WWALS Against Small-Scale Natural Gas Exports

Submitted by WWALS in Public Comment Concerning Unregulated Small Scale LNG Processing Facilities.

Duke and two canals to the Gulf, Crystal River, FL,
Duke and two canals to the Gulf, Crystal River, FL, 28.9420800, -82.7818000

From: Wwals Watershed Coalition <wwalswatershed@gmail.com>
Date: Mon, Oct 16, 2017 at 4:21 PM
Subject: RIN 1901-AB43 and FE Docket No. 17-86-R
To: fergas@hq.doe.gov
Cc: WWALS Watershed Coalition <wwalswatershed@gmail.com>

WWALS Watershed Coalition, Inc. Against Small-Scale Natural Gas Exports

The path to U.S. energy independence is to finish the conversion of energy production from obsolete fossil fuels and nuclear power to clean, safe, renewable, solar, wind, and water power. Any resources spent on LNG would be better spent on getting on with real renewable power.

Proponents of pipelines often claim new pipelines will reduce the amount of natural gas shipped by road or rail. The Sabal Trail pipeline through Alabama, Georgia, and Florida, under the Withlacoochee, Suwannee, and Santa Fe Rivers, demonstrates that is not the case.

The Department of Energy’s Office of Fossil Energy (FE) has already authorized:

  • Multiple LNG operations at the end of Sabal Trail’s sibling pipeline Florida Southeast Connection (FSC) at Lake Okeechobee in Martin County, Florida,
  • At least one LNG container operation (Strom, Inc.) in Crystal River, Florida, at the end of Sabal Trail’s lateral the Citrus County Pipeline
  • Plus the Federal Energy Regulatory Commission (FERC) approved Kinder Morgan’s Jacksonville Expansion Project (JEP) of the Florida Gas Transmission (FGT) pipeline from Sabal Trail in Suwannee County to Jacksonville, to feed Eagle LNG, which is already shipping through Crowley Maritime to Puerto Rico.


    NW across FGT Brooker Compressor Station, 10:09:39, 29.9211000, -82.3220760

  • FE has authorized Crowley Maritime to ship to all Free Trade and Non-Free Trade countries.
  • FE also authorized Florida East Coast Railway (FECR) to pick up LNG from several of these LNG sites and to ship it up and down Florida as far as Jacksonville and Miami.

All of these LNG export operations are fed by Sabal Trail (in addition to being fed by the earlier FGT and Gulfstream pipelines).

None of these pipelines or LNG operations are needed for electrical power for Florida. Even Florida Power & Light (FPL) admitted in its 2016 Ten-Year Plan that:

“Difference: FPL does not project a significant long-term additional resource need until the years 2024 and 2025.”

http://www.psc.state.fl.us/Files/PDF/Utilities/Electricgas/TenYearSitePlans/2016/Florida%20Power%20and%20Light.pdf

Containerized LNG enables shipping on trucks and trains, which brings additional hazards beyond those of pipelines:

  • Immediate hazard to human health and water quality from leaks and explosions
  • Widespread hazard from water contamination
  • Long-term hazard from surface water and underground contamination plumes

Meanwhile, more new U.S. electricity in 2016 came from solar power than any other source (more than natural gas, even more than wind). The solar industry employs more people in electrical production than coal, oil, and gas combined. Many of those jobs are in planning, delivery, and installation in rural areas where jobs are in sore demand.

Total U.S. solar power electrical production is more than doubling every two years. At that rate by 2023 more total U.S. electricity will come from solar power than any other source. Solar panels require no fuel and thus no fuel shipping, not by road, rail, nor pipeline. Solar panels emit nothing but electricity and do not leak or explode.

Far from facilitating containerized LNG, the Department of Energy should be banning new LNG facilities and actively phasing out LNG in favor of solar, wind, and water power.

WWALS also supports the more detailed comments from SpectraBusters, Inc., which are appended to this message.

For the rivers and the aquifer,

-jsq

John S. Quarterman, Suwannee RIVERKEEPER®
WWALS Watershed Coalition, Inc.,
is the WATERKEEPER® Alliance Member for the Suwannee River
and its tributaries the Withlacoochee, Little, Willacoochee, and Alapaha Rivers.
WWALS is a member of Georgia River Network, Georgia Water Coalition,
Florida Springs Council, Floridians Against Fracking,
and national River Network.
229-242-0102, 850-290-2350
contact@suwanneeriverkeeper.org, wwalswatershed@gmail.com www.suwanneeriverkeeper.org, www.wwals.net
PO Box 88, Hahira, GA 31632

See separate post for SpectraBusters comments; those were written by WWALS member Cecile Scofield.

 -jsq, John S. Quarterman, Suwannee RIVERKEEPER®

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