufacturing led to a golden era in many of the region’s cities, it also led to astonishing pollution in the Sound and its tributaries.

The industrial era is gone. And now that factories have abandoned the region, leaving the heavy metals that still contaminate our harbors and the useless mills that blight our cities, we’re finally shaking the attitude about the Sound that the industrial era typified – namely, that the main function of Long Island Sound and its tributaries is to subsidize our incompatible economic activities.

In the old days that subsidy amounted to free disposal of industrial waste. Now, with Broadwater, the subsidy would be the use of publicly-owned waters for private corporate gain. But there’s no difference. In both cases, it’s not what Long Island Sound is for.


Monday, December 17, 2007

Environmentalism Online and Via Email

Three things came in via email within the last few days, offering further proof that everybody in the United States now has a presence online. These things also happened to be interesting enough to pass along however.

Chris Zurcher, who for years was communications director for Connecticut Fund for the Environment, has gone out on his own and is sending around a daily compilation of environmental headlines from national and Connecticut newspapers. Mine arrived at 7:30 this morning, so he must be getting up pretty early. He covers more areas of interest than I do, although it’s an email newsletter-compilation rather than a blog and so he doesn’t include the wry, perceptive and wise commentary that my posts do. Here’s his address: I’m sure he’d be happy to sign you up.

Also happy to sign you up, particularly if you have kids, is Meg Robustelli. I don’t know her but she sent me an email yesterday asking if I do Long Island Sound presentations for children, because she has started a new online newsletter, with an environmental/nature bent, about things for kids to do in Fairfield County. As it happens, I did a Long Island Sound talk at my son’s fourth-grade class a couple of weeks ago, and another at my daughter’s fourth-grade class five years ago. Both went well but my lack of patience with kids is legendary in my family and so I’m unlikely to go out on the nature education circuit (unless someone offers me money). Nevertheless, here’s Ms. Robustelli’s online newsletter. You can sign up for her emails too.

Do you ever get emails inviting you out for Green Drinks? I used to think it was just a weird, unappetizingly-colored cocktail but apparently I’m wrong and the “Green” in Green Drinks refers to environmentalists. A Green Drinks invitation came last week from someone else I don’t know, Heather Burns-DeMelo. I was about to ignore it when I noticed that it had a link to a new mag that Ms. Burns-DeMelo is editing called AllGreen (it might be on paper too but I’m not sure). It seems to be geared mainly to consumer topics, which are mildly interesting to me. Check it out here.

On Sustainability

Michael Pollan starts another excellent piece, about the dangerous way we produce our food here in America, in yesterday's Times magazine with a discussion of the word "sustainability":

The word “sustainability” has gotten such a workout lately that the whole concept is in danger of floating away on a sea of inoffensiveness. Everybody, it seems, is for it whatever “it” means. On a recent visit to a land-grant university’s spanking-new sustainability institute, I asked my host how many of the school’s faculty members were involved. She beamed: When letters went out asking who on campus was doing research that might fit under that rubric, virtually everyone replied in the affirmative. What a nice surprise, she suggested. But really, what soul working in agricultural science today (or for that matter in any other field of endeavor) would stand up and be counted as against sustainability? When pesticide makers and genetic engineers cloak themselves in the term, you have to wonder if we haven’t succeeded in defining sustainability down, to paraphrase the late Senator Moynihan, and if it will soon possess all the conceptual force of a word like “natural” or “green” or “nice.”

Confucius advised that if we hoped to repair what was wrong in the world, we had best start with the “rectification of the names.” The corruption of society begins with the failure to call things by their proper names, he maintained, and its renovation begins with the reattachment of words to real things and precise concepts. So what about this much-abused pair of names, sustainable and unsustainable?

To call a practice or system unsustainable is not just to lodge an objection based on aesthetics, say, or fairness or some ideal of environmental rectitude. What it means is that the practice or process can’t go on indefinitely because it is destroying the very conditions on which it depends. It means that, as the Marxists used to say, there are internal contradictions that sooner or later will lead to a breakdown.

For years now, critics have been speaking of modern industrial agriculture as “unsustainable” in precisely these terms, though what form the “breakdown” might take or when it might happen has never been certain. Would the aquifers run dry? The pesticides stop working? The soil lose its fertility? All these breakdowns have been predicted and they may yet come to pass. But if a system is unsustainable — if its workings offend the rules of nature — the cracks and signs of breakdown may show up in the most unexpected times and places.

He goes on to tell two stories of unsustainability -- the MRSA staph infection and the die-off of honeybees -- that, after you finish reading, turn out not to be so unexpected after all. Here's his Times piece. Read his other stuff here to see how it all all fits together.

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Friday, December 14, 2007

If ExxonMobil Can Put a Floating Gas Terminal in the Atlantic, Why Can't Broadwater?

