ferc – Page 2 – RI Future

January 15, 2016January 23, 2016

Alternatives and Solutions: Strategies for Climate Justice and a Just Transition

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The Environmental Justice League of Rhode Island (EJLRI) has created a brilliant position paper, “National Grid’s Liquefied Natural Gas (LNG) Liquefaction Facility: Toxic Hazards in the Port Providence: Proposals for a Just Transition” that eviscerates National Grid‘s plans to build a new liquefaction facility for fracked LNG at Fields Point in South Providence. Over the next few days RI Future will be presenting the EJLRI’s position paper in its entirety.

Solutions and Alternatives

The information presented in the previous posts show that in addition to not being necessary, National Grid’s proposed LNG Liquefaction Facility would be dangerous and would contribute to existing environmental racism. LNG Liquefaction is not needed in Rhode Island in general, and it certainly should not be placed in the most toxic and most impoverished part of the state.

The immediate solution is to stop this facility from being built. The Federal Energy Regulatory Commission (FERC) needs to deny National Grid LNG LLC’s application, and the RI Department of Environmental Management (RI DEM) and RI Coastal Resources Management Council (RI CRMC) need to deny the state level permits.

That being said, the proposed liquefaction facility is not the only problem outlined in this position paper. Even without the added significant risks of the liquefaction facility, the existing LNG storage tank, the Motiva oil terminal, the Univar chemical plant, the Enterprise LPG terminal, and other facilities in the area all pose significant environmental health hazards, and create the overall context of environmental racism. Toxic and hazardous facilities are dangerous for communities and dangerous for workers. Yet families are dependent on them for jobs, municipalities are dependent on them for tax income, and the way our socioeconomic system is set up we are all collectively dependent on the products they produce. Regardless of our dependency, the reality of climate science is that the fossil fuel / petrochemical industry is rapidly pushing our planet past its limits, producing present and future catastrophic impacts, and making people sick, especially front-line communities of color and indigenous communities. Our dependency on these industries is literally killing us.

As an organization, the EJ League is interested in big picture, long term, real solutions to interlocking crises that impact communities of color, marginalized communities, and planetary ecosystems. We are members of three national coalitions of grassroots, membership based organizations: Right to the City, Grassroots Global Justice, and Climate Justice Alliance. Together, and lead by our members and our communities, we are developing and sharing solutions that address these intersecting crises from the grassroots. These community based solutions are in opposition to the corporate top down false solutions that pretend to address a single symptom while reinforcing the underlying root causes of the problems.

True solutions are rooted in the work of grassroots internationalism, and using the framework of a “Just Transition”. We are collectively building a different context and a different system, an economy for people and the planet. The Just Transition framework emerged from partnerships between environmental justice and labor organizations. In the words of the Just Transition Alliance, “together with front-line workers, and community members who live along the fence line of polluting industries, we create healthy workplaces and communities. We focus on contaminated sites that should be cleaned up, and on the transition to clean production and sustainable economies.”

As part of the Climate Justice Alliance (CJA) Our Power Campaign, we are part of a collaborative that is:

uniting front-line communities to forge a scalable, and socioeconomically just transition away from unsustainable energy towards local living economies to address the root causes of climate change.

“We are rooted in rooted in Indigenous, African American, Latino, Asian Pacific Islander, and working class white communities throughout the U.S. We are applying the power of deep grassroots organizing to win local, regional, statewide, and national shifts. These communities comprise more than 100 million people, often living near toxic, climate polluting energy infrastructure or other facilities. As racially oppressed and/or economically marginalized groups, these communities have suffered disproportionately from the impacts of pollution and the ecological crisis, and share deep histories of struggle in every arena, including organizing, mass direct action, electoral work, cultural revival, and policy advocacy.

“Together we are strengthening relationships between community based organizations, environmentalists, labor unions, food sovereignty/sustainable agriculture groups and other sectors of society.

“As CJA we are coalescing our power to reshape the economy and governance in the coming decades we are communities united for a just transition.”

CJA’s Our Power Campaign has the long term goals to: 1) End the Era of Extreme Energy, and 2) Implement a Just Transition to Local Living Economies. This will be achieved by:

Building Local Living Economies with a model that that centers on: Zero Waste, Regional Food Systems, Public Transportation, Clean Community Energy, Efficient Affordable and Durable Housing, and Ecosystem Restoration and Stewardship
Building Community Resilience: Creating climate jobs that will build stronger, resilient, and more equitable communities through Grassroots Economies (ex. worker owned cooperatives) and Rights to Land, Water, and Food Sovereignty.

Economic strategies around Just Transition require strong partnerships between environmental justice community advocates and the labor movement. Too often the corporate 1 percent strategy of divide and conquer is successful, but Just Transition pushes us to build powerful working class alliances to overturn the economic and political power structures that simultaneously harm workers, create widespread economic inequality and poverty, and destroy the planet’s ability to sustain life. There is a growing international movement to change this, and the following reports outline some of the strategies to build strong labor/environmental alliances around energy systems and a Just Transition:

Just Transition in Port of Providence

Working with our national alliances and using these strategic frameworks, EJ League will continue to convene local and regional coalitions to develop and implement Just Transition strategies in Rhode Island, focusing on the Port of Providence as an urgent need. Our goal is to develop concrete strategies and tactics to leverage a rapid transition away from natural gas and all fossil fuels, with democratic front-line community ownership over the development of the sectors for truly renewable energy and energy efficiency work. Through workshops, teach-ins, and hosting a Just Transition Assembly with Grassroots Global Justice in late summer / early fall, we will be doing the collective work of developing local solutions to massive social and planetary problems. We will share our joint understandings and perspectives on the problems, learn about the frameworks and strategies that are effective elsewhere, and will forge pathways to transform our oppressive realities.

There are too many solutions and alternatives to list, and most solutions will be built collectively through praxis and not through theory. As a starting point, one could easily envision how the $100 million price tag for the proposed liquefaction facility could be better spent in ways that would address energy needs, create jobs in the economically marginalized and oppressed front-line communities next to the Port, support renewable energy and energy efficiency, and build greater community health instead of increased toxic risk. With the high percentage of old housing stock and rental units in low income communities, there is a large need to improve housing quality with weatherization, energy efficiency, and improvements in indoor air quality, lead abatement, and other healthy housing requirements. This investment would reduce the need for heating fuels, improve health outcomes, and would be able to employ many people from the community.

Job training programs around weatherization and housing work are already in place, and are focused on people of color, youth, and people with records who are excluded from many other sectors of the dominant economy. EJ League has a Board Member who is a weatherization job training specialist, energy auditor, and is working on seeking investors to build a production facility for cellulose to be used in blown-in insulations and home weatherizations. Worker owned cooperative enterprises in the industries of energy efficiency would transform economic power dynamics, bring democratic control into the workplace, and build wealth at the local level. These types of economic developments would be community owned, community led, would employ community members, and would support true community wealth development in stark contrast with the corporate fossil fuel and petrochemical model developments that poison, displace, and extract wealth at the expense of community wellbeing.

In addition to worker owned businesses for energy efficiency, we need community owned renewable energy development. National Grid is required to make a bare minimum level of investment into renewables, and is allowed to add a surcharge to all consumer bills to cover this. Despite the fact that everyone is paying for this, National Grid’s limited investments into renewables have been in affluent white suburban communities. Front-line communities, which have been sacrifice zones for hazardous energy developments for generations, need massive investments in renewable energy. But these investments cannot operate like most investments in the dominant capitalist economy, which come in from outside with disregard for residents, take advantage of poverty conditions, lead to gentrification and displacement, and extract wealth for the investor’s return on investment. We are also not asking for charity or handouts that would support public relations campaigns for polluting industries. We are demanding reparations.

We are exploring mechanisms to make it possible for renewable energy to benefit our communities, given that current capitalist market mechanisms favor larger corporations, municipalities with surplus budgets and strong tax bases, and families that are homeowners who can afford upfront costs in order to get the return on their solar/renewable energy investments. We are determined to make renewable energy a working reality that benefits low income communities of color in multiple ways, from reduced toxic hazards, lowered bills, better jobs, and shifting away from energy sources that are literally killing us. We know this will not happen overnight, and it will be a massive cross sector effort to manifest this vision. But we also know that we cannot afford to wait, and nothing is more urgent. We invite you to join us.

● Potential Disasters: dangerous facility in a high risk area

● Environmental Racism: ongoing and underlying environmental justice issues

● Climate Change: it causes climate change and is at risk from climate impacts

● Public Health: health disparities and impacts on health care institutions

● Economic Inequality: high cost project that will cause economic damage

● Alternatives and Solutions: Strategies for Climate Justice & a Just Transition

January 14, 2016January 23, 2016

Economic Inequality: high cost project that will cause economic damage

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Economic Inequality

The Fields Point Liquefaction Facility project takes advantage of, and will increase problems with economic inequality and economic injustice related to energy. First and foremost, the massive $100 million price tag for construction will be passed onto consumers as an added charge. National Grid tries to hide this fact by saying “the cost of the natural gas commodity on a customer’s bill is a pass through cost. This project will allow National Grid and other companies who use the Fields Point facility to supply domestic LNG at a more stable cost.” But “pass through cost” means they pass that cost through to us, and there is no guarantee that prices of domestic fracked gas will be any more stable than prices of internationally sourced LNG. If anything, the international prices of LNG have been steadily declining while domestic fracked gas prices are at historic lows and likely to increase as the industry builds LNG export terminals and fracked gas power plants that increase demand and lead to rising prices. There are existing plans and proposals to connect the Spectra Pipeline (the source of the fracked gas for this facility) (See: here and here) to an LNG export facility in Canada and to build a massive 900 MW power plant in Burrillville, RI that would be powered by gas from Spectra’s “Algonquin” pipeline.

Despite the industry’s claims of needing to build these projects to lower prices, with power plants and other major purchasers getting preferential treatment with locked in prices in long term contracts, individual consumers in Rhode Island will see rising gas prices for home heating and cooking. The $100 million construction costs for the liquefaction facility will be added on top of the price of gas, and collectively we are the ones who will end up paying the bill. On a purely economic level, the proposed facility does not make sense and will be locking us into further dependency on fracked gas.

Income and wealth inequality in Rhode Island means increasing gas prices won’t impact everyone equally. There are only four municipalities in RI that qualify as high poverty “core cities”, with childhood poverty rates over 25 percent – Providence, Pawtucket, Central Falls, and Woonsocket. Providence as a whole has a 27.7 percent poverty rate, almost twice the national average of 12.8 percent, and the front-line communities close to the Port includes the census tracts with the greatest concentrations of poverty in the state, specifically census tracts 5, 7, and 12. Five of the twelve census tracts in the adjacent neighborhoods are within the top 10 poorest tracts in Rhode Island, ranking 1st, 2nd, 4th, 6th and 10th. The median family income is $31,800 with the poorest tracts having median family income as low as $14,067. On average, 35 percent of people in the community live below the poverty line and 63 percent are below the 200 percent poverty line. In the poorest census tracts, 64 percent live below the poverty line and 83 percent are below the 200 percent poverty line. EJLRI Position Paper_Page_27

The Providence unemployment rate of 12.4 percent is much higher than the statewide average of 7.7 percent , while the highest unemployment levels were found in Wards 8, 9, 10, and 11 (South Providence and Washington Park), where unemployment rates range from 15.3 percent to 40.5 percent . Ward 10, directly adjacent to the Port, has the highest unemployment levels including Census Tract 5 which is the highest at 40.5 percent.

Given this data, it is clearly a myth that expanding operations at the Port will create jobs to solve economic issues such as unemployment. There is no public data available on the workforce in the Port, but based on personal accounts and parallels with other comparable sectors, the jobs for work in Providence are not given to residents of Providence, let alone residents of the neighborhoods that are directly impacted. With the limited number of temporary jobs promised with the proposed LNG Liquefaction facility, the high paying jobs requiring specialized skills will be going to Kiewit, a multinational corporation that has also worked on the Keystone XL pipeline.

The increased costs of home gas prices will have a devastating impact in Washington Park and South Providence, where families living in poverty are already dealing with the frequent impacts of National Grid terminating utility service. This is especially true in rental units which are often less energy efficient: because tenants pay utility costs, landlords have no incentive to invest in weatherization or energy efficiency, making heating costs higher. In violation of state and federal law, National Grid routinely shuts off utilities for low income medically vulnerable people who are dependent on heat and/or electricity for medical needs. The RI Center for Justice filed a class action lawsuit against National Grid and the RI Division of Public Utilities and Carriers to stop these utility terminations.

The press release for the suit included the following:

“In my work on behalf of medically vulnerable children and families, I have witnessed National Grid’s routine disregard for health and safety considerations,” says attorney Jeannine Casselman, legal program director of the RI Medical Legal Partnership at Hasbro Children’s Hospital. “Even in cases involving children with severe illnesses and disabilities, we see utility shut offs happening on a regular basis. In some instances, this can lead to loss of housing altogether. Rather than provide a reasonable repayment plan for struggling families, National Grid too often shuts off services, causing further disarray and trauma to low income households.”

In collaboration with the George Wiley Center’s Lifeline Project, this effort is working to protect the health and welfare of families that are put in danger by National Grid’s reckless and greedy energy policies. The EJ League endorses the George Wiley Center’s campaign and the full demands described in the letter from health care professionals and delivered to the RI PUC:

1. A one-year moratorium on termination for all accounts that are coded as ‘medical’.

2. The engagement of an independent third party monitor to review the Division of Public Utility’s approval of petitions for permission to terminate for all accounts coded as medical. The monitor will be selected by a joint committee composed of members of the George Wiley Center, the medical community, the Department of Health and the Public Utilities Commission.

