Save Passamaquoddy Bay

Save Passamaquoddy Bay
3-Nation Alliance

Alliance to Protect the Quoddy Region
from LNG Development

US Flag
Canadian Flag
Passamaquoddy Flag
Scale Baskets for sale
Facebook button

"For much of the state of Maine, the environment is the economy"
                                           — US Senator Susan Collins, 2012 Jun 21


FERC eLibrary
Downeast LNG Formal Application
Comment Filings List

Docket Number CP07-52

2009 July

Listed here in Ascending Date Order by Date Posted to FERC eLibrary.
NOTE: The Docket List on the FERC website is in Date Order by Date Filed, rather than by Date Posted.

Color Key: Project Developer, Contractors & Supporters
Project Opponents
Project Neutral
Unknown, non-public comments

2009 July

Jul 1

Filed By: TOWN OF PERRY (sic)
Filed Date: 6/29/2009
Accession No: 20090701-0030
Description: Town of Perry submits comments re the proposed Downeast LNG Project under CP07-52 et al.

Webmaster’s Comments: The three Perry Selectmen took it upon themselves to send a Comment in support of the DEIS, and against enlarging the Comment Period — without a supporting vote from their bosses, the citizens of Perry.

The only LNG vote by the Perry electorate resulted in a rejection of LNG.

Information: FILE LIST

Filed Date: 7/1/2009
Accession No: 20090701-5234
Description: Comment of MAINE STATE PLANNING OFFICE under CP07-52, et al. on Draft EIS

Summary: Maine SPO Director Mary Freeman pretty much likes the project.

Maine Pilotage Commission Administrator Kevin Rousseau finds no reason to dispute LNG vessels can be safely piloted to the terminal.

However, the Submerged Lands Program is concerned about the LNG pier’s impact on other users of the waterway.

Information: FILE LIST

Jul 2

Filed By: Individual No Affiliation [Art. MacKay]
Filed Date: 7/2/2009
Accession No: 20090702-5015
Description: Comments of Art A. MacKay re Downeast LNG, Inc and Downeast Pipeline Project under CP07-52, et. al.

Summary: The comment points out numerous flaws in the DEIS, including the failure to take into account potential Downeast LNG-project ecological impacts on the Canadian side of the waterway. Mr. MacKay points out security issues with the “leaky” border. He also points to DEIS lack of knowledge needed about the Canadian side in order to institute mitigation on that side to compensate for the project’s negative impacts.

In addition, Mr. MacKay enumerates a plethora of Canadian regulations that must be applied to the LNG ship and jetty, but have been ignored.

Information: FILE LIST

Filed By: NOAA Fisheries, Northeast Region
Filed Date: 7/2/2009
Accession No: 20090702-5106
Description: Comment of NOAA Fisheries, Northeast Region under CP07-52, et al.

Summary: National Marine Fisheries Service will submit complete comments re endangered and threatened species under a separate Comment submission.

They claim no activities at the terminal or pier will impact endangered species.

They state that ship strikes are the primary cause of mortality to listed species, and the measures described in the DEIS will satisfactorily mitigate that problem within some areas of the waterway; however, no measures have been indicated for other areas of the ship transit route — the Bay of Fundy, Grand Manan Channel, and Head Harbour Passage.

They indicate the DEIS is lacking data regarding Atlantic salmon in the affected waterways. Problems also exist regarding winter flounder data. Downeast LNG has failed, so far, to provide required data regarding construction timing to minimize impacts on marine species, marine-construction acoustics data, pipeline horizontal directional drilling plans, and marine resource impact compensation.

NMFS also remains concerned about suspended sediments resulting from LNG ship transits.

Downeast LNG has not properly attended to impacts on non-commercial fish and planktonic species impacted by LNG vessel ballast water and engine cooling water.

NMFS lists mitigation measures that would need to be implemented.

Information: FILE LIST

Jul 6

Filed By: U.S. Department of the Interior
Filed Date: 7/2/2009
Accession No: 20090702-5156
Description: Comments of U.S. Department of the Interior on CP07-52, et. al., Downeast LNG Project, DEIS, Washington County, ME

Summary: “Considerable substantive information has not been included in the DEIS,” and “we recommend that the Commission prepare a supplement to the DEIS.” Downeast LNG “has never provided any copies of any reports to the BIA [Bureau of Indian Affairs],” even though the BIA is an intervenor in these procedings. The project would subject an undue Hazard burden on the members of Pleasant Point Passamaquoddy Reservation; plus, would negatively impact Tribal cultural resources — Environmental Justice issues. Another Environmental Justice issue is DeLNG’s claim that Tribal members have no aboriginal fishing rights in the waters proposed for the project.

Lighting at the facility and pier might negatively impact St. Croix Island International Historic Site. The DEIS does not — but must — analyze need for the project. Alternatives to the project are dismissed without supporting evidence.

DEIS inappropriately dismisses the “no action” alternative to the project.

Information: FILE LIST

Filed By: Individual No Affiliation [Arthur MacKay]
Filed Date: 7/6/2009
Accession No: 20090706-5002
Description: Comments on inadequate coverage of marine mammals by EIS - Arthur A. MacKay under CP07-52, et al.

Summary: “Downeast LNG EIS provides insufficient data, analyses, and review for marine mammals and other marine species in the Quoddy Ecosystem.” The writing style is misleading. Data are lacking. False assumptions are made. The nocturnal ecosystem is ignored. Cumulative impacts are insufficiently covered. Impacts on some marine mammals are ignored.

Information: FILE LIST

Filed By: Roosevelt Campobello International Park Commission
Filed Date: 7/6/2009
Accession No: 20090706-5012
Description: Roosevelt Campobello International Park Commission Comments relating to Downeast LNG's Draft Environmental Impact Statement under CP07-52.

Summary: RCIP agrees that LNG vessels should have to comply with the US Coast Guard Waterway Suitability Report (WSR). [The WSR requires Downeast LNG to obtain Canada’s cooperation — in essence, Canada’s approval.] RCIP continues to have serious concerns regarding safety, since the project would put portions of the park, its visitors, staff, and assets within Federal Hazard Zones. Impacts from real or perceived safety issues would likely reduce visitors to the park, as well as to the surrounding area.

Air quality is also a concern, and the DEIS should have contained a cumulative air impact analysis. The DEIS statement that another energy generating facility in the area is questioned as being unexplained.

The park is especially concerned about impacts to their floating pier from LNG ships holding in Friar Roads.

Information: FILE LIST

Filed By: Save Passamaquoddy Bay [Robert Godfrey]
Filed Date: 7/6/2009
Accession No: 20090706-5016
Description: Comments of Save Passamaquoddy Bay in rebuttal to claim by Captain Robert Peacock at FERC Public Scoping Meeting under CP07-52.

Summary: Comparison of histories of Canaport LNG and Downeast LNG demonstrate that it was Downeast LNG’s late entry into the process (roughly six years later) that has put them so far behind Canaport. The FERC permitting process had nothing to do with Canaport’s completion so far ahead of Downeast LNG.

Information: FILE LIST

Filed By: Roosevelt Campobello International Park Commission
Filed Date: 7/6/2009
Accession No: 20090706-5023
Description: Comments of the Roosevelt Campobello International Park Commission relating to the Draft Environmental Impact Statement for Downeast LNG under CP07-52 et al.

Summary: This is a duplicate of Accession No: 20090706-5012.

Information: FILE LIST

Filed By: Atlantic Salmon Federation
Filed Date: 7/6/2009
Accession No: 20090706-5061
Description: Report / Form of Atlantic Salmon Federation under CP07-52.

Summary: “[W]e see no acknowledgement of our intervention nor any evidence that an attempt has been made to evaluate whether these specific concerns about the proposed project will have significant impacts upon Atlantic salmon. There is no evidence in the document that potential impacts of the project upon salmon from rivers on the Canadian side of the border have been evaluated.”

“We are also troubled by the logic that pervades the document that suggests because there are few salmon in the area, the project can only impact a small number of fish, and thus will have small impacts.”

Information: FILE LIST

Filed By: City of Eastport, Maine
Filed Date: 7/6/2009
Accession No: 20090706-5065
Description: Comments of City of Eastport, Maine under CP07-52.

Summary: Cumulative impacts on Western Passage vessel traffic are insufficiently addressed. Emergency and security resources and social infrastructure are inadequately addressed.

The City takes exception to some DEIS conclusions regarding the projects impacts on the economy, citizens, visitors, and resources, and believes the DEIS underestimates safety and security requirements when population is highest in the city, such as during the 4th of July period — when Eastport reaches approximately 15,000 people.

Eastport recommends an independent pilot and tug operator review regarding the suitability of the waterway — since nearly all project-related ad hoc safety and response meetings, and the applicant’s Waterway Suitability Assessment, relied significantly on representatives of local Pilot groups who have a financial conflict of interest in the proposed project, and since appropriate data were not available for use by the project’s transit simulations.

The DEIS ignores Eastport’s significance as a nationally-ranked port within the project’s Federal Hazard Zones, and the population increase (and concomitant infrastructure and economic burden) that would result from the project.

The DEIS does not address the cumulative impact on local tidal power projects in or near the LNG transit route.

The City of Eastport is concerned the DEIS considered insufficient data, analyses, and thorough assessment to support its conclusions.

Information: FILE LIST

Filed By: US Environmental Protection Agency — Region 1
Filed Date: 7/6/2009
Accession No: 20090706-5081
Description: Comment of EPA Region 1 under CP07-53 et. al.

Summary: “[W]e note our disappointment that information relevant to the characterization of environmental impacts [that we supplied] is not included.”

“[W]e believe that … information should have been included in the DEIS and not made available for the first time in the FEIS.”

We have rated the DEIS "EC-2" (Environmental Concerns-Insufficient Information) in accordance with EPA's national rating system, a description of which is enclosed.

“The DEIS notes FERC's request for information from Downeast regarding total emissions from LNG vessel and support vessels traveling between the pilot station and the import terminal berth. We believe this information should have been provided in the DEIS and was specifically requested in our May 3, 2006 scoping comments.”.

Information: FILE LIST

Filed By: Conservation Law Foundation
Filed Date: 7/6/2009
Accession No: 20090706-5086
Description: Comment on DEIS of Conservation Law Foundation under CP07-52, et. al.

Summary: CLF believes LNG terminal siting must be “proactive, regional, and strategic,” and “must first answer the question of whether the need for any further LNG supply is necessary for the region.” If not, then it violates Section 3(a) of the Natural Gas Act.

CLF refers to FERC Chairman Wellinghoff’s previous statement that regional need assessment is needed prior to permitting any more LNG terminals. They also refer to former FERC Chairman Pat Wood’s statement that only one or two projects at that time would be needed to supply the New England region. Since then, three terminals have been approved and/or constructed (Northeast Gateway, Canaport LNG, and Neptune LNG).

Information: FILE LIST

Filed By: St. Croix International Waterway Commission
Filed Date: 7/6/2009
Accession No: 20090706-5088
Description: Comment of St. Croix International Waterway Commission under CP07-52, et al.

Summary: FERC recognized Horizontal Directional Drilling to be an issue but does not adequately address it in the DEIS. The DEIS does not address an alternate route that was previously requested.

Information: FILE LIST

Filed By: Individual No Affiliation [Bill Robertson, Huntsman Marine Science Centre]
Filed Date: 7/6/2009
Accession No: 20090706-5106

Description: Comments of WD (Bill) Robertson under CP07-52, et al.

Summary: There is no evidence in the DIES the applicant or FERC consulted with Huntsman to identify the scope and scale of the Huntsman operations, impacts of the project on Huntsman, or mitigation measures related to impacts on Huntsman. Since the Scoping process began, Huntsman is planning on a $8 million expansion to make the facility a four-season tourist attraction.

Huntsman “houses the one of most complete collections of reference specimens of the North Atlantic Ocean ecosystem. The collection is used by taxonomists all over the world, including for an international initiative known as the Barcode of Life Initiative (CBOL).” It would be negatively impacted by Downeast LNG.

Information: FILE LIST

Filed By: Province of New Brunswick
Filed Date: 7/6/2009
Accession No: 20090706-5110
Description: Comments of Province of New Brunswick under CP07-52, et al.

Summary: New Brunswick Premier Shawn Graham reminds FERC that FERC and the US Government have no jurisdiction over New Brunswick/Canadian waters, and that the impacts and issues addressed in the DEIS that fall on New Brunswick are within the jurisdiction of New Brunswick and Canada, alone.

Included is a report from numerous Provincial departments.

The report reiterates the US Coast Guard Waterway Suitability Report requirement that Downeast LNG project cannot proceed without Canadian approval, and that “the Canadian government has issued an unequivocal ban on the transit of LNG vessels through the Head Harbour Passage.”

The report “concludes that LNG transits would present substantial and unmanageable risks and losses to the Province, its citizens, economy, and environment,” and that the DEIS is inadequate.

The Province demonstrates a plethora of negative impacts in numerous categories from the DeLNG project, and enumerate a multitude of absences or deficiencies in the DEIS. In addition, they point to regulatory inconsistencies between FERC requirements and Canadian standards as they would impact on New Brunswick people and assets, violating Canadian safety standards.

Information: FILE LIST

Filed By: Province of New Brunswick
Filed Date: 7/6/2009
Accession No: 20090706-5111
Description: Comments of Province of New Brunswick under CP07-52, et al.

Summary: CEII (Critical Energy Infrastructure Information) — no public access to this filing.