If there are now two legitimate proposals for liquefied natural gas terminals in the Atlantic south of Long Island -- one on a man-made island, the other floating -- then how can Long Island Sound be the only viable alternative for Broadwater's LNG terminal, as Shell and TransCanada assert? So asks Adrienne Esposito, of Citizens Campaign for the Environment, in Newsday, here.

And just as Long Islanders and Connecticut residents aren't thrilled with Broadwater, State Islanders don't love ExxonMobil's Blue Ocean Energy project. This story also reminded me of something I had forgotten about -- a big LNG explosion that killed 40 people on Staten Island when I was 19.

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Revolver, by Richard Foster, Philip Johnson's Collaborator

For fans of modern houses,
this one is interesting, to say the least: a revolving house, on a pedestal, with a view of the suburban countryside in Wilton, Connecticut. It was built by Richard Foster, who worked on a lot of projects with Philip Johnson. Foster in fact lived there until his death, in 2002.

[Read 'Modern,' our new blog about mid-century modern houses, here.]


More Oysters, Please

Roger Williams College, in Rhode Island, is working on restoring oysters to Narragansett Bay, and for good reason, the Providence Journal reports:

He likens oysters to powerful little water filters that clean more than 50 gallons of water a day, straining out the particles they feed on and depositing the rest at the bottom of rivers, salt ponds and estuaries. This reduces the turbidity of water, which allows more sunlight to support aquatic life, which bolsters fisheries, including habitat for lobster and winter flounder....

In theory, oysters could be deployed to highly polluted waters for the express purpose of filtration, Patterson said.

However, Rhode Island aquaculturists haven’t been aggressive about that so far because they worry about people eating oysters harvested from dirty water, he said.

Nonetheless, over the long term, the program hopes to make a visible impact on water quality in Narragansett Bay.

“If we can get a gazillion of these things out there filtering, within our lifetime — and I like to think we’re young — we should begin to see a difference,” Patterson said.


Wednesday, December 12, 2007

LNG Terminal Proposed for the Atlantic Ocean, Out of Sight of Long Island

Exxon Mobil, a company that's as hard to love as the two Broadwater sponsors, Shell and TransCanada, is proposing a Broadwater-like liquefied natural gas terminal 30 miles south of Long Island, in the Atlantic Ocean. It picked the spot specifically because it does not want to deal with Broadwater-like protests:

Exxon said its plant anchored off New Jersey, about 30 miles south of Long Island, would not be visible from shore and would stay clear of shipping lanes and recreational areas.

“We have tried to learn from our past experiences and that of the industry in general,” said Ron P. Billings, Exxon’s vice president for global liquefied natural gas.

The Times also has this useful summary:

The terminal, if approved, would connect through an underwater pipeline to an existing network that feeds New York and New Jersey, two of the top consumer markets in North America.

Exxon’s project is the latest of several dozen gas terminals that have been proposed in recent years in the United States. Energy specialists say more natural gas supplies will be needed to meet the growth in consumption and to make up for an expected drop in imports from Canada.

In many cases, energy companies have faced stiff opposition in finding sites for large new terminals. This has become one of the thorniest energy issues, especially since the attacks of Sept. 11, 2001, raised security concerns about cargo ships carrying liquefied gas near big cities.

Still, companies are slowly moving forward with their plans. Since 2002, federal and state authorities have approved 18 new liquefied gas terminals around the country, including 4 offshore, though most analysts do not expect all of them to be built.

While most of the projects are planned along the Gulf Coast, the northeastern corner of the country is attracting attention because of its reliance on natural gas and its large populations. Two terminals to be built off Massachusetts gained approval last year. For Exxon, going so far offshore is an effort to duck the vociferous opposition that has dogged projects on both coasts. Its project, called BlueOcean Energy, would be able to supply 1.2 billion cubic feet of natural gas a day, about 2 percent of the nation’s gas consumption — and enough to meet the needs of five million residential customers.

Exxon’s project is the third offshore terminal proposed for the greater New York region in recent years.

One proposal, to build a gas terminal in the middle of Long Island Sound, has aroused concern since its announcement in 2004 because of the impact it might have on fishing and boating; it is strongly opposed by shore communities and politicians.

That opposition could intensify in coming months as the project, which is known as Broadwater and is a joint venture by Royal Dutch Shell and TransCanada, is expected to receive notice about federal and state permits.

Another company, the Atlantic Sea Island Group, plans to build a terminal for liquefied natural gas on an artificial island about 14 miles south of Long Island, a project called Safe Harbor Energy....

“So far no one has been able to crack the nut of getting infrastructure sited in the Northeast, and that’s why you have all these proposals to go offshore and avoid heavily populated areas,” said Mariano Gurfinkel, a project manager at the Center for Energy Economics at the University of Texas.

Exxon’s new project would receive two cargo ships a week. The gas would be carried by underwater pipeline that would come ashore at Raritan Bay in New Jersey.

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First Meteorite: Friday is the 200th Anniversary of "a brisk scintillation ... like that of a burning firebrand carried against the wind"

Friday marks an odd anniversary. Shortly before dawn on December 14, 1807, a meteorite landed in the Connecticut countryside, in what was then Weston. It was the first recorded meteorite strike in the United States. Some local events marking the anniversary are on tap, and the Stamford Advocate has an interesting story about it all today. I particularly liked the description of the reaction two centuries ago:

"In the clear sky a brisk scintillation was observed about the body of the meteor, like that of a burning firebrand carried against the wind," he wrote in the American Journal of Science and Arts.

The flash was seen from as far north as Rutland, Vt., and as far south as New Jersey, Silliman wrote. There were explosions. There were whizzing and roaring sounds.

Some who saw and heard the meteorite thought it was a tornado, Silliman wrote. Others compared the sound to gunfire or to a wagon rolling down a rocky hill.

Many of the witnesses were farmers, said Judy Albin, a Weston Historical Society trustee.

"They were the ones who were up in the early morning milking the cows," she said. "One woman in Massachusetts, near the Connecticut border, was on her farm when she saw the fireball streaking across the sky. She thought it was the moon. She said, where is the moon going? Then it disappeared behind a cloud."

One farmer said his cattle were so terrified they jumped over a fence into a neighboring field, Albin said.

Here’s reporter Tim Stelloh’s story.

Tuesday, December 11, 2007

It Would Be Nice If We Could Pick Up the Pace on Clean Energy Projects, Even Small Ones Like This Proposal for Block Island

I suppose it’s wise to go slowly before we approve new clean energy projects, like the wave energy project that Rhode Island and a company called Oceanlinx are working on for the waters off Block Island. On the other hand, we’re sort of in a global climate crisis, and speed can be a virtue. Here’s how the Block Island Times describes what still has to happen to get this small – 1.5 megawatt – project built:

The state energy office hasn’t yet decided whether it will be the state or Oceanlinx that applies for permits. Once that is decided, there could be a long wait: procedures for permitting by the state’s Coastal Resources Management Council and the federal Energy Regulatory Commission are still being written, although Dzykewicz said federal permitting for a pilot plant has been issued before and should take no more than six months.

Most crucially, it won’t be clear until early next year whether the General Assembly is willing to approve $45 million in revenue bonds to finance the project.

If the state legislature fails to create a state power authority next session, then the state’s Economic Development Corporation could initiate the bonds, said Dzykewicz — but the General Assembly would still need to give its blessing.

We wouldn’t want to act rashly and end up making things worse. On the other hand, as I said once before, if we’re going to move slowly, we need to hurry up about it.

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Monday, December 10, 2007

A Vote for Her or Him is a Vote Against or For Broadwater

Will Long Island voters decide who to vote for in the presidential primary based on the Broadwater proposal? Hillary Clinton has come out against Broadwater, but Rudy Giuliani's firm is on Broadwater's payroll. The unsaid part of this story is that for it to make a difference, Barack Obama or some other Democrat would have to be for it and Mitt Romney or some other Republican against it, which I suppose could happen.

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No Nukes? Then What?

In the Times yesterday, Peter Applebome asks what do those of us concerned with climate suggest we use instead of the non-greenhouse gas energy that nuclear power plants produce if Indian Point shuts down, as New York State (which just a few years ago owned Indian Point) now wants. One answer, as he implies, is that we use a lot less energy -- that is, we conserve. But could Sam Wells be right when he says, here, that conserving energy will cost us more money?


Fighting About Pollution in Connecticut

In the town of Clinton, which is on Long Island Sound and the Hammonasset River, and near Hammonasset State Park, 2,000 houses and businesses have substandard sewage disposal systems (2,000 out of how many, I wonder). The Town Board is quarreling over the issue with the town's water pollution control commission.

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Friday, December 07, 2007

Millstone, Nuclear Power, Dead Fish

An e-mail from Terry Backer, Soundkeeper and co-chairman of the General Assembly's peak oil caucus, about the Millstone nuclear power plant:

Some time ago in a post you remarked that you were not sure what my position was on nuclear power. Your statement was prompted by my position that the Millstone Power Station in Waterford should be required to install close cycle cooling.

I have never called for the closure of Millstone and have focused my attention for more than a decade on its impact on marine life.

