EJLRI confronts the EPA in Boston


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2016-01-19 EJLRI 02Environmental justice leaders from frontline communities hardest-hit by climate change and pollution converged on all 10 Environmental Protection Agency (EPA) regional office headquarters yesterday, to mark the end of the final public comment period for the Obama Administration’s federal Clean Power Plan (CPP) to reduce power plant carbon emissions 32% by 2030.

Members of the Environmental Justice League of Rhode Island (EJLRI) lead the efforts in Region 1, meeting with Curt Spalding, Administrator for the EPA’s New England Region, headquartered in Boston.

After their meeting with Spalding, I spoke to Dania Flores, EJLRI’s Executive Director and the coordinator of the action, and Julian Rodríguez-Drix, an EJLRI board member, in the hallway of the EPA offices.

“We’re part of the Climate Justice Alliance (CJA), a national alliance of climate justice grassroots groups. We decided that no one has engaged on the side of the people on the CPP plan which is a power generation plan on how the states are going to clean up their act,” said Flores.

The CJA is a collaborative of over 35 community-based and movement support organizations uniting frontline communities to forge a scalable and socio-economically just transition away from unsustainable energy towards local living economies to address the root causes of climate change. They have developed an “environmental justice counterpoint to the Clean Power Plan” they call “Our Power Plan.”

“One the first things in our plan is to engage with the EPA in each region to try to convince them that no one has actually meaningfully engaged the people,” said Flores, “We’re asking the EPA to comply with the law. They have the power to ask state governments to engage in meaningful engagement with frontline communities.”

Under Obama’s CPP, states have “until August to come up with a plan [reduce power plant carbon emissions] or they can ask for an extension,” said Flores, “but we are asking the EPA to tell states that already have a plan, ‘No, we don’t believe that you have actually meaningfully engaged with [frontline] communities.’”

Flores says that states have until 2018 to present their plan and that the CJA wants the plans “to include exactly how states engaged in meaningful engagement [with frontline communities.]”

Rodríguez-Drix said, “Here in Region 1 the issue we see is that the transition away from coal and oil very much favors natural gas as a fuel source and we have a number of very strong reasons that we do not believe that’s [a viable solution].”

The EJLRI’s position is that “if there’s energy infrastructure being built it has to be true renewables,” not energy based on extraction and burning.

Right now, to satisfy a requirement to invest in weatherization and renewables, National Grid tacks on a surcharge to all energy customers, “but the fund is mostly used for solar panels in the suburbs,” says Rodríguez-Drix. This means that poor communities are helping to subsidize the energy conversions of their richer neighbors.

“It benefits white homeowners, primarily,” says Rodríguez-Drix, “We need to look at the whole system and the economics behind it so that the system benefits frontline communities, not just in terms of jobs installing solar panels, but in terms of generating energy that is owned by people of color.”

This problem is exasperated by another issue primarily faced by poorer communities of color. “Slum lords aren’t the ones paying [energy] bills and they don’t care about [weatherization and energy efficiency]. [The communities we represent] have a lot of housing insecurity. We need incentives and investments that will put people of color to work installing and benefiting from increased weatherization and energy efficiency.”

“I had the sense that Spalding was sympathetic to what we had to say,” said Rodriguez-Drix.

“A lot of the conversation revolves around what the translation of certain words in the law is,” said Flores, “What it means to them and what it means to us. When we talk about community engagement, what does it mean to be meaningful? We think we are going to be engaged and be part of the conversation. When they talk about engagement it means they are going to leaflet someplace and schedule two meetings.

“Real meaningful engagement is a lot more work than they have been doing.”

Though this was a nationwide effort, not every EPA office allowed for this level of engagement from CJA aligned groups. “In some EPA offices, meetings like this did not occur,” said Flores, “In some offices an activist would hand over written material to a secretary.”

“EPA welcomes public input from all parties on the Clean Power Plan,” said Spalding when asked for a comment, “We are pleased that stakeholders and communities are actively engaging in the public comment process because robust public participation leads to better outcomes for our health and environment.  It is important that environmental justice communities provide EPA with their unique perspective on proposals like the Clean Power Plan.

“EPA is committed to ensuring meaningful public involvement throughout implementation of the Clean Power Plan, so that all communities benefit equally from this vital step to address climate change and protect our health and environment. EPA will consider the input we have received before taking final action.”

