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DEP letter
Nat. Marine Fisheries Letter
SE Reg.Planning & Econ. Dev. Letter
Letter to
FERC Re: Weaver's Cove
Southeastern Regional Planning and Economic Development District
(SRPEDD)
January 29, 2005
Secretary Magalie R. Salas
Federal Energy Regulatory Commission
888 First St., N.E., Room 1A
Washington, D.C. 20426
Secretary Ellen Roy Herzfelder
Exec. Office of Environmental Affairs
100 Cambridge St., Suite 900
Boston, MA 02114
Attn: MEPA Office
Re: Docket No. CP04-36-000
Dear Secretary Salas and Secretary Herzfelder:
The Southeastern Regional Planning
and Economic Development District (SRPEDD) has reviewed the Draft
Environmental Impact Statement for the Weaver's Cove LNG Project
in Fall River that was released on July 30, 2004. We offer these
comments in response to the September 20, 2004 deadline of the
Federal Energy Regulatory Commission (FERC) and the September
24, 2004 deadline for the Massachusetts Environmental Policy
Act (MEPA) review.
SRPEDD supports the position of the City of Fall River that it
is inappropriate to locate this facility in such a densely developed
area. It is of particular concern that there is no plan or strategy
being followed by the FERC for the development of LNG sites in
New England or the east coast.
SRPEDD also supports the comments made by the Taunton River Wild
and Scenic River Study Committee, for which SRPEDD is the project
coordinator. These comments were contained in a letter dated
September 16, 2004 and signed by Jim Ross, Chairman of the Committee.
We further believe that several of the issues that were required
to be addressed in Secretary Herzfelder's certificate of August
28, 2003 have been addressed only partially or not at all.
These would include a no build baseline, alternative site analysis,
Chapter 91 (Waterways) and Section 401 (Dredging) requirements,
and several other areas requested by the Secretary. SRPEDD
was heavily involved with the environmental impact analysis and
mitigation for the construction of the Brightman Street Bridge
and we believe, at a minimum, that the LNG project should be
held to the same standards of prevention and mitigation as that
project was, especially for work done in the Taunton River.
While there are many issues related to safety and environment
that we are concerned with, these comments are directed in three
specific areas in which SRPEDD has specific expertise:
Navigation, dredging and the impact on the Brightman Street
Bridge replacement;
Transportation (roadway access in and out of the site); and
Land use and waterfront redevelopment.
NAVIGATION, DREDGING AND THE IMPACT ON THE BRIGHTMAN STREET BRIDGE REPLACEMENT
On page 2-33, the construction schedