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FERC eLibrary
Calais LNG Project Company LLC Proposal
Pre-Filing Comment Filings List
2009 January
Docket Number PF08-24
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 Jan
NOTE: The bold Year Month Date (e.g., 2009 Jan 5) headings below are the dates the filings appeared on the FERC eLibrary Docket, but not necessarily the dates the comments were actually submitted or received by FERC.
To help users find the most recently-posted comments, we display the filings by date of appearance on the Docket, not by date filed or date accessioned. FERC's eLibrary displays comments by date filed, rather than by date posted to the eLibrary Docket; therefore, newly-posted comments in FERC's online eLibrary Docket List may appear in places other than at the end of the list.
2009 Jan 5
Filed By: BAILEYVILLE, TOWN OF (ME) [Baileyville Utilities District]
Filed Date: 12/29/2008
Accession No: 220081231-0269
Description: Comments of Baileyville Utilities expressing concerns re the Calais LNG Project under PF08-24. [Brief Summary & Comments: The Utilities District opposes Calais LNG's proposed natural gas pipeline route, since it could compromise the town's water supply.]
Information: FILE LIST
or Immediately Download theFERC PDF file (629.56 KB).
Filed By: CALAIS LNG PROJECT COMPANY, LLC
Filed Date: 12/23/2008
Accession No: 20090102-0043 [Webmaster's Comments: The Accession Number appears to be an error. The individual files indicate the following Accession No.: 20090102-0042]
Description: Calais LNG Project Company LLC submits draft Resource Reports 1 - 4 etc under PF08-24.
[SPB Summary: Submitted are Resource Reports…
- 1 (General Project Description);
- 2 (Water Use and Quality);
- 4 (Cultural Resources)
- 3 (Fish, Wildlife, and Vegetation);
- 6 (Geologic Resources);
- 7 (Soils);
- 8 (Land Use, Recreation and Aesthetics);
- 9 (Air and Noise Quality);
- 10 (Alternatives); and
- 12 (PCB Contamination).
Some files are Non-Public; however, none of the listed files actually appeared in this filing.]
Information: FILE LIST
or Immediately Download theFiled By: Calais LNG Project Company, LLC
Filed Date: 1/5/2009
Accession No: 20090105-5079
Description: Calais LNG Project Company LLC Responses to Comments Field during the Pre-filing Scoping Period under PF08-24. [Summary: Calais LNG responds to Scoping Comments. Responses include:,
- They claim endangered species would not be significantly affected;
- They claim emissions from the Terminal Site sources will not cause or contribute to exceeding ambient air quality standards and will not exceed the thresholds established for preventing the significant deterioration of air quality in the region;
- They claim drinking water will not be affected;
- They claim that taking on ballast water will have only a minor negative effect on local species populations, even though they're still doing studies regarding this issue;
- They admit wetlands and vernal pools would be affected. They say they intend to minimize and mitigate the effects;
- They claim the negative socioeconomic impacts from their project can be adequately mitigated as indicated in the study they had done by the Maine Center for Business and Economic Research and the University of Southern Maine.
- They claim, "Available existing resources are adequate to accommodate the project without harmful effects to the local economy." [Observation: This claim is specious, especially regarding Emergency Management issues. The FERC-required area Emergency Response Plan isn't completed until after FERC issues a permit to construct; thus, no one knows what the actual Emergency Management responsibilities and economic costs would be to area communities or local and state taxpayers at this time. For instance, what would be the costs of building — and the ongoing operations of — a local major burn-treatment hospital? (There is no hospital within one hour of this area that has such a facility or even enough beds for such a facility.) But, Calais LNG claims in this filing, "Local, county, and state public safety resources should be more than sufficient."];
- They claim minor impact would occur on fishing, even though they're still studying that issue. They claim LNG transits would have "no measurable impacts on fishing boats or other uses of the waterway for shipping," and "the studies of impact on local fisheries and fishing gear determine there is no measurable impact."
- They claim the aesthetic impacts of the terminal would be "acceptable." They claim, "Safety is a core commitment of Calais LNG." [Observation: And yet, they propose a terminal site and ship transit lane that cannot be made to conform with world LNG industry terminal siting best practices as published in 1997 by the Society of International Gas Tanker and Terminal Operators (SIGTTO) in "Site Selection and Design for LNG Ports and Jetties." (See LNG Terminal Siting Standards Organization for an abbreviated list of the industry's terminal siting best practices.)];
- "The Coast Guard will make its own determination as to the suitability of the waterways for the proposed Project from a safety and security standpoint, and its determination will be reflected in a public document to be issued once the Commission and the Coast Guard have concluded their comprehensive Environmental Impact Statement with respect to the Project." [Observation: In other words, Calais LNG cannot claim waterway suitability or that the route and terminal location can be secured. Security along the transit route cannot be assured since Canada prohibits LNG transits and will not cooperate in security of the proposed LNG carriers through Canadian waters. Just as the United States has the authority to determine suitability of a US waterway for LNG transit (and the authority to deny LNG transits), Canada likewise has the sovereign authority to make those same decisions for its own waters. Canada has already made that determination, with a decision that is in keeping with world LNG industry terminal siting standards— the waterway is not suitable and Canada is prohibiting LNG transits into Passamaquoddy Bay.];
- They claim "a compelling need for natural gas in the New England market area." They state, "The overarching need for competitively priced [emphasis added] natural gas to meet peak demands in New England has three principal bases: (1) New England has the most expensive natural gas in the country, which translates into higher electricity prices; (2) reliable natural gas supply is constrained by pipeline congestion; and (3) New England lacks sufficient local natural gas production and storage." [Observations: Yes, there's a need, but that needis already being met into the future. Also, LNG is more expensive than domestic natural gas. In other words, Calais LNG wants to increase the price of natural gas (or, at least, to keep it high) in New England, with Calais LNG reaping the profit from that higher price to be paid by New England residents and businesses.];
Calais LNG also claims, "floating storage and regasification units are not feasible in many of the rough waters of Northern New England, including the Gulf of Maine, Grand Manan, and the Bay of Fundy." [Observations: This is a case of "blowing smoke" to obscure reality. Offshore regasification (based on technology used successfully for decades by the oil industry in the North Sea and elsewhere) already in place in the Gulf of Mexico (Gulf Gateway Deep Water Port) have shown that even Hurricane Katrina didn't prevent regasification of an entire ship's LNG cargo during that storm. Calais LNG ignores the two offshore LNG receiving facilites — one already in operation (Northeast Gateway Deepwater Port), the other (Neptune LNG Deepwater Port) to be completed by the end of this year — in the Gulf of Maine off Gloucester, Massachusetts. Offshore submerged-buoy technology more easily handles rough seas than does shoreside receiving technology, and with less risk. Further, LNG storage is more flexible (can be moved to locations with greater need) when on ships designed for that purpose, as is used and advocated by Excelerate Energy, masterminds of the Gulf Gateway and Northeast Gateway LNG facilities]; and, finally- They claim, "the extensive assessments undertaken to date indicate that the Project is unlikely to have any significant additional physical or visual impact [emphasis added] on culturally or historically significant resources in the vicinity of the Terminal Site or along the Preferred Pipeline Route." [Observation: Using the Port of Bayside as an excuse for Calais LNG approximately doubles the impact — a significant cumulative impact.]
Information: FILE LIST
or Immediately Download the
Filed By: INDIVIDUAL [Diane Barnes, City Manager, City of Calais]
Filed Date: 12/15/2008 [NOTE: Document is dated November 19, 2008, was filed with FERC on December 15, 2008, but was accessioned and posted to the Docket on January 6, 2009. It appears on the FERC Docket under December 15, 2008.]
Accession No: 20090106-0279
Description: Comments of Diane Barnes re the Calais LNG Project that is being proposed for Washington County under PF08-24. [Summary: Employment and conomic reasons for support.]
Information: FILE LIST
or Immediately Download theFiled By: INDIVIDUAL [Jim Porter, Assistant Manager, City of Calais]
Filed Date: 12/15/2008 [NOTE: Document is dated December 4, 2008, was filed with FERC on December 6, 2008, but was accessioned and posted to the Docket on January 6, 2009. It appears on the FERC Docket under December 15, 2008.]