Flores, the EJLRI and the CJA see this contact as the beginning of a series of conversations. “We’re going to up the ante as this develops. If the EPA doesn’t push states to wait until 2018 to submit plans, after meaningfully engaging with frontline groups, we will be pushing towards a national gathering in the Summer,” said Flores.

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Photo (c)2016 EJLRI

2016-01-19 EJLRI 01

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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.

See also:

●  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

Economic Inequality: high cost project that will cause economic damage


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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.

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.

See also:

●  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

Public Health: health disparities and impacts on health care institutions


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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.

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_23

EJLRI Position Paper_Page_24At 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.

See also:

●  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

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


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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.

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 a​nd 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.

EJLRI Position Paper_Page_22
Image source: slide from presentation by Austin Becker titled “Hurricane Consequences in the face of climate change: Case studies of two seaport clusters, Gulfport (MS) and Providence (RI). In the report, both ports are referred to as “highly vulnerable.” Note: overlaid words show organizations involved, do not correlate with locations on map

See also:

●  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

Strong public opposition to Burrillville power plant at hearing


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2016-01-12 EFSB 01The new methane gas power plant planned by Invenergy for the Town of Burrillville met strong opposition from a variety of environmental groups but also had what seemed like strong support from both members of the Energy Facilities Siting Board (EFSB) which will ultimately approve or deny the application.  The EFSB is chaired by RI Public Utilities Commission (RIPUC) Chairperson Margaret Curran and has only one other sitting member, Janet Coit, director of the Department of Environmental Management (DEM). The third position on the board is usually filled by the associate director of  the RI Administration for Planning, a position currently unfilled, but it is expected that Governor Gina Raimondo will choose someone to fill that role soon.

As the standing room only hearing got under way, Chairperson Curran noted that there hasn’t been a hearing like this since 1999, the last time an energy project of this size was considered. No public comment was allowed at this meeting, but Curran said that there were three public comment meetings scheduled. (It turns out they have not been scheduled at the time of this writing.)

Board member Coit spent some time near the beginning of the hearing informing the room that her position as head of the DEM will not impact her decisions as an EFSB board member. The duties of the DEM in deciding on key aspects of Invenergy’s proposed power plant have been delegated to her assistant, Terry Gray, and Coit says she is firewalling herself from her department’s work in this area. Some activists in the room expressed doubt in the possibility of such a firewall. It should be noted that Governor Gina Raimondo nominates all three EFSB board positions and that she has publicly backed Invenergy’s plan.

The two member board’s first order of business was to deal with an unprecedented number of motions for intervention, which if granted, would allow standing in these hearings for several groups and individuals. Invenergy objected to many of the motions, but did not object to allowing intervenor status for the Conservation Law Foundation (CLF), the Burrillville Land Trust (BLT), The RI Department of Energy Resources, the RI Building Trades Council and National Grid. The board granted all but the Burrillville Land Trust intervenor status, and said that the decisions on the rest of the motions for intervention would be announced at a January 29 meeting.

One motion immediately granted to Invenergy allowed the company to keep certain “proprietary” financial information secret from the public. Between this and Invenergy’s eagerness to deny intervenor status, it becomes difficult to believe the company is truly committed to an open, public process.

I covered Invenergy’s objections to granting intervene status here. Since then the Building Trades filed for last minute intervenor status because their union would represent the vast majority of workers who will build the plant if approved. The Building Trades were granted limited intervenor status pertaining to employment.

Both the Conservation Law Foundation and the Burrillville Land Trust had motions before the board asking that Invenergy’s application be denied. BLT said bluntly that the Invenergy application contains erroneous information or deliberate omissions. There are, says BLT,  no biodiversity impacts and no noise impacts cited in Invenergy’s application. BLT maintains that Invenergy underestimated the impact of their power plant on species diversity by half. The effects on birds and bats, so important to keep insect populations down, is likely to be severe. Invenergy’s estimated water impacts are 75% less than what BLT expects. Ultimately, says the BLT, the impact of this power plant will be felt for decades after its estimated 40-50 life span.

The CLF’s motion to dismiss was based in part on the Resilient Rhode Island Act, and on the fact that Invenergy’s application is incomplete. Under the law, says CLF attorney Jerry Elmer, “Incomplete applications must be rejected.”

Invenergy could not argue that their application was complete. They even admitted that they are still in negotiation for some permits. But Invenergy maintained that this is business as usual and not a reason to reject the application. Invenergy is pushing hard on this application, and want the EFSB to make a quick decision because if this application process drags on too long, they could be out hundreds of millions of dollars, said the CLF. But Attorney Elmer said that Invernergy needs to live with their business decisions, and the EFSB must deny incomplete objections even if Invenergy might face a monetary loss.

Chairperson Curran argued for Invenergy’s position, it seems to me, better than Invenergy’s own lawyers. Curran said that she thinks incomplete applications can move ahead despite what the CLF sees as important, material omissions. The application, says Curran, will be finished by the time the EFSB makes a decision, but Attorney Elmer countered that the statute and rules say that the application must be complete when filed, not when decided upon.

A chisel of lawyers
A chisel of lawyers

Board member Coit also argued passionately for Invenergy’s position. If Curran and Coit want to obey the law though, it would seem that they might have to reject Invenergy’s application, something they clearly didn’t want to do.

Invenergy’s lawyers were clearly pleased with Curran and Coit’s defense of their application. They assured the EFSB board that the board will have plenty of information about the power plant by the time they make their decision. The lawyers maintained that what isn’t in the application isn’t important. In fact, in all their years of practice, these lawyers say they have, “never seen such a detailed application.”

The CLF was next questioned about their reliance on the Resilient RI Act. Under the law, all state agencies shall follow this act. This means that the act applies to the EFSB and that the EFSB has the discretion to consider the climate change impact of the proposed energy plant.

Invenergy seems to feel that the Resilient RI Act is a toothless reminder about the importance of greenhouse gas reductions. They said that the act says nothing about their project and really doesn’t apply.

The second half of the hearing consisted of Invenergy’s sales pitch, a 51 page PowerPoint presentation that is both an ad for Invenergy (including slides touting the companies wind and solar projects, projects they seem to have no interest in bringing to Rhode Island) and plenty of information about the robustness of the company’s finances.

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Environmental Racism: ongoing and underlying environmental justice issues


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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.

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


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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.

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 t​rue, 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. “B​enton 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 ­

I​n 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 ­

I​n 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 ­

T​he 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.” A​ny potential accident, and the resulting disaster scenario, must be taken into consideration with National Grid’s proposed Liquefaction Facility.

Ethanol “bomb” trains ­

E​thanol 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,“E​thanol 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. A​lternatives 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, “t​he 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 ­

H​urricane 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 L​NG 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?

See also:

●  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

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

EJLRI01

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

Invenergy attempts to sideline public input on proposed power plant in Burrillville


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2015-12-07 FANG BASE Raimondo Whitehouse 003Lawyers for Invenergy have filed documents with the court objecting to the Motions for Intervention filed by several local property owners, activist groups and individuals. At contention is the proposed “Clear River Energy Center” (CREC), a 850-1000 megawatt power plant fueled by imported methane gas, to be built in Burrillville.

The Rhode Island Energy Facilities Siting Board (RI EFSB) has scheduled a preliminary hearing to consider Invenergy’s application for January 12 at 9:30am. Public commentary will not be heard at this hearing, only those parties and participants granted intervenor status by the Siting Board will have a voice in the proceedings.

In their court filing, Invenergy objected to the following groups and individuals’ motion for intervenor status: property owners Dennis and Kathy Sherman and Paul and Mary Boldue; activist and political groups Occupy Providence, Fossil Free RI, the Progressive Democrats of Rhode Island (RIPDA), Fighting Against Natural Gas (FANG) and  Burrillville Against Spectra Expansion (BASE); and Sister Mary Pendergast, as an individual.

Invenergy does not have “specific objections” to the intervention requests of the Town of Burrillville, the State of RI Office of Energy Resources, National Grid, the Burrillville Land Trust or the Conservation Law Foundation.

Invenergy contends that intervention should only be granted to “Parties that have either statutory rights to intervene, directly affected interests that will not be adequately represented by other parties, or special public interests that compel intervention as a Party.”

Invenergy also objects to a separate motion “to extend the intervention period and to postpone the Preliminary Hearing” submitted by FANG and BASE.

RawsonIn their motion requesting a 45 day extension of the deadline to intervene, FANG and BASE argued that, “At the December 9th Burrillville Town Council Meeting, several residents voiced their confusion with the intervenor process and expressed frustration with the lack of information provided about the process. Residents posed questions to the Town Council that the Council was not equipped to answer.” Note that the Town of Burrillville, though ill-equipped to answer rudimentary questions about the process at the Town Council meeting, is one of the groups that Invenergy says will “adequately” and “capably” represent the public interest.