Information: FILE LIST [will result in a file indicating an error.]

Filed By: Sierra Club of Canada - Atlantic Chapter
Filed Date: 7/6/2009
Accession No: 20090706-5119
Description: Comments on the Downeast LNG FERC Draft Environmental Impact Statement (Project Docket Numbers: CP07-52, et al.

Summary: “A ‘threat of serious or irreversible harm’ would be posed [to North Atlantic right whales] by the Downeast project.

“Tolerance of risk of impacts should be lower for threats to wildlife at risk for projects that cannot demonstrate fulfilling a significant need than for projects that can.”

“We recommend that FERC and Downeast seriously consider engaging Taggart and his team to conduct a full risk analysis addressing vessel encounters with right whales and to assess the soundness of Downeast's selection of Grand Manan Channel as a safer tanker route. The lack of such an analysis is a serious deficiency in the Downeast DEIS.

Information: FILE LIST

Filed By: Nulankeyutmonen Nkihtahkomikumon
Save Passamaquoddy Bay Canada Inc.
Save Passamaquoddy Bay-U.S
Filed Date: 7/6/2009
Accession No: 20090706-5123
Description: Comment of Three Nation Alliance (Save Passamaquoddy Bay Canada Inc., et. al.) under CP07-52, et al.

Summary: Many, many insufficiencies are enumerated in the DEIS. The DEIS is so flawed, the process must start over from the beginning.

Information: FILE LIST

Jul 7

Filed By: Individual No Affiliation [Jeanne Guisinger]
Filed Date: 7/7/2009
Accession No: 20090707-5001
Description: Comments of Jeanne A Guisinger re the Downeast LNG, Inc terminal at Gleason's Cove etc under CP07-52, et al. Letter and attachments.

Summary: Perry Town Selectmen’s previously-filed Comment overstepped the Selectems’s authority.

Information: FILE LIST

Filed By: Nulankeyutmonen Nkihtahkomikumon
Save Passamaquoddy Bay Canada Inc.
Save Passamaquoddy Bay-U.S.

Filed Date: 7/7/2009
Accession No: 20090707-5003
Description: Comments of Three Nation Alliance (Save Passamaquoddy Bay Canada Inc., et. al.) under CP07-52, et al.

Summary: This is a duplicate of SPB’s filing on July 6.

Information: FILE LIST

Filed By: Nulankeyutmonen Nkihtahkomikumon
Save Passamaquoddy Bay Canada Inc.
Save Passamaquoddy Bay-U.S.

Filed Date: 7/7/2009
Accession No: 20090707-5021
Description: Attachments 46-65 to Comments of Three Nation Alliance (Save Passamaquoddy Bay Canada Inc., et. al.) under CP07-52, et. al.

Summary:This Filing consists of 20 Attachments of Testimony, Comments, and Transcripts to SPB’s filing that appeared on the Docket on July 6:

  1. Professor Paul H. Templet, physical chemist —Downeast LNG is in a particularly poor location from a risk perspective. The risk from human error is excessive and the site should be avoided. FERC has not fully evaluated other locations with lower inherent risk. The DEIS is significantly flawed.
  2. James A. Fay, Ph.D., Professor Emeritus of mechanical engineering at MIT, specializing in fluid mechanics, including the safety hazards of liquefied gases — FERC regulations ignore several important public safety risks. Downeast LNG’s site selection seriously underestimated the required Exclusion Zone size.
  3. Dr. D. Leigh Smith, Professor of Geological Sciences (retired) — “The predetermined bias of the Response is transparently clear. Excellent professional analysis has been expended to answer the wrong questions. All effort has been expended to rationalize or justify the Downeast LNG Project, not to test its environmental consequences.”
  4. Kenneth B.S. Burke, Honorary Research Professor, University of New Brunswick — The area is historically an active earthquake zone.
  5. Robert Godfrey, SPB researcher — While the US Coast Guard advocates following best practices, and while it recognizes SIGGTO as the leading authority on LNG best practices, it tossed aside SIGGTO terminal siting best practices when vetting the suitability of the Passamaquoddy Bay waterway. FERC and the Coast Guard are knowingly abetting a Department of State falsehood regarding the UN Convention on the Law of the Sea — a treaty to which the US is not a member, and under which the US has no rights.
  6. Town of St. Andrews — Downeast LNG would impose economic hardship on area residents.
  7. Friends of Head Harbour Lightstation — The lightstation is a significant cultural icon, located just outside of LNG ship Hazard Zone 1. It would place significant numbers of tourists’ and residents’ lives and health at risk. The project is also a security risk. LNG ships would disturb whales on a regular basis and industrialize the bay, negatively impacting whales and herring
  8. Mark L. Horn and Brady B. Ryburn, summer and fall Deer Island residents — Porpoise in large numbers frequent Western Passage in large numbers. Finback whales have also been seen there. The DEIS failed to study whale and porpoise populations in Western Passage, and the impacts LNG traffic would have on those populations in that waterway.
  9. Richard E. Berry, paper industry worker (retired), recreational boater, recreational clammer — The heavy industry indicated in the DEIS would have devastating impacts on Passamaquoddy Bay, its users, and area residents. There are significant omissions in the DEIS.
  10. Paul V. Crawford, Ph.D., professor of geography and cartography (retired) &
    Suzanne Crawford, professor (semi-retired), on the national board of RCAP (Rural Community Assistance Partnership) — The DEIS contains many ambiguities that need to be clarified. Impacts on all affected communities was not addressed. Seismic impacts were not considered.
  11. Enterprise Charlotte — Downeast LNG would negatively impact businesses and quality of life on both sides of the border.
  12. Fundy Baykeeper — The entire LNG ship route lacks adequate Emergency Response infrastructure, mitigation mentioned is inadequate, local economy would be negatively impacted. The DEIS oversteps its authority by recommending for the project when its authority is only to recommend mitigation measures. The DEIS exhibits a bias in favor of the project.
  13. Travis Bradford, equity fund manager investing in energy companies — Kestrel Energy does not appear to have sufficient funds to commit to building the project, but merely agrees to “arrange financing.” Included in this file is an affidavit by Jerold Levey, an energy finance professional. He agrees that Kestrel Energy does not have sufficient funds to construct, but offers to “arrange financing.” Also, Levey states that Canada’s prohibition of LNG transits into Passamaquoddy Bay would prevent bank financing.
  14. Gary Guisinger, environmental photographer, pleasure boater, Elderhostel provider — DeLNG’s project would endanger kayakers, would reduce enjoyment of the waterway, and would negatively impact his business.
  15. Arthur MacKay, biologist and Executive Director (former) of the St. Croix Estuary Project Inc. — He provides his publication, “Regulating Protection of the Quoddy Region,” suggesting a ship-regulatory regime to protect Passamaquoddy Bay.
  16. Charlotte Coastal Region Tourism Association — The project would negatively impact tourism and cultural resources, as well as the existing economy. They are critical of the DEIS’s circular logic regarding likelihood of an accidental LNG release.
  17. State of Maine Board of Environmental Protection 2007 July 16 DeLNG Hearing Transcript
  18. State of Maine Board of Environmental Protection 2007 July 17 DeLNG Hearing Transcript
  19. State of Maine Board of Environmental Protection 2007 July 19 DeLNG Hearing Transcript
  20. State of Maine Board of Environmental Protection 2007 July 20 DeLNG Hearing Transcript

Information: FILE LIST

Filed By: Nulankeyutmonen Nkihtahkomikumon
Save Passamaquoddy Bay Canada Inc.
Save Passamaquoddy Bay-U.S.

Filed Date: 7/7/2009
Accession No: 20090707-5022
Description: Attachments 1-20 to Comments of Three Nation Alliance (Save Passamaquoddy Bay Canada Inc., et. al.) under CP07-52-000, et. al.

Summary:This Filing consists of 20 Attachments of Testimony, Comments, and Transcripts to SPB’s filing that appeared on the Docket on July 6:

  1. State of Maine Board of Environmental Protection 2007 July 18 DeLNG Hearing Transcript
  2. Harry Shain, lobster fisherman, former chairman of Cobscook Bay Fishermen’s Association — Mill Cove is a productive lobster fishing resource and important lobster nursery. DeLNG would spoil the lobster fishery at Mill Cove and along the LNG tanker route. He disagrees with local pilots’ claims that the project would not negatively affect lobstering.
  3. Dr. Robert Steneck, professor of Marine Biology, Oceanography and Marine Policy, University of Maine Darling Marine Center — The DEIS is critically deficient and faulty. Mill Cove contains large reproductive lobsters that are critical to the area’s lobster population. A minimum of two years is required to study the lobster nursery in that cove. The study that was conducted by DeLNG used inappropriate methodology, and at the wrong time. An LNG project would be devastating to lobster fishing and the regional economy — not adequately considered in the DEIS.
  4. Heike Lotze, Canada Research Chair in Marine Renewable Resources, an Assistant Professor in the Biology Department. of Dalhousie University, and has conducted research in Passamaquoddy Bay — the relative small area of Passamaquoddy Bay contains an important diversity of biogeographic habitats and food sources, critical for a variety of animals, including herring, right whales, and harbour porpoise. Many endangered species are found here. Campobello Island, Deer Island, Western Passage, and Head Harbour Passage are key to biological productivity in the Bay of Fundy. An LNG release would kill birds, krill, fish, and bivalves near the waters surface, and would kill or severely injure marine mammals as they surface to breathe. It could also kill terrestrial animals if the event occurred near land. Methane dissolved into the water as a result of a release is toxic to fish and other marine biota. Ship-whale strike potential is increased with an increase in ship traffic. Ship traffic also disturbs feeding, breeding, nursing, and migrating animals. Passamaquoddy Bay is one of the least degraded estuarine and coastal systems, and should be preserved.
  5. Maria Inez-Buzeta, biologist (retired), St. Andrews Biological Station — Passamaquoddy Bay is ecologically unique, and supports the highest level of benthic diversity in the Bay of Fundy. Protection is of interest to the Passamaquoddy-Schoodic Tribe, and there are cultural/archaeological reasons for doing so. Enumerated is a list of reasons for protecting the Quoddy region.
  6. Tracey Dean, Director of Education, Huntsman Marine Science Centre — An LNG release could have significant impacts on birds. The project and its construction will cause disruption and possible loss of habitat, due to noise, lights, and activity. Study procedures used have been inadequate.
  7. Fred Whoriskey, Vice President, Research and Environment of the Atlantic Salmon Federation — DeLNG uses a false premise to arrive at their conclusions regarding impacts on Atlantic salmon, and did not scientifically verify their conclusions. He has concerns about lighting impacts on salmon.
  8. Laurie Murison, Executive Director, Grand Manan Whale & Seabird Research Station — the DEIS proposes to use untested whale-strike reduction techniques. The DEIS contains significant inaccuracies, and fails entirely to address some impacts on endangered species “(including, but not limited to, disclosure of Biological Opinions from the U.S. Fish and Wildlife Service, and the National Oceanographic and Atmospheric Administration).” Vessel noise is discounted or ignored re acoustic harrassment of endangered marine mammals, even though research indicates noise may have a devistating effect on whale populations. The DEIS under-represents marine mammals within the project area. Whale birth length data are erroneous; right whale data are absent. Biocides used in ship ballast water could harm local marine organisms. The DEIS claim that marine mammals would detect and avoid an LNG release on water is unsubstantiated. “FERC has failed to provide the public with the results of its consultation with FWS and NOAA concerning the Project’s potential impacts on threatened and endangered species”; therefore, the public has no way of commenting on those results.
  9. Danielle Dion, whale-identification photographer and data recorder — The DEIS fails to mention how project-related water quality would affect harbour porpoise and grey seals, or wild Atlantic salmon and herring weir fishing. DEIS fails to mention impacts of project sound on harbour porpoise or grey seals. DEIS errs regarding baleen whale diet. Important marine mammal data are missing from DEIS. (Whale sighting records and photographs are included.)
  10. Lars Lund, Master Mariner and ship’s master (retired) — He addresses impacts to endangered Northern Right Whales, and impacts of adverse weather and LNG tanker transit on use of the waterway. The DEIS whale mitigation is misleading, since spotting whales in time to take evasive action is difficult. There is no room to maneuver around whales in Head Harbour Passage. The DEIS inadequately addressed area weather impacts on LNG ship transits, and the impacts from LNG ship delays on other marine traffic. Sudden squalls during transit could affect LNG tanker ability to navigate, and this scenario was not addressed in the DEIS. LNG ships are different from other vessels frequenting these waters; LNG tankers have lots of “sail” area presented to the wind, making them harder to control in windy weather. The waterway is not suitable for transiting LNG ships on a routine basis; there is no margin for human error.
  11. Terris John Greene, owner of Island Cruises and captain of the Campobello Whale Rescue Team — The DEIS is inaccurate and incomplete regarding marine mammals and related impacts. Right whales have been observed in Head Harbour Passage every year since 1995, or before. Vessel strikes are the main cause of North Atlantic right whale deaths. The DEIS inappropriately designates Head Harbour Passage as light traffic. The narrow transit fairway prevents navigating around whales. The DEIS fails to acknowledge the American bald eagle nesting sites along and around Head Harbour Passage.
  12. Joyce Morrell, local resident, BS in biology, Masters degree in medical illustration, student of the natural world, and board member of Friends of Head Harbour Lightstation — The DEIS ignores marine mammals around Head Harbour Passage. She includes photo-documented marine mammals around Head Harbour Lightstation. Whales frequent Head Harbour Passage from late June through the end of October, and sporadically after that. DEIS contains serious omissions, misinformation, unsupported assumptions, and other problems, including many unsupported claims. DEIS fails to describe the Head Harbour environment. Impacts on food web interrelationships are ignored. (Whale photographs and dates/locations are included.)
  13. Jon M. Van Dyke, William S. Richardson School of Law, University of Hawaii at Manoa — “Canada’s Authority to Prohibit Transit of LNG Vessels Through Head Harbour Passage to U.S. Ports.” In the San Onofre Nuclear Reactor circumstance, the United States recognized coastal countries’ “authority to take action to protect their coastal populations and resources, even if such actions impose limits on navigation.”
  14. Stan Lord, East Coast Ferries, Ltd. — The DEIS is contradictory and totally insufficient regarding impacts on ferry services. He is working on developing year-’round service between Deer Island and Campobello Island, which would be devastated by ship transits from an LNG project. The DEIS failed to consider such impacts.
  15. Peter McPhail, lobster, crab, and herring fisherman — 500 of his 800 lobster traps are placed from along the Perry shore out to the international boundary. From Gleason Cove to Mill Cove is the most heavily fished area for lobsters by Mainers in Passamaquoddy Bay, and traps and fishing activity that area would be harmed by LNG ship transits. LNG ships’ ballast intake would suck up seed lobsters, since Mill Cove is habitat for many egg-bearing female lobsters. Gear loss would result from LNG ships and escourt tugs, and income would be lost due to transiting LNG vessels disrupting tide-critical fishing schedules.
  16. Timothy Griffin, lobster, crab, sea urchin and scallop fisherman — Mill Cove has lots of large egg-bearing lobsters. Mill Cove is a lobster nursery. Many lobster traps must be hauled at low tide, due to currents pulling the buoys under water at other times. The LNG project would ruin the fishery and the ability to navigate on schedule.
  17. David Pottle, lobster, scallop, musses,halibut, and urchin fisherman; lobster and scallop buyer; and pleasure boater — From Pleasant Point to St. Croix Island, near the boundary line, is the most-fished in the area for lobster. LNG would damage gear and block access to the fishing area.
  18. Mark McGuire, Jr., lobster, halibut, and scallop fisherman — He fishes using 6-trap to 15-trap trawl-lines, only, for lobster in Grand Manan Channel. Lobster fishing for most generally begins in April, and continues for three months or more. LNG would cause delays, lost gear, lost fishing time, lost money, and lost income.
  19. Mark McGuire, Sr., lobster fisherman — He fishes in Grand Manan Channel, from April through November. The proposed LNG project would reduce fishing area, and since there is no other available area, his income would be reduced. Gear loss is also a concern from the proposed LNG project. If an LNG ship were bound in by fog, it would need to circle around, further reducing available fishing ground, resulting in more gear loss and income loss.
  20. Angus McPhail, lobster and herring fisherman — He is concerned the LNG project and ships would affect herring fishing. To his knowledge, Mill Cove is the largest lobster nursery on the Maine side of Passamaquoddy Bay. From Gleason Cove in Perry to Mill Cove in Robbinston, out to the Canadian boundary, is heavily fished for lobster. The LNG project would negatively impact his ability to fish.