Accession No: 20090106-0280
Description: Comments of Kim [stet; "Jim"] Porter re Calais LNG Project under PF08-24. [Summary: Employment and economic reasons, plus "convenient availability of natural gas" for support.]
[Comment: The availability of natural gas has existed for years via the Maritimes & Northeast Pipeline if Calais were seriously interested in accessing it.]
Information: FILE LIST
or Immediately Download theFiled By: CITY OF CALAIS [Mayor Vinton Cassidy]
Filed Date: 12/6/2008 [NOTE: Document is dated December 4, 2008, was filed with FERC on December 6, 2008, but was accessioned and posted to the Docket on December 15, 2008. It appears on the FERC Docket under December 15, 2008.]
Accession No: 20090106-0281
Description: Comments of Calais City Council re Calais LNG project under PF08-24. [Summary: He cites employment, more efficient and cleaner fuel, economic benefit, and availability of natural gas. Also, Calais will be prepared to train for and respond to any emergency incidents. They "believe in the safety of LNG."]
[SPB Webmaster Comments:
- The net economic impact from Calais LNG would be negative, according to The Whole Bay Study;
- Natural gas has been available to Calais for some years, if they had an interest in accessing it.
- How could Calais know what it would cost taxpayers to train the city's Emergency Responders, since the Emergency Response Plan wouldn't be developed until after FERC were to issue a permit?
- Why would the City of Calais "believe in the safety" of the proposed LNG terminal when its siting violates world LNG industry safe siting standards (per the SIGTTO publication "Site Selection and Design for LNG Ports and Jetties")? (See LNG Terminal Siting Standards Organization for an abbreviated list of those standards.]
Information: FILE LIST
or Immediately Download theFiled By: THREE NATION ALLIANCE [SAVE PASSAMAQUODDY BAY]
Filed Date: 12/3/2008 [NOTE: This set of documents was hand-delivered to the FERC representative at the Scoping Session on December 4, 2008, but FERC indicates the Filed Date as December 3. It was posted to the FERC online Docket on January 6, 2009. It appears on the FERC Docket under December 3, 2008.]
Accession No: 20081203-4023
Description: Three Nation Alliance's CD containing relevant BEP testimony under PF08-24.
[Summary: Comments consist of the 2007 July Maine Board of Environmental Protection hearing testimony from the following: Hugh Akagi, Chief of Passamaquoddy People in Canada; David Moses Bridges, Passamaquoddy tribal member; Laurence Cook, Grand Manan fisherman; Donnell Dana, Sr., Perry fisherman; James A. Fay, Ph.D., Professor Emeritus of Mechanical Engineering at MIT; Martin "Dute" Francis, Passamaquoddy tribal member and clam digger; Vera Francis, Passamaquoddy tribal member, ecologist, educator, and coordinator of Nulankeyutomonen Nkihtahkomikumon ("We Take Care of Our Land"); Linda Godfrey, Eastport and Campobello Island business person, and coordinator of Save Passamaquoddy Bay 3-Nation Alliance; Robert A. Godfrey, Eastport business owner and webmaster for Save Passamaquoddy Bay 3-Nation Alliance; Clifford Goudey, naval architect and research engineer at MIT; Brent R. Griffin, Eastport-to-Cutler fisherman; Dale Griffin, lobsterman in Eastport and logger; Lars Lund, retired Master Mariner; Angus McPhail, US lobster fisherman in Grand Manan Channel; Maria Recchia, staff of Fundy North Fishermen's Association, also representing Fundy Weir Fishermen's Association, Grand Manan Fishermen's Association, and Campobello Fishermen's Association; Fred Whoriskey, Vice President for Research and Environment of the Atlantic Salmon Federation; and Shanna Ratner, agricultural economist and principal of Yellow Wood Associates, authors of "The Whole Bay Study" "(Summary of Potential Economic and Fiscal Impacts on the Passamaquoddy Bay Region of an LNG Import Terminal").]