The requested extension, maintains FANG and BASE, would allow “interested individuals and parties… more time to learn more about the intervention process, seek legal counsel and draft motions to intervene.”

The Siting Board, according to the motion filed by FANG and BASE, sent out “the first announcement for the public hearing… on November 17th to only sixteen parties, most of whom were local or state government agencies or elected officials. November 17th was one week before the Thanksgiving holiday. The deadline for filing as an intervenor was set as December 22rd, leaving two days before Christmas and one day before Eid Milad ul­Nabi (the observance and celebration of the Prophet Muhammad’s life). Also happening during the intervention period was the Hanukkah holiday from December 7th-­14th.”

Residents affected by the proposed power plant’s siting were informed of the process with little time to seek counsel or determine if their interests were to be covered by approved intervenors. At the December 9 Burrillville Town Council meeting, Town Manager Michael Wood told Kathy Sherman that the town council’s job is to represent Burrillville, but that doesn’t mean that the town council will be representing every concern of every resident.

Yet in their court filing objecting to intervenor status being granted to Dennis and Kathy Sherman and Paul and Mary Boldue, Invenergy claims that their interests will be adequately protected by the Town of Burrillville as a Party.

Invenergy objected to Occupy Providence, Fossil Free RI  and RIPDA being granted intervenor status because none of the groups is represented by a lawyer. The groups maintain that the rule cited by Invenergy is applicable to Parties, as legally defined, and not to participants. Further, Invenergy claims that the groups will not “be ‘directly affected’ by the project in a manner that will not be represented by other parties.”

Hilariously, one of the Parties that Invenergy claims will represent the interests of Occupy Providence, Fossil Free RI  and RIPDA is National Grid, a company with a history of disregarding the concerns of Rhode Islanders and the environment in its endless craving for corporate profits.

Raimondo Clear River presser
Governor Raimondo at the CREC press conference

Invenergy further claims that “interests related to carbon emissions and the state’s overall energy policy will be more than adequately represented by other Parties” including the Governor’s Office of Energy Resources. Governor Gina Raimondo has very publicly supported the proposed energy plant, so it is highly doubtful that the interests of Occupy Providence, Fossil Free RI and RIPDA will be represented by Parties advocating for her interests.

FANG and BASE were represented by a lawyer in their motion to intervene, but Invenergy says that these “grassroots organizations” will be “cabably represented” by the Conservation Law Foundation (CLF), the Town of Burrillville, the DPUC and the RI Department of Environmental Management.

This is another strange statement, because when I emailed Josh Block, the press secretary for the Conservation Law Foundation, he wrote back saying, “By intervening in the pending Energy Facility Siting Board (EFSB) docket, CLF will present multiple arguments as to why Invenergy should be denied a permit to build an expensive, long-lived, carbon-emitting fossil-fuel power plant. A proposal such as this which makes little economic or environmental sense has unsurprisingly garnered opposition from a large number of stakeholders, each with unique interests and perspectives. Thus, any assertion that CLF’s participation in the docket is a reason for excluding other intervenors in the process is as misguided as the proposal itself.” (Italics mine)

2015-12-05 FANG Arrests Spectra 022
Sister Mary Pendergast, in pink, being arrested

Sister Mary Pendergast, explaining her reasons for being arrested during a protest organized by FANG and BASE, said, “Pope Francis has called us all to an ecological conversion and he said it is essential and not an option.” Her motion to intervene has also been opposed by Invenergy, apparently, because her philosophical and theological concerns will be “adequately” and “capably” represented by the corporate and governmental interests of approved Parties, which is errant nonsense.

The fact is that the interests of the people will not be adequately represented in these proceedings if these motions for intervention are denied. The interests of the public are routinely and bureaucratically sidelined by relegating our voices to public commentary hearings with no real power or weight. Invenergy, though, depends on these public hearings to provide the appearance of public input where there is none, saying, “There will be ample opportunity… to provide comments, views, oppositions and data, in the form of public comment, in writing or in public testimony, at the appropriate time…”

This is how the voices of the public are silenced. We are relegated to separate, lesser forums, scheduled after the real decisions have been made. We are allowed to speak only when our objections have been rendered moot. It is only after our rights have been sacrificed to appease corporate power and after our world is destroyed that our voices will be heard, and that will be too late.

The motions for intervention should be granted.

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National Grid restores power to two dozen homes


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National Grid agreed to restore power to about two dozen homes this afternoon pending the resolution of a lawsuit.

