Comment of Sierra Club, et. al. under CP13-113.

ALASKA CALIFORNIA FLORIDA MID-PACIFIC NORTHEAST NORTHERN ROCKIES NORTHWEST ROCKY MOUNTAIN WASHINGTON, DC INTERNATIONAL May 3, 2013 VIA ELECTRONIC FILING Kimberly D. Bose, Secretary Federal Energy Regulatory Commission 888 First Street NE, Room 1A Washington, DC 20426 Re: Comments on Dominion Cove Point LNG, LP, Docket No. CP13-113-000 Dear Secretary Bose: On behalf of proposed interveners EarthReports, Inc. (dba Patuxent Riverkeeper); Potomac Riverkeeper, Inc.; Shenandoah Riverkeeper; Sierra Club; and Stewards of the Lower Susquehanna, Inc., and the additional undersigned organizations, we respectfully submit these comments on the application of Dominion Cove Point LNG, LP (DCP) for authorization to construct, install, modify, own, operate, and maintain facilities for liquefaction and export of natural gas and for a Certificate of Public Convenience and Necessity (Application).1 In its Application, DCP sets forth its intent to resuscitate the largely moribund Cove Point liquefied natural gas (LNG) import terminal near Lusby, Maryland, by adding liquefaction facilities with nameplate capacity of 5.75 million metric tons per annum (MTPA) of LNG (collectively, the Project). If approved, the Project will increase industrial activity and pollution in impaired waters, sensitive wetlands, and intact forest in Maryland and Virginia, and it will induce upstream gas production and associated pollution in shale gas regions to the north. As a result, the Project will have significant adverse effects on the Cove Point site and off-site Project areas, the lands and waters of Mid-Atlantic states, and communities and ecosystems throughout much of the Northeast. Those Project impacts, taking into account both their context and intensity, warrant preparation of a comprehensive environmental impact statement (EIS), especially when considered together with impacts from other proposed LNG export facilities. Because the significant direct, indirect, and cumulative effects that will be revealed in the EIS cannot be fully mitigated, the Federal Energy Regulatory Commission (FERC or the Commission) should deny DCPs requested approvals. Independently, these significant effects also warrant a finding that the Project does not satisfy the requirements of Sections 3 and 7 of the Natural Gas Act (NGA). Given the severity of the environmental and economic impacts, the Project is not and will not be in the public interest or required by the public convenience and necessity. Indeed, rather than benefitting the United States public, the Project will concentrate negative 1 In their accompanying Motion to Intervene, EarthReports, Inc. (dba Patuxent Riverkeeper); Potomac Riverkeeper, Inc.; Shenandoah Riverkeeper; Sierra Club; and Stewards of the Lower Susquehanna, Inc., have moved for permission to participate ...