Information: FILE LIST
or Immediately Download theFiled By:
MAINE, STATE OF(sic; corrected by FERC on Jan 7) INDIVIDUAL [Former Maine State Senator Harold Silverman]
Filed Date: 12/15/2008 [Note: This document is dated December 4, 2008, was accessioned December 15, but didn't appear on the FERC Docket until January 6, 2009. It is filed on the FERC Docket under December 15, 2009.]
Accession No: 20090106-0283]
Description:Maine State Senator(sic; corrected by FERC on Jan 7) Former Maine State Senator Harold L Silverman submits comments re the Calais LNG Facility under PF08-24..
[Summary: [NOTE: Harold Silverman is not a state senator, although by the way he filed his comments he seems to believe he represents the entire State of Maine. On January 7, 2009, FERC edited Silverman's "Filed By" and "Description" entries to correct Silverman's misrepresentations in the filing.] His comments relate to jobs and economy; he claims the LNG facility and LNG transport would provide a low-cost, safe, alternate source of energy. He also claims the LNG industry has spent millions on research to make LNG safe and environmentally sound. SPB Webmaster's Comment:Silverman wrongly implies that his comments are from the State of Maine. He ignores the LNG industry's own safety guidance that Calais LNG's site selection violates — the same guidance that cost the industry some of the dollars that Silverman mentions.]
Information: FILE LIST
or Immediately Download theFiled By: ROOSEVELT CAMPOBELLO INTERNATIONAL PARK COMMISSION
]
Filed Date: 12/15/2008 [Note: This record did not appear on the FERC Docket until January 6, 2009. It is filed in the Docket under December 15, 2008.]
Accession No: 20090106-0282
Description: Roosevelt Campobello International Park Commission submits comments re Calais LNG Project under PF08-24..
[Summary: The Park expresses grave concerns regarding this project, particularly about degradation of air quality and potential water pollution. Concerns are expressed re LNG transport safety and risk of potential death, damage, and injury due to thermal impacts on Campobello Island, residents, Park visitors, and the Park's historic structures; re the lack of Emergency Response preparedness and infrastructure; re the cascading negative economic impact the LNG project would bring to area toursim; and re interruptions to essential ferry transport. The Park also mentions the international treaty of binidnig responsibility to protect the Park.
Information: FILE LIST
or Immediately Download theFiled By: INDIVIDUAL [Former US Assistant Surgeon General Brian W. Flynn]
Filed Date: 12/15/2008 [Note: This filing was submitted by hand at the December 4, 2008, FERC Scoping Session, was not filed by FERC until December 15, and wasn't accessioned and did not appear on the FERC Docket until January 6, 2009. It appears on the Docket under December 15, 2008.]
Accession No: 20090106-0284
Description: Comments of RADM Brian W Flynn re Calais LNG Project under PF08-24.
[Summary: Considerable detail is provided on the requirement for emergency preparedness, and how the Calais LNG project is exceptionally complicated by the need for international emergency cooperation and preparedness. Two papers are presented on health care in the case of a mass-casualty LNG incident. Details are provided about scope of injuries to be anticipated, and the medical response requirements for such an event. The closest Level 1 Trauma Center (with only 12 burn beds) in Maine is in Portland, with the closest New Brunswick Level 1 Trauma Center being in Saint John. Flynn asks how FERC weighs adequacy of state and local emergency capacity in the permit decision process. Many other cogent questions are asked about the FERC decisionmaking process as it relates to emergency response and treatment that would be required on both sides of the international border.]
Information: FILE LIST
or Immediately Download theFiled By: THREE NATION ALLIANCE [SAVE PASSAMAQUODDY BAY]
Filed Date: 12/13/2008 [Note: This document was prepared on December 3, 2008, and manually submitted on December 4, 2008, to FERC personnel at the Scoping Session in Calais; however, it was filed by FERC on December 13, and not accessioned or posted to the Docket until January 6, 2009. It appears on the FERC Docket under December 13, 2008.]
Accession No: 20090106-0286
Description: Three Nation Alliance submits comments on the scoping stage of the Calais LNG Project Company, LLC import and storage terminal etc under PF08-24.
