The Matanuska-Susitna Borough submitted their comments today on the Draft Environmental Impact Statement for the Alaska LNG Project. The filing addresses technical deficiencies in the Federal Energy Regulatory Commission’s 3,800 page Draft Environmental Impact Statement. The Mat-Su Boroughs “intervenor” status gives them an opportunity to weigh in on FERC’s decisions and even challenge in Federal Court, if needed. Last week, in a procedural move, the MSB filed a motion requesting a supplemental environmental impact statement in order to correct “foundational defects” and “legal shortcomings” in the current draft.
Today’s filing with FERC was a comments document arranged in three parts and is accompanied by multiple attachments.
Part A responds to the narrative portion of the DEIS and corrects specific inaccurate statements made in the report. One such correction addresses AGDC’s claim that the existing deep draft dock at Port MacKenzie can not accommodate LNG carrier Vessels and “will have to be demolished and rebuilt,” the DEIS states. The MSB contends, this not only is false but when analyzed correctly, will show Port MacKenzie as having a significant advantage over the Nikiski alternative. “At Nikiski, an MOF (Marine Terminal Material Offloading Facilty) does not exist, and a new facility must be constructed. At Port MacKenzie, there is an existing MOF with capabilities that exceed requirements set by AGDC. Therefore, all of the environmental impacts associated with construction of the MOF at Nikiski could be avoided by sitting the liquefactions facility at Port MacKenzie.”
Part B of the document responds to the DEIS side by side comparison between alternative sites. (See corrected table below) MSB states, “…this table contains numerous errors which substantively impact FERC’s analysis of Port MacKenzie. The DEIS alternatives analysis will not be adequate until these errors are corrected and FERC’s conclusion are based on the facts.” One side by side comparison, inaccurately singles out Port MacKenzie by claiming up to 1,258,000 cubic yards of dredging is needed annually around Port Mackenzie. 700,000 cubic yards of that total are what AGDC claims is needed annually to dredge the Knik Shoal and for widening of the shipping channel. That stands in contrast to what the Army Corp of Engineers have shared with Mat-Su Borough staff. The response states, “The COE informed the MSB that, even with the size and frequency of the vessels associated with the project, the COE did not see a need for additional dredging.” As for the remaining 650,000 and 80,000 cubic yards, AGDC’s estimates come in about 350% higher than prior survey data obtained by the MSB. “AGDC has not provided any reasoning as to why it ignored MSB’s data,” states the response.
|c||Environmental / Engineering Factor||Proposed Nikiski site||Port MacKenzie Revised Estimates (best data available)|
|1||Mainline Pipeline length (miles)||807||749|
|2||Waters of the United States within LNG plant site (acres)||14||0|
|3||NWI-mapped wetlands affected by mainline pipeline, Livengood to liquefaction site (acres)||1,618||1,161.70|
|4||Number of major waterbodies (>100 feet wide) crossed by mainline pipeline, Livengood to liquefaction site||23||21|
|5||Beluga whale Critical Habitat Area 2 crossed by mainline pipeline (miles)||27||0 (b)|
|6||Beluga whale Critical Habitat Area 1 traversed by vessel traffic (miles)||0||29 (c )|
|7||Beluga whale Critical Habitat Area 2 traversed by vessel traffic (miles)||138||64.5 (c )|
|8||Approximate assumed pipeline lateral length to Fairbanks (miles)||30||0|
|9||Approximate assumed pipeline lateral length to Anchorage (miles)||0||0|
|10||Compression required (hp)||344,000 (d)||248,193|
|11||Approximate dredging required (cubic yards)||1,682,581 (a)||91,500|
|12||Existing land use||Mixed||Industrial|
|13||Number of residences displaced||16||0|
|14||Number of displaced industrial/commercial facilities||10||0|
|15||Residences within 100 feet of mainline pipeline||1||0|
|16||Road relocation necessary||Yes||No|
Part C is a review of the impacts on endangered and threatened species at the Nikiski alternative and how these impacts can be avoided using the Port MacKenzie alternative for the Liquefaction facility. The threat to the Beluga Whale is major focus of the DEIS, and rightfully so. However, once again, inaccurate and missing data supplied by AGDC to FERC has tilted the argument against Port MacKenzie. This portion of the response addresses these miscalculations. One major omission of the DEIS deals directly with Beluga strikes as it relates to the laying of pipe across Cook Inlet on its way to Nikiski. The project will require 12 anchor lines, mid line anchor bouys, at more than 13,000 feet wide for 27.3 miles over the course of two seasons. Despite AGDC citing research that warn of “…risks of entrapment, entanglement and harmful, perhaps even lethal collisions,” a footnote on a Table of Total Number of Beluga strikes on page 0-90 states, “does not include vessels for pipe lay activities for Mainline Pipeline construction in Cook Inlet.” The response states, “This means that although research identifies serious risks with anchor lines, which could result in lethal collisions, the DEIS does not take these risks into consideration.” The response further states, “These 12 anchor lines, each stretching more than a mile in length…is similar to a spider-web of guillotine wires stretched across cook inlet, more than two-miles wide.”