3. The Public Utilities Commission immediately begin requiring data submissions from National Grid that are consistent with those requirements placed on the company in Massachusetts, as per the George Wiley Center’s formal request from March of 2015.

4. The Public Utilities Commission immediately begin accepting and thoroughly reviewing petitions for emergency restoration and providing timely responses to each request.

There is no publicly available address specific data that shows geographic distribution of utility shut offs. Regardless, the concentration of extreme poverty and high levels of chronic disease and health problems in the front line communities next to the Port make it highly likely that these neighborhoods are disproportionately impacted by utility terminations. Testimonials for grassroots membership based organizations in the community confirms that utility termination is a major problem for many families living in front-line communities next to the fossil fuel energy complexes in Port of Providence which provide energy for the entire region. This is yet another sign of environmental injustice and systemic injustice that is built into the normal business operations of the fossil fuel industry.

● Potential Disasters: dangerous facility in a high risk area

● Environmental Racism: ongoing and underlying environmental justice issues

● Climate Change: it causes climate change and is at risk from climate impacts

● Public Health: health disparities and impacts on health care institutions

● Economic Inequality: high cost project that will cause economic damage

● Alternatives and Solutions: Strategies for Climate Justice & a Just Transition

January 13, 2016January 23, 2016

Public Health: health disparities and impacts on health care institutions

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Public Health

All of the above issues discussed in this position paper are also public health issues. In looking at the social and environmental determinants of health, public health paints a picture that helps explain why particular populations are more likely to be sick. Issues of potential disasters, environmental racism, climate change impacts, and economic inequality are all public health issues. The EJ League is the backbone organization for COHEP (Community Organizing for Health Equity in Providence), a collaborative effort with DARE (Direct Action for Rights and Equity), PrYSM (Providence Youth Student Movement), and the RI Doula Collective. COHEP is funded through the RI Department of Health’s “Health Equity Zones” (HEZ). As a place based initiative that works to develop collective impact strategies to address health problems and health disparities, COHEP’s HEZ work focuses on a few neighborhoods in South Providence including Washington Park, a front-line community to Port of Providence. Research and GIS mapping conducted as part of the HEZ community assessment show that Washington Park has largest concentration by far of chemical exposures in Providence, and also has the highest concentration of leaking underground storage tanks:

EJLRI Position Paper_Page_24 At hearings and public events about the proposed liquefaction facility, multiple community members have spoken out about issues of high asthma rates in the community being a major concern. Public health data backs up this concern, and shows that the area is one of the state’s largest asthma hot spots. While most of the state has asthma rates of 04.4 percent or 4.56.2 percent, most of Providence has asthma rates of 8 – 10.3 percent and the neighborhood next to I95 and the Port has the highest levels in the state at 10.4 – 15.4 percent. (link)

On top of the high level of children with asthma, the front-line community and asthma hot spot next to the port also has some of the highest levels in the state for Emergency Department visits or Hospitalizations due to asthma. Among children with asthma living next to the Port of Providence, 15.5 – 24.1 percent have had an Emergency Department visit, compared to rates of 03.3 percent for more affluent neighborhoods in Providence. Similarly with asthma related hospitalizations, for front-line neighborhoods adjacent to the Port or Providence, children with asthma had inpatient hospitalizations at a rate of 5.1 – 8.3 percent compared to the rate of 00.7 percent in the more affluent neighborhoods in Providence.

In addition to the many health problems and health disparities impacting the neighborhoods of South Providence and Washington Park, there are also public health impacts relating to healthcare facilities in these communities. The Lifespan and RI Hospital complex is the largest and most visible concern, containing the state’s only level 1 trauma center, Rhode Island Hospital, Women and Infants Hospital, and Hasbro Children’s Hospital.

In addition to this major hospital complex, there are many other healthcare facilities within a close radius (1 to 2 miles) from the proposed liquefaction facility and close to the other hazardous facilities in Port of Providence. These include but are not limited to:

Hasbro’s Medicine Pediatrics Primary Care (245 Chapman St) this facility offers primary care for children, and also offers specialty services for chronic conditions including asthma, diabetes, and hypertension, which exist at very elevated levels in this neighborhood. The facility also offers gender and sexual health services. It falls within the one mile radius of the proposed liquefaction facility.

Providence Community Health Centers (375 Allens Ave) PCHC serves approximately 50,000 patients in Providence, many of whom are low income, uninsured or under insured, and suffering from health problems impacted by social determinants of health. This location has their administrative building for all 9 health centers in Providence, as well as the Chaffee Health Center which serves patients. It is located within the half mile radius of the proposed liquefaction facility.

Providence Community Health Centers Prairie Avenue complex (369 Prairie Ave) this health center location also includes the asthma and allergy specialty clinic for the entire PCHC health center system across Providence.

Fertility Solutions (758 Eddy St) specializes in fertility treatments and in vitro fertilization and other related services

New Beginnings (717 Allens Ave) offers perinatal and ultrasound care

It is clear from this limited list, that any cumulative or emergency related impacts from the proposed liquefaction facility would not only impact the whole state’s health care system, but would particularly impact health care services related to maternal and child care, reproductive care, chronic disease care, and emergency response services. Ongoing background pollution and risks in this area should be seen as a public health crisis. Any potential future disaster impacting the port could cause a public health emergency of unimaginable proportions.

● Potential Disasters: dangerous facility in a high risk area

● Environmental Racism: ongoing and underlying environmental justice issues

● Climate Change: it causes climate change and is at risk from climate impacts

● Public Health: health disparities and impacts on health care institutions

● Economic Inequality: high cost project that will cause economic damage

● Alternatives and Solutions: Strategies for Climate Justice & a Just Transition

January 12, 2016January 23, 2016

Climate Change: LNG plant causes climate change and is at risk from climate impacts

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Climate Change

As a new fossil fuel facility involving methane, a potent greenhouse gas, the Fields Point Liquefaction Facility will create emissions that contribute to climate change. The source of the methane that would be liquefied is the Spectra Energy pipeline, which carries gas produced by hydraulic fracturing (fracking) from the Marcellus Shale into New England. As a result, the emissions and climate change impacts of the fracked gas life cycle must be taken into account, from drilling to consumption. While the oil and gas industry and their supporters like to present “natural” gas as a “cleaner” alternative or a “bridge fuel” towards a renewable future, in reality gas produced by fracking is worse for the climate than coal.

The proposed liquefaction facility is part of a much larger regional strategy to massively expand fracked gas infrastructure across the region, coordinated by the “Access Northeast” project linking Spectra Energy, National Grid, and Eversource Energy. In order to take climate science seriously and hopefully avert devastating runaway climate change, fossil fuel use must be rapidly scaled back not expanded. This is especially true for natural gas, given the much higher potency of methane as a greenhouse gas. Instead of investing in the build out of new fracked gas infrastructure, massive investments need to be made in energy efficiency and truly renewable energy.

National Grid’s proposed facility would contribute to climate change emissions

National Grid will need a compressor station to take the incoming gas from the pipeline and bring it up to the needed pressure for liquefaction. This compressor would be powered by gas from the pipeline, contributing in addition to methane leaks throughout the natural gas pipeline, storage, and delivery system.

Running the liquefaction facility requires a large amount of energy and will use 15 Megawatts of electricity to liquefy the gas. For comparison sake, the Deepwater Wind offshore wind farm project will be generating 30 Megawatts of electricity, which means National Grid’s proposal would essentially cut the benefits of this groundbreaking renewable energy development in half. In general, 98 percent of Rhode Island’s electricity is generated from natural gas.

Climate Adaptation?

In addition to contributing to climate change, the proposed facility and the Port of Providence in general is at high risk from climate related impacts and severe weather events. It, along with the rest of the Port, is at sea level and is at risk from climate change amplified hurricanes as well as from future sea level rise. In both projected scenarios, as well as in other major flood events, the proposed liquefaction facility would be underwater, along with the adjacent facilities storing hazardous, flammable and/or explosive substances. National Grid claims the facility will be built to withstand a 500 year flood yet it also claims to have done outreach with community organizations that have never existed, which brings their trustworthiness into doubt. In recent years, multiple 1000 year floods have occurred, supercharged by the overheated climate. While it may be poetic justice or karmic effect to have the major producers of climate change emissions be impacted by the effects of climate change, once again it would be the neighboring front-line communities that would be hurt most by any climate related disaster.

● Potential Disasters: dangerous facility in a high risk area

● Environmental Racism: ongoing and underlying environmental justice issues

● Climate Change: it causes climate change and is at risk from climate impacts

● Public Health: health disparities and impacts on health care institutions

● Economic Inequality: high cost project that will cause economic damage

● Alternatives and Solutions: Strategies for Climate Justice & a Just Transition

January 12, 2016January 23, 2016

Environmental Racism: ongoing and underlying environmental justice issues

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Environmental Racism

Beyond the potential disaster scenarios described in the previous section, there are many ongoing disasters that daily impact the front-line communities living next to Port of Providence. Business as usual under the current economic system is a state of disaster for marginalized communities, with concentrated poverty, mass incarceration, substandard housing conditions, and health disparities.

Environmental racism t?akes many forms, but is simply defined as the concentration of environmentally hazardous conditions in communities of color. A legal definition states:

“Environmental racism refers to intentional or unintentional targeting of minority communities or the exclusion of minority groups from public and private boards, commissions, and regulatory bodies. It is the racial discrimination in the enactment or enforcement of any policy, practice, or regulation that negatively affects the environment of low income and/or racially homogeneous communities at a disparate rate than affluent communities.”

The Supreme Court’s recent decision upheld the Federal Housing Act’s assertion that racism in housing policy does not need to be individually intentional if it can be shown as a systemic outcome of racial disparities.

Similarly, environmental racism is evidence as the result of sets of institutional policies and practices, regardless of whether the intent to discriminate is apparent. As described by Charles Ellison in an article titled Racism in the Air You Breathe, “?w?here you live—down to your exact zip code—can determine how fast you get sick and how soon you die.”? The following section will take a detailed look at the front-line communities of Southside (upper and lower South Providence) and Washington Park, which are right next to the Port of Providence.

EJLRI Position Paper_Page_13

Demographics and the Waterfront?

This map shows the “percentage nonwhite” (based on 2010 census data) in a block by block geography. The approximate area of the industrial Port of Providence is highlighted in red. The line between Providence and Cranston (south of Fields Point and Roger Williams Park) shows a dramatic shift in demographics from people of color to predominately white.

The front-line communities adjacent to the Port of Providence are a corporate sacrifice zone; areas of concentrated poverty and marginalization where polluting industries are allowed to be sited and conduct hazardous operations with little regard for health or environmental impacts on the neighborhoods. This comparison of waterfront areas paints a clear picture of apartheid and de facto environmental racism. Downtown, Fox Point, and East Side / Blackstone neighborhoods in Providence, as well as Pawtuxet Village in Cranston and along the East Bay Bike Path in East Providence all have beautiful waterfront access with parks, biking, yachts, boating, sport fields, and festivals in relatively affluent and predominately white neighborhoods. Meanwhile South Providence, with concentrated poverty and communities of color, has little to no waterfront access in an area zoned for heavy industrial use with multiple polluting and hazardous facilities.

Environmental Justice Analysis?

Environmental Justice involves looking at the intersection of environmental hazards and their health impacts, demographics, and social inequalities, and forges strategies to erase inequities and ensure that everyone has a healthy environment to live, work, pray and play. Due to deeply entrenched institutional racism and societal inequalities areas of concentrated and racialized poverty are often also pollution hot spots filled with refineries, landfills, lead paint, highways, etc and lacking in benefits such as green space, waterfront access, healthy food, and clean air. Public transportation travels more frequently through poorer communities. Rhode Island Public Transportation Authority (RIPTA) terminal is also located in this community. In fact, South Providence is one of the largest “environmental justice” communities where all of these factors are concentrated statewide. Several tools from the Environmental Protection Agency (EPA) make it possible to use hard data to tell the story of Environmental Justice concerns in the areas around the Port of Providence. The tools used to generate the following analyses include the EPA’s Toxic Release Inventory (TRI) and the EJSCREEN tools, the open source data mapping project JusticeMap.org and the Center for Effective Government’s national mapping tool for schools and high risk chemical facilities. The area of analysis is primarily local, at the neighborhood level (Upper and Lower South Providence, Washington Park), zip code level (02905, 02907), and facility specific (one mile radius from proposed facility). It should be noted that while the one mile radius is used for the initial Environmental Justice impact analysis, a greater radius of two miles or more should be used to analyze cumulative and secondary impacts of the proposal.

The one mile radius around the proposed Liquefaction Facility, including a section of East Providence across the Bay which is more affluent and more white, has a combined demographic risk score calculated by EPA that is in the 90th percentile for Rhode Island, and 94th percentile for EPA Region 1 (New England). In other words, there are more at risk demographics in this radius than in 90 percent of the rest of RI, and more than 94 percent of the rest of New England. That combined profile consists of the following: 75 percent “minority population” (in 91st percentile for RI; 93rd percentile for EPA region 1) 56 percent low income (in 85th percentile for RI; 91st percentile for Region)17 percent linguistically isolated (in 88th percentile for RI; 92nd percentile for Region)31 percent with less than high school education (86th percentile for RI; 93rd percentile region) EJLRI Position Paper_Page_15a

EPA Toxic Release Inventory?

This EPA database catalogues releases of toxic chemicals. All 11 polluters listed for City of Providence are included in zip code 02905, which contains a greater number of polluting facilities than any other city or town in Providence County. All 11 of the polluters listed are within the one mile radius of the proposed Liquefaction Facility, both within the industrial area in the Port of Providence and but also in the neighborhood area between Eddy St. and Allens Ave in Washington Park.

EJLRI Position Paper_Page_15b

According to EPA the industry that contributes most to onsite toxic releases in the 02905 zip code are Petroleum Bulk Terminals. The TRI facilities listed include many of the risks described in the previous section, such the Motiva fuel terminal (Petroleum Bulk Terminals) and Univar USA Inc (Chemical Wholesalers), as well as facilities located even closer within residential communities: Monarch Metal Finishing Co (Fabricated Metals), SafetyKleen Systems, Inc (Hazardous Waste/Solvent Recovery) and Mahr Federal, Inc. (Computers/Electronics Products).

Schools at Risk

A?s described earlier, the Univar chemical facility has a 14 mile hazard radius, pictured below as the large red circle. There are 311 schools within this zone, which are attended by approximately 110,000 children. The table below shows the national rankings of the percent of children within vulnerability zones. RI’s high ranking is due almost entirely to the Univar facility in Port of Providence, adjacent to the proposed Liquefaction Facility.

EJLRI Position Paper_Page_16

EPA’s EJ SCREEN Tool

This new interactive mapping tool is a way to analyze the intersection of demographic risk profiles alongside environmental indicators such as air quality (particulate matter and ozone levels), lead paint, and proximity to traffic or facilities that require a chemical risk management plan, that store and process toxic materials, or that are water discharge polluters. The results can be mapped out and compared to the rest of the state, the rest of the EPA region, or nationally. In all of the following maps, the national percentile is displayed with the 95th100th percentile in red and 90th95th percentile in orange.

Proximity to Facilities Requiring a Chemical Risk Management Plan

The following map shows the Greater Providence area and highlights the areas that have close proximity to a large chemical facilities that require having a chemical Risk Management Plan (RMP). The area adjacent to the port is highlighted in red, meaning that it is in the 95th – 99th percentile nationwide in a combined measure of chemical risk proximity and demographic risk.

EJLRI Position Paper_Page_17

The one mile radius around the proposed Liquefaction Facility ranks in the 97th percentile for the state, the 98th percentile for EPA Region 1 (New England), and 95th percentile nationally. This is an Environmental Justice community that is at high risk for exposure in a chemical incident.

Proximity to Water Discharger Facility

The following map for the combined EJ indicator for proximity to Major Direct Water Discharger Facilities and demographic risk. Again, the areas in Providence closest to the port are in the highest percentiles nationwide. In state, regional, and national comparisons, the one mile radius from the proposed facility is in the 97th percentile for this risk factor.

EJLRI Position Paper_Page_18a

Traffic Proximity

The following map shows the EJ SCREEN risk status for Traffic Proximity and Volume. The one mile buffer from the site is in the 96th percentile for both state and national comparisons, and in the 98th percentile compared to the rest of EPA Region 1.

EJLRI Position Paper_Page_18b

Traffic proximity and volume is an issue that requires careful attention for the proposed liquefaction facility. The I95 corridor is a major interstate roadway with heavy vehicle traffic. The Thurbers Ave exit, Eddy St. exit, and residential streets along Eddy St. and Allens Ave. carry most traffic in and out of the Port of Providence, and are located in some of the largest asthma hot spots in the state. This asthma hot spot has a high concentration of people with asthma (impacting Black and Latino families most) and some of the highest rates of emergency room visits and hospitalizations due to asthma. Air pollution in the form of Volatile Organic Compounds (VOCs), particulate matter (PM), ultra-fine particles, and black carbon are connected with heavy vehicle traffic and especially truck traffic. These air pollutants are known asthma triggers and are also linked to other respiratory health issues, certain cancers, and developmental disabilities. This is an existing burden that severely impacts Southside and Washington Park neighborhoods. The construction and operation of the liquefaction facility will be additional cumulative impacts in an area that is already overburdened. The proposed export of LNG via tanker trucks is a large concern: why should these communities now bear the burden of supplying the rest of RI and MA with LNG? National Grid says that there won’t be a net change in truck traffic, with 16 tankers per day currently delivering LNG and an estimated 16 tankers per day exporting LNG once the facility is built. However, there are no binding guarantees this wouldn’t increase later. National Grid’s partners in Access Northeast are proposing major new LNG storage tanks near New Bedford, if these tanks are built would they be supplied with LNG from Fields Point? FERC should analyze the production capacity of this facility and determine if the supply produced would require additional tanker traffic to distribute. In either case, the two years of construction will have a significant impact on additional traffic in the community.

Toxic Storage and Discharge Facilities

Toxic materials are a major issue in these neighborhoods, and are some of the highest ranking EJ Indexes placing all of South Providence and West End above the 95th percentile.

EJLRI Position Paper_Page_19

For proximity to Toxic Storage and Disposal Facilities, communities in the one mile radius surrounding the proposed facility are in the 98th percentile for the state and the 99th percentile for EPA Region 1 and National comparisons.

Environmental Justice: working towards equitable healthy environments

In simplistic terms, environmental justice means guaranteeing equitable access for all people to have healthy environments where they live, work, play and pray. For a more detailed description of environmental justice, please read the EJ Principles. The environmental justice movement has exposed the reality of the extent to which this equitable world does not exist. Because of ongoing legacies of racism, economic inequality, segregation, redlining, and other systemic injustices, someone’s zip code is the greatest factor in their health and life expectancy. Unfortunately, the front-line communities next to the Port of Providence, which are densely populated and filled with schools, day cares, home, and healthcare facilities, are a prime example of an area suffering from a concentration of pollution and a lack of environmental benefits such as parks, healthy food, and safe recreational areas. Many of the numerous schools in the community are crumbling and don’t have funding to deal with issues such asbestos, lead paint, mold, and poor indoor air quality. At home, many residents are faced with substandard housing quality. The high percentage of older homes means that many are energy inefficient, have lead paint, and are likely to have mold, mildew, and other air quality issues. Homeowners in the community were and continue to be hard hit by the foreclosure crisis, and the high percentage of rental apartments means that many residents are dependent on landlords to improve housing quality and make home more energy efficient. For homes that aren’t owner occupied, there is no financial incentive for the owner to make these upgrades, and the tenants are the ones who suffer from high energy costs and negative health impacts.

? Potential Disasters: dangerous facility in a high risk area

? Environmental Racism: ongoing and underlying environmental justice issues

? Climate Change: it causes climate change and is at risk from climate impacts

? Public Health: health disparities and impacts on health care institutions

? Economic Inequality: high cost project that will cause economic damage

? Alternatives and Solutions: Strategies for Climate Justice & a Just Transition

January 11, 2016January 23, 2016

Potential Disasters: dangerous facility in a high risk area

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Potential Disasters: dangerous facility in a high risk area

EJLRI02
Despite what the gas industry says, LNG is a dangerous substance. Developing additional large scale LNG infrastructure in densely populated urban areas, and particularly at Fields Point in the Port of Providence, poses a number of risks for potential disasters. This following section is an abbreviated summary of some of the risks and potentially dangerous scenarios. The gas industry is quick to state that LNG isn’t flammable or explosive, and that it isn’t stored under pressure. This is somewhat true, but it’s a dangerous half truth. LNG is stored at very cold temperatures (under 260°F), in double shelled containers without any air present. In these conditions, LNG is in stable liquid form and without air it is not flammable.

The potential dangers with LNG occur if something goes wrong and it leaves these conditions. At any temperature over 260°F it begins to boil and convert to methane gas, which causes it to expand by 600 times. At these temperatures, any sealed container would become rapidly pressurized. If LNG spills and begins mixing with air, it does become flammable between concentrations of 5 – 15 percent gas to air. For comparison, propane is flammable at concentrations of 2.1 – 9.5 percent, gasoline is flammable at 1.3 – 7.1 percent. As leaking or spilled LNG boils and expands, at first it presents hazards of cryogenic freezing (due it’s very cold temperature) and asphyxiation (due to it being heavier than air, displacing oxygen). If the expanding LNG cloud comes across an ignition source with enough air mixed in, it would become a pool of fire that can ignite back to the source of the spill. If the spilled LNG is pressurized (for example during the re-vaporization process, when LNG is converted back to gas to re-inject in to the grid), it can cause a jet fire. If a vapor cloud of boiling and expanding LNG occurs within a confined structure, and catches fire, it can become over pressured and potentially explosive. Ignition of pressurized liquids can cause a BLEVE: Boiling Liquid Expanding Vapor Explosion. (See here and here)

Relevant Past LNG Disasters

Washington State: March 31st, 2014

A rupture in one of the “pressure vessels” next to an LNG storage tank was cited as the cause of an explosion that injured 5 workers, sent 250 pound fragments of steel shrapnel flying over 300 yards, punctured a double shell LNG storage tank, and caused an evacuation of people within two miles from the LNG storage facility. “Benton County sheriff’s Deputy Joe Lusignan said Wednesday that it was ‘a little bit of a miracle’ that no one was killed. ‘It was an extremely powerful explosion, the initial explosion,’ he said. ‘Fortunately, we didn’t have any subsequent ones after that.’” The blast caused an evacuation within a 2 mile radius, far larger than the half mile area that National Grid is considering for impacts in Providence. Luckily, the area in Washington was sparsely populated, with only 1000 residents and agricultural workers evacuated, whereas a 2 mile radius from the LNG tank in Providence has a population of close to 80,000 people, which doesn’t include additional people at work, school, or in RI Hospital and trauma center. According the Reuters, the LNG blast in Washington “could focus attention on the risk of storing massive gas supplies near population centers.”

Skikda Algeria, January 2004

The port city of Skikda, Algeria suffered an explosion and deadly incident at an LNG Liquefaction Facility. A steam boiler exploded “after it probably drew flammable vapors from a hydrocarbon refrigerant leak into its air intake. This triggered a secondary, more massive vapor cloud explosion destroying a large portion of the plant. The incident killed 27 people, injured 74, and created an $800 million loss.” In the U.S, the 2004 incident spurred increasing opposition to LNG import facilities being proposed at the time. In response, “energy industry executives and regulatory officials have pointed out that the explosion in Skikda [was] attributed to a boiler that is not expected to be part of LNG terminals in the United States, which are to be used for warming liquefied gas back into a vapor, then storing it. The Skikda plant did the opposite, chilling natural gas until it condensed into a liquid.” National Grid’s proposed Liquefaction Facility in Providence would perform the same function as the Skikda plant in Algeria.

LNG Facility in Providence Denied in 2005 due to safety risks

In 2005, FERC denied an application from Keyspan (now National Grid) to expand the existing Fields Point LNG storage tank into an LNG import facility. FERC Commissioner Nora Brownell stated that the proposal was turned down because of safety risks and the “very real concerns made by the residents in communities and all of the towns nearby.” The “Commission staff concluded that the KeySpan LNG conversion project would not meet current federal safety standards… [and] identified 75 specific environmental mitigation measures that must be met by KeySpan LNG and its accompanying pipeline project [CP04223, CP04193].

A report by former White House anti-terrorism adviser Richard Clarke concluded that “urban import terminals, such as Fields Point LNG, would be vulnerable to “catastrophic” terrorist attacks, and also make “extremely attractive” terrorist targets.” In the detailed 159 page report, Clarke details multiple scenarios in which an attack on the LNG facility in Fields Point Providence results in an LNG pool fire and catastrophic mass casualties. The comprehensive report detailed neighboring industrial and chemical facilities that would be impacted by a LNG fire, but said that further study would be needed to assess the additional risks posed.

High Risk Neighbor: Univar Chemical Facility 

The proposed LNG Liquefaction facility neighbors a chemical facility owned by Univar, a multinational chemical corporation that also happens to manufacture chemicals for hydraulic fracturing (“fracking”). Fracking is a controversial process used in extracting natural gas from shale and other unconventional formations; the process has been banned in New York State due to public health concerns raised by the NY Department of Health. While it is unknown whether Univar’s facility in Providence has a direct link with fracking, the facility is listed on EPA’s Toxic Release Inventory due to onsite release 1,275 pounds of toxic chemicals in 2013. Chemicals listed on the EPA’s Toxic Release Inventory database for the Univar site in Fields Point include but are not limited to:

1,1,1TRICHLOROETHANE, ACETONE, AMMONIA, CHLORINE, CHLOROBENZENE, DI(2ETHYLHEXYL) PHTHALATE, DIBUTYL PHTHALATE, ETHYLENE GLYCOL, FORMALDEHYDE, FREON 113, METHANOL, N,NDIMETHYLFORMAMIDE, PHOSPHORIC ACID, SODIUM HYDROXIDE, STYRENE, TETRACHLOROETHYLENE, TOLUENE, TRICHLOROETHYLENE and TRIETHYLAMINE.

Former White House Anti-Terrorism official Richard Clarke wrote in his 2005 report on LNG in Fields Point that,

In the event of a [LNG] pool fire, temperatures would be high enough to compromise chemical storage tanks. Univar workers handle such chemicals as chlorine, sodium hydroxide, hydrogen peroxide, and potassium hydroxide at the site. Chlorine leaks can be lethal. For example, a recent chlorine gas leak in South Carolina killed nine people and required evacuations for up to one mile from the site. We do not know all the effects of gas leaks on all these chemicals, or the potential consequences of explosion of these chemicals caused by high heat from an LNG pool fire. Additional research into the safety of this chemical facility is needed in assessing the risks posed.”