Information: FILE LIST

Filed By: Nulankeyutmonen Nkihtahkomikumon
Save Passamaquoddy Bay Canada Inc.
Save Passamaquoddy Bay-U.S.

Filed Date: 7/7/2009
Accession No: 20090707-5023
Description: Attachments 21-45 to Comments of Three Nation Alliance (Save Passamaquoddy Bay Canada Inc., et. al.) under CP07-53, et. al.

Summary:This Filing consists of 25 Attachments of Testimony, Comments, and Transcripts to SPB’s filing that appeared on the Docket on July 6:

  1. Brent R. Griffin, lobster, halibut, and scallop fisherman, and buys lobsters — The LNG shipping route would severely impact fishing in Grand Manan Channel and Western Passage, and will result in lost gear.
  2. Dale Griffin, lobster fisherman and wood cutter — He fishes in Grand Manan Channel, from Gleason Cove in Western Passage to Mill Cove, as well as Friar Roads and Cobscook Bay. LNG traffic at high or low slack tide would prevent him from accessing his traps. Lost gear would occur from the passing LNG ships and tugs. Mill Cove is an important lobster nursery that would be negatively affected by the Downeast LNG terminal.
  3. Michael Griffin, lobster fisherman, lobster buyer, and seafood market owner — He fishes from Eastport to north of Mill Cove, and in Grand Manan Channel. Mill Cove has big egg-bearing lobsters, more so than other places. An LNG project would cause a large loss in income due to being unable to access traps at slack tide, and because of the safety/security zone blocking traffic. If the LNG tanker had to circle around in Grand Manan Channel during foggy weather it would be impossible to fish.
  4. Dale Mitchell, commercial fisherman of lobster, scallops, and herring; board member of Fundy Weir Fishermen’s Association; board member of Fundy North Fishermen’s Association — “The DEIS contains many inaccuracies and fails to adequately consider significant impacts to commercial fisheries.” Lobstering is very heavy on both sides of Grand Manan. Around Head Harbour (north end of Campobello Island) is a prolific lobster resource, with 4000 lobster traps per square mile. “The most productive herring weirs of Deer Island and Campobello Island are within the ‘Zones of Concern’ [Hazard Zones]. The effects of the security lighting on herring will extend far outside of [Hazard] Zone 3, affecting all of these productive weirs.” Canadian-caught herring is an important source of lobster bait for Maine lobster fishermen, especially during the annual August–September herring fishery closure. Noise and light from an LNG project would catasrophically disturb the herring weir industry, with knock-on effects to the lobster fishery. The DEIS fails to take this into account. The DEIS lobster mitigation plan is infeasible. LNG tugs are likely to cause gear loss, as already happens in Saint John Harbour. The DEIS fails to consider the extent of gear loss. Gear loss also means the lost traps "ghost fish" for up to a full year, wastefully killing lobsters. The DEIS fails to consider that problem. The DEIS fails to address what would happen during foggy weather, requiring LNG ships to circle around until the fog abates, damaging more fishing gear. The DEIS fails to consider that problem. The effect of ships’ lights on herring behavior is not addressed in the DEIS.
  5. Laurence Cook, lobster, herring weir, and scallop fisherman; Chair of the Grand Manan Fishermen’s Association’s Advisory Board of Lobster Fishing Area 38 — LNG ships could damage fishing gear and prevent access to fishing areas. Ships’ lights would negatively impact herring weir fishing.
  6. Curtis R. Malloch, lobster fisherman — transiting LNG ships would cost lobster fishermen, since they would prevent hauling traps in the LNG ships’ Safety/Security Zone at slack water, and would damage fishing gear. Transiting LNG ships would also make it difficult to boat out to tend herring weirs. LNG vessels would also put whales at risk. LNG in this bay would result in lost fishing jobs.
  7. Burton “Sonny” Flynn, herring buyer and seller — He sells herring bait to hundreds of lobster fishermen down the Maine coast. In Grand Manan Passage and Western Passage there must be around 10,000 lobster traps. The LNG proposals’ lights, noise, movement, and vibration, as well as lobster gear loss, would devastate the herring and lobster businesses.
  8. Reid Brown, scallop, herring, and lobster fisherman — An LNG project would interrupt his herring weir access, affecting his income. Noise and light would also have an effect on his income.
  9. Tom Beckerton, crab and scallop fisherman — He fishes in Western Passage and the west side of Passamaquoddy Bay. An LNG project, with ships and several tugs, would destroy his ability to fish from loss of fishing ground access and loss of gear.
  10. David Smith, owns MDI Shellfish in Southwest Harbor; buys, processes, and packs crab — He buys primarily from fishermen Tom Beckerton and Calvin Malloch in the Quoddy area. An LNG project could destroy his business by interrupting his supply of crab.
  11. Clifford A. Goudey, commercial fisheries, offshore aquaculture, and ocean-based renewable energy research engineer, Massachusetts Institute of Technology — “[T]he DEIS fails to consider some of the more important factors and misrepresents others.” The DEIS is deficient in addressing conflicts between commercial fishing gear and LNG transits, devastating significance of tractor tugs on fishing gear loss, and in impacts on aquaculture. The width of LNG ships would be unprecedented in Passamaquoddy Bay. Added to that would be the width of the tugs tethered to the LNG vessel. That would create a large swath of destruction to fishing gear, especially when multiple gear units are attached to a trawl line (an illustration is included). The DEIS fails to detail the “comprehensive compensation plan” to fishermen for lost gear. “[T]he DEIS is based on inaccurate assumptions and fails to adequately consider the impacts to aquaculture.”LNG transits would restrict access to the bay by aquaculture-related vessels, including towing of pens. The DEIS fails to consider water quality would be compromised by construction and propeller wash, likely impacting the health and productivity of salmon farms.
  12. Maria Recchia, Fundy North Fishermen’s Association. She works closely with Fundy Weir Fishermen’s Association, Grand Manan Fishermen’s Association, and Campobello Fishermen’s Association.— The DEIS fails to fully consider impacts on fisheries, and under-categorizes the size of the area fishery. The DEIS fails to consider that Downeast LNG’s “Fishermen Coordination and Compensation Plan” is not a real plan; and, this plan should be completed as part of the EIS process, not after the fact. The DEIS falsely claims LNG would not impact the Canadian lobster fishery. The DEIS fails to consider the severe impact from LNG tankers and tractor tugs. The DEIS fails to consider the impacts of the transiting Safety/Security Zone. While the DEIS claims some boats would receive special permission to enter the Safety/Security Zone, it fails to consider how this could be done safely. The DEIS fails to consider LNG facility and ship impacts on the herring fishery. The DEIS falsely claims Downeast LNG consulted with Fundy North Fishermen’s Association, when that has never happened. Ballast water uptake would remove larvae of many commercial species and significant feed species, harming the local fisheries. The project site is in an important lobster nursery, and would negatively affect it. The project would harm the fisheries in both Maine and New Brunswick.
  13. Shanna Ratner, Yellow Wood Associates, Inc. rural community economic development company, and author of the “Whole Bay Study” that assesses the socioeconomic impacts from LNG on the area — The DEIS analysis of direct and indirect economic impacts is incomplete and inadequate. The DEIS failed to consider impacts from support population influx — a support population greater than Robbinston, Pembroke, Perry, Pleasant Point, and potentially Eastport, combined. The DEIS, without supporting evidence, assumes construction workers would be evenly distributed throughout Washington County, when it is more likely they would cluster close to the project. The DEIS wholly fails to demonstrate adequate housing and utilities infrastructure to support the anticipated population influx. The DEIS fails to consider the impacts on tourists from the population influx and competition for facilities. The DEIS fails to show how traffic congestion would be mitigated. The DEIS fails to consider the boom and bust impact from worker population, and impacts on existing businesses. The DEIS fails to consider impacts on perception of safety among tourists, and the desire to visit the area. The DEIS fails to consider impacts on tourism related to ferry services, whale watching, traffic, changes in coastal character, and more. Emergency Reponse planning and execution costs to the affected communities, county, and state are not adequately addressed in the DEIS [Webmaster’s comment: DEIS ignores Charlotte County, Canadian communities, and Province of New Brunswick]; additional personnel and equipment are underestimated; an agreed-upon cost-sharing plan is not presented. DEIS inappropriately states local medical facilities would be adequate for handling a significant emergency. Costs for Hazard Zone school emergency plans or relocations are not addresed. Costs for affected communities’ greater school expansion and administration costs resulting from population influx is not addressed. Impacts on the Port of Eastport are not addressed. Impacts on fishing income are not addressed. DEIS hypocritically claims the project would benefit local communities by providing natural gas, while the project does not plan to distribute natural gas to local communities. “The study by the University of Maine that the DEIS relies upon to illustrate economic impacts is deeply flawed.” Loss of access to cultural areas by tribal members is not addressed.
  14. Lea Sullivan, owner, Katie’s on the Cove/Handmade Confections, and affected landowner — The US Coast Guard appears to inappropriately have authority over Canadian portions of the waterway. The DEIS incorrectly claims there are no schools or transportation infrastructure affected by the LNG ship Hazard Zones. The DEIS fails to include Mill Cove and Pulpit Rock as a local recreation area, when these features are actually important culturally, and are used by grade school classes and are a well-known tourist attraction.
  15. Linda Cross Godfrey, business owner; Elderhostel provider — Her businesses and home fall within the LNG ship Federal Hazard Zones. Her businesses rely in large part on the natural attributes surrounding Passamaquoddy Bay that would be negatively impacted by an LNG project.
  16. Vera Francis, Passamaquoddy ecologist and educator in bioregional ecology and the arts; coordinator of Nulankeyutomonen Nkihtahkomikumon; pleasure boater — LNG vessels would impede her free passage on the bay, would impede aboriginal fishing rights, and would violate her traditional life and culture. It would also potentially harm whales. She and her family use Mill Cove and Pulpit Rock as a classroom, and for cultural ceremonies. “LNG is a direct threat to the health and well being of the Passamaquoddy Nation and the rights of our descendants.”
  17. Martin “Dute” Joseph Francis, Passamaquoddy clam digger — His access to clam at Mill Cove would be affected, decreasing his income and benefit to those who depend on his clamming.
  18. David Moses Bridges, Passamaquoddy canoe builder — DeLNG would unreasonably restrict his use of traditional tribal waters his ability to safely canoe along the shore, and his ability to appreciate local wildlife.
  19. Donnell Dana, Sr, scallop, urchin, lobster, and flounder fisherman; rockweed harvester — DeLNG would reduce his ability to fish, and could negatively impact the lobster nursery in Mill Cove. An LNG facility and ships would affect herring fishing, affecting the bait-herring supply. Ballast water and engine-cooling water would hurt the fisheries. LNG may create some jobs, but it would also reduce area jobs.
  20. Chief Hugh Akagi, Passamaquoddy; science, biology, physics, chemistry, and mathematics teacher; estuarine researcher, chemist (retired), St. Andrews Biological Station; Nulankeyutomonen Nkihtahkomikumon member — DeLNG would desecrate the viewshe. Industrial noise across the water would be disturbing. The project would impact sacred tribal lands, personal safety, and the environment. His role as Chief is to help protect his people, culture, the territory, and local creatures. Area waters have suffered enough from misuse by another culture’s industries. DeLNG would keep his people from the bay — even by the use of arms. It would be an assault on the Native world and on treaty rights as a Native citizen in their own territory. Sound pollution would harm marine mammals by disorienting and frightening them, and would change breeding and migratory patterns. “To allow others ownership of what we hold in the highest regard as Natives (ancestral land, waters, tradition, culture) is to commit cultural suicide.
  21. Mary Bassett, Passamaquoddy elder — LNG ships would hurt life in the bay. She often visits Mill Cove, for its beauty, and writes in her journal. An LNG terminal there would ruin her enjoyment of the cove. DeLNG would halt the re-emergence of Mill Cove as a clamming resource. She enjoys boating, but LNG would disrupt her use of the bay; it would change the experience. An LNG terminal would make the waters less safe for Native canoers and boaters, and would ruin the annual Indian Township-to-Sipayik canoe ceremony.
  22. Madonna Soctomah, Passamaquoddy elder; past Tribal Councilor, past Joint Tribal Councilor; past Tribal Representative to the Maine Legislature — She has enjoyed unimpeded canoeing, boating, and fishing in the bay. An LNG project would eliminate safety and free use of the waterway, and would impact important ceremonies, making things out of balance. LNG would damage Native culture.
  23. “An Independent Assessment of the Downeast LNG Facility,” prepared by Howard J. Axelrod, Ph.D., Energy Strategies, Inc.“The flattening demand for natural gas in New England will result in a rise in surplus capacity, eliminating the need for added LNG capacity.; FERC has incorrectly characterized Downeast LNG as a necessary addition to the New England natural gas supply portfolio even as projections of LNG demand decline by ½ while projected LNG capacity expands; The inventory of natural gas reserves is much greater than even recently thought, thereby reducing the need to increase our reliance on foreign-derived fuels; The softening of natural gas demand in New England is matched by similar patterns in the mid-Atlantic region (see EIA 2009 Energy Outlook), freeing up pipeline capacity for added delivery to New England.”
  24. J.E.S. Venart, P.Eng., Ph., Professor Emeritus of Mechanical Engineering, University of New Brunswick; researcher of fires and explosions — FERC inappropriately dismisses potential hazard of unconfined vapor explosions, as even researchers have reported and as published by Sandia National Laboratories; safe fire-radiation zones are under-calculated in the DEIS; the DEIS fails to consider knock-on events and consequences to LNG terminal, berthing facilities, ship, and the public; thermal flux calculations reported in the DEIS undercalculate actual consequences. Some standards used have not been verified as correct or have been misapplied. (Computer vapor, fire dispersion, and thermal flux modelling illustrations are included.)
  25. Clifford A. Goudey, BS in Mathematics, MS in Naval Architecture and Marine Engineering, MS in Mechanical Engineering; commercial fisheries and aquaculture research engineer, MIT — Distortion by LNG project proponents about many qualities of LNG was not addressed in the DEIS. Such distortion examples include LNG vapor as rising harmlessly into the air (when it actually hugs the ground), having a narrow flammability range (when the flammability range is actually the broadest of common hydrocarbon fuels), having a lower energy density (true, based on volume, but false based on weight); FERC-allowed DEIS calculations of hazards are disputed by experts; knock-on impacts from an incident are ignored; the calculated terminal Exclusion Zone would result in not preventing harm to civilians outside the facility fenceline. In fact, the danger zone to humans extends nearly 4 miles from a ship at the facility. (Illustrations are provided.) The DEIS likened navigation for the proposed location to other existing LNG facility waterways, failing to consider the unique hazards of navigation (such as sharp rocky outcroppings) along the actual proposed transit route and the unique associated risks (illustrations are included). Also, the navigation simulation that was conducted does not evidence actual conditions in the transit area, and actually indicates necessary data were absent. Mr. Goudey’s presentation to the Maine Board of Environmental Protection, “An Assessment of LNG Risks to Passamaquoddy Bay,” is included. The navigation simulation under-accounted by around 50% the actual speed of tidal currents in the waterway. The simulation report “fails to provide sufficient information to support its conclusions regarding the adequacy of the waterway for the purpose suggested.” The simulation report is critically flawed from lack of data, inconsistencies, false assumptions, and with improper inputs.