The Rhode Island Center for Justice filed a class action lawsuit against National Grid and the RI Division of Public Utilities and Carriers on behalf of families that had their utilities terminated even though a member of the household suffered from severe or chronic medical conditions. Under state law these families should have been protected from shut-offs pending regulatory review by the RI Public Utilities Commission.

Though the case is not yet over, this move does offer preliminary relief to all families whose circumstances would be covered under the present lawsuit, which the Center for Justice estimates may be as many as 80 homes.

2015-11-25 Center for Justice
After the decision

Camilo Viveiros, Executive Director of the George Wiley Center, which collaborated with the Center for Justice on the Lifeline Project, issued the following statement:

Today’s action is important for the families who will have their utilities restored before the holidays and the judgment is a crucial step toward assuring that Rhode Islander’s utility rights and protections are recognized and respected.

‘Most Rhode Islanders would be shocked to find that people with serious medical conditions are routinely denied their medical protections stated in the Termination Rules when our taxpayer funded Rhode Island Division of Public Utilities grants National Grid permission to terminate thousands of households with seriously ill people, despite doctors’ documentation of life-threatening medical conditions.

‘The George Wiley Center is glad that it is increasingly coming to light the ways that the rights of utility consumers with medical conditions have been disregarded and disrespected.

‘Today’s action was an important step in recognizing how the RI Division of Public Utilities should be working to utilize the protections for vulnerable families rather than undermining protections in favor of the financial interests of the utility company.

‘The George Wiley Center will continue our efforts with the Rhode Island Center for Justice to expose the continued and larger patterns of utility injustice, as we organize to establish affordable utilities that would allow for access to important and essential utility services.”

[Note: The story originally said that a judge had ordered the restoration of power. In fact, National Grid agreed to restore power without a judge compelling the action]

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National Grid responds to liquefaction opposition


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2015-10-08 LNG 001
Jesus Holguin

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.”

2015-10-08 LNG 020
Aaron Regunberg

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).

2015-10-08 LNG 032
Juan Pichardo
2015-10-08 LNG 005
Monay McNeil
2015-10-08 LNG 017
Nick Katkevich

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.

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RIPUC adopts emergency regulations to help shut-off victims


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2015-10-30 RIPUC 009The Rhode Island Public Utilities Commission (RIPUC) today adopted “emergency regulations” designed to make it easier for those who have fallen behind on their payments to National Grid to restore power and heat to their homes. Margaret E Curran, chair of the board, lead fellow commissioners Paul J Roberti and Herbert F DeSimone Jr in an unanimous vote to allow people to get their power restored for a 15 percent payment of the total owed upfront plus the adoption of a regular payment plan. Currently that number can be 50 percent or higher.

2015-10-30 RIPUC 006The George Wiley Center made the request on behalf of utility customers, as they have for the last seven years, but had requested the number be set at 10 percent. After some discussion, Curran arrived at 15 percent because in the past there was a tiered system that allowed for down payments of between 10 and 20 percent. Curran eliminated the tiers and came up with 15 percent as a compromise.

In the past it was routine to allow these emergency regulations to last for 3 months, but in the last two years this was shortened to thirty days. Curran suggested that the new thirty day mark is somehow “traditional,” though one might argue that recent changes to a tradition are not themselves traditional. Given the shortened time, it’s important, says George Wiley organizer Camilo Viveiros, to get the word out to families and individuals in need.

2015-10-30 RIPUC 005Over thirty people attended today’s RIPUC meeting a good crowd considering the last minute change in date and time of the meeting. Had the board met when originally planned, people would be that much closer to having their power restored. Though the board’s ruling came as a relief to many, to some it will have little effect. Anna told me that she has spent money she might have used to reinstate her gas heat to purchase electric space heaters. In order to have the money back on her debit card in time, she will have to return the space heaters today, wait for the money to be back on her card early next week, and make her payment then. This means that she and her children will be in a house with no heat all weekend.

Today’s ruling has no effect on those affected by National Grid’s policy of ignoring rules against shutting off power on the elderly and those suffering from illnesses. That lawsuit is still ongoing.

Further complicating this year’s execution of emergency relief is Governor Gina Raimondo‘s executive order 15-07, which will have the impact of delaying this much needed emergency regulation. Under this order, rules adopted by the RIPUC need to be reviewed and signed off on by the Office of Regulatory Reform (ORR) prior to the effective date. Why the governor is mandating the adoption of bureaucratic practices that delay good policy is not yet clear. The governor’s office has been asked for comment. The policy was supported by both Speaker of the House Nicholas Mattiello and Senate President Teresa Paiva-Weed.