14 mile hazard radius: 110,000 schoolchildren at risk

In 2014, the Center for Effective Government released a report titled “Kids in Danger Zones: One in Three U.S. Schoolchildren at Risk from Chemical Catastrophes” which investigated schools being located within the hazard radius of chemical facilities. Appendix III of the report shows the percentage of students in vulnerability zones, by state. With 67 percent of students at risk from a chemical incident, Rhode Island is ranked 2nd highest nationwide, ranking above both Texas and Louisiana which are both known for welcoming petrochemical facilities in busy Gulf of Mexico ports. RI’s high chemical risk ranking is due almost entirely to the Univar chemical facility in Providence, adjacent to the proposed LNG Liquefaction Facility. Within the 14 mile hazard radius of the facility there are 311 schools with approximately 110,000 children.

Major Fuel Terminals and Fuel Transportation 

The Port of Providence is the largest fuel port in Southern New England, and supplies oil products (gasoline, diesel, ethanol, jet fuel, etc) to all of Rhode Island, Eastern Connecticut, and Worcester County and South Coast Massachusetts. The fuels are transported in and out of South Providence by international tanker ships, heavy truck traffic, and and a railway line that travels between I95 and Roger Williams Park and Zoo before connecting with the Amtrak and MBTA Commuter Train tracks in South Elmwood. Port of Providence has terminals operated by Sprague Energy, Global Partners LP, Enterprise Products (subsidiary of Duke Energy), New England Petroleum, and Motiva (a joint venture between Shell Oil and Saudi Arabia’s Aramco). National Grid’s LNG storage tank and proposed liquefaction facility is bordered by the Motiva terminal to the West and Northwest, and next to Global’s terminal to the South and Southeast.

Given the close proximity of highly flammable and potentially explosive substances, an incident at one facility could trigger a secondary incident at a neighboring facility. An incident, whether caused by natural disaster, human error, equipment malfunction, or terrorism, could quickly spread and cause much larger incidents. The presence of pipelines, tanker ships, fuel trucks, storage tanks, and ethanol trains each pose individual risks, their concentration in close proximity multiplies the potential scenarios in which an incident could occur. The Thurbers Ave exit is one of the busiest set of highway ramps in Rhode Island, with sharp turns and confusing cross traffic patterns. This is the exit that the majority of truck traffic into and out of the port uses, including the LNG tanker trucks carrying “methane refrigerated liquid.” Any potential accident, and the resulting disaster scenario, must be taken into consideration with National Grid’s proposed Liquefaction Facility.

Ethanol “bomb” trains

Ethanol trains docking at the Motiva terminal are within the half mile hazard radius of the proposed Liquefaction Facility, and are directly adjacent to the sharp turn on I95 by the Thurbers Ave exit. It is not unfathomable to conceive of a potential disaster involving a traffic accident with a fuel tanker or train car containing explosive ethanol or toxic chemicals traveling into or out of the port. In preparation for a potential incident, RI Department of Environmental Management and the City of Providence hosted a TriState HAZMAT FullScale Response Exercise on September 10th, 2011 focusing on a scenario of an ethanol train derailment at the Motiva terminal in Port of Providence, requiring both landbased and marine response teams.

According to the joint press release,“Ethanol is a highly volatile, flammable, colorless clear liquid and unlike gasoline, is completely soluble in water rendering containment boom and absorbent boom virtually useless during a release. More than two million gallons of denatured ethanol move through the Port of Providence area by rail, barge, and tractor trailer every week.” In 2014, community groups in Boston organized against ethanol trains coming through densely populated neighborhoods and sharing tracks with MBTA and commuter rail trains. Alternatives for Communities & Environment(ACE), Chelsea Collaborative, and Chelsea Creek Action Collaborative successfully won a statewide legislative moratorium against the dangerous ethanol “bomb”trains. (See here and here)

Dangerous incidents occurring in the Port of Providence

The following are not just hypothetical scenarios to study, they have occurred in the past. Luckily, previous incidents have been contained and have not escalated to worst case scenarios, but that potential exists.

Lightning Strike

On July 19, 2006 lightning struck an oil tanker that was about to dock at the Motiva facility adjacent to National Grid’s LNG tank. Associated Press reported that it resulted in a four alarm fire and that “every firefighter in Providence was on the scene.” A truck driver parked nearby said he“saw a bolt of lightning, followed by an explosion and a large fireball. [He] said he could feel the heat from the initial explosion several hundred feet away in a nearby parking lot. ”I’ve never seen anything in the world like this,” he said.” EPA responded by setting up air quality monitors nearby to check for toxic releases of airborne pollutants.

Earthquake

On July 22, 2015 there was a 2.3 magnitude earthquake in Rhode Island which was felt in Johnston RI, and Bristol RI, and Fall River, MA. The epicenter was determined to be in the Port of Providence at Fields Point, the exact location of the existing LNG storage tank and proposed Liquefaction Facility. According to R.J. Heim, reporting for WJAR/NBC10, “the earthquake leaves many people wondering if it compromised infrastructure at the busy port or shake a cluster of fuel tanks located nearby.” National Grid reported that their facility was not compromised, but questions remain as to whether the outcome would have been different if the Liquefaction Facility were in operation at the time, or if a stronger earthquake were to hit along the same fault line.

Hurricane

Hurricane Sandy was devastating for New York City and parts of the southern coast of Rhode Island, but luckily was not a direct hit on Providence. The Port of Providence is at sea level, and is on the wrong side of the Hurricane Barrier. A significant storm surge coming up Narragansett Bay would be blocked at the Hurricane Barrier, protecting downtown Providence that would cause additional surge and impacting the port. Of three major tidally influenced rivers that flow into Narragansett Bay in Providence, the Hurricane Barrier would block a storm surge from entering the Woonasquatucket or Moshassuck Rivers, displacing that excess water into the Blackstone River and the narrow top of the bay, where this heavy industrial port is located. A joint research project by University of Rhode Island, the RI Department of Transportation, and the Federal Highway Administration recognizes that “hurricanes pose a significant threat” and is undertaking a vulnerability assessment of infrastructure at the Port of Providence. However, most studies of storm impacts on the Port of Providence only consider the economic impact and how to make infrastructure more resilient; the impact on the communities of South Providence and Washington Park is often ignored.

Emergency Preparedness and Response

There are many potential disasters waiting to happen with the existing industries in Port of Providence, let alone with the proposed $100 million liquefaction facility. While there has been at least one disaster response exercise focused on the port, and a large quantity of specialized foam was purchased following the lightning induced fire at the Motiva terminal, neither of these initiatives relate to the specialized disaster response scenarios required in the event of an LNG or a secondary Univar chemical facility incident. Given the high concentration of facilities in the Port that store toxic materials, discharge pollutants, and/or require a chemical risk management plan, there are major questions remaining about what the overall disaster response plan is, who would be able to respond, and whether those responders would have the proper training and equipment required.

Richard Clarke’s 2005 report LNG Facilities in Urban Areas details many possible disaster scenarios that the state is ill equipped the handle. While scenarios involving LNG import tankers no longer apply due to FERC’s rejection of the previous 2005 proposal, the existing LNG incidents around the world have all been with Liquefaction Facilities, Peak Shaving storage tanks, or tanker trucks all of which are or will be present in Port of Providence.

What would happen if an incident compromised the I95 corridor near Thurbers Ave, or if an event impacted the state’s only trauma center? How would a two mile radius evacuation of a densely populated area occur, with RI Hospital, Hasbro Children’s Hospital, and Women and Infants all being within the two miles? What plans are in place to protect the children who attend schools within the hazard radius? Do any existing plans for disaster preparation and response take into account the high level of linguistic diversity within the community?

● Potential Disasters: dangerous facility in a high risk area

● Environmental Racism: ongoing and underlying environmental justice issues

● Climate Change: it causes climate change and is at risk from climate impacts

● Public Health: health disparities and impacts on health care institutions

● Economic Inequality: high cost project that will cause economic damage

● Alternatives and Solutions: Strategies for Climate Justice & a Just Transition

January 10, 2016January 23, 2016

Flawed Proposal: Background info on National Grid’s liquefaction proposal

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The Environmental Justice League of Rhode Island (EJLRI) has created a position paper, “National Grid’s Liquefied Natural Gas (LNG) Liquefaction Facility: Toxic Hazards in the Port Providence: Proposals for a Just Transition” that eviscerates National Grid‘s plans to build a new liquefaction facility for fracked LNG at Field’s Point in South Providence. Over the next few days RI Future will be presenting EJLRI’s paper in its entirety.

Introduction

This document is a detailed response to the many reasons to oppose National Grid’s proposal to build a $100 million Liquefied Natural Gas (LNG) production plant in the Port of Providence. This project (also known as the “Fields Point Liquefaction Facility”) is costly and dangerous, and it is being planned for an area with many existing environmental justice concerns.

Beyond the obvious problem of having ratepayers (all of us) pay the bill for National Grid to benefit their own bottom line, there many specific concerns about the project. This report groups these concerns into the following major categories:

● Flawed Proposal: Background info on National Grid’s unnecessary project

● Potential Disasters: dangerous facility in a high risk area

● Environmental Racism: ongoing and underlying environmental justice issues

● Climate Change: it causes climate change and is at risk from climate impacts

● Public Health: health disparities and impacts on health care institutions

● Economic Inequality: high cost project that will cause economic damage

● Alternatives and Solutions: Strategies for Climate Justice & a Just Transition

The goal of this report is to make the case for organizations, businesses, residents, agencies, and public officials to join us in rejecting National Grid’s proposal, and supporting the alternatives and solutions highlighted at the end of the report.

Background on National Grid’s proposal

According to National Grid, their proposal to build a Liquefied Natural Gas production facility in South Providence in necessary, safe, clean, and will have no major negative impact. We disagree on all these counts, and explain why throughout the remainder of this report.

National Grid’s case for the project is available on their website. National Grid needs to get approval from the Federal Energy Regulatory Commission (FERC), and all of the documents submitted by National Grid and comments from any other stakeholder are available on FERC’s website under Docket # PF1528 (Search at https://elibrary.ferc.gov/) . Since National Grid’s perspective is detailed on websites, media stories taken directly from company press releases, and in hundreds of pages sent to FERC, we won’t use much space here describing their project proposal.

The main points are:

● Instead of delivering LNG to the storage facility in Providence via truck, National Grid wants to build a $100 million facility to produce LNG directly from a Spectra Energy pipeline that delivers gas from Marcellus Shale (Pennsylvania) to Providence.

● LNG is produced by cooling natural gas (methane) to 260 degrees, which reduces its volume by 600 times and puts it into liquid form

● LNG is currently only needed in RI for up to 9 days each year

● National Grid would then use LNG tanker trucks to export the LNG produced in  Providence to other locations in Rhode Island and Massachusetts

● The production facility would require a gas compressor station and an electrical cooling  system that would use 15 Megawatts. (for reference, this is half of the 30 megawatts that Deepwater Wind will generate off the coast of Block Island)

There is no justified need for the project.

According to National Grid’s own information, the existing LNG storage is only used up to 9 days each year, and is less than half of the gas used even on the coldest days with the highest demand. National Grid says the requests to increase the supply of LNG come from two storage customers: Narragansett Electric Company and Boston Gas Company. Both of these companies are subsidiaries of National Grid.

National Grid’s “Public Participation Plan” is incredibly flawed.

In the document submitted to FERC, there are no actual community groups on their listing of Environmental, Community, and Neighborhood Stakeholders. The only two groups included, the South Providence Neighborhood Association and the Washington Park Neighborhood Association, don’t actually exist. When questioned about this, National Grid’s spokesperson David Graves responded that “The stakeholder list was first developed when both of these groups were active in the  neighborhood” which is also false, since neither group has ever existed. David Graves also stated that National Grid “[has] not been successful in locating any other neighborhood groups in the area that have an organized board of directors or a published list of officers and, to my knowledge, we have not been contacted by any neighborhood groups asking to be included in the list of stakeholders.” This is despite the fact that there are many thriving organizations in Providence, including three local groups that came to National Grid’s Open House on August 13, 2015 to speak out against the project (PrYSM: Providence Student Youth Movement, PSU: Providence Student Union, and EJLRI: Environmental Justice League of Rhode Island).

There were numerous articles written about the protest at the open house. (See: here, here and here.)

National Grid’s internal review and list of impacted stakeholders is flawed and limited in multiple ways. Most of their documents only refer to a 1⁄2 mile radius from the project, at some points only a 1⁄4 mile. Within this range are mostly other industrial projects and businesses, with only a few residential buildings considered. National Grid suppressed the addresses of who they have contacted, but stated they sent letters to affected landowners within 1⁄2 mile, which would only include industrial businesses and some landlords (not rental tenants). The required public Open House, held on August 13th 2015, was not well advertised. The time and date were printed once in the Providence Journal in July as part of the initial press release, but the time and date were not listed on National Grid’s project website, which just listed the Open House as being “in August” and required emailing National Grid to ask for time and date.

At the time of the Open House, the website and all materials were only in English, despite the fact that Spanish is a predominant language in the community where the facility is being proposed. It appears that National Grid has not made any effort to actually engage the community. Those community members who did participate in the poorly promoted Open House were racially profiled and threatened by an excessive police presence and were ignored by National Grid in later correspondences with FERC and media inquiry.

In order to understand the impact of the project on the neighboring community, the analysis must use a radius of at least 1 mile from the proposed site. Cumulative impacts and evacuation plans for potential disasters must consider at least a 2 mile radius. Given the demographics of the community and the concentration of other industrial activity at the location, a full analysis of the cumulative impacts must be included, and issues such as public health, climate change, and environmental justice concerns need to be analyzed in depth.