[Summary: The LNG transit route for Calais LNG would be identical to the previous two are LNG proposals, with the additional transit up the narrow St. Croix River. Canada prohibits LNG transits into Passamaquoddy Bay and up the St. Croix River. The project is incompatible with existing uses of the waterway, including rights of Passamaquoddy Tribal fishermen. Numerous negative impacts would impinge on the environment and area conservation areas and parks as well as on residents' quality of life.]
Information: FILE LIST
or Immediately Download theFiled By: SAVE PASSAMAQUODDY BAY
Filed Date: 12/15/2008 [Note: This filing was manually submitted on December 4, 2008, to FERC personnel at the Scoping Session in Calais; however, it was filed by FERC on December 15, and not accessioned or posted to the Docket until January 6, 2009. It appears on the FERC Docket under December 15, 2008.]
Accession No: 20090106-0285
Description: Save Passamaquoddy Bay submits comments re a Report on Potential Economic and Fiscal Impacts of LNG Terminals on the Whole Passamaquoddy Bay under PF08-24.
[Summary: This submission consists of what is commonly known as "The Whole Bay Study."]
Information: FILE LIST
or Immediately Download the
]
Filed By: INDIVIDUAL [Michael A. Reynolds]
Filed Date: 1/05/2009
Accession No: 20090109-0125
Description: Reponse letter re Calais LNG under PF08-24.
[Summary: Submitter claims there is a national need for LNG.
Information: FILE LIST
or Immediately Download the
FERC PDF file (86.45 KB).
Filed By: CALAIS LNG
Filed Date: 1/14/2009
Accession No: 20090114-5105
Description: Calais LNG Project Company LLC Monthly Pre-Filing Status Report No. 5 under Docket No. PF08-24.
Information: FILE LIST
or Immediately Download theFiled By: CALAIS LNG
Filed Date: 1/08/2009
Accession No: 20090113-0287
Description: Calais LNG Project Company LLC submits Draft Resource Report 5 (Socioeconomic Conditions and Impacts) under PF08-24.
[Summary: Calais LNG states no adverse environmental justice impacts are anticipated, nor are adverse impacts expected due to the influx of a large number of workers during construction. LNG ship transits from entrancing near Head Harbour would be 23 nautical miles (26.5 statute miles/42.6 kilometers). They also claim the pier would be "less than 1,000 ft from mean low water." They claim a wide margin of citizens of Washington County support the project, but provide no empirical evidence. The City of Calais doesn't anticipate needing to increase its emergency response capability. Maritimes & Northeast Pipeline will have adequate capacity to carry Calais LNG's output.][SPB Webmaster's Comments:
- Calais LNG used the IMPLAN economic impact model to make its predictions — the same flawed method used by Downeast LNG. Darius Irani, the featured speaker whom Downeast LNG's Dean Girdis paid to make a presentation at a Sunrise County Economic Council Economic Summit on LNG in Machias, agreed that IMPLAN was a "poor man's" method of economic analysis, and that it relied on dated and flawed assumptions;
- Calais LNG ignores The Whole Bay Study that predicts a net negative economic impact on the area from an LNG terminal.
- The indicated total pier length will probably be longer than 1,000 feet, in apparent violation of Maine littoral rights;
- Calais LNG provides no basis for the claim that a majority of Washington County citizens support the project. The vast majority of the population — the majority being citizens of Canadia — surrounding Passamaquoddy Bay oppose all LNG projects in the bay;
- Calais and all communities along the LNG transit route would need to increase their emergency response capability, but costs for that increase are not known until after FERC issues a permit to construct; thus, Calais and all other affected communities would be caught with unexpected expenses and higher demands on taxpayers;
- Calais LNG assumes envrionmental justice applies only to race-related issues, ignoring impacts on otherwise disadvantaged populations.]
Information: FILE LIST
or Immediately Download the
Filed By: INDIVIDUAL [Richard Gayton]
Filed Date: 1/09/2009
Accession No: 20090113-0397
Description: Comments of Richard A Gayton expressing support for the Calais LNG facility under PF08-243.