Any reasonable person should have reservation about the status of spent nuclear fuel and the lack of a national disposal site. Even then the long term storage of spent fuel rods remains challenging on every front from trucking to storing for 10,000 years. Currently, all the high level contaminated spent fuels rods sit on site. Nuclear power will be touted as a way to reduce our oil and gas use along with greenhouse gases. The dirty little secret is there isn't enough uranium in the world to power all the plants it would take to replace a portion of existing fuels. The US isn't the only country that needs oil, gas or uranium. Any one who doesn't have long term reservation about nuclear power and its long range viability must work in the industry or doesn't care to know. The fact is Soundkeeper Inc. does not have a position pro or com on nuclear power. I personally can accept it as needed at this point and into the future.

That said, I believe that for better or for worse nuclear power generation is here for years to come. It's never been my or Soundkeeper's position to force Millstone to closure. In fact, like it or not Millstone will be needed as natural gas supplies drop over the next several years. This is especially important since the Energy Board Canada in October has said Canadian exports of natural gas will be cut up to 30% between now and 2015.

What I want from Millstone is for them to stop killing winter flounder and other marine organisms, period. I want then to install the best technology available for this purpose, closed cycle cooling. The heat from the closed cycle cooling could be captured and used in cooling or heating a combined cycle per se. Whether they have enough land or not I can't address but I can say that everything seems to be impossible until it is required.

Winter flounder populations are down across their range for a number of reasons. One of the reasons and one that can best be controlled are power station intakes. Consider this: If a fisherman takes a sub-legal fish he can be fined up to $50 per fish even if they have a permit to take fish. Yet, Millstone can take millions upon millions of fish at all stages of life with its operating permit. No fines, no penalties.

I understand that power plants need to run and they need water to do that. I don't understand given the technology available why they would need to use once through water continually sucking the life from the sea.

Soundkeeper's action at DEP is not just about Millstone, our efforts would apply to all the plants that take water from the Sound in the coming years. DEP should require closed cycle cooling at all Long Island Sound power plants now and allow the companies a period of time to demonstrate that closed cycle cooling isn't feasible. A license to operate a power plant shouldn't be a license to kill.



Let's Build a Bridge from the North Fork to Rhode Island

What would you think of a highway that runs from Riverhead east along the North Fork, crosses via bridge to Plum Island and then Fishers Island, and crosses again to Watch Hill, Rhode Island, with a spur from Fishers Island to New London? As David Collins, a columnist for the New London Day, says, "Wow."

The idea for a highway like that was alive, at least in the minds of some people, from 1938 until 1966, when smart people in Rhode Island said they weren't interested. It's a ludicrous idea in retrospect but really it's no more preposterous than the Chesapeake Bay Bridge-Tunnel (maybe less preposterous, in fact), the motto of which is "Follow the Gulls to the East Coast Scenic Shortcut."

My opinion is that in general we've had enough of these engineering marvels to last us a while. Collins's column talks about the old proposal for a bridge across the Race in the context of the new proposal for a tunnel under the western end of the Sound, which most definitely wouldn't be known as the East Coast Scenic Shortcut.


Tuesday, December 04, 2007

Long Island Sound tunnel: One Thumbs Down, Lots of Questions

The New London Day is the first paper I've seen to comeout against the Long Island Sound tunnel. An editorial in the Day on Sunday said:

If you thought the Broadwater plan to build a floating liquefied natural gas terminal in the middle of Long Island Sound was one of the worst, environmentally abominable ideas ever proposed for the 110-mile-long estuary, consider the plan announced recently by a New York multimillionaire.

The editorial notes, by the way, that New London is about 100 miles away from where the tunnel would be built. From even further away, near Dallas (does it reflect badly on a Long Island Sound blog that the two people who comment most frequently, Bryan Brown and Sam Wells, both live in Texas?), Bryan Brown has sent me some worthwhile thoughts on the tunnel, in response to this post. Here's part of what Bryan says:

Where are they going to dump the material from the tunnels? It's 500 million cubic feet or 18.4 million cubic yards of rock and soil. If they used it as fill, 100ft of it would cover 116 acres.

If half the borings come out of the LI tunnel, how are they going to move 9.2 million cubic yards? At 30 cubic yards per load, that's 300,000 truck trips.

Have 55-ft diameter tunnels been bored before? I haven't found any that are that big. The tubes all seem to be less than 40ft in diameter.

24 million gallons of gasoline per year saved seems reasonable based on a trip that's 30 miles shorter. Is it still 24 million gallons in 2025 when we're all driving hybrids or electric cars that get 100mpg?

How much of the so-called green benefit from this project gets eaten by the CO2 emissions associated with building it? Cement is responsible for GHG and this project will take a lot of concrete. The construction equipment will be burning diesel (or maybe CNG or LNG).

If Sam is right and it induces more traffic, that would reduce or even wipe out the so-called green benefits, particularly if there is no rail component.


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