Next: Potential Disasters: dangerous facility in a high risk area

November 30, 2015May 28, 2016

Former inspectors allege safety issues with Spectra pipeline project

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Two safety inspectors who worked on Spectra Energy’s proposed methane gas pipeline that will cut through Burrillville, RI, say the company cut corners when it came to project, worker and environmental safety.

“Right now, what they’re hoping to do, is they’re hoping to slam all this through, and then at the end ask for forgiveness,” said one of the former inspectors. “Oops, sorry about that, I didn’t know, let me write you a check. Because once this thing’s turning meter, they’re going to be making millions of dollars a day. It doesn’t matter what your problems are…”

The other added, “We were told to shut the fuck up or quit.”

Both men, who spoke on the condition of anonymity, were subcontracted by Spectra and both were terminated from the project this summer. I was introduced to them through FANG (Fighting Against Natural Gas), an environmental group that opposes the project, and have spent time talking with both men by phone as well as reviewing audio interviews and emails provided by FANG.

“Like every other company, Spectra gives a tremendous presentation about their commitment to safety, but their actions lack any kind of resolve. No one ever says, ‘Safety’s #2 here,’” said the first inspector. “At every turn when I made a safety suggestion, I was met with monumental resistance from the company on every level.”

Perhaps suspecting their days are numbered, fossil fuel companies are rushing to build the infrastructure required to keep us dependent on methane or “natural” gas for the next 50 years or more, even as evidence mounts that methane is a major contributor to climate change. This gives lie to the claim that methane will serve as a bridge fuel, something to ease the transition from fossil fuels to green energy sources, as the infrastructure investments being made are long term and permanent. Companies are investing billions laying pipelines, building compressor stations, and constructing energy plants and other infrastructure ahead of industry-wide extinction.

In their rush to build, safety and environmental concerns are being brushed aside, suspect many experts. A recent “Pipeline Safety Trust analysis of federal data,” shows that, “new pipelines are failing at a rate on par with gas transmission lines installed before the 1940s.” Sarah Smith writes that Carl Weimer, director of the Pipeline Safety Trust, told attendees at a National Association of Pipeline Safety Representatives annual meeting in Tempe, AZ that, “The new pipelines are failing even worse than the oldest pipelines.”

Though some of the problems may be related to workers learning how to implement the latest technologies, Weimar says, “there’s also some suggestions that we’re trying to put so many new miles of pipeline in the ground so fast that people aren’t doing construction … the way they ought to.”

In the same piece Smith quotes Robert Hall, of the National Transportation Safety Board Office of Railroad, Pipeline and Hazardous Materials Investigations, who agreed that, “the rapid construction of pipelines in the U.S. is likely a contributing factor to ‘people … out there possibly taking shortcuts or not being as diligent’ as they would be if the pace of construction were less fervent.”

Coming forward to confirm these observations are two former Spectra contractors I’m calling Inspector One and Inspector Two. Both wish to remain anonymous for this piece for personal and professional reasons, though they know that their former bosses may be able to identify them.

Inspector One is a safety contractor who briefly worked for Spectra in the Summer of 2015. His job was to act as the safety inspector for the four compressor stations being built in Burrillville RI, Stony Point NY, Cromwell CT and Chaplain CT. Inspector One claims that safety and the environment are being compromised in the rush to build pipelines.

His job was to document accidents and write reports, correcting behaviors so that accidents will not be repeated. His job is also to be on site and monitor the work, correcting actions that might lead to injuries before they happen. He worked with two other inspectors on his level, and supervised the work of many other onsite inspectors.

“‘Safety Above All Else’ is the slogan, it’s the sticker on our helmets,” he told me. “Instead of talking about what we could do better, and valuing my opinion … what they were doing is they were coaching us, telling us specifically how to circumvent rules.

“First week of being on [the Spectra] job, a guy breaks his leg. Steps out of a trailer that did not have a notice to occupy, steps out, breaks his leg. I wasn’t involved in the process of documenting that accident. I was told, ‘we’ll handle that, we’ve got it under control, don’t worry about it.’ I was told not to write up a report.”

The injuries kept on coming.

“Two weeks before I was let go they had a guy turn an excavator over… with the guy in the cab. How that happens is that you got a guy who doesn’t know the machinery, doesn’t have it rigged properly, doesn’t understand leverage or topography,” said Inspector One. “It’s a pretty big deal when someone turns over a half million dollar machine.”

When contacted, a Spectra spokesperson told me that they have no record of an excavator turnover happening on any of their work sites. I asked if the Spectra system includes subcontractors, and was told they did. When I spoke to Inspector One, he provided more details. “It was the lay down yard in Franklin Ct,” he said. That’s a fab shop where materials are prepared for installation out in the field. The excavator was loading or unloading pipes. “I was told to stay out of it,” he said. “My direct supervisor told me he had it under control.”

Another time, “I had three guys in one day suffer from heat exhaustion.”

Eventually Inspector One’s boss just wanted him to train people to be on site. Before a worker is allowed on site they receive a three hour orientation. Inspector One’s job is to run them through the 90 minute safety training, before they receive their environmental and site specific training. Inspector One suspects that his new focus on training was a way of getting him out of the way, so he wouldn’t be able to report safety violations and slow down the job.

“They were always strategically placing me out of the field when something critical was going on,” says Inspector One, “They started doing work on Sundays, they shouldn’t work on Sundays without me knowing. They had guys working until 11 o’clock at night one night. We get to work at 6:30 in the morning. How can I keep things safe when I work all day and into the night like that? And you don’t even let me know?

“We’ve had guys break their legs, burns, cuts, near misses, dropped objects, slough off in holes, working in standing water in holes, not monitoring spaces, huge violations. Huge violations that anywhere else I’d say ‘you’re gone, you’re gone, you’re gone.’

“I’ve got people working after hours and on weekends to get critical stuff done so that I will not have an opportunity to intervene in it.

“It’s safety above all else until you have a one billion dollar project that’s behind on permits, then its go, let’s go.”

In addition to a lax attitude towards worker safety, Inspector One also alleges some environmental trespasses.

“This is a FERC project, okay? The way we treat the environment is hypercritical, but you got guys pot-shotting deer out of season on our property in New York, and everybody knows it. And they’re throwing them into the back of a truck and driving off with them. Do you know what would happen if that were to be caught? Our whole project would be shut down.”

Spectra does not allow weapons on a work site, says Inspector One, but one worker brought along his bow and arrow, claiming that they were for competitive archery, not hunting. The deer was shot with an arrow, but wasn’t the only imperiled wildlife.

“You know there’s some endangered spotted turtles, I don’t know, I just tell the men don’t touch it. Whatever it is, don’t harass any species, whatever it is, don’t touch it. If there’s a snake that doesn’t disperse on its own leave it alone we’ll get a wrangler out there to deal with it…” says Inspector One, but some among the construction crews didn’t listen. Men were moving snakes or throwing cans to disperse raccoon.

Once Inspector One gets going on the environmental concerns, it’s like a flood gate opened. “I’ve got run off going into goddamn public streams! I got tires not being washed going out onto public roadways. I’m telling them we can’t have this, and if you think I’m a prick, wait until the FERC inspector gets out here… Taking topsoil off the property, to your home to use, that’s not allowed. That soil could be contaminated. Taking metal parts, flanges, elbows, things like that and getting scrap metal money for them so you can buy lunch for your crew that day, it’s not allowed. That stuff could be contaminated with all kinds of cancer causing things that can hurt you, hurt the environment.”

The lack of concern Spectra allegedly showed towards safety and the environment extended to the cultural concerns of Native Americans, maintains Inspector One. “The delaying of our permits was in part due to the ceremonial stones and things like that that are related to the Native American population… I have observed stones moved in New York, but no one has the documentation to say that it is okay. I know where there are ceremonial Indian grounds that have been moved.”

This is where Inspector Two comes in. Before he was let go by Spectra he was an electrical and instrumentation inspector with real concern for the sanctity of sacred spaces. He confirmed much of Inspector One’s story, saying, for instance, “Spectra neither cares for the public nor the workers. This is a fact. They do not care what happens as long as they flow gas.”

Native American land was clear cut far more than was required for the project, says Inspector Two. “They bulldozed 75 percent just for work space… When the big trucks made their delivery no attempts were made to protect the trees.”

Trees were clear cut for temporary parking and work space says Inspector Two. With planning that could have been avoided.

This isn’t simply an issue of a company cutting corners and taking risks with worker safety, endangered turtles and tribal lands. Inspector One says that the behaviors he’s noted could have catastrophic consequences.

“These pipes have to last underground for at least 50 years,” says Inspector One, “If there’s the smallest mistake in their cathodic protection, that’s what’s going to corrode. All of a sudden you’ve got, even at 800-900 pounds of pressure, doesn’t sound like much, but when you’ve got a 42 inch pipe, traveling that distance and it goes ka-bang, you’re not talking about taking out a block, you’re talking about taking out a large area. You’re talking about a humongous ecological impact, you’re talking about displacing hundreds of families, you’re talking about leveling homes, killing people instantly, I mean, if one of those places were to go up, it’s going to be a bad day.”

In 2011 a cast-iron gas pipe cracked, causing an explosion that killed five people in Allentown, PA. Pipes like those are no longer used. But when work is rushed, construction is sloppy and disaster is possible.

“There’s a reason we do what we do,” said Inspector One, “Every bolt is torqued. I know when you torqued it, I know what torque wrench you used, what model number, when it was calibrated. That’s how serious every flange has to be. Because if one of these points blow up you’re talking about a humongous issue. These guys are making those kind of mistakes. They’re short-cutting things, they’re not inspecting things properly, they’re covering stuff up before an inspector’s had a chance to look at it.

“I have had inspectors that have come up to me in the field and have said to me that there is a pipe buried under ground that was not inspected appropriately. And the reason that it was not excavated and inspected is that it cost too much money.”

All pipeline welds are examined with x-rays to make sure they are up to code. After the weld is x-rayed the inspector waits for the film to come back from the lab. “How is it that you have a pipe already buried before you receive the film?” Inspector One asks, noting that he had a tech “receiving the film (on Tuesday) for a pipe buried last Wednesday.”

Spectra has a “has a checkered history of accidents and violations of federal safety rules in the U.S. and Canada dating back decades,” says Dan Christensen writing in the Miami Herald. “Since 2006, the U.S. Pipeline and Hazardous Materials Safety Administration recorded 25 incidents that caused more than $12 million in property damage along Spectra’s main line — the 9,000-mile Texas Eastern Transmission that connects Texas and the Gulf Coast with big urban markets in the Northeast. The causes ranged from equipment failure and incorrect operations to pipe corrosion.”

SpectraBusters has a long list of links to stories about Spectra’s poor performance record.

Inspector One was let go in August. To this day he has not been told why. One day he realized that his computer privileges had been shut down and his laptop erased remotely. His dismissal affected him economically, personally and professionally.

Meanwhile, the hits keep coming.

In June a pipeline rupture closed two miles of river in Arkansas, and in the last few days a chemical leak shut down a Spectra gas plant in British Columbia.

As Rhode Island welcomes more and more gas infrastructure into our state, the question must be asked: Is Burrillville, RI next?

These are “large diameter, high pressure, long distance gas pipelines,” says Inspector One, “A failure represents a catastrophic environmental and personal hazard. Just look at situations like Allentown…

FANG (Fighting Against Natural Gas) is launching a website, SpectraExposed to store full transcripts of their interviews with the two inspectors.

November 10, 2015

National Grid responds to liquefaction opposition

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National Grid has proposed a liquefaction plant as an addition to the Field’s Point gas storage facility, to be located in South Providence, and every single comment the Federal Energy Regulatory Commission (FERC) received on the proposed facility from the public was negative and against the facility’s construction. No one from the public, it seems, is in favor of the project.

Of course this will not deter National Grid.

In a 39 page letter, National Grid’s legal counsel responded to every commenter. Of course, some of the comments were dismissed as irrelevant with the phrase, “Expression of commenter’s view.” This phrase was repeated 27 times, in response, for instance, to Greg Gerritt saying, “Climate change is the crisis of our times” or Jesus Holguin saying, “This facility is not going to benefit us in any way. Something that would benefit us is [a] just transition away from fossil fuels.”

National Grid’s legal team sorted through the testimony of the various commenters and pulled out all the statements that “identify potential environmental effects, reasonable alternatives, and measures to avoid or lessen environmental impacts.” Expressed concerns that were not environmental in nature will be addressed at a later time, says National Grid.

The sloppiness of the response’s composition is evident in some of the misspellings of various names. Monay McNeil is misspelled Money McNeil and state Representative Aaron Regunberg is misidentified as Erin Regunberg for instance.

Further, the response to each comment, if the comment was deemed worthy of response, is footnoted in some 13 documents called “draft resource reports” and filed with FERC on November 2 and 4. This means that finding the reason for National Grid’s objection to a particular comment requires cross referencing footnotes with the draft resource reports.

For instance, when Rhode Island state Senator Juan Pichardo was paraphrased as saying he was, “Opposed to this LNG or this facility being built and the waterfront is so close to hospitals and so close to the neighborhood,” National Grid responded with:

Refer to Resource Report 1, Section 1.4 (page 1-14) (Operation and Maintenance).

Refer to Resource Report 5, Section 5.3.2 (pages 5-8 through 9) (Fire Protection), Section 5.7 (pages 5-13 through 5-22) (Environmental Justice) and Section 5.9.2.6 (page 5-28) (Environmental Justice Socioeconomics).

Refer to Resource Report 8, Section 8.2.2 (Existing Residences and Buildings).

Refer to Resource Report 11, Section 11.1 (pages 11-2 through 11-8) (Safety Issues), Section 11.2.3.2 (pages 11-10 and 11-11) (Thermal Radiation and Flammable Exclusion Zones) and Section 11.3.1 (page 11-11) (Facility Response Plan).