[Summary: This retired Border Patrol officer doesn't believe the Calais LNG location poses any greater security concerns than any other LNG terminal in the US.]
[SPB Webmaster's Comments: Considering the ease of ongoing smuggling by water here due to the numerous islands, the woods-lined waterway, proximity to the international boundary, and the proposed LNG carrier transit route within those conditions, Mr. Gayton's confidence is not reassuring.]
Information: FILE LIST
or Immediately Download the
Filed By: Individual No Affiliation [Ron Rosenfeld]
Filed Date: 1/20/2009
Accession No: 20090120-5080
Description: Comment of Ronald S. Rosenfeld under PF08-24, regarding Purpose and Need for the Project.
[Summary: Calais LNG has used outdated information that contradicts the Energy Information Administration's current energy report to justify its project. Calais LNG also "fudges" US/New England energy consumption data.]
Information: FILE LIST
or Immediately Download theFiled By: Calais LNG Project Company, LLC
Bracewell & Giuliani LLP (as Agent)
Filed Date: 1/21/2009
Accession No: 20090121-5196
Description: Calais LNG Project Company LLC Submits Supplemental Responses to Comments Filed During The Pre-filing Scoping Period under Docket No. PF08-24-000.
[Summary: Calais LNG "agrees with" every pro-project comment, and cites a nebulous, unnamed "scientific study" when attempting to refute anti-projet comments.]
Information: FILE LIST
or Immediately Download the
Filed By: CALAIS LNG PROJECT COMPANY, LLC
BRACEWELL & GIULIANI LLP (as Agent)
Filed Date: 1/16/2009
Accession No: 20090123-0047
Description: Calais LNG Project Company, LLC submits Draft Resource Report 13 for the LNG terminal facilities and related natural gas facilities etc under PF08-24.
[Summary: NON-PUBLIC.]
Information: FILE LIST
Filed By: Individual No Affiliation [Brian Flynn]
Filed Date: 1/26/2009
Accession No: 20090126-5021
Description: Comments of Brian William Flynn under PF08-24.
[Summary: Calais LNG's responses to Scoping Comments omit many comments. Also, as demonstrated by the recent US Coast Guard's Waterway Suitability Report, Calais LNG falsely claims LNG ship Hazard Zones would not reach residential areas or historic areas, when in truth, they would endanger many residential areas and also Roosevelt Campobello International Park, Eastport's Downtown Historic District, and other historic areas.]
Information: FILE LIST
or Immediately Download the
Filed By: CALAIS LNG PROJECT COMPANY, LLC
Filed Date: 1/27/2009
Accession No: 20090127-4006
Description: Calais LNG Project Company LLC submits Draft Resource Report 11 under PF08-24. (CD 1 of 1)Information: FILE LIST
Filed By:CALAIS LNG PROJECT COMPANY, LLC
Filed Date: 1/27/2009
Accession No: 20090127-4007
Description: Calais LNG Project Company LLC submits Draft Resource Report 11 under PF08-24. (CD 1 of 1)Information: FILE LIST
Filed By:CALAIS LNG PROJECT COMPANY, LLC
Filed Date: 1/27/2009
Accession No: 20090127-4008
Description: Calais LNG Project Company LLC submits Draft Resource Report 11 under PF08-24. (CD 1 of 1)Information: FILE LIST
Filed By:CALAIS LNG PROJECT COMPANY, LLC
Filed Date: 1/27/2009
Accession No: 20090209-0001
Description: Calais LNG Project Company LLC submits Draft Resource Report 11 under PF08-24.Information: FILE LIST
Filed By:CALAIS LNG PROJECT COMPANY, LLC
Filed Date: 1/27/2009
Accession No: 20090209-0002
Description: Calais LNG Project Company LLC submits Draft Resource Report 11 under PF08-24.Information: FILE LIST
Filed By:CALAIS LNG PROJECT COMPANY, LLC
Filed Date: 1/27/2009
Accession No: 20090209-0003
Description: Calais LNG Project Company submits its non public version of Draft Resource Report 11 under PF08-24.Information: FILE LIST
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