Information: FILE LIST

Jul 10

Filed By: INDIVIDUAL [Mike Footer]
Filed Date: 7/7/2009
Accession No: 20090709-0267
Description: Comments of Mike Footer re Downeast LNG's project under CP07-52 et al.

Summary: Mr. Footer doesn’t agree with SPB’s request to expand the Comment Period, claiming it is an unreasonable attempt to waste time.

Information: FILE LIST

Filed By: US Army Corps of Engineers, New England District
Filed Date: 7/10/2009
Accession No: 20090710-5007
Description: Comments of Corps of Engineers, New England District under CP07-52.

Summary: The DEIS contains numerous shortcomings, including: “[I]t appears to only note the applicant's stated purpose without conveying FERC's position.” “The Corps encourages that alternatives be analyzed and dismissed in accordance with the Section 404(b)(1) Guidelines, not with the terms ‘reasonable’ or ‘unreasonable.’” Reasonable alternatives, including Canaport, were inappropriately dismissed. The DEIS inappropriately used DeLNG’s objectives — rather than the actual purpose — as the standard. Questions are left unanswered. The impacts from expanding Maritimes & Northeast Pipeline (M&NE) need to be taken into account. Cumulative impacts were insufficiently covered. All M&NE permits should be obtained before allowing construction.

Information: FILE LIST

Filed By: Downeast Pipeline, LLC
Downeast Pipeline, LLC
Downeast LNG, Inc.
Downeast LNG, Inc.
Filed Date: 7/10/2009
Accession No: 20090710-5103
Description: Downeast LNG, Inc., and Downeast Pipeline, LLC (“Downeast LNG”) submits its Responses to DEIS Conditions under CP07-52, et al.

