NEPA Scoping Comment of Sierra Club under PF13-11.
01/05/2014UNITED STATES OF AMERICA FEDERAL ENERGY REGULATORY COMMISSION IN THE MATTER OF ) ) DOCKET NO. CE FLNG, LLC ) PF13-11 CE Pipeline, LLC ) NEPA Scoping Comments Nathan Matthews Natalie Spiegel Associate Attorney Legal Assistant Sierra Club Environmental Law Program Sierra Club Environmental Law Program 85 2nd St., Second Floor 85 2nd St., Second Floor San Francisco, CA 94105 San Francisco, CA 94105 (415) 977-5695 (tel) (415) 977-5638 (tel) (415) 977-5793 (fax) CE FLNG, LLC and CE Pipeline, LLC (collectively referred to as CE FLNG) propose to construct and operate liquefied natural gas (LNG) export, and interstate natural gas transmission pipeline facilities in Plaquemines Parish, Louisiana. On December 5, 2013, the Federal Energy Regulatory Commission (FERC) requested comments regarding the scope of the Environmental Impact Statement (EIS) that FERC currently intends to prepare for the project under the National Environmental Policy Act (NEPA). Sierra Club submits the following comments regarding the appropriate scope of NEPA review. The Sierra Club submits these comments on behalf of its hundreds of thousands of members, including its members who live in and around the CE FLNG project site, near proposed compressor stations, and throughout the natural gas fields where production would increase as a result of the proposed project. These scoping comments are intended to assist FERC as it identifies key issues in the NEPA process, and so are not intended as a comprehensive discussion. We intend to continue to participate in the process, including submitting more detailed comments, as FERC prepares draft documents. The proposed project has substantial environmental implications for Louisiana and for the United States generally. It will create a new source of industrial activity and pollution at the terminal and along the proposed pipeline route. It will also substantially increase natural gas production, and associated pollution, in upstream gas production fields. These issues must be included among the issues considered in the EIS. I. Important Local Impacts and Considerations FERCs notice of intent to prepare an EIS identifies many important siting and related considerations which FERC must analyze. Sierra Club further shares the concerns 1 highlighted by the National Marine Fisheries Service and the Louisiana Department of Wildlife and Fisheries in their respective January 6, 2014 comments. FERCs analysis of local impacts must include, inter alia: The magnitude and nature of any air or water emissions associated with any facility connected to the CE FLNG project, including compressor and pipeline emissions. The effects of emissions, as well as other operational and construction activities, upon ...