Refer to Resource Report 13, Section 13.14 ((pages 13-102 through 104) Hazard Detection System), Section 13.15 (pages 13-105 through 109) (Fire Suppression and Response Plan) and Section 13.16 (pages 13-110 through 111) (Hazard Control Systems).

Senator Pichardo could spend quite a bit of time wading through page after page of reports to find out exactly why National Grid believes his concerns are without merit, if he were so inclined.

To be fair, pages 2-9 of National Grid’s legal response attempt to distill the information from the draft resource reports into a few paragraphs organized by subject, such as “Traffic Impacts” or “Comments on Rate and Cost Impacts on Retail Gas Customers.” In these sections, the concerns and opinions expressed by the public are legally elided by claiming that the law is on the side of National Grid, a legal position that National Grid maintains, but does not prove. Remember that all the documentation National Grid is submitting to FERC are essentially sales documents, created to convince FERC to approve the project over the objections of the public.

For instance, in response to a complaint made that the public meetings were not adequately advertised within the affected community, National Grid’s legal team writes, “Some stakeholders commented on the quality of the public notification that has been provided to local residents for the proposed Project. Resource Report 5, section 5.7.2 discusses the public outreach undertaken by NGLNG to communicate with the environmental justice populations near the proposed Project…”

In other words, despite the experience of the community, National Grid maintains that they satisfied the letter of the law.

There’s a lot in the legal team’s response worthy of comment, and I hope others will chime in with comments on this, but one more point is worth consideration. National Grid is a huge company, with many subsidiaries and ventures. So when National Grid says that there is a customer need for the new liquefaction facility, it should be noted that the customer mentioned is The Narragansett Electric Company, which is owned by National Grid.

At another point, when discussing rate impacts, National Grid disingenuously claims that, “State public utility commissions regulate retail rates.” This is true as far as it goes, until one realizes that the Rhode Island Public Utility Commission serves as a virtual rubber stamping agency for any rate increase proposed by utility companies such as National Grid or its subsidiary, Narragansett Electric.

Like an evil octopus, National Grid wants us to believe that it’s various tentacles aren’t actually all parts of some enormous beast, but independent snakes acting alone.

This is why it is difficult to take seriously National Grid’s answer to the comments of Nick Katkevich, who “urged that the environmental effects of the proposed Project be considered in the same environmental document as pipeline projects sponsored by subsidiaries of Spectra Energy Partners, LP in New England, specifically the AIM, Atlantic Bridge, and Access Northeast projects.”

National Grid claims that these are all separate projects that must each be judged independently, and that there will be no cumulative environmental effects, at least as can be judged under present law. National Grid claims that the liquefaction facility “would be undertaken even if those pipeline projects did not or do not proceed” and “is an unconnected single action that has independent utility so it would not be appropriate to consider it in the same environmental analysis with any of the pipeline expansion projects.”

Despite the contentions of National Grid’s legal team, the planned expansion of fracked and unfracked methane gas infrastructure in Rhode Island seems part of a grand plan to keep our state addicted to fossil fuels that are destroying the environment. These proposed projects have lifespans of 50 years or more, yet optimistically we have much less than 35 years to kick the fossil fuel habit.

No amount of corporate legalese can change that math.

October 29, 2015October 30, 2015

RIDOH Director Alexander-Scott weighs in on LNG in PVD

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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.

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.

October 15, 2015May 3, 2016

Burrillville Town Council claims to be powerless against Spectra, Invenergy

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More than 50 people packed the Burrillville Town Council chamber to register their objection to the Spectra energy pipeline expansion and the new $700 million “Clear River” methane power plant that’s proposed for Wallum Lake Road by Invenergy. Kathy Martley, of Burrillville Against Spectra Expansion (BASE), presented the town council with research she had gathered outlining the health risks and dangers of pipelines and power plants in the community.

Council President John Pacheco III and the other councilors did not seem very receptive to the concerns of the citizens in attendance. In response to questions raised at previous meetings about half the town council recently toured the Spectra plant and examined the work being done on the pipeline. They left satisfied that the pipes were not corroding and that the noise levels were within acceptable limits.

One town councilor said that during the tour they were told that Spectra was digging up some pipelines, so the noise was louder than usual. She seemed surprised that those in attendance laughed. But it was less funny when the town council revealed that all the information they have on Spectra’s actions and all the information they have on safety and public health issues comes from Spectra, and there are no other sources of information available.

“We have no legal authority to regulate or look at their reports,” said Pacheco, “We have to rely on Spectra.”

This was the refrain of the Burrillville Town Council throughout the meeting. Only FERC (the Federal Energy Regulatory Agency) can regulate Spectra, claims the town council. Spectra doesn’t even have to obey the town’s noise ordinances. “We don’t have control over Spectra and we can’t enforce local ordinances” against them, said Town Councilor David Place.

Meanwhile the vibrations from the pipeline compressors are so overpowering that plates rattle in the cabinets of Kathy Sherman’s home, who lives across the street from Spectra, she said. She warned the town council that there may be dire impacts on Burrillville due to Spectra’s expansion that have nothing to do with health or the environment.

“When you have people leaving, not paying their taxes, you will suffer for that,” she said.

Said Kathy Martley of BASE, “The value of this town is going into the toilet. I urge you to pass a resolution to oppose this power plant.” The crowd overwhelmingly agreed, applauding and cheering Martley’s words. But the town council seemed unwilling to be moved by their voters.

“FERC and the governor have all the power,” says Councilor Nancy Binns, “we don’t.”

Several times Council President Pacheco tried to close off comment, and several times those in attendance had to insist on being heard. “Why don’t we get to vote on this?” asked a man at the back of the crowd, “Newport votes on gambling over and over again, but we just have to accept this?”

Instead of addressing the man’s concerns, Councilor Stephen Rawson insisted that discussing the new power plant would be illegal, since it’s not on the agenda, only the pipeline expansion is. This was news to Kathy Martley of BASE, who told me after the meeting that she’s pretty sure she asked that both items be on tonight’s docket.

Spectra held an open meeting recently in Burrillville. Residents were annoyed that “union people” holding signs in support of Spectra arrived early and took up all the parking spaces at the too small venue. Others complain that they don’t get proper notification about meetings from Spectra.

“Don’t you get notification of meetings?” asks a councilor.

“NO!” shouts virtually everyone in frustration.

“We asked about their notification process,” says Councilor Donald Fox, “they admitted that they aren’t as good as they used to be.”

Meanwhile, says Kathy Sherman, “No one from Spectra will return calls.”

The Town Councilors don’t want to be discussing this. They claim to be powerless in the face of Spectra. They recommend contacting Governor Gina Raimondo or State Representative Cale Keable. A man behind me says, referring to Keable, “He’s useless.”

Burrillville is home to two interstate methane gas pipelines, two methane gas compressor stations and the Ocean State power plant. Spectra Energy’s compressor station is already being expanded and a second expansion has been proposed. The proposed “Clear River” power plant plans to use Pascoag’s MBTE (methyl tert-butyl ether) tainted water supply for cooling.

In their press release, BASE suggested three things the town council could do in opposition to new methane energy infrastructure:

-Invenergy, the company that wants to build the plant, will try to negotiate with the town for a lower tax rate. If the Town refuses to negotiate with Invenergy and refuses to give them a tax break, the plant won’t be built.

-The Town will be asked by State agencies to submit official opinions about the power plant. If the Town Council says that they are against the plant, the State permits might not get approved.

-The power plant would need huge amounts of water to operate. The town has some power to deny Invenergy access to the local water supply and the pipes that will be needed to transport the water.

Amanda, another member of BASE, wants to know what the town council has done to move Burrillville towards a renewable energy future. After a few minutes of prevaricating, Councilor David Place is forced to admit that they’ve done almost nothing.

Invenergy also builds renewable energy power plants says Amanda, before demanding that the town council tell Invenergy to, “go solar or go home!”

After public comment on the subject is finally closed, and the citizens leave the building and gather outside on the sidewalk, no one seems happy with the performance of the town council. There is anger and frustration and talk of electing town councilors willing to stand with them against Spectra and Invenergy.

“When I started this two years ago, they could ignore me,” says Kathy Martley, of BASE, “They can’t ignore us any more.”

October 9, 2015October 29, 2015

FERC listens as no one speaks in favor of National Grids’ LNG facility

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No one spoke in favor of the project, but more than 100 people packed the room and 33 people spoke against National Grid‘s plan to build a $100 million methane gas liquefaction facility in Fields Point in South Providence before representatives of FERC (Federal Energy Regulatory Commission), the agency tasked with the job of approving or disapproving the project.

One after another speakers from the affected community, environmental activists, concerned Rhode Islanders and elected members of the General Assembly spoke passionately about negative environmental impacts and the explicit environmental racism implicit of National Grid’s plan.

The liquefaction facility is to be located adjacent to one of Rhode Island’s poorest communities, which already suffers from higher rates of asthma and other respiratory ailments. This community has become a sacrifice zone, a place where dangerous chemicals are stored. A representative from FERC admitted that some additional methane leaks are to be expected as a result of this plan, and methane is one of the most dangerous gases contributing to global warming and global catastrophe.

Peter Nightingale, a member of Fossil Free Rhode Island, has been involved in several FANG (Fighting Against Natural Gas) actions and who was arrested for his peaceful protest at Senator Sheldon Whitehouse‘s Providence office, pulled no punches when he told FERC, “To you who are here silently doing your jobs for this project I have but one thing to say: You are complicit in crimes against humanity and against Mother Earth.”

Monae McNeil, from the Environmental Justice League of Rhode Island (EJLRI), a group central to the community’s resistance to this project, said, that this project “puts low-income communities at risk, if something were to happen.” The site of the project is not protected by the hurricane barrier. There was an earthquake near this location in August. A disaster at this facility would affect as many as 140 thousand Rhode Islanders.

Jan Luby pointed out that no storage facilities like this are being proposed for Barrington, Lincoln or East Greenwich. Instead, these projects are proposed for low-income communities where resistance is expected to be minimal.

Greg Gerritt spoke on behalf of the Green Party of RI and Prosperity For RI. FERC, he said, “has never turned down one of these projects” demonstrating that the agency is not serious about climate change.

Kate Schati doesn’t live on the South Side, but she cares what happens there, because “it affects the people who live in Providence with me… I don’t want them to be at risk of a breach or a leak or an explosion or even the normal operation of a plant…”

Ben Boyd: “…we need to be investing in clean, renewable, sustainable energy sources…”

One of the most impassioned testimonies of the evenings came from Stephen Dahl, of Kingston, RI. “Weep, weep, weep, weep,” he began, quoting William Blake on the Industrial Revolution. This was more performance piece as testimony, and was powerful.

Marti Rosenberg lives within the affected community. “This project shows us that the impact of fracking is much closer than we think.” Methane is used by communities near the South Side, but the South Side itself not so much. Instead, this community bears the brunt of the negative impacts of methane gas, and none of the benefits.

Peter Sugrue questioned National Grid’s motives for project. “We will clearly see a rate increase for this $100 million project,” yet all National Grid is promising is a smoothing of price volatility. How does this benefit Rhode Islanders, is that even to be honestly expected and is it worth the cost?

Paul Klinkman

Liberty Goodwin

Karen Palmer

Nick Katkevich of FANG, which has lead several actions against fracked gas infrastructure in Burrillville and Providence, promised resistance to this project in the event that FERC approves it.

Gina Rodriguez-Drix is a resident of Washington Park, a mother of two and a birth worker, is “deeply concerned about the disproportionate effects” this project will have on women and children of color in her neighborhood and other affected communities.

Julian Rodriguez-Drix is tired. “I’ve got a family with two kids, a full time job, and now it’s up to us to us, spending our free time poring through pages and pages of bureaucratic nonsense that is trying to find ways to justify a facility that you’ve heard everyone here speak out against.”

Representative Aaron Regunberg

Claudia Gorman

Servio

Lisa Petrie

Yudiglen Sena-Abrau

Jesus Holguin

Ana Quezada

Dania Flores is a board member of EJLRI. She spoke to the community (not to FERC) about how National Grid’s plan impacts the Latino community, about how we have our own solutions, and how we need to deport National Grid.

Paul

Beth Milham

Senator Josh Miller

Senator Juan Pichardo

August Juang

Vanessa Flores-Maldonado

Helen MacDonald

Steve Roberts

Susan Walker

Michelle Lacey

Will Lambek

October 1, 2015October 5, 2015

Public hearing on National Grid’s LNG production facility needs you

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Rhode Islanders will get their only chance to directly address their concerns regarding a proposed methane liquefaction facility in South Providence next Thursday night. The proposal needs approval by FERC (Federal Energy Regulatory Commission), an agency that has almost never turned down such an application in the past. (Though in 2005 FERC did reject an application for LNG infrastructure at Fields Point. It was from Keyspan Energy, a company later acquired by National Grid and it was a very different proposal.) So opponents need to turn out in force if the plan is to be defeated.

The liquefaction plant would be an expansion of an existing methane storage facility at Fields Point, near Thurbers Avenue. The expansion would allow National Grid to convert methane imported through the lng import facility in Everett MA and delivered by tanker truck into liquid form, allowing a greater amount of methane to be stored on site.

The Environmental Justice League of Rhode Island (EJLRI) says that the location of the site, near one of the poorest communities in Providence, and mostly populated by people of color, is environmental racism. Further, questions have been raised about the safety to the community due to unavoidable leaks of methane, benzene and the chemicals harmful to human health.