Summary: DeLNG provides to FERC information required by the end of the DEIS Comment Period, including: M&NE Pipeline expansion information; however, capacity is not addressed. Ground motion analyses. Horizontal Directional Drilling plans; however, it is not final, and cannot be completed until Maine BEP permitting is completed. Construction timing cannot be completed until Maine BEP permitting. DeLNG is still revising air emissions calculations for CO2, CH4, and N2O. DeLNG claims it was impossible for DeLNG to complete cumulative air impact analysis in the timeframe requested, requiring an additional 2–3 months, or more.

The requirement to demonstrate the vapor dispersion exclusion zone remains within areas of legal control by DeLNG is being withheld from the public as “privileged and confidential” business and design information.

Webmaster’s Comments: It is hypocritical that there was such a hue and cry by Downeast LNG (Jun 18 DeLNG filing) and its supporters against Save Passamaquoddy Bay’s request for an expanded Comment Period, when Downeast LNG, itself, then proceeded to unilaterally violate FERC’s deadline — by over a year. That is how long State of Maine permitting would take once it started. Even if ignoring the State permitting, Downeast LNG instructed FERC that it will be taking 2–3 additional months, or more, to complete the required cumulative air impact analysis that was due on Jul 6.
Downeast LNG has demonstrated its disregard for the public and the FERC process, while FERC has demonstrated it favors developers, rather than the public interest.

Information: FILE LIST

Filed By: Downeast Pipeline, LLC
Downeast Pipeline, LLC
Downeast LNG, Inc.
Downeast LNG, Inc.

Filed Date: 7/10/2009
Accession No: 20090710-5104
Description: Downeast LNG, Inc., and Downeast Pipeline, LLC ("Downeast LNG") submits its Responses to DEIS Conditions under CP07-52, et al.

Summary: [Privileged, not released to the public].

Information: FILE LIST [Downloading will result in a file indicating a error occurred.]

Jul 14

Filed By: INDIVIDUAL [Gerald Morrison]
Filed Date: 7/8/2009
Accession No: 20090714-0018
Description: Comments of Gerald S Morrison expressing concerns re Downeast LNG, Inc's project under CP07-52 et al.

Summary: Mr. Morrison includes pages from the Washington County Council of Governments’ Perry and Pembroke Survey, in an attempt to refute July 7 comments by Jeanne Guisinger.

Information: FILE LIST

Filed Date: 7/13/2009
Accession No: 20090714-0014
Description: Town of St Andrews submits comments re its objection to the proposed construction of a LNG facility in Passamaquoddy Bay under CP07-52 et al.

Summary: St. Andrews substantiates many of the financial costs to the town if Downeast LNG were to construct — a $200,000 annual increase for a Hazardous Material Response Team; $700,000 for an additional water reservoir for fire protection; $500,000 additional annually for fire, police, and emergency services; plus, $millions in equipment requirements. There would be a drop in property values and associated loss in property tax revenue. The town’s multi-million dollar tourism-based economy would suffer. There would be a diminshed desire by professional services to locate in the town. The area standard of living would decline.

Information: FILE LIST

Jul 15

Filed By: Town of Perry [Originally appearing to be submitted ANONYMOUSLY. See Summary, below.]
Filed Date: 7/14/2009
Accession No: 20090715-0092
Description: Comments of Town of Perry re LNG under CP07-52 et al.

Summary: The original FERC Docket file omitted the signature page that had been included with the filing. After questioning, FERC corrected the omission; however, the Selectmen’s signatures still do not make the filing a legitimate representation of the Town of Perry, since that would require a town vote

Information: FILE LIST

Filed By: Embassy of Canada
Filed Date: 7/7/2009
Accession No: 20090715-0157
Description: Comments of Ambassador of Canada Michael Wilson re the development of liquefied natural gas terminals in North America etc under CP07-52.

Summary: Ambassador Wilson writes to FERC Chairman Wellinghoff…

  1. Citing FERC’s Draft EIS requirement, Downeast LNG must obtain Canada’s cooperation to transit into Passamaquoddy Bay.
  2. Chairman Wellinghoff should advise Downeast LNG to withdraw their applications, since Canada will not allow the LNG transits into Passamaquoddy Bay.

In addition, an internal FERC memo is included (apparently by mistake) that attempts to minimize Canada’s letter to Chairman Wellinghoff.

Information: FILE LIST [This filing has been removed by FERC, and replaced by 20090707-4003, below.]

Webmaster’s Comments: To read the original posting, download the PDF file — 20090715-0157(22096282).pdf — (from the Save Passamaquoddy Bay webserver).

Jul 17

Filed Date: 7/7/2009
Accession No: 20090707-4003
Description: The Government of Canada provides comments on the development of liquefied natural gas terminals in North America etc under CP07-52. (This replaces 20090715-0157)

Webmaster’s Comments: FERC apparently doesn’t want the public or Government of Canada to read the memo minimizing Canada’s letter that was attached to the original Docket posting, 20090715-0157 above.

Download the original PDF posting to the Docket (from the Save Passamaquoddy Bay webserver).

Information: FILE LIST

Jul 21

Filed By: City of Eastport, Maine
Filed Date: 7/21/2009
Accession No: 20090721-5050
Description: Notice of Withdrawal of Comments of City of Eastport, Maine to the Draft Environmental Impact Statement for the Proposed Downeast LNG Project under CP07-52, et. al.

Webmaster’s Comments: The Eastport City Council, at a 2009 July 20 special Workshop on the 2009 July 6 Comments on the DeLNG DEIS issue, voted to withdraw the Comments, since the Comments had been submitted by the Council Chairman without conferring with, or agreement from, the City Council.

Withdrawal does not diminish the validity of those July 6 Comments.

Information: FILE LIST

Jul 27

Filed By: Save Passamaquoddy Bay
Filed Date: 7/27/2009
Accession No: 20090727-5009
Description: Comments of Save Passamaquoddy Bay on Downeast LNG's Failure to meet FERC Comment Deadline for Draft EIS under CP07-52.

Webmaster’s Comments: Downeast LNG abused the FERC Comment Deadline, and anticipates not providing answers to FERC information requests that were due on 2009 July 6 for around another year. Therefore — like the action FERC took when Quoddy Bay LNG did not answer FERC’s questions for a year — FERC should dismiss Downeast LNG from the permitting process. Otherwise, FERC should craft another DEIS that includes the FERC-required information that Downeast LNG failed to supply by the Deadline; accordingly, FERC should reschedule the Final DEIS and the Commission’s permitting decision.

Information: FILE LIST


Add our banner to your webpage: Save Passamaquoddy Bay

Read about the effort to Fix FERC: FixFERC

Spam Harvester Protection Network
provided by Unspam