Tag Archives: Rulemaking

WWALS response to FERC on opposition comments of Pivotal LNG about small, inland LNG Rulemaking 2022-10-04

Update 2022-10-26: WWALS response to opposition comments by Eagle LNG about small, inland LNG 2022-10-17.

Today WWALS and seven other organizations rebutted the opposition comments of Pivotal LNG, LLC to the WWALS, et al. petition to FERC for Rulemaking on small, inland, LNG facilities.

[First and last page]
First and last page

If you also want to intervene or comment, here’s how:
https://wwals.net/?p=59062#tocomment.

Yes, the comment deadline has passed, but a FERC attorney told me the Commission usually considers comments filed later.

Thanks to all the co-signers on today’s response: LEAD Agency, Inc., Kissimmee Waterkeeper, Lake Worth Waterkeeper, Peace+Myakka Waterkeeper, Collier County Waterkeeper, Three Rivers Waterkeepers, and Food and Water Watch.

Thanks to all the previous commenters, especially Floridians Against Dirty Energy (FADE), League of Women Voters, Physicians for Social Responsibility, Florida Springs Council, Sierra Club, Waterkeeper Alliance, Waterkeepers Chesapeake, Lower Susquehanna Riverkeeper, Anacostia Riverkeeper, Potomac Riverkeeper, Assateague Coastal Trust, Delaware Riverkeeper Network, and others too numerous to list here.

Thanks to Maxine Connor for rustling up many of those organizations.

Thanks as always to Cecile Scofield, doggedly pursuing LNG for decades now.

The Response

Filed with FERC 2022-10-04 12:40:32 PM as Accession Number: 20221004-5116, “Response to Opposition Comments of Pivotal LNG, LLC, by WWALS Watershed Coalition, Inc., et al., under RM22-21.”

See also Continue reading →

Comment on FERC LNG Export Rulemaking with Florida Physicians for Social Responsibility, 2022-09-20

Update 2022-10-04: WWALS response to FERC on opposition comments of Pivotal LNG about small, inland LNG Rulemaking 2022-10-04.

Florida Physicians for Social Responsibility has invited Suwannee Riverkeeper to talk about the FERC Rulemaking on small, inland, LNG export facilities on the comment deadline day, as FL PSR members and others write comments on that FERC Docket RM22-21.

You do not have to attend this zoom meeting to comment or intervene. Here’s how:
https://wwals.net/?p=59062#tocomment

Please comment or intervene as timely as you can before the comment deadline of 5PM, Tuesday, September 20, 2022. However, a FERC attorney advises us that the Commission usually considers comments filed after the deadline, so if you can’t comment by 5PM, comment anyway.

When: 7 PM – 7:45 PM, Tuesday, September 20, 2022

Register: for zoom

Event: facebook,

[FL PSR & WWALS comment on FERC LNG Export]
FL PSR & WWALS comment on FERC LNG Export

Continue reading →

One week left to comment on FERC LNG Rulemaking, deadline 2022-09-20

Update 2022-10-04: WWALS response to FERC on opposition comments of Pivotal LNG about small, inland LNG Rulemaking 2022-10-04.

Here’s how you can comment or intervene on the FERC Rulemaking on small inland LNG export facilities:
https://wwals.net/?p=59062#tocomment

It’s easy to comment or intervene, so you can do it by the deadline of September 20, 2022. Public Citizen and Food and Water Watch have already intervened. We guess they are preparing comments to convince the Federal Energy Regulatory Commission to resume the responsibility it abdicated in 2015, of environmental oversight of Liquid Natural Gas (LNG) export facilities even when are not located where they can directly load LNG onto ocean-going tanker ships. Instead, those inland facilities send highly compressed and explosive LNG in trucks and train cars down public highways past schools, business, churches, and homes, through counties none of which have adequate emergency plans. And where-ever that gas eventually gets burned, in Europe, Caribbean, or Asia, it adds to the atmosphere more methane, a worse greenhouse gas than CO2, cooking the planet and raising sea levels. You are affected, even if you do not have an LNG export operation near you.

[LNG tanker truck on I-75 turning onto I-10 for Jacksonville, LNG export map by WWALS]
LNG tanker truck on I-75 turning onto I-10 for Jacksonville, LNG export map by WWALS

If you comment or intervene, we will invite you to join us and our co-signers in the series of zoom meetings we’re having with the FERC Office of Public Participation (OPP). You can help find out what OPP is actually doing. At least they’re asking for Continue reading →

FERC must close regulatory gaps in small-scale inland LNG export facilities –Cecile Scofield 2022-08-11

Update 2022-09-19: Comment on FERC LNG Export Rulemaking with Florida Physicians for Social Responsibility 2022-09-20.

Update 2022-09-13: One week left to comment on FERC LNG Rulemaking, deadline 2022-09-20.

Should citizens be expected to pay $33,690 to file a Petition for Declaratory Order just to get FERC to oversee LNG facilities like the law says they should?

Cecile Scofield details many other problems FERC created back in 2014 and 2015 when it abdicated oversight of Liquid Natural Gas (LNG) export facilities that do not load directly onto onceangoing tanker ships.

[Flaws in FERC's reasoning; citizens cannot be expected to police LNG]
Flaws in FERC’s reasoning; citizens cannot be expected to police LNG

You can also file comments on FERC Rulemakeing for small inland LNG export facilities, started at the request of WWALS et. al. Your comments do not have to be as elaborate as Cecile’s, and you have until September 20, 2022.

Your organization could also intervene on FERC Docket RM22-21, as two organizations have done: Public Citizen and Food and Water Watch.

 -jsq, John S. Quarterman, Suwannee RIVERKEEPER®

You can join this fun and work by becoming a WWALS member today!
https://wwals.net/donations/

FERC Accession Number 20220811-5068 in FERC Docket RM22-21, SMALL-SCALE INLAND LNG EXPORT FACILITIES: FERC MUST CLOSE REGULATORY GAPS (see also PDF)

Purpose of Petition for Rulemaking:

The proposed Rulemaking is needed to clear up ambiguity as to Continue reading →

FERC Requests Comments on Rulemaking for small inland LNG export facilities

Update 2022-10-26: WWALS response to opposition comments by Eagle LNG about small, inland LNG 2022-10-17.

Update 2022-10-04: WWALS response to FERC on opposition comments of Pivotal LNG about small, inland LNG Rulemaking 2022-10-04.

Update 2022-09-19: Comment on FERC LNG Export Rulemaking with Florida Physicians for Social Responsibility 2022-09-20.

Update 2022-09-13: One week left to comment on FERC LNG Rulemaking, deadline 2022-09-20.

Update 2022-08-29: FERC must close regulatory gaps in small-scale inland LNG export facilities –Cecile Scofield 2022-08-11.

Hahira Georgia, July 26, 2022 — At the request of WWALS Watershed Coalition, the Federal Energy Regulatory Commission (FERC) has opened a process that could correct its mistakes of eight years ago when it disclaimed oversight of dangerous compressed methane export facilities as long as they did not load directly onto ocean-going ships. Those decisions produced environmental, safety, and economic problems. The request provides FERC with an opportunity to “revisit” and “revise” those old decisions, as FERC Chair Richard Glick has recommended.

LNG tanker truck, Southbound I-75, 2018-03-26; Photo John S. Quarterman
LNG tanker truck, Southbound I-75, 2018-03-26; Photo John S. Quarterman

Anyone can comment and organizations can intervene on this new FERC docket for potential Rulemaking on Liquid Natural Gas (LNG) export. The deadline is September 20, 2022. That’s Docket RM22-21 on ferc.gov. Detailed instructions are below.

Please also contact your state and national elected officials and ask them to ask FERC to resume its oversight.

The Introduction of the Petition lays out the problem we want to get solved: Continue reading →

FERC requests comments on WWALS Petition for Rulemaking on FERC Oversight of Small-Scale Inland LNG Export Facilities 2022-07-22

Update 2022-07-26: Press release, FERC Requests Comments on Rulemaking for small inland LNG export facilities.

FERC has created a docket for our petition and has filed in it a notice requesting comments by September 20, 2022.

[Notice and map]
Notice and map

Interested parties can file in that docket RM22-21 to intervene and then file comments and motions.

Also on Friday, FERC asked if we wanted to file the cover letter in the docket, so I did. It feels very strange to have FERC politely asking us to file things.

Thanks again to Continue reading →

Waterkeepers Florida Against FDEP Assumption of Army Corps CWA 404 permitting 2020-11-02

Waterkeepers Florida, representing all fourteen Waterkeepers of Florida, wrote to U.S. EPA and FDEP yesterday objecting to FDEP’s plan to take over water permitting from the Army Corps of Engineers. FDEP hasn’t even kept up with the responsibilities it has, and is in no way prepared to take on a much heavier load. Suwannee Riverkeeper voted for this letter, which was also signed by many other organizations, including OSFR and Paddle Florida.

Please vote today for people who will support clean water.

[Opposition and Addendum Letters]
Opposition and Addendum Letters

The Florida Department of Environmental Protection (FDEP)’s list of waterways it plans to assume (see FDEP’s Appendix A) omits numerous navigable waterways previously listed by the U.S. Army Corps of Engineers. Checking all the Florida rivers that empty into the Gulf of Mexico, I found that most of them were included by FDEP, except not the Suwannee River or its tributaries (many creeks, Lake Santa Fe, and the Santa Fe, New, Ichetucknee, Alapaha, Alapahoochee, and Withlacoochee (north) Rivers), not the Withlacoochee (south) River nor its tributaries such as the Rainbow River, and not the Ochlockonee River nor its tributaries, such as Lake Talquin. I added 30 Suwannee River Basin waterways and 24 others to the Waterkeepers Florida list of missing waterways, which is the main subject of the Addendum letter (see PDF). The Addendum also contains copies of several letters previously sent to FDEP: an opposition letter similar to the one to EPA, a request for Public Hearings, and a request that online rulemaking hearings be discontinued until the pandemic allows holding them in person.

Opposition Letter

Here is a transcription of the letter to EPA. See also the PDF.

Don’t forget to vote for clean water. Continue reading →