Due Diligence

On Father’s Day this year, I got to spend some quality phone time with my father, who’s only recently gotten hearing aids (for which my mother is grateful and Dad seems to be taking a shine to). This makes it a little easier to converse with him, at least physically. But therein lies the rub: It’s never been easy for me to talk with Dad. Even if we basically agree about the issues confronting humanity, we don’t necessarily agree how to solve them—or, in his case, whether solving them lies within the realm of what’s possible.

So, I had to share my letter to the Federal Energy Regulatory Commission (FERC) with Dad, even though it may not amount to, as he likes to say, “a pinch of shit in a windstorm.” Some things we humans need to do simply because our conscience requires us to do so. The letter was a response to the FERC’s Environmental Assessment of Dominion Resources’ proposal to liquefy natural gas at Cove Point in Lusby, Md., just south of

LNG Dock in Chesapeake Bay (Photo by Pam Hairston, Baltimore Sun)

LNG Dock in Chesapeake Bay (Photo by Pam Hairston, Baltimore Sun)

Calvert Cliffs State Park and Flag Ponds Nature Park and surrounded by conservation easements owned by, among others, the Sierra Club and the Nature Conservancy. The EA does not go far enough as FERC only concerns itself with issues of interstate-commerce energy. But, of course, I and legions of others believe that development of an LNG facility in Lusby will only increase the pressure for more fracking of shale gas and this gas will come from outside Maryland—hence “interstate.”

Letters to editors and elected representatives and government regulators are, as far as I know, a tradition in my family—even if the practice leapfrogged my father. My great uncle Frank Glenn, who grew up and lived his whole life in Hattiesburg, Miss., wrote many, many letters, I was told by a cousin-in-law. I never got to meet Uncle Frank, but some part of him no doubt lives on in me, because no matter how hopeless something feels, I can always pick up a pencil or pen or take to the laptop and try to make my voice heard.

Dad these days is fond is saying, “There are no easy answers.” I believe this is the case, especially for Americans, as we’ve been conditioned to desire “easy.” But the more we go for ease, the more difficult we seem to make things for ourselves and especially for future generations who will be stuck to sort out the messes we’ve and those before us have created.

We need to take responsibility for our actions—and our reactions. Because ultimately, we control only those two things—how we act and react.

So, this letter to FERC is both an action I’ve taken and a reaction—to FERC’s inadequate assessment.

Ms. Kimberly D. Bose, Secretary
Federal Energy Regulatory Commission
888 First Street NE, Room 1A
Washington, DC 20426

Re: Docket No. CP13-113-000, FERC Environmental Assessment of Cove Point Liquefaction Project

Dear Ms. Bose:

The Environmental Assessment performed by the Federal Energy Regulatory Commission of Dominion Resources’ Cove Point LNG facility in Lusby, Md., is simply not adequate and therefore understates—and greenlights—potential adverse impacts.

The EA says that the FERC’s authority is to review requirements relating only to natural gas facilities involved in interstate commerce, and that “Thus, the facilities associated with the production of natural gas are not under FERC jurisdiction.”

Fracking Liquid Container Trucks in Dimock, Pa. (Photo by JH Fair via http://blog.skytruth.org/2011/04/fracking-safe-or-not.html)

Fracking Liquid Container Trucks in Dimock, Pa. (Photo by JH Fair via http://blog.skytruth.org/2011/04/fracking-safe-or-not.html)

I beg to differ. The potential for natural gas obtained by hydraulic fracturing of shale is just as likely to come from outside Maryland as from within, and would therefore be subject to review, because it will have crossed state lines. By extension, based on where Dominion and its affiliates currently operate in Appalachia and along the Marcellus shale, it is, contrary to the FERC’s EA, most definitely “reasonably foreseeable” that there will be impacts associated with increased natural gas production should DCP’s liquefaction project proceed.

Far-Ranging Impacts
The FERC is required to examine a range of impacts, including temporary, short-term, long-term and permanent. The EA states, “A permanent impact could occur as a result of any activity that modifies a resource to the extent that it would not return to preconstruction conditions during the life of the Project….”

Does it matter whether such permanent impacts are confined within the acres of Dominion’s Cove Point site—or whether they occur hundreds of miles away, so long as we are talking about the “life of the Project”?

Permanent impacts along an impermanent shoreline? (Historic shorelines map from USGS)

Permanent impacts along an impermanent shoreline? (Historic shorelines map from US Geological Survey)

Because we are talking about permanent impacts, including the loss of water “resources” to hydrofracking, the permanent inability by humans and other species to utilize such water, which, whether it’s locked away “forever” underground or simply polluted, is no longer usable, unless, of course, people naturally want to subject themselves and others to radioactive and/or endocrine-disrupting chemicals. Multiple examples of such losses already exist in areas where hydrofracking has taken place. And that is only contamination and does not include an estimate from the U.S. Environmental Protection Agency that some 35,000 fracking wells glug 70 to 140 billion gallons of water every year.

I realize that the FERC may be limited to look at just one aspect of this picture—the Cove Point facility itself and what Dominion is proposing. But it’s really time for all those who serve on behalf of the public and who are tasked with protecting water, air and land to do their jobs. In this case, that would mean a full assessment of the impacts—ecological and economic—which this EA does not do.

In effect, this ongoing “silo-ing” (this agency is responsible for this, this one’s responsible for that) comes at a huge cost, literally and figuratively, whether it be degraded landscapes or the release of chemicals into the environment and the consequent harms that extend from such releases. Dominion is not required to include all such costs—no corporation is. Essentially, the company need only consider those things within a narrow purview—and whether its proposal will be good for shareholders, in the short-term, regardless of long-term losses paid by nonshareholders and taxpayers.

And, frankly, it’s not enough to try to cordon off things to protect them from harm. For example, even if, as the FERC is requiring, Dominion must fence off, say, the threatened tobaccoweed (located at Offsite A), and can cut down everything around it, that plant lives in a large community of other plants and its health depends on their health.

Elephantopus_tomentosus goes by tobaccoweed here and other names elsewhere.

Elephantopus tomentosus goes by tobaccoweed here and other names elsewhere. (From Southeastern Flora)

Just as the health of the Chesapeake Bay and our own water supplies depend on the health of the adjacent waters. Everything alive is connected by a “neural net” and for plant communities, this includes roots and rootlets and the soil and all of its micro and macroorganisms.

The same applies to us, whether we live in Maryland, Ohio, Virginia, West Virginia, or Pennsylvania. We may be cut off because of political boundaries, but water, air and soil don’t give a whit about political boundaries.

The FERC needs to conduct a full Environmental Impact Statement and, as part of such an EIS, staff need to fully assess the ecological and consequent economic impacts of this project. To say that such impacts are not “reasonably foreseeable and quantifiable” is a way of weaseling out of doing your due diligence and working on behalf of those who don’t own shares in Dominion and have no way of protecting themselves against the unfolding travesty and tragedy that is hydrofracking. It is high time that we start ceding privilege to all those support systems that enable us to live, to give precedence to them, because as they go, so goes our health and our overall economic well being. Compromising those things is not worth the economic benefit to a few in the form of jobs or short-term profits.

Thank you for your attention.

Sincerely,

Leigh Glenn

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