There are wider environmental concerns over the logic of expanding Rhode Island’s reliance on fossil fuels at a time when we should be seeking alternative forms of energy that do not contribute to global warming. Rhode Island has several infrastructure projects in the works to expand our dependence on fracked methane, infrastructure planned to last over fifty years, yet our best case estimates on fossil fuels gives us maybe a fifteen year window to leave them behind before passing the no return point in saving the planet from the worst effects of global warming.

And all this says nothing about the environmental devastation being wrought in those communities where methane is extracted.

Rhode Island should also carefully consider its relationship with National Grid, a company that each year seems to request (and is granted) obscene rate increases for energy, is being sued for violating the law by shutting off the power of the elderly and disabled, and included false information in the application for the liquefaction facility submitted to FERC.

How long are our political leaders, including Gina Raimondo, who wants to be seen as an environmental governor, going to support a lying, price gouging, environment destroying foreign multinational corporation over the health, wellbeing and future of the citizens of Rhode Island? There is a rising chorus of voices demanding substantive change in Rhode Island’s energy and environmental policy, and National Grid is not part of that change.

The EJLRI hopes to “pack the house” at the public hearing, saying that “otherwise, issues like environmental racism, health effects, economic inequality impacts, etc., won’t even be part of the debate.” They provided logistics and organizing info:

Logistics for FERC’s public hearing:

– each person will have a max of 3 minutes to speak
– starting at 6pm people can sign up to speak
– at 6:30, FERC will do a short presentation about the proposed project and their process for reviewing it, and will then call for speakers
– the hearing will go until everyone who signed up as spoken, or until 10:30, whichever comes first

Organizing info:

– whether or not you want to speak, COME SUPPORT! And bring signs or banners if you can
– If you know you’ll be wanting to speak, email info@ejlri.org with the topic you’ll want to speak out. Since everyone only has 3 minutes, we’ll work to make sure all the important topics get covered
– If you don’t know what to say, contact us (info@ejlri.org) and we can give you suggestions. We will also be passing out info sheets and brochures at the event with more info

Background on the issues – here are some articles that talk about reasons why this is a terrible idea and needs to be stopped.

Eco RI: National Grid Wants to Bring New LNG Project to Providence Waterfront

RI Future: Environmental Racism and the Fields Point LNG Plant

Eco RI: Activists Rally Against Providnece LNG Project

RI Future: Southside PVD Activists Speak Out Against Fields Point LNG Plant

September 25, 2015

Beyond Extreme Energy breaks fast at noon today

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Day 15 of fast at the Federal Energy Regulatory Commission—industry's rubber-stamp machine — Day 15 of fast at the Federal Energy Regulatory Commission, industry’s rubber-stamp machine

Fasters from Beyond Extreme Energy (BXE), together with their supporters from several faiths, will break bread in front of the Federal Energy Regulatory Commission (FERC) in D.C. today to end a dramatic 18-day hunger strike undertaken to demand that FERC stop issuing permits for the pipelines, storage facilities and LNG export terminals that use fracked natural gas, and instead heed Pope Francis’s call to care for the Earth, according to a BXE press release.

On Friday copies of the pope’s encyclical will be presented to the five FERC commissioners. There will be music, brief statements, and a procession, featuring BXE’s colorful and moving 50-foot anti-fracking banner, “The United Sates of Fracking.” BXE will also display the new quilt made in collaboration between fasters and residents of far-flung communities fighting fracking infrastructure in their communities.

“Being here, eating no food for 18 days, has taken me at 72 the oldest faster a fascinating and disorienting rabbit hole, where ‘normal’ appears absurd and even suicidal, and where unrealistic may be our only way out,” said Steve Norris, 72, of North Carolina, is one of the oldest fasters. “I think because of our legal structures, because of their narrow fossil fuel focus, and because people disbelieve in viable alternatives, their minds are wedded to the madness of more fossil fuels.”

Sean Glenn, 23, of Connecticut, is one of the youngest fasters. “I think this fast has just reinforced my belief in the power of people and our ability to overcome our old ways and really embrace new ones with complete curiosity, not knowing what we’re getting into,” she says. “The love that everyone has shown has been really powerful and the respect that we’re receiving for it is what has surprised me.”

WHERE: Federal Energy Regulatory Commission (FERC), 888 1st St NE, Washington, DC.

WHEN: Friday, Sept. 25, noon to 1:30 p.m.

WHO: The fasters, their supporters, and faith leaders.

WHY: The BXE fasters demand that FERC end its fracking-friendly support for expanding natural gas infrastructure, which has led to a toxic locked-in fossil fuel network at the expense of safe, sound, and clean renewable energy. Fracking wells and gas pipelines contaminate the homes and communities nearby, and also leak methane, which is responsible for about 25% of the man-made global warming we experience today.

Earlier this week a rally took place at the RI State House for People, Peace and Planet.

On Wednesday afternoon fasters adorned a street corner on the city side of the State House.

After that, on Wednesday, there was a vigil and prayer service at the State House in anticipation of Pope Francis’ address to Congress the following day.

Finally on Thursday, Fossil Free RI attended the celebration of International Peace Day at URI.

My oldest grandson, and youngest Fossil Free RI member, Octavio, at Peace Day on Quad at URI — My oldest grandson and youngest Fossil Free RI member, Octavio, at Peace Day on Quad at URI

Today at noon, our friends in DC, in Rhode Island and across the nation will break their fast. Also my wife, Beatrijs, and I will end our two-week fast; the battle against extractivism and wholesale destruction of life on Earth continues: “Where there is no vision, the people perish …” (Proverbs 29:18)

September 23, 2015

Protesters stage hunger strike outside FERC for Pope’s visit to DC

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The climate rally that took place outside the State House on Tuesday was just one of many protests taking place across the country in solidarity with a committed group of protesters who have occupied the side walk outside FERC (Federal Energy Regulatory Commission) since September 8. Members of Beyond Extreme Energy (BXE) have been targeting FERC for protest for a while, says Ted Glick, who has been fasting for two weeks and has lost over 20 pounds.

In July, BXE conducted an action that resulted in 25 arrests, Glick said. In November the group arranged to have people arrested for five straight days, culminating in an action that prevented FERC from opening for business for two and a half hours. The group’s latest tactic is fasting outside the FERC offices, hoping that FERC employees have a conscience and that they’re willing to act on it.

“In concert with the Pope coming to the US we decided to do a fast,” said Glick, “to both support the Pope on environmental issues and to draw attention to FERCs failure to do its job as a regulatory agency.”

2015-09-22 DC FERC 009 — Pramilla Malick

Glick says that the “gas energy companies always wins when it comes to interstate gas infrastructure.” FERC approves “virtually everything.” One group went back through FERC’s records and found that “there were 160 consecutive approvals of pipelines, with no dis-approvals.”

Over the course of the fast, BXE members have had a number of interactions with FERC employees, from conversations to glances. “We know we’ve had some impact,” says Glick hopefully, even as he maintains that FERC is corrupt.

“There is a revolving door in terms of people working at FERC and people going to work for the gas industry… It’s a classic case of what Robert Kennedy called a ‘captured agency.'”

Protesting BXE members came and went as I interviewed Glick, maybe 25 in total. Glick described the group as a “spiritual community.” When I asked him about that, he explained that, “I describe it as a spiritual community. We meet twice a day at nine. We check in on everybody physically, we try to help them… at the end of the meeting we join hands and have a minute of silence together. Its very powerful. It’s like a family atmosphere.”

Can activists turn our government, captured as it is by those who profit off of fracked methane, towards a truly renewable energy future in time to prevent the worst effects of climate catastrophe? That’s an open question.

With FERC closing up shop for two days because of the traffic congestion expected to accompany the Pope’s visit, the BXE fasters are taking their protest into the city, marching tomorrow to meet up with activists from the Franciscan Action Network. Twenty-five college students from North Carolina are arriving to help the weakened fasters make the trek.

On Friday, after the Pope leaves for New York and the fast is officially broken, BXE will attempt to distribute copies of the papal encyclical on climate to the FERC’s five commissioners.

“The Pope’s opposed to fracking,” says protester Jimmy Betts in a statement, “FERC is responsible for rubberstamping pretty much every application for fracked-gas infrastructure.” When the fasters brought pointed this out to FERC Chairman Norman Bay as he was leaving the building a few days ago, he said, “These are just pipelines. Blaming us is like blaming the steel companies that make pipes.”

You can watch my full interview with Ted Glick below:

September 15, 2015September 17, 2015

National Grid lists groups that don’t exist in their Public Participation Plan

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The Environmental Justice League of Rhode Island (EJLRI) has revealed that the “Public Participation Plan” that National Grid submitted to the Federal Energy Regulatory Commission (FERC) contains no actual community groups in its listing of “Environmental, Community and Neighborhood stakeholders.” The two groups that National Grid did included on the list, the South Providence Neighborhood Association and the Washington Park Neighborhood Association, don’t actually exist. Further, EJLRI points out that “dangerous oil and chemical facilities like Motiva, Univar, and Sprague Energy are counted as community partners.”

The nonexistent groups were listed with FERC as part of National Grid’s plan to build a LNG liquefaction system at the Fields Point LNG Plant on Providence’s South Side. The EJLRI and many other environmental and community groups oppose the expansion. The location of the Fields Point Plant, adjacent to low income communities of color, is seen as environmental racism. And investing in methane gas, which has been revealed to be worse for the environment than coal and oil, seems economically and environmentally catastrophic given the reality of global warming.

David Graves, who does media relations for National Grid, responded that, “The stakeholder list was first developed when both of these groups were active in the neighborhood. The list continues to evolve and contacts for various organizations have been, and will continue to be updated. We have not been successful in locating any other neighborhood groups in the area that have an organized board of directors or a published list of officers and, to my knowledge, we have not been contacted by any neighborhood groups asking to be included in the list of stakeholders. Despite that, our efforts will continue.”

Said the EJLRI, “…there are hundreds of thriving organizations in South Providence and Washington Park.”

August 15, 2015August 18, 2015

Environmental racism and the Fields Point LNG Plant

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National Grid‘s plan to build a LNG liquefaction system at the Fields Point LNG Plant on Providence’s South Side met with vocal opposition from several environmental, social and economic justice groups and highlighted the issue of racial injustice in environmental politics. Representatives from the Providence Youth Student Movement (PrYSM), the Providence Student Union (PSU) and the Environmental Justice League of Rhode Island (EJLRI) took control of the room at one point to conduct a peaceful speak out for the benefit of representatives from both National Grid and FERC (Federal Energy Regulatory Commission.)

The event, as planned by National Grid, was unusual. Instead of a series of presentations delivered from a stage, the presentations were arranged around the room in the cafeteria of the Juanita Sanchez Educational Complex. At each stop you could learn more about National Grid’s plans for installing a new plant for liquefying natural gas for storage in an existing tank. This had the effect of making each stop along the way a little more personal, as aspects of the project were explained in a one on one manner by National Grid reps.

When I arrived, about an hour before the event started, I noticed the presence of five Providence police officers outside. Inside, the event was being watched over by two additional officers, one a lieutenant. There were some members of the community present, but most of those who attended seemed to be with the RI Sierra Club or Fossil Free Rhode Island and opposed to National Grid’s plan. Members of these groups were content to engage the various National Grid and FERC reps in conversation.

When the young people representing PrYSM, PSU and EJLRI entered the room, they were followed in by the police officers from outside, three of whom were wearing their motorcycle helmets.

“They’re motorcycle officers,” said the Lieutenant when I asked why seven police officers were needed, “That’s not riot gear. I just called them in.”

“So they were outside, directing traffic?” I asked.

“Yes,” he replied, “Once we clear here, they’ll go back to traffic duty.”

“I know from other actions I’ve covered that these are all decent kids,” I said.

“We don’t know that,” said another officer, “We didn’t know who was coming, or how many. We saw a bus pull up and then we saw all the bullhorns and the lieutenant asked, ‘All right, who’s in charge?’ We just wanted to lay down some ground rules, some normal, by the law ground rules, and they just completely ignored us.”

When I asked David Graves, media relations representative for National Grid about the number of police officers present, he said that initially, National Grid had asked for a two officer detail, but, “when those protesters were arrested this morning in Burrillville, the police department called us and we said that they should do what they feel is the right thing to do and assign a larger detail.”

Graves was talking about activists from FANG (Fighting Against Natural Gas) chaining themselves to the gate at the Spectra Energy Compressor Station. “I don’t think these people are associated with that group,” added Graves.

Still, it was hard not to see the sudden explosion of police on the scene occurring precisely when people of color arrived as anything other than an expression of the kind of institutionalized environmental and economic racism that the groups were protesting. For a primer on environmental racism, you could a lot worse than watching Jesus Holguin below.

The appearance of racialized policing was heightened when the activists from PrYSM, PSU and EJLRI left the room and all seven police officers followed them outside, leaving no police officers in the room. I note here that the two men arrested in Burrilville were white and middle-aged, like the people left in the room without police officers, not young people of color, who conducted themselves fully within the law and left the room in peace. One of the two men arrested in Burrillville, Dr. Curtis Nordgaard, commented on the treatment he experienced as he made his first foray through the criminal justice system, after being released from District Court on personal recognizance earlier the same day. “Part of why we can do this,” said Nordgaard, “is because of our privileged status.”

National Grid’s rep David Graves disagreed with much of what the various protesters said during their speak-out, but he knew the protesters weren’t trouble. “These kids are wonderful,” he said.

As the fight against environmental racism and for a clean energy future intensifies in the years to come, we should expect large corporations such as National Grid to increasingly rely on the government to use the power of the police to intimidate opposition. Billions of dollars are ready to be spent to prevent the transition to a clean energy future, and the billionaires in control of that money will not let go without a fight. As Dr. Noel Healy said, “There is no fixable flaw in fossil fuel industry business plan. We are asking a company to go out of business.”

