Providence Student Youth Movement

January 15, 2016January 23, 2016

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

Deprecated: Function get_magic_quotes_gpc() is deprecated in /hermes/bosnacweb08/bosnacweb08bf/b1577/ipg.rifuturecom/RIFutureNew/wp-includes/formatting.php on line 4387

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

Solutions and Alternatives

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

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

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

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

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

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

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

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

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

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

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

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

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

Just Transition in Port of Providence

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

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

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

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

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

● Potential Disasters: dangerous facility in a high risk area

● Environmental Racism: ongoing and underlying environmental justice issues

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

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

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

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

January 14, 2016January 23, 2016

Economic Inequality: high cost project that will cause economic damage

Deprecated: Function get_magic_quotes_gpc() is deprecated in /hermes/bosnacweb08/bosnacweb08bf/b1577/ipg.rifuturecom/RIFutureNew/wp-includes/formatting.php on line 4387

Economic Inequality

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

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

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

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

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

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

The press release for the suit included the following:

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

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

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

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

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

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

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

● Potential Disasters: dangerous facility in a high risk area

● Environmental Racism: ongoing and underlying environmental justice issues

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

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

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

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

January 13, 2016January 23, 2016

Public Health: health disparities and impacts on health care institutions

Deprecated: Function get_magic_quotes_gpc() is deprecated in /hermes/bosnacweb08/bosnacweb08bf/b1577/ipg.rifuturecom/RIFutureNew/wp-includes/formatting.php on line 4387

Public Health

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

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

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

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

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

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

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

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

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

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

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

● Potential Disasters: dangerous facility in a high risk area

● Environmental Racism: ongoing and underlying environmental justice issues

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

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

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

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

January 12, 2016January 23, 2016

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

Deprecated: Function get_magic_quotes_gpc() is deprecated in /hermes/bosnacweb08/bosnacweb08bf/b1577/ipg.rifuturecom/RIFutureNew/wp-includes/formatting.php on line 4387

Climate Change

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

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

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

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

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

Climate Adaptation?

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

● Potential Disasters: dangerous facility in a high risk area

● Environmental Racism: ongoing and underlying environmental justice issues

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

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

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

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

January 12, 2016January 23, 2016

Environmental Racism: ongoing and underlying environmental justice issues

Deprecated: Function get_magic_quotes_gpc() is deprecated in /hermes/bosnacweb08/bosnacweb08bf/b1577/ipg.rifuturecom/RIFutureNew/wp-includes/formatting.php on line 4387

Environmental Racism

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

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

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

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

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

EJLRI Position Paper_Page_13

Demographics and the Waterfront?

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

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

Environmental Justice Analysis?

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

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

EPA Toxic Release Inventory?

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

EJLRI Position Paper_Page_15b

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

Schools at Risk

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

EJLRI Position Paper_Page_16

EPA’s EJ SCREEN Tool

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

Proximity to Facilities Requiring a Chemical Risk Management Plan

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

EJLRI Position Paper_Page_17

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

Proximity to Water Discharger Facility

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

EJLRI Position Paper_Page_18a

Traffic Proximity

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

EJLRI Position Paper_Page_18b

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

Toxic Storage and Discharge Facilities

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

EJLRI Position Paper_Page_19

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

Environmental Justice: working towards equitable healthy environments

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

? Potential Disasters: dangerous facility in a high risk area

? Environmental Racism: ongoing and underlying environmental justice issues

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

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

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

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

January 11, 2016January 23, 2016

Potential Disasters: dangerous facility in a high risk area

Deprecated: Function get_magic_quotes_gpc() is deprecated in /hermes/bosnacweb08/bosnacweb08bf/b1577/ipg.rifuturecom/RIFutureNew/wp-includes/formatting.php on line 4387

Potential Disasters: dangerous facility in a high risk area

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

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

Relevant Past LNG Disasters

Washington State: March 31st, 2014

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

Skikda Algeria, January 2004

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

LNG Facility in Providence Denied in 2005 due to safety risks

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

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

High Risk Neighbor: Univar Chemical Facility 

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

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

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

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

14 mile hazard radius: 110,000 schoolchildren at risk

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

Major Fuel Terminals and Fuel Transportation 

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

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

Ethanol “bomb” trains

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

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

Dangerous incidents occurring in the Port of Providence

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

Lightning Strike

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

Earthquake

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

Hurricane

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

Emergency Preparedness and Response

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

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

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

● Potential Disasters: dangerous facility in a high risk area

● Environmental Racism: ongoing and underlying environmental justice issues

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

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

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

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

January 10, 2016January 23, 2016

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

Deprecated: Function get_magic_quotes_gpc() is deprecated in /hermes/bosnacweb08/bosnacweb08bf/b1577/ipg.rifuturecom/RIFutureNew/wp-includes/formatting.php on line 4387

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

Introduction

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

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

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

● Potential Disasters: dangerous facility in a high risk area

● Environmental Racism: ongoing and underlying environmental justice issues

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

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

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

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

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

Background on National Grid’s proposal

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

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

The main points are:

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

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

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

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

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

There is no justified need for the project.

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

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

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

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

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

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

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

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

Solutions and Alternatives

Economic Inequality

Public Health

Climate Change

Environmental Racism

EPA Toxic Release Inventory?­

Schools at Risk

EPA’s EJ SCREEN Tool

Proximity to Facilities Requiring a Chemical Risk Management Plan

Proximity to Water Discharger Facility

Traffic Proximity

Toxic Storage and Discharge Facilities

Environmental Justice: working towards equitable healthy environments

Potential Disasters: dangerous facility in a high risk area

Relevant Past LNG Disasters

Dangerous incidents occurring in the Port of Providence

Introduction

Background on National Grid’s proposal

EPA Toxic Release Inventory?