Saturday, October 20, 2012

LNG: Downeast LNG persists in its application for a Passamaquoddy Bay Terminal - Time for FERC to reject the last outstanding application.


From tourism to whales to cotton-tail rabbits Downeast LNG doesn’t understand Passamaquoddy Bay. It’s now long past the time for FERC to reject the last outstanding application to place an import LNG terminal in Passamaquoddy Bay, a process that, if it weren’t so serious, would be a comedy about how the dead keep walking.


Just how crazy this process has been is well documented at www.savepassamaquoddybay.org. Below is the essence of our concerns relating to marine life in the area taken from an analysis of the Environmental Impact Statement provided to FERC by DeLNG. The full commentary can be read at: http://www.scribd.com/doc/110624491/Downeast-LNG-EIS-A-MacKay-comments-to-FERC or below.



The primary elements of the “Quoddy Ecosystem” showing the proposed traffic route from the Fundy shipping lane to St. Croix Estuary and indicating the various proposals for LNG terminal development that have been considered or have made application to FERC. An alternate tanker route has been proposed through the Grand Manan Channel.



The Quoddy Region is well-known as a distinct ecosystem that encompasses St. Croix Estuary, Passamaquoddy Bay, Western Passage, Cobscook Bay, Head harbour Passage, West Isles, Grand Manan Channel, Owen Basin, and offshore areas reaching to Point Lepreau and Grand Manan (Buzeta, et.al, 2003) as shown in Figure 1. As can be seen from this aerial view, most of the ecosystem lies within Canada; although the Passamaquoddy Bay shore and Cobscook Bay form an integral and important part of this system. The shipping lanes into and out of Saint John Port are shown in the background. This clearly illustrates the considerable difference between a well-established, straight-in, commercial service route and the convoluted route into the proposed terminal at Robbinston, Maine.


While I have a number of comments and criticisms to make about the DeLNG EIS as it relates to marine mammals and whales in particular, I was pleased to see that the EIS takes note of and recognizes the threat to listed endangered species and moreover recognizes the tight confines that exist in the Head Harbour to Passamaquoddy Bay portion of their proposed tanker route. The EIS correctly identified the conflicts that will arise. However, it is not sufficient to simply state that their operation is not likely to jeopardize the continued existence of marine mammals. The proximity to endangered species that are protected under law in both Canada and the United States makes this a questionable venture. Breach of law becomes inevitable under these circumstances and, if, as we are all fond of saying, we believe in the rule of law, it makes no sense to test the obvious with an inappropriate sighting of a facility that could easily be placed elsewhere and out of harms way.


Like you, I am aware of the splendid efforts that are being made to avoid contact with right whales that
cluster around the shipping lanes into Boston and the Bay of Fundy. But, Head Harbour Passage is quite different. This is a narrow, pipe-like, passage that is full of whales, seals, fish, plankton and people and into which we will be inserting a huge ship the size ofthe QE2. Trust me, the passage at Green Island Shoal off Casco Island will barely accommodate an LNG tanker at low slack water. One minor little twist or tum in these turbulent waters and we will all be faced with an interesting problem.


During the Pittston oil refinery hearings, it was, in fact, the whales that led governments in the United States to tum down that proposal together, of course, with Canada’s scientific risk analysis on Head Harbour Passage and their firm position that still exists today. We are not being stubborn. We know what a special gift this place is and we know what we stand to lose!


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