The following position statement was adopted by the Delaware Audubon Board of Directors, and presented to a public meeting, sponsored by Common Cause of Delaware, on December 29, 2004. Copies were distributed as noted in the letter. A PDF version of this letter is available for printing and distribution.
December 29, 2004
John A. Hughes, Secretary
RE: Request for Coastal Zone Status Decision on the Proposed Docking Facility for the BP/Crown Landing LLC Liquefied Natural Gas (LNG) Import Facility
Dear Secretary Hughes:
The Delaware Audubon Society (DAS) respectfully submits comments on the December 7, 2004, request by BP (made through its wholly owned indirect subsidiary, Crown Landing LLC) for a Coastal Zone Status Decision regarding the proposed construction of a docking facility within the coastal waters of Delaware. The proposed docking facility is designed exclusively to serve a Liquefied Natural Gas (LNG) import facility at the Crown Landing site in Logan Township, New Jersey.
Delaware Audubon recognizes the environmental benefits associated with the use of natural gas over other forms of fossil fuels, such as coal and oil. While we recognize these benefits, we believe more emphasis should be placed on energy conservation and the development of alternative or renewable forms of energy, such as solar, wind and geothermal energy. We are very concerned that the rush to build LNG import facilities will further our dependence on foreign sources of energy. According to a June 2004 U.S Energy Information Administration report, at least 35 company announcements of proposed LNG import terminals are targeted for North America. Algeria served as virtually the sole supplier of LNG to the United States until the latter half of the 1990's. More recently, Trinidad and Tobago have replaced Algeria as the source country with the largest volume imports (75% of total imports to the U.S. in 2003). Other source countries include Nigeria, Qatar, Oman and Malaysia. This growing dependence on foreign sources of energy is occurring at a time of increasing global instability. We also are extremely troubled by recent attempts in the U.S. Congress to undermine states' authority over siting and permitting of LNG import facilities through a rider on the appropriations bill (HR 4818) that was inserted into a conference committee report without the benefit of discussion or debate.
Delaware Audubon acknowledges the historic safety record of the LNG industry in general. Although this record is impressive, the accidents that have occurred demonstrate the destructive force of this fuel. It is important to note, however, that this period of record near totally pre-dates the events of September 11, 2001 and the significant rise in global terrorism that makes LNG facilities attractive terrorist targets or, perhaps more correctly stated, terrorist weapons.
Delaware Audubon takes issue with the suggestion that the proposed LNG import facility should be considered manufacturing as defined under the state Coastal Zone Act. We believe this operation is more properly classified as a bulk product transfer operation. The commodity being received by this facility is a fuel. This fuel is altered only slightly to facilitate safe storage, distribution and use. The commodity coming out of the facility unarguably retains its identity as a fuel by both its composition and use. Delaware's Coastal Zone Act prohibits the siting of any new bulk product transfer facilities in the coastal zone; therefore a docking facility to support such an operation also would be prohibited.
Finally, Delaware Audubon expresses its strong opposition to the siting of this facility in an area of high population density. A recent report issued by Sandia National Labs found that the "high hazard" zones from LNG tankers extend up to 1¼ mile, further than previously believed. They also found that fires from some attack scenarios could set a building ablaze more than a third of a mile away and create a flammable vapor cloud of more than 2¼ miles. The devastation that would result from either such incident if they were to occur at the site or on a tanker in the Delaware River is unthinkable both in terms of death and personal injury and destruction of property.
Delaware Audubon is not unalterably opposed to the siting and operation of LNG import facilities. We believe that existing facilities should be expanded or new facilities should be sited in remote locations, away from population centers and ecologically sensitive areas, as a way to minimize the inherent risks associated with these operations. The added cost of constructing pipelines to connect these remote facilities to major markets seems a small premium to pay.
Delaware Audubon appreciates the opportunity to provide comments on this extremely important issue.
pc: Governor Ruth Ann Minner