Despite these difficulties, today’s ruling is good news for many Rhode Islanders suffering from shut-offs due to financial constraints.

2015-10-30 RIPUC 004
Margaret E Curran
2015-10-30 RIPUC 001
Paul J Roberti
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Herbert F DeSimone Jr

2015-10-30 RIPUC 002

2015-10-30 RIPUC 007

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RIDOH Director Alexander-Scott weighs in on LNG in PVD


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2015-09-11 Food on the Move 013 Nicole Alexander Scott
Dr. Nicole Alexander-Scott, director of the Rhode Island Department of Health

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.

Patreon

PUC protesters repelled by bureaucratic disinterest


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2015-10-20 PUC 004More than 30 people entered the RI Public Utilities Commission (PUC) yesterday to demand an end to the epidemic of unfair utility shut-offs. Many in attendance have been victims of these shut-offs, even though they complied with the law and produced letters from their doctors indicating that their health would be seriously compromised by shut-offs. The protest was lead by the George Wiley Center and culminated in an action where dozens of protesters entered PUC offices to deliver a letter to the PUC board.

No one from the board would consent to meet with the protesters. Instead, Kevin Lynch, who works for the PUC, fed the crowd bureaucratic folderol for 30 minutes. (Readers with a peculiar masochistic streak can watch the entirety of that interaction in the last video below.) Mind you, this was after making the protesters wait in the tiny receiving room/staircase for nearly ten minutes. Ultimately, the letter was time stamped by a clerk before being filed away unread by board members.

Those among the protesters with specific issues left with those issues unresolved.

Though Lynch was professional and polite, he did nothing to resolve any issues that anyone in the crowd brought up. At first Lynch tried to dismiss the protesters by saying that since the George Wiley Center and the Rhode Island Center for Justice was suing over the issue, he would not be able comment, but Camilo Viveiros, lead organizer of the George Wiley Center, countered that the George Wiley center was not a plaintiff in the suit.

2015-10-20 PUC 022According to a George Wiley Center press release, “Every year tens of thousands of households in Rhode Island experience the stress of utility service termination due to unaffordable bills. It is shocking that in many of these homes live people struggling with medical conditions. This injustice is due to a loophole that allows the state’s Division of Public Utilities to grant National Grid permission to shut off households, even when their medical status is on file.”

The Wiley Center says such shut-off are, “inhumane and a threat to public health and safety.”

“Stopping utility shut-offs on people with medical conditions has been recommended by medical professionals who seek to protect and improve health,” says the George Wiley Center, “With access to utility service patients can be warm or cool as needed, see and not stumble in the dark, refrigerate medications, use nebulizers and oxygen tanks, take a warm bath. When service is shut off, basic needs are not met and medical conditions will likely worsen, sometimes leading to hospitalization and other serious consequences.”

Alan Costa has a medical condition that literally stops his heart a hundred times a minute. Without electricity, he dies. He fell behind on his electrical bills while undergoing two complex medical procedures in a very short period of time. He wonders why Governor Gina Raimondo doesn’t use her executive power, as the person who nominates people to the PUC board, to push for enforcement of laws that protect the health and well being of Rhode Island citizens instead on the profits of National Grid.

Annabel Alexander is 77 years old and suffers from a long list of ailments. (She showed me the list!) She has had her heat and her electricity turned off, and sleeps in her overcoat in her bed at night. National Grid will not make a deal with her to catch up on her bills for less than 50 percent of her income. “It’s a damn shame,” she says, “that we have to suffer while they are up there getting paychecks and living in mansions!”

In the next two videos we meet Kevin, who survived the Station Night Club fire. He pulled people out of that building that night, but today suffers from post traumatic stress and other ailments. On Saturday night he ran out of oil. On Monday morning his electricity was turned off. He needs to keep his medication chilled. He was promised that his condition would prevent a shut-off.

“I feel I’m being punished now, for things that people called me a hero for.”

Kevin was invited into the offices to see if there was a possibility of resolving his issue. He left disappointed, his case still pending.

Diane has asked her daughter for help with her bills. National Grid wants to take more than half her paycheck to turn her power back on. She has a host of ailments, and told the crowd that people with arthritis need a hot shower, as opposed to washing yourself of in water you’ve heated up in your microwave…

Camilo Viveiros, lead organizer of the George Wiley Center, rallied the crowd and explained the costs of these utility shut-offs in terms of human misery, but also in terms of dollars wasted.