August 15, 2015

Southside PVD activists speak out against Fields Point LNG Plant

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National Grid asked for public comment on their plan to build a LNG liquefaction system at the Fields Point LNG Plant on Providence’s South Side, and boy, did they get it. Representatives from the Providence Youth Student Movement (PrYSM), the Providence Student Union (PSU) and the Environmental Justice League of Rhode Island (EJLRI) took control of the room to conduct a peaceful speak out for the benefit of representatives from both National Grid and FERC (Federal Energy Regulatory Commission.)

Despite the presence of an intimidating police presence, these activists and protesters fearlessly and passionately presented their case.

Julian Rodríguez-Drix of the EJLRI, did a great job outlining the dangers, from asthma to earthquakes. In under seven minutes Rodríguez-Drix basically presented every objection to the liquefaction expansion. He also told a chilling story of taking pictures of the LNG tank after the recent earthquake to see if it had suffered an damage, and his friend’s interrogation by the FBI as a result.

“This whole area is on the wrong side of the hurricane barrier. So a storm surge is just going to double back, protecting downtown, but hitting South Side doubly hard.”

Jesus Holguin of the EJLRI said, “All that pollution rains in our community, giving our community high rates of asthma.”

“So my mom just had a baby three weeks ago,” said Daniel, speaking on behalf of PrYSM. Daniel lives practically across the street from the proposed site. “You should already know that living there is not a safe place to raise a baby.”

Steven Roberts, of the EJLRI, openly doubted that the temporary construction jobs this project would create would impact his community at all. “We don’t know how many jobs have been set aside for folks in this disadvantaged community.”

“Slave ships create jobs, asbestos creates jobs, fracking creates jobs,” said Roberts, “we want people to have jobs and economic stability, but not on the backs of people who look like me…”

April 2, 2015April 3, 2015

Multi-state coalition files for pipeline expansion rehearing

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Individuals, grassroots groups and towns from the four states adversely impacted by Spectra Energy’s Algonquin Incremental Market (AIM) natural gas pipeline expansion project have formed a coalition to file a Request for Rehearing after the Federal Energy Regulatory Commission (FERC) approved the project on March 3, 2015. The coalition engaged DC attorney, Carolyn Elefant, who filed the request on April 2, 2015, asking FERC to vacate the Certificate.

If FERC rejects the request, the coalition will consider taking legal action.

Suzannah Glidden, a co-founder of Stop the Algonquin Pipeline Expansion (SAPE) in New York said: “Local, state and federal elected officials and citizens along the entire AIM route have repeatedly cited the flawed FERC review. FERC’s approval is not supported by substantial evidence. The Certificate of Approval of the AIM Project should be withdrawn.”

Boston Mayor Martin J. Walsh today joined the West Roxbury delegation to announce that the City of Boston has also filed a request for a rehearing with the Federal Energy Regulatory Commission (FERC) in regards to the West Roxbury Lateral Gas Pipeline.

After Spectra Energy submitted its application to FERC last year, groups and individuals from New York, Connecticut, Rhode Island and Massachusetts filed to become intervenors in the FERC process. This entitles them to file a Request for Rehearing within 30 days after FERC’s issuance of a Certificate of Approval. FERC issued this certificate for the project and failed to adequately consider dangerous health and safety impacts as the pipeline and its infrastructure invade the region. For example, FERC approved siting of the 42-inch diameter, high pressure pipeline next to the Indian Point nuclear facility in a seismic zone in Buchanan, New York, and a new pipeline and Metering & Regulating station next to an active quarry in West Roxbury, Massachusetts.

Alex Beauchamp, Northeast Regional Director of Food & Water Watch, said: “In light of the serious health, safety, and environmental concerns that FERC failed to address before approving this dangerous project, the agency must grant a rehearing. Without studying the threats posed to the Indian Point nuclear facility or the human health risks from airborne contaminants, it is disgraceful that FERC has approved the AIM pipeline.”

Rickie Harvey of West Roxbury Saves Energy, Massachusetts, said: “No meaningful alternatives to a high-pressure lateral scheduled to deliver nearly 30 percent of the proposed gas via the AIM expansion were provided, despite repeated requests from citizens and politicians alike. Because this proposed West Roxbury lateral pipeline traverses a densely settled neighborhood adjacent to an active quarry, a full rehearing is warranted.”

Spectra Energy’s AIM Project, a $1 billion venture, is the first of three projects designed to ship massive quantities of “natural” gas from the Marcellus Shale to New England and onto Canada and proposed LNG export facilities. Lisa Petrie of Fossil Free Rhode Island said: “Dividing projects to minimize their environmental impacts is considered impermissible segmentation and violates the NEPA process, as FANG (Fighting Against Natural Gas) argued convincingly in a recent letter to FERC.

Emily Kirkland of the Better Future Project in Boston said: “As a climate justice organization, we have been fighting the AIM Project every step of the way, both through regulatory avenues like the request for rehearing and through grassroots organizing in communities all along the pipeline route. It’s simply irresponsible to expand the Algonquin Pipeline when we know that our continued addiction to fossil fuels is exacerbating the climate crisis and putting our safety at risk. We should be transitioning as quickly as possible to clean energy, not deepening our dependence on fossil fuels.”

The coalition of residents and groups includes: Better Future Project (MA); Capitalism v. the Climate (CT), Community Watersheds Clean Water Coalition (NY); Town of Cortlandt, NY; Food & Water Watch; Fossil Free Rhode Island; Keep Yorktown Safe; City of Peekskill, NY; Sierra Club Lower Hudson Group; Stop the Algonquin Pipeline Expansion (NY); W. Roxbury Saves Energy (WRSE) and impacted residents of W. Roxbury and Dedham, MA.

January 28, 2015January 29, 2015

FERC delivers for corporate stakeholders

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The Federal Energy Regulatory Commission (FERC) took the next, and almost final, step required to force through Spectra Energy’s AIM project Friday. If approved, it would expand pipelines and compressor stations needed to transport fracked-gas from the Marcellus Shale in Pennsylvania to New England.

FERC admits that the proposed project will have “some adverse environmental impacts” but it is of the opinion that most of these would be reduced to “less-than-significant” by minor changes to the original plan, FERC wrote, with a toxic brew of acronyms and legal jargon designed to be impenetrable by the average reader in its Final Environmental Impact Statement (FEIS).

I admit that wrecking the global climate and exposing humanity to the risk of wiping out a couple of billion people is highly suggestive of an “adverse environmental impact.” The support offered for the opinion that minor changes would reduce this problem to “less-than-significant” is less-than-convincing.

To put the FEIS in perspective, let me recall some background information. Fracked gas is an essential component of the President’s Climate Action Plan – aka all-of-the-above. It provides the fossil fuel industry with cover for enterprises like the AIM project.

James Hansen, former head of NASA’s Goddard Institute for Space Studies, submitted an amicus science brief in a lawsuit brought against the U.S. government:

[U]nabated fossil fuel emissions continue to drive the Earth increasingly out of energy balance. Unless action is undertaken without further delay … Earth’s climate system will be pressed toward and past points of no return … [D]elay in undertaking sharp reductions in emissions will undermine any realistic chance of preserving a habitable climate system.

The bracketed edits are by Mary Christina Wood in her book Nature’s Trust. For more on Hansen’s work this see this short version of a paper, or this long version of the same.

Another important piece of background information is the contained in a video clip from Gassland 2 in which Robert Howarth explains the results of a series of scientific studies:

HOWARTH: The hypothesis here is that shale [fracked] gas is better for global warming than other fossil fuels and it’s a good transitional fuel. We tested that and the answer is: “No, it’s not!” The Whitehouse has clearly bought into this idea that natural gas is part of the solution of moving us gradually off of fossil fuels. I don’t think that they did that with good science.

The result of a convincing study of the effects of fracked gas on the climate is that

… both shale [fracked] gas and conventional natural gas have a larger GHG [greenhouse gas footprint] than do coal or oil, for any possible use …

a quote from a peer reviewed paper A bridge to nowhere: methane emissions and the greenhouse gas footprint of natural gas.

With this in mind, deconstructing the FEIS requires only common sense. The conclusion is that our lawmakers fail in their fiduciary duty to cherish and protect the Earth —water, land and air— for current and coming generations.

This is my “favorite” part of the FEIS (see page I-5); you won’t miss a thing if you only read what I highlighted, but I’m including the whole paragraph for lovers of bureaucratic hogwash:

Commentors also noted that the EIS should address the indirect impacts of induced Marcellus shale development. Impacts that may result from additional shale gas development are not “reasonably foreseeable” as defined by the Council on Environmental Quality (CEQ) regulations. Nor is such additional development, or any correlative potential impacts, an “effect” of the Project, as contemplated by the CEQ regulations, for purposes of a cumulative impact analysis. The development of the Marcellus shale, which is regulated by the states, continues to drive the need for takeaway interstate pipeline capacity to allow the gas to reach markets. Therefore, companies are planning and building interstate transmission facilities in response to this new source of gas supply. In addition, many production facilities have already been permitted and/or constructed in the region, creating a network through which natural gas may flow along various pathways to local users or the interstate pipeline system, including Algonquin’s existing system. Algonquin would receive natural gas through its interconnection with other natural gas pipelines. These interconnecting pipeline systems span multiple states with shale formations in the northeast, as well as conventional gas formations. We cannot estimate how much of the Project volumes would come from current/existing shale gas production and how much, if any, would be new production “attributable” to the Project.

Take the phrase: “not ‘reasonably foreseeable’ as defined.” Of course, it is perfectly clear that we have a problem: we’re importing gas to Rhode Island and exporting death and destruction to Pennsylvania and to the globe as a whole and we are causing health problems for the people living in the vicinity of the pipelines. Might there be a reason why the pipeline does not run through Watch Hill? No worries! The problem has been defined out of existence by laws written by lobbyists in exchange for campaign contributions. The law is an ass; you can ride it wherever you like, but it usually delivers for the ruling class.

Then there is is the phase “[w]e cannot estimate.” Clearly, our system of government has reversed the burden of the proof: pollution is just fine until the People prove that it’s not. Nobody seems to notice that this runs contrary to the original intent of the Clean Air and Clean Water acts.

There is more of this in the next paragraph, also from page I-5 with my bold:

We also note that the EPA and the states have imposed regulations within the past 2 to 3 years on natural gas production to minimize leaks and methane emissions. Therefore, past studies on production leaks and methane emissions cannot be used to appropriately predict future methane emissions. Predicting methane emissions and associated climate impacts is speculative given the newly required minimization efforts.

Again, the burden of the proof has been reversed. There is no evidence that the fugitive methane problems can be solved; all we have is the “yes we can” from the likes of Halliburton.

Tony Ingraffea explains the problem of methane emissions in this video:

Let me summarize it. There are numerous workshops and conferences, and countless papers on “well-bore integrity” for a simple reason: wellheads leak and nobody knows how to fix it. EPA and FERC act as if they have super-natural powers: “We impose regulations; nature know who’s the boss; problem solved!” I also wonder, if past studies cannot be used to make predictions, how does FERC predict the impact of what it’s approving? Once again, in case of doubt, the corporate stakeholders win.

The next paragraph of the FEIS talks about “improper segmentation.” Let me explain what that means: chop the project into several segments and build the first one under different, national regulations. That has the additional advantage that you’re working with New England senators and governors whose main concern, as we know, is to keep the poor in New England warm. Most importantly, you to never have to evaluate the cumulative impact of all the segments that you incrementally ram down the People’s throat.

FERC has yet another half-assed argument to show that improper segmentation is not a problem for the AIM Project. I’ll spare you the gobbledygook; it’s again on page I-5 of the FEIS. Let me just mention that the price of natural gas on the world market was probably three of four times as high as the national fracked-gas price when the AIM Project was hatched, but we are supposed to have forgotten that.

FERC goes by statutory law written by polluters for polluters. Here is The Trillion-Gallon Loophole: Lax Rules for Drillers that Inject Pollutants Into the Earth, yet another case that strengthens me in my conviction that:

There has been a corporate takeover of government. We have to step up street protests, blockades, civil resistance, and direct action in general. This will become increasingly more difficult as the proposed law to make blocking roads in RI a felony demonstrates: the ruling class is waking up to the reality that the party is over and they are fighting back.
The fracking ban in NY (see this press release) goes a long way toward putting the burden of the proof where it belongs. The NY argument is essentially that not enough is known to proceed with fracking and that what is known does not bode well. That indeed suffices to warrant a ban.
For failing to fulfill its fiduciary duty to protect the environment and Nature’s Trust of which this office is a trustee, we should file a lawsuit against the Governor of Rhode Island. We should name our congressional delegation as co-defendants. In other words, let’s join the Atmospheric Trust Litigation movement!

This last point deserves a fuller explanation. For that see this video or better yet read Mary Christine Wood’s book: Nature’s Trust.

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Solutions and Alternatives

Economic Inequality

Public Health

Climate Change

Environmental Racism

EPA Toxic Release Inventory?­

Schools at Risk

EPA’s EJ SCREEN Tool

Proximity to Facilities Requiring a Chemical Risk Management Plan

Proximity to Water Discharger Facility

Traffic Proximity

Toxic Storage and Discharge Facilities

Environmental Justice: working towards equitable healthy environments

Potential Disasters: dangerous facility in a high risk area

Relevant Past LNG Disasters

Dangerous incidents occurring in the Port of Providence

Introduction

Background on National Grid’s proposal

EPA Toxic Release Inventory?