Dr. Nicole Alexander-Scott, director of the Rhode Island Department of Health (RIDOH), responded to the Federal Energy Regulatory Commission’s (FERC) request for comments on National Grid’s plans to build a new liquefaction plant at Field’s Point on the south side of Providence.
The project has been the target of sharp criticism by environmental and social justice groups as an example of environmental racism, and much in Dr. Alexander-Scott’s assessment backs up such an assessment.
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Though the director does not outright oppose the project, she does recommend that “FERC conduct a robust review of the project that fully incorporates public health perspectives and reviews potential public health concerns” and that RIDOH, “be deemed a cooperating agency, with all the rights and opportunities to participate in FERC’s review of this project preserved thereby.”
“Given the set of potential risk scenarios,” says Dr. Alexander-Scott in her final paragraph, “RIDOH requests that FERC consider requiring a Risk Management Plan for both the proposed liquefaction facility as well as the existing LNG storage facility, which does not currently have a Risk Management Plan.” [Emphasis mine]
“As Director,” says Dr. Alexander-Scott, “my strategic priorities for RIDOH are to address the social and environmental determinants of health, to eliminate health disparities in Rhode Island by promoting health equity, and to ensure access to quality services, especially for vulnerable populations.”
In her letter, Dr. Alexander-Scott outlines quite a few hazards and “risk scenarios” relative to the project.
Examining the proposal from a geographic standpoint, Dr. Alexander-Scott notes that the facility is planned within “an industrial area with a concentration of facilities listed in the EPA’s Toxic Release Inventory (TRI), facilities requiring Risk Management Plans (RMP), and Treatment, Storage, and Disposal Facilities (TSDF) that handle hazardous materials.”
Perhaps more critical “is the concentration of healthcare facilities and critical health system infrastructure within close proximity to the proposed project. Rhode Island’s only Level 1 Trauma Center is located in the Rhode Island Hospital complex, which includes Hasbro Children’s Hospital and is adjacent to Women and Infants Hospital. There are many additional primary care, specialty care, pediatric healthcare, and Federally Qualified Health Centers within this area of interest at varying degrees of proximity to the site location of the proposed facility. Providence Community Health Center’s administrative building and Chafee Health Center are within the half mile radius parcel map…”
Having this much emergency and non-emergency medical care infrastructure in one area, and an area so close to the proposed liquefaction facility requires “that careful attention be paid to any potential impacts to this critical healthcare infrastructure, including both for the cumulative impacts of construction and normal operation of the facility, and for any potential increased risk for accidents or emergency situations,” says the Director.
She sums up some of the potential accidents or emergency situations:
Although the possibility of an emergency or disaster may be low, the combination of multiple hazardous facilities, healthcare infrastructure, and vulnerable communities requires extra care and attention. Potential hazards may include leaks, fires, floods, earthquakes, hurricanes, storm surge, equipment malfunction, accident, terrorism, and the added risk of secondary offsite incidents including chemical incidents or explosions from co-located facilities requiring chemical risk management plans. RIDOH is concerned about the health impacts that would results from a worst-case scenario involving secondary impacts, which might involve amplified chemical reactions with substances such as chlorine, ammonium, and heat from flammable materials stored in co-located facilities. The close proximity to the I-95 highway corridor, and Rhode Island’s level 1 trauma center present an additional risk to the critical infrastructure needed for responding to any potential disaster situation. With a medically-vulnerable population and a relatively high percentage of people who are linguistically-isolated in the adjacent community, considerations around communications in disaster preparedness and response should also be taken into consideration as part of the environmental assessment and/or a broader emergency/risk management review.”
Though she doesn’t use the term “environmental racism,” Dr. Alexander-Scott provides numbers making it impossible not to draw such a conclusion.
“Socioeconomically,” says Dr. Alexander-Scott, “the one mile buffer around the proposed facility is 75 percent minority population…, 56 percent low-income…, 17 percent linguistically isolated… and 31 percent have less than high school education.” (86th percentile for state). The combined socioeconomics for the neighborhoods of Upper and Lower South Providence and Washington Park are 82 percent minority population…, 64 percent low-income…, 24 percent linguistically isolated… and 33 percent have less than high school education.” She notes that “these socioeconomic statistics are of important public health interest as significant social determinants of health.”
“RIDOH,” says the director, “has ample data on poor health outcomes, elevated health risks, and racial and ethnic health disparities within the City of Providence and in particular within the neighborhoods of Upper and Lower South Providence and Washington Park, which are in closest proximity to the proposed project. RIDOH’s 2014 Asthma Claims Data Report used health insurance claims data to produce detailed hot spot maps for asthma prevalence, emergency department visits, and hospitalizations, which all show asthma hot spots and elevated asthma risk in this focus area, at some of the highest levels in the state. Providence has the highest asthma-related pediatric hospitalization rates in the state, and asthma is elevated in low-income individuals and Black/African American and Hispanic/Latino communities.”
It seems that the efforts of National Grid, in building this facility, stand in direct opposition to the Department of Health’s mission to improve health outcomes in at risk neighborhoods.
“RIDOH is funding 11 Rhode Island non-profit organizations and local governments at various levels to support innovative approaches to improving health outcomes,” says the director. “The Department of Health and these grantees have created Health Equity Zones – defined geographic areas where high rates of obesity, illness, injury, chronic disease or other adverse health outcomes will be improved by coordinated strategies to reduce and manage chronic diseases, promote healthy lifestyles, improve birth outcomes, assure healthy child development, and create environments where healthy choices are easier to make. It is the vision of the Department of Health, that communities are engaged in democracy and committed to equality and diversity. Through these Health Equity Zones we will create and maintain sustainable and healthy places for all Rhode Islanders to live, work, and learn. It is imperative that alterations to the community’s landscape by other sectors does not impede the progress being achieved by such initiatives.”
Ironically, the build up of LNG infrastructure in Rhode Island will contribute to climate disaster, yet the location of the proposed liquefaction facility is at risk from sea level rise caused by climate change. Dr. Alexander-Scott doesn’t explicitly touch on this irony, but says, “Other environmental factors that are worth considering in the scope of the review include coastal flooding, both current and future levels given projected sea level rise, as well as potential storm surge and wind impacts. The effects of climate change on this project and therefore long-term population health is a necessary, additional component of the current environmental review.”
You can read the full letter from Dr. Alexander-Scott here.