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ROOSEVELT CAMPOBELLO INTERNATIONAL PARK
Statement Regarding the Proposed LNG Terminal Introduction This statement is respectfully submitted by the Roosevelt Campobello International Park Commission to the governments of Canada and the United States of America in connection with and in opposition to the proposed development of a liquid natural gas (“LNG”) treatment and transshipment facility to be located on lands owned by the Passamaquoddy (Sipayik) tribe at Pleasant Point, Maine, USA, immediately adjacent to the international border with Canada. Background The Roosevelt Campobello International Park and its Commission were established in 1964 by treaty between the United States and Canada, and implemented by authorizing legislation in each country. The Park is governed by a Commission consisting of equal numbers of Canadians and Americans, appointed by the respective heads of state of each country. Located on Campobello Island, New Brunswick, Canada, near the border with Lubec, Maine, U.S.A., and connected to Lubec by an International Bridge dedicated in 1962, the Park’s main attraction is the historic summer home of U.S. President Franklin Delano Roosevelt (FDR), who vacationed on Campobello with his family over a period of 56 years (1883-1939). On average, approximately 130,000 people visit the Park between May and October (when Park facilities are open), with approximately 150,000 visitors annually. The Park was created to commemorate FDR and as a symbol of friendship between the U.S. and Canada. It encompasses an area of 2,800 acres/1,120 hectares that provides a natural setting for the Roosevelt Cottage and an historic summer-cottage district. The district includes four other turn-of-the-century cottages, which are used by the Park as a governmental/academic Conference Center. The setting of coastal headlands, rocky shores, wetlands, fields, and forest offers a variety of naturalhabitats, and there are numerous trails, drives, overlooks, and picnic areas for visitors to explore and enjoy. Herring Cove Provincial Park, adjacent to the north, offers 730 acres/290 hectares for recreation. The two parks occupy the southern one-third of Campobello Island; the northern twothirds of the island are privately owned, with the northern and western shoreline being primarily residential. Most of the two-thirds remain undeveloped. The Park is a major tourist attraction in the Province of New Brunswick. Most of the people visitingthe Park enjoy the spectacular unbroken views of rugged coastline, estuarine bays and open ocean, often the main purpose of their trip to the area. Many also enjoy watching waterfowl and seabirdsand/or hiking to enjoy the scenic views from several locations along the trails and roadways of the Park. Tourism dollars attracted to the Park and the immediate area have a significant and positive “ripple” effect on the economic health of the area. The Roosevelt Campobello International Park employs approximately 53 full-time and part-time or seasonal employees, about equally divided between citizens of Canada and the United States. The contribution of this payroll to the economic health of the communities of Campobello Island and Lubec is significant. The purpose and mission of the Park and its Commission are to memorialize FDR and to protect andenhance for current and future generations these irreplaceable and valuable historic, cultural and natural resources that both Canada and the United States have found worthy of protection and preservation in the national interests of both nations. Issues of Importance to The Park, Its Mission and Its Resources The Roosevelt Campobello International Park and its Commission have grave concerns regarding the proposed development of an LNG terminal to be located on Passamaquoddy (Sipayik) Tribal lands at Pleasant Point. These lands are adjacent to the communities of Eastport and Perry, Maine and abut the “Western Passage” leading to Passamaquoddy Bay and the international boundarybetween Pleasant Point and Moose Island, Maine, on the U.S. side, and Deer Island, New Brunswick, on the Canadian side. Our concerns relate to the following subjects. SAFETY OF TRANSPORT OF LNG The safety of the transport of LNG on international and Canadian waterways and navigable routes immediately abutting or adjacent to the Park and to virtually all areas on Campobello Island’s northern and western shores is of critical importance. Using a figure of 500 yards (1,500 feet) as the minimum thermal radiation danger zone for spills, fires and explosions of an LNG tanker (the tankers themselves range in size from 900 ft to more than 1,100 ft), there are significant areas of Campobello Island, including residential areas, substantial portions of the Park and the historic district within the Park, that would be immediately, dramatically and devastatingly involved. It is clear from analyzing the various safety reports available from both U.S. Federal sources and private independent institutions that the heat alone from any fire or explosion involving an LNG tanker in transit to or from the proposed terminal would immediately render to ashes much of the shoreline vegetation and structures on northern and western Campobello Island, the Island’s most populated areas, including the Park’s shoreline buildings and the historic Roosevelt cottage. The pressurewave of any explosion of any large LNG tanker has been compared to be the equal of 55 Hiroshima nuclear bombs. Injuries and deaths to humans would clearly be involved, and the substantiality of those losses would be somewhat dependent on in which season the critical event occurred. These risks are simply unacceptable to the Roosevelt Campobello International Park and would completely betray the dual national commitments and investments of the two countries to preserve and protect the Park’s historic and natural resources. The only transit route available and possible for the 900 ft to 1,100 ft LNG tankers from the open ocean and the Bay of Fundy to the proposed LNG terminal at Pleasant Point would be throughCanadian waters, passing around the northern end of Campobello Island and Head Harbor, then taking several modest left turns to run south - southwest down through the narrow Head Harbor Passage, and then a sharp turn to the northwest before Eastport, Maine, to head up Western Passage. Until the sharp turn to the northwest to go up Western Passage, the entire “inland” route is in Canadian waters. After that sharp turn, the route would be along the international boundary between Canada and the United States. In several areas along this route, the navigational passage is less than a mile wide, narrower in some instances, and the tankers transiting these areas will be up to one fifth of a mile long. Furthermore, these waters are world-renowned for dramatic tides, both in height and current speeds, and for frequent fog that reduces visibility to zero on many occasions. The area immediately between Moose Island (Eastport) and Deer Island has several large whirlpoolsincluding a well-known, major whirlpool named the “Old Sow.” Taking the route all together withthe attendant physical, tidal, current and fog limitations, this proposal poses risks that are of such proportions and degrees as to make the safe transport of LNG in tankers to Pleasant Point impossible. PRECEDENT Such a conclusion relating to these waters is not only prudent, given all the information available, it is fully consistent with past judgements of both the Canadian and United States governments relating to an oil refinery and transshipment facility proposal that was posed in the 1970's. As concluded by the U.S. Department of Transportation in its 1976 study on the Pittston ship terminal proposal, “The degree of navigational risk associated with the continuous year-round supply of crudeoil and product distribution from the [proposed] refinery poses a serious threat to the ecology of the region.... While highly sophisticated aids to navigation can certainly increase thenavigator’s awareness of track and heading deviations, it should be emphasized that even with massive dredging the approaches to Eastport would remain‘winding,’ the currents‘extremely difficult to judge’ and weather conditions cannot as yet be controlled. In consequence, the riskof pollution remains high and is environmentally unacceptable.” (Emphasis added.) Unfortunately, in the present situation we are talking about significantly greater impacts than “mere” pollution. The position of the Canadian government has been stated publicly in Notes and letters on at least five occasions between 1973 and 1981. The conclusion has consistently been that “a large scale movement of pollutants in an area unsuited to such traffic, ... would place at risk the economy, the environment, indeed the way of life of Canadians in the Passamaquoddy area, and a part of the natural heritage of all Canadians.” The Roosevelt Campobello International Park Commission fully agreed with and supported this position of the Canadian government at that time. This LNG proposal creates even greater risks, andeconomic and environmental concerns are even greater today. Although the species sought havechanged since the 1970s, fishing for lobster, herring, sea urchins, soft-shelled clams, periwinkles, mussels, scallops, and sea cumbers is of vital economic significance to the local and traditional economy, as is the fish and shellfish aquaculture industry. All such fisheries would be threatened. OTHER ECONOMIC AND COMMERCIAL ACTIVITIES IMPACTED It is clear from the limited information available that the proposed terminal facility would have to be constructed out into or verging on the regular shipping channel between Deer Island and the U.S. mainland, thus obstructing or interfering with local ship and boat traffic as well as ocean going vessels traveling to Bayside Port in the St. Croix River. These are frequent and include large bulkcarriers and ocean going freighters carrying frozen fish from the Baring Sea, potatoes to Cuba and other bulk products. It should be noted that there is a strong likelihood that all boat, fishing and ship traffic from beyond Head Harbor on Campobello Island to and including the area of the proposed LNG terminal would be completely shut down and excluded from the area at any time when an LNG delivery was expected. That alone would have significantly disruptive and negative effects on the local and regional economy and all marine related commercial and recreational activities. It should be noted that in a number of ports around the United States it is already standard practice and required Federal and local procedure to exclude all traffic from shipping lanes and adjacent areas and to shut down all port activities when LNG tanker traffic is scheduled. DIRECT THREATS TO CAMPOBELLO ISLAND AND THE PARK With regard to the route of passage of LNG tankers from the open ocean to the proposed terminal, it should be noted that at several points in such a tanker’s passage along the Campobello Island northern and western coasts, the tanker’s proximity to shore (and established residential areas) would be, in some instances, less distance than the length of the tanker itself (distance 1,056 feet; tanker length 1,000 feet), and generally far less than a mile. From the Park’s resources (and assuming that an LNG tanker would keep to the preferred or recommended shipping lane), the distance would be only slightly more than 2 miles (12,408 feet), a distance that would place the Park’s historic and natural resources well within the zone of certain damage from an explosion and virtually certain harm from the heat of a fire. Given the highly flammable nature of much of the natural forest covering much of Campobello Island and the extremely modest emergency response capabilities of the entire area, especially in terms of fire response capabilities, it should be taken as a given that any LNG tanker fire or explosion anywhere along the Campobello Island coast would (a) involve an extensive, raging fire on the Island itself (which is a virtual certainty given the closeproximity of the LNG tanker routes to the Island), and (b) an almost impossible task of saving any structures or property on large portions of the Island. If a flammable vapor cloud were to be released in an LNG tanker accident anywhere proximate to the Island, the drift zone could encompass significant portions of Campobello Island, including the Park. If the cloud subsequentlyencountered an ignition source (a virtual certainty), those portions of the cloud with a combustible gas-air concentration would burn. CONCLUSION It is certain that if any “accident” were to take place, whether by mechanical failure, human oversight or error, or due to terrorism, the results would be catastrophic and devastatingly compounded by the absence in this remote area of Canada and Maine of both trained personnel and proper response equipment necessary to fight either explosion or fire or to treat the likely number of human burns and injuries. In the words of Franklin D. Roosevelt, Jr., alternately a chairman or vice chairman of the Roosevelt Campobello International Park Commission at the time of the Pittston oil transshipment and refinery proposal, the Commission, “...is responsible to the Governments of the United States and Canada for the maintenance and protection of the Roosevelt Campobello cottage as a memorial to President Roosevelt and as a symbol of international friendship between our two countries. It is also responsible for thepreservation and protection of some 2,600 acres [actually 2,800 acres] of natural areas, including extensive shorelines, on Campobello Island.” Because of these obligations and the responsibilities of the Commission, placed on the Commission by treaty as well as by the respective enabling legislation in both countries, the Commission opposes the location of an LNG terminal at Pleasant Point or any area in the vicinity of Campobello Island that would require the transport of LNG through Head Harbor Passage or any area proximate to Campobello Island. The Commission respectfully requests both the United States and Canada thoroughly review boththe proposed location of this LNG facility and the route of passage required for LNG tankers toreach the proposed facility at Pleasant Point. We would specifically and urgently recommend that the Canadian government reiterate its stated policy against the movement of tankers through Head Harbor Passage and its considered position (at the time of the Pittston proposal) that “Canada views the waters concerned as‘internal waters’ and therefore not subject to limitations of sovereign action, such as might be implied by the doctrine of ‘freedom of innocent passage.’” Respectfully submitted, The Roosevelt Campobello International Park Commission (Unanimously adopted at the Commission’s March 2005 meeting, with one Alternate Commissioner not participating.) |