Here is the full letter the protesters attempted to deliver to the PUC board, and it was signed by a long list of health care professionals, including Dr. Michael Fine, MD, former RI State Director of Health.

I’m writing to express my support for the Lifeline Project’s work to improve protection from utility termination for medically vulnerable households in our State. Unaffordable utility bills are especially prevalent among low-income medically vulnerable households because these households lack the financial resources to make ends meet and often require utility service for ongoing treatment of chronic illness. As a medical professional, I see first-hand the way that termination of utility service can lead to disastrous consequences for families such as an unexpected trip to the emergency room, the loss of a housing voucher, or eviction. Households with a permanently disabled individual, or a person with a pre-existing, serious medical condition such as asthma, chronic obstructive pulmonary disorder, or diabetes, are among the most at risk because these conditions require electric medical devices or refrigerated medication.

The Lifeline Project is a collaboration between the Rhode Island Center for Justice and the George Wiley Center, which aims to protect and expand the rights of medically vulnerable households facing gas and electric utility shut off through the provision of legal assistance and community organizing. The Lifeline Project has identified a host of routinized, unfair and illegal practices and procedures on the part of the public utility company, National Grid, and the state regulatory agencies, the Division of Public Utilities and the Public Utilities Commission with respect to residential utility termination. These practices need to be fixed and in the meantime, medically vulnerable households need protection from shut-off.

I am specifically writing to support the Lifeline Project’s current campaign to challenge these illegal practices and urge National Grid and the state regulatory agencies to meet the following demands:

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.

As a medical professional in this state, I understand the dire need to protect these consumers from the dangerous impacts of utility shutoff.

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Patreon

Peter Nightingale’s call to action at URI


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Peter Nightingale

At the University of Rhode Island’s 19th annual Diversity Week, Peter Nightingale, professor of physics at URI, and climate activist, challenged students’ perspectives on climate change and offered a call to action in order to address environmental racism. The event, “Race and the Environmental Justice Movement,” was held at the Multicultural Student Services Center.

Nightingale began the event with a stark warning: in order to avoid catastrophic climate change, we must reduce greenhouse emissions globally by 7 percent. The U.S. is home to a fraction of the world’s population, it emits 25 percent of global greenhouse gasses. Even though the U.S. is greatly responsible for climate change, it will be the poor of the world, nations with less developed infrastructure, that will bear the consequences.

Nightingale referenced Robert Bullard’s work, “Dumping in Dixie”, in the presentation:

The environmental movement in the United States emerged with agendas that focused on such areas as wilderness and wildlife preservation, resource conservation, pollution abatement, and population control. It was supported primarily by middle- and upper-middle-class whites. Although concern about the environment cuts across racial and class lines, environmental activism has been most pronounced among individuals who have above-average education, greater access to economic resources, and a greater sense of personal efficacy.”

“I’m one of those people who are in a position of privilege,” said Nightingale. It was Nightingale’s privilege that allowed him to be treated politely by police when resisting fracked gas expansion. “Suppose I were half my age, and my color is a little bit darker – would they be equally polite, and nice? No – absolutely not.”

In the fight for the environment, there are the following stakeholders: the environmentalists, the social justice advocates, and the neo-liberal boosters, who, “have as their chief concerns maximizing profits, industrial expansion, economic stability, laissez-faire operation, and deregulation,” said Nightingale, quoting Bullard.

“If you follow the economic discussion in Rhode Island,” continued Nightingale, “all you hear people say is ‘all we need is more jobs, more jobs’ – but when you scrape away the rhetoric, a lot of people of color and poor minorities are being divided among themselves… the elites never mention that it’s all about their profits, about busting unions, about exploiting people – and this is one of the problems we have to deal with.”

For instance, Governor Gina Raimondo stated, “I am committed to moving ahead with cost-effective, regional energy infrastructure projects—including expansion of natural gas capacity—that will improve our business climate and create new opportunities for Ocean State workers.”

Nightingale also referred to the President’s Climate Action Plan as the “President’s Business Climate Action Plan” – stating that it is based on the interests of Wall Street, not in science. We are moving away from fossil fuels, and going towards natural gas, essentially replacing carbon dioxide with methane, a gas that is much more potent than carbon dioxide. “Let that sink in – that’s what [Senator] Sheldon Whitehouse is saying we should do and it’s a bad plan”

Not only are we “Dumping in Dixie,” but we are dumping in Providence, we are dumping in Burrillville, and we are dumping globally. From National Grid’s proposed LNG liquefaction facility to the proposed gas-fired power plant in Burrillville, the environment and the people are under assault says Nightingale.

