Waterkeeper Coalition Comment Letter re: DCP's Pre-Filing & Intent to Export LNG under PF12-16.

October 24, 2012 Kimberly D. Bose, Secretary Federal Energy Regulatory Commission 888 First Street, N.E., Room 1A Washington, D.C. 202426 Re: Dominion Cove Point LNG, LP, Docket No. PF12-16-000 Proposed Liquefaction Project Response to Notice of Intent to Prepare and Environmental Assessment for the Planned Cove Point Liquefaction Project, Request for Comments on Environmental Issues, Notice of On-Site Environmental Review, and Notice of Public Scoping Meetings Dear Ms. Bose, The undersigned oppose Dominion Cove Points (DCP") proposal to convert its Calvert County, Maryland, LNG facility from an import to a bi-directional, export-focused facility. This comment letter discusses why the instant proposal creates significant, long-term environmental harms. This letter then pinpoints several key issues within the Notice of Intent that must thoroughly be analyzed. Last, this letter discusses why the Project constitutes a major federal action significantly affecting the quality of the human environment and therefore requires a full Environmental Impact Statement (EIS). We submit the following comments on behalf of ourselves and supporting membership organizations concerning the scope and substance of the Environmental Assessment (EA) to be prepared by the Federal Energy Regulatory Commission (FERC or Commission) with respect to the Cove Point Liquefaction Project (Project) proposed by Dominion Cove Point LNG, LP (DCP). FERC provided notice of this action on September 28, 2012.1 The Project, and others like it proposed around the nation, fit into the larger picture of recent industrial development of shale gas plays. Development of shale plays recently became economically feasible due to technological improvements in extractive techniques, such advances collectively known as high-volume hydrofracturing, or fracking. The use of fracking technologies spurred one of our nations speediest natural resource extraction stampedes, especially in newly discovered plays of the East. In 2000 shale gas provided only 1% of U.S. natural gas production; by 2010 it was over 20% and the Energy Information Administration predicts that by 2035 46% of the United States' natural gas supply will come from shale gas.2 Particularly relevant here is recent exponential shale gas production from the Marcellus Shale of the Northeastern United States, the overwhelming majority of which occurs within the states of Pennsylvania and West Virginia. Records from the Pennsylvania Department of Environmental Protection show that drilling of wells in the Marcellus Shale increased by nearly 400 percent 1 77 Fed. Reg. 59601, Friday September 28, 2012. 2 U.S. Energy Information Administration, Effect of Increased Natural Gas Exports on Domestic Energy Markets, 2 U.S. Energy Information Administration, Effect of Increased Natural Gas Exports ...