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LWF Position on Development of LNG Processing Facilities in Gulf and Coastal Waters
The Gulf of Mexico has become a favored region for the proposed location and operation of facilities/ports to receive and regasify liquefied natural gas (LNG). The potential economic benefits and handsome profits expected from investment in this method of supplying feedstock for the manufacture of chemicals as well as relatively clean and economical energy have compelled a "gold rush" to implementation. It has been reported that up to 22 LNG terminals have been proposed for location in the Gulf of Mexico, even though experts predict that current and reasonably foreseeable markets for natural gas will not support so many suppliers.
Most of the LNG facilities already licensed, or that are currently being evaluated for licenses, propose to employ an open system that uses ambient seawater to regasify the liquid before pumping it ashore through pipelines. Such a process will suck millions of gallons of seawater each day through the system, causing the mortality of millions of eggs and larvae of economically-important fish and shellfish, and planktonic organisms at the base of the marine food chain. Estimates of the impacts of open system LNG regasification on species' populations range widely, and at best are guesses. Extrapolations of the expected egg/larvae mortality to economic impact at the fishery level, such as predicting a decrease in the annual recreational redfish harvest or the annual harvest of red snapper, are also simply guesses. Unfortunately, due to the state of marine fisheries science in the Gulf of Mexico and the short time period (365 days) provided by law to gather sufficient empirical data to accurately characterize the impacts of an open LNG regasification facility on natural resources, the public, resource managers and resource users are left without the answers they need to determine whether or not the impacts from the development of LNG processing facilities in the Gulf of Mexico will be negligible to fisheries, or unacceptably high.
Fisheries concerns may not have been anticipated when the Deepwater Port Act was amended in 2002 to stimulate development of LNG processing capacity. That was an oversight that Congress should correct by further amendment to expand the evaluation and licensing process for Gulf LNG terminals in time and collaboration to allow for adequate deliberation and data-gathering, and to involve shared decision-making with those agencies responsible for the management and conservation of public trust resources. Licensing, if appropriate, should come after, not before, that evaluation. Congress failed on that score in 2002, but has the opportunity to correct that failing with future legislation.
Therefore, these are the recommendations of the Louisiana Wildlife Federation pertaining to the siting and operation of LNG processing facilities in the Gulf of Mexico and coastal waters.
1. Congress should amend the Deep Water Port Act to provide for a process for evaluating and permitting LNG terminals sufficient to understand, measure and minimize adverse impacts to the environment, including fish and wildlife resources prior to the issuance of a license to operate.
2. Those businesses already licensed and permitted to operate LNG terminals should commit to undertaking a scientifically-sound monitoring and assessment program evaluated and approved by the National Research Council, and executed in collaboration with the National Marine Fisheries Service (NMFS) and the Louisiana Department of Wildlife and Fisheries (LDWF) to determine the impacts to marine organisms, the food chain, the Gulf of Mexico ecosystem and ultimately, to the economic value of Gulf fisheries and other renewable natural resource-based activities in the Gulf of Mexico. Those businesses should fund the necessary monitoring and assessment program, including support for the participation of NMFS and LDWF personnel. Most importantly, those businesses should commit to the employment of alternative technologies, including a closed loop regasification process as appropriate, considering the practicality of implementation with respect to specific prevailing conditions at the site of operation, if the monitoring and assessment program reveals unacceptable sustained impacts to natural resources as defined by the National Research Council in collaboration with LDWF and NMFS.
3. Decisions on all pending and future applications for licenses for LNG terminals in the Gulf of Mexico and coastal waters proposing to employ an open process for regasification should be held in abeyance pending an analysis of the cumulative impacts of the operation of all potential economically viable LNG terminals in the Gulf; or, licenses should be conditioned on certain proof that operation of the permitted facility will have no measureable impact to marine organisms at the size and age classes those organisms enter the fishery.
4. Damages to natural resources must be mitigated. Mitigation requirements for these facilities should focus on reduction of impact through an application of alternative technologies. If it is found that impacts are significant, they must be reduced to acceptable levels. Mitigation for losses in terms of funding for hatcheries, stocking, agency research and management (outside of what is necessary for the monitoring and assessment of impacts), coastal restoration, acquiring and donating habitat to the state, etc. is not acceptable mitigation.