“Who are the people that live next to I-95 in Providence… the people are about to thrown out of their houses… their skin tone is a couple of shades darker than mine.” Nightingale directed attendees to the Environmental Protection Agency’s Environmental Justice website, which shows several environmental and demographic indicators regarding pollution. In the presentation, Nightingale showcased the current indicators for the proposed LNG liquefaction facility at Fields Point location in Providence, and compared the indicators to those of East Greenwich.

Nightingale continued by critiquing Cap and Trade. “We are taking a serious problem [and] financializing it. We’re putting it on the stock market, and we’re allowing people to speculate.” By allowing environmental destruction to continue in impoverished communities, while Wall Street profiteers from the destruction, we thus institutionalize environmental injustice. “We can live yet another day, because we are taking the livelihood from someone else in the Southern Hemisphere.” A prime example of this is the continued deforestation of the Amazon rain forest. Nightingale drew a parallel to Pope Francis’ comments on climate change and tax credits:

The strategy of buying and selling ‘carbon credits’ can lead to a new form of speculation which would not help reduce the emission of polluting gases worldwide. This system seems to provide a quick and easy solution under the guise of a certain commitment to the environment, but in no way does it allow for the radical change which present circumstances require. Rather, it may simply become a ploy which permits maintaining the excessive consumption of some countries and sectors.”

Nightingale concluded by offering a powerful statement from Pope Francis, “The Earth, our home, is beginning to look more and more like an immense pile of filth.”

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


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2015-10-08 LNG 018No 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.”

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Yudiglen Sena-Abrau

Jesus Holguin

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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.

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Patreon

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.

2015-08-31 ECOS 02 Gina RaimondoHow 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

Patreon

National Grid sued to stop illegal utility shutoffs


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2015-09-29 George Wiley 006National Grid and the Rhode Island Division of Public Utilities and Carriers are being sued for turning off the electricity of seriously ill and disabled consumers, putting profits before people’s lives and in violation of Rhode Island state law.

The George Wiley Center and the RI Center for Justice have been working together since May to provide free legal assistance to “hundreds of low-income, medically vulnerable utility consumers.” Their collaboration, said Robert McCreanor, RI Center for Justice executive director, lead to the realization that existing  state laws were not being enforced. Since National Grid refuses to negotiate in good faith or follow the law, a class action lawsuit was filed Tuesday morning.

The plaintiffs named in the suit, “suffer from severe medical conditions including chronic respiratory failure, which requires electric powered oxygen machines. They asked National Grid to take their medical conditions into consideration when setting up a payment plan for their back bills, as required by law. When National Grid sent shut-off notices without making the required legal determination, these consumers looked to the state regulator of public utilities for protection but were repeatedly denied. Some plaintiffs required emergency medical treatment and hospitalization after their electric and gas services were shut off.”

Shane Ward, one of the plaintiffs in the suit, told the crowd gathered at the press conference about his experience having the electricity turned off at his home, where his 74 year old mother has Alzheimer’s and epilepsy. She requires the use of a respirator. After being told he was in arrears with his bill and given a shut off date, National Grid arrived a week early. When Ward asked for a few minutes to switch his mother to a different respiratory system, he was denied, and the electricity was turned off, sending his mother into an epileptic fit.

Attorneys are requesting immediate relief through a temporary restraining order. Robert McCreanor estimates at least 3,000 Rhode Islanders may be affected by this class action suit. A restraining order would prohibit termination of service to the proposed class and restoration of service for those now shut off.

“The system is broken,” said McCreanor, “National Grid routinely violates the law and the Division of Public Utilities automatically grants the shut offs National Grid requests. The consequences for seriously ill and disabled consumers are costly for our communities.”

Camilo Viveiros, lead organizer of the George Wiley Center, has battled for years on behalf of utility consumers. Many of the laws National Grid seems content to ignore were passed in the RI General Assembly only through the extraordinary lobbying and organizing work of the Wiley Center under the leadership of poverty advocate Henry Shelton.

“We’re simply asking for the rules that are on the books to be practiced, they’re there to protect people. We’re asking the Division of Public Utilities to follow the law…”

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


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National Grid fake groups
photo courtesy EJLRI

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.”

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