The state of Oregon says federal environmental impact findings for the Jordan Cove liquefied natural gas project are inadequate and sometimes incorrect. State agencies submitted 250 pages of comments to federal energy regulators late last week on the project's draft environmental impact statement (DEIS). The Federal Energy Regulatory Commission (FERC) has the power to determine whether the controversial project can be built.
The Canadian company Pembina is proposing to build an LNG export terminal and pipeline in southwest Oregon. Natural gas from the Rockies and Canada would be piped from a new pipeline juncture in the Klamath County town of Malin about 230 miles across public and private property to a terminal at the Port of Coos Bay. There, the gas would be liquefied and loaded onto tanker ships bound for Asia.
Several Oregon state agencies reviewed economic, environmental and social impacts outlined in the project's DEIS, for which the public comment period closed on July 5. The overall message was that Jordan Cove and federal energy regulators do not tell the full story of how the project will affect local communities.
Some of the most critical feedback came from Oregon's Department of Geology and Mineral Industries (DOGAMI), which evaluated Jordan Cove's plans to handle landslides, tsunamis and a Cascadia subduction zone earthquake.
“Geologically, it’s a very active area,” said DOGAMI resiliency engineer Yumei Wang of the four-county region in southwest Oregon.
She said for natural disasters like a Cascadia earthquake, it’s not if it’s going to happen, it’s when.
“When it happens, has the facility been designed to be safe? You don’t want to have things exploding and failing in a ways that hurt the public,” she said.
This planning for safety and resiliency is referred to as “mitigation.” Wang said the problems start with the underlying assessment of the risk of these natural disasters because Jordan Cove relied on outdated information and technology in their analysis.
For example, DOGAMI states in comments that Jordan Cove planners relied on earthquake fault data from the U.S. Geological Service along the pipeline route. But by examining recent maps made using lidar (a laser surveying method), "DOGAMI has identified dozens of previously unknown active faults." Lidar technology can also be used to identify landslide activity.
“They didn’t characterize the hazards adequately,” Wang said. “Because they didn’t do that, they really can’t propose mitigation that is acceptable because they haven’t done that first step.”
Fish And Wildlife Habitat
Oregon’s fish and wildlife agency also looked critically on FERC’s analysis of the environmental impacts of the project.
ODFW examined the pipeline and terminal plan to see if the company is proposing enough habitat restoration to offset what would be lost through construction. In regulatory terms, these kinds of projects are also referred to as “mitigation.”
“The way we’re reading the proposal, the end result would be a net loss in fish and wildlife habitat. So we don’t find that that allows us to meet our public trust responsibility,” said Sarah Reif, statewide energy coordinator for ODFW.
The agency submitted a list of dozens of additional restoration projects that would need to be done to ensure no net loss of fish and wildlife habitat.
"Those would all be necessary and then some," Reif said. "We talk about what we think would be necessary to offset the loss of, for example, eelgrass in the Coos Bay estuary [or] late successional forest habitat for [marbled] murrelet and [northern spotted] owls."
These habitat types will be destroyed through the dredging of the terminal slip and laying of the pipeline through public forests.
In addition, ODFW says that the regulatory documents "grossly underestimate" the economic impact the project will have on the state's $2.5 billion commercial and recreational fishing industries. The comments specifically point out the importance of the Coos Bay estuary in providing habitat for young Dungeness crab, a cornerstone fishery for fishing fleet in Coos County, and concerns that dredging associated with the Jordan Cove project would diminish the productivity of the bay.
In its comments to FERC, the state of Oregon also aimed criticism the energy agency itself.
Last February, the commission first applied what it called a "new approach" to calculating the emissions of climate warming gasses like carbon dioxide and methane for liquefied natural gas projects. FERC decided to only consider emissions associated with the immediate footprint of the project.
For Jordan Cove, that would be 2.14 million metric tons of carbon dioxide equivalent in Oregon alone. If built, it would be the largest greenhouse gas emitter in the state, higher even than Oregon's only coal-fired power plant.
The DEIS says “it is not currently possible to determine localized or regional impacts from [greenhouse gas] emissions from the Project.” And without that, “we are unable to determine the significance of the Project’s contribution to climate change.”
In its response, Oregon argues this approach is not good enough and “fails to describe and assess the potential impacts on Oregon’s lands and state waters due to air contaminant emissions, including greenhouse gas emissions, from the transportation of LNG during natural gas exploration, collection, distribution and export to markets outside the United States.”
From the latest international climate assessment, it's known that climate change has already resulted in longer wildfire seasons in the Pacific Northwest. Warmer winters have led to reductions in the mountain snowpack. This is speeding the historically slow release of water for communities, agriculture, rivers and fish. In addition, climate change is expected to continue affecting the natural resources sector of the Northwest economy, with impacts on coastal fishing, Douglas fir plantations, vineyards and farming.
Oregon argues FERC’s assessment that life-cycle climate impacts of Jordan Cove are “outside the scope” of the regulatory documents is “legally incorrect.”
Jordan Cove officials say they are reviewing the comments and will submit responses to FERC by the July 22 deadline.
After receiving Jordan Cove’s responses, federal energy regulators will decide what additional measures, if any, are required.