On June 16th, 2014 we submitted this technical comment letter detailing why the proposed Liquefied Natural Gas (LNG) Export Facility in Lusby, MD cannot move forward because of significant flaws in its environmental review.
The comment letter was submitted to the Federal Energy Regulatory Commission (FERC), the federal agency with authority over proposals to export and import natural gas. As we’ve discussed in previous posts, FERC is the federal agency that is responsible for assessing the environmental impacts of LNG export proposals pursuant to the National Environmental Policy Act (NEPA).
The proposal to export LNG from the Chesapeake Bay via the existing, Lusby MD import terminal is bad news for upstream watersheds and communities like the Susquehanna. This is because LNG export from the Chesapeake is specifically tied to development of shale gas reserves like the Marcellus and Utica, shale reserves which underlay much of the Susquehanna River Basin and Pennsylvania.
Development of these shale plays is and continues to occur via the use of hydraulic fracturing, an inherently polluting industrial practice that, in order to extract shale gas, disturbs wide swaths of intact forest, meadow, and farmland, disturbs headwater creeks and vital fisheries habitat, and threatens groundwater supplies with its deep-earth injections. Furthermore, its infrastructure – like new and expanded pipelines, compressor stations, and the like – is already converting valuable cropland and threatening public safety and well-being throughout the downstream Lower Susquehanna. For instance, the proposed, controversial Lancaster Co. natural gas pipelines are part and parcel of helping bring gas from upstream watersheds to the export facility in the Chesapeake.
These and other environmental impacts associated with shale gas development in the Susquehanna and Mid-Atlantic are what FERC’s environmental review should have considered. Unfortunately, FERC has turned a blind-eye to these types of impacts, and refused to consider them as it moves forward in trying to authorize LNG export from the Chesapeake Bay. In fact, FERC not only refused to consider impacts to upstream communities like the Susquehanna, it also refused to even perform a robust study, choosing to perform an abbreviated review – called and Environmental Assessment – instead of a thorough, probing review – called an Environmental Impact Statement.
Lower Susquehanna Riverkeeper will continue its strong, science-based advocacy to ensure decisionmakers rightfully consider the full-range of impacts that an LNG export facility in the Chesapeake will mean for upstream communities and watersheds like the Susquehanna.