WWALS response to opposition comments by Eagle LNG about small, inland LNG 2022-10-17

[Table of Contents]

[1. No LNG regulation in the state of Florida]

[B. The State of Florida regulates LP but not LNG]

[II. Need for Regulation by FERC]

[CASE IN POINT (#1): Floridian Natural Gas Storage, Martin County, Florida,]

[Page 7]

[CASE IN POINT (#2): Carib Energy, Martin County, Florida, September 10, 2014]

[Page 9]

[CASE IN POINT (#3): American LNG Marketing, Hialeah Yard (Miami), August 7, 2015]

[not require modification to accommodate the ISO containers, whether the end user is located in the]

[CASE IN POINT (#4): Eagle Maxville, Jacksonville, Florida, September 15, 2017]

[Page 13]

[CASE IN POINT (#5): Flint Hills Resources, LP, for LNG sources including Stabilis, April 13, 2016]

[CASE IN POINT (#6): Stabilis GDS, Inc., various LNG sources, June 21, 2022]

[In Appendix C of Stabilis’ DoE application we find this table: “Stabilis Source Facilities Include”]

[B. Complaint filed with U.S. DoE about Categorical Exclusion from NEPA]

[C. DoE FE Voicemail about NEPA Categorical Exclusion for “Hialeah Yard” facility.]

[BS5.7: Import/export natural gas, no new construction]

[Page 20]

[CASE IN POINT (#7): American LNG Marketing, Titusville, Florida, May 29, 2015]

[B. Titusville told DoE it expects to start operations in 2023 or 2024]

[III. DoE Categorical Exclusion revision widened regulatory gap with FERC, January 4, 2021]

[Page 24]

[IV. PHMSA expects FERC NEPA document before issuing Letter]

[V. Summary; A. PHMSA, DoE, etc. left with no lead agency]

[B. The consequences of FERC’s regulatory gap need to be addressed]

[]

[C. Conclusion: FERC should issue a NOPR]

[Exhibit A: Citizen Proposal to regulate LNG in Florida, October 19, 2017]

[Written listing of applicable NFPA (National Fire Protection Association) requirements]

[Page 32]

[Exhibit B: FERC informed Floridian of PHMSA re-interpretations, October 8, 2010]

[name, position, and telephone number of the respondent to each item.]

[Exhibit C: Aerial of Hialeah Yard LNG and nearby populated area]

[Exhibit D: NEPA/CEQ Questions and Feedback, February 19, 2018]

[Exhibit E: Complaint filed with U.S. DoE about Categorical Exclusion from NEPA]

[Exhibit E.2: Complaint discussion, Steven Henderson to Cecile Scofield, March 26, 2018]

[Exhibit F: Transcript, DoE FE Voicemail, NEPA Categorical Exclusion, “Hialeah Yard”, Dec. 18, 2015]

[Exhibit G: Guy Yudin & Foster, LLP to PHMSA Re: NFE Titusville, November 2, 2016]

[provide the following comments in response to Docket # PHMSA-2016-0073 -- New]

[consideration of proximity to population centers; consideration of adequacy of]

[Exhibit H: Email exchange with PHMSA about Titusville LNG, September 20, 2018]

[Exhibit I: Titusville Semi-Annual Report to DoE, September 30, 2022]

[Exhibit J: PHMSA denial of TICO variance from 49 CFR 193.2155(b), October 2, 2018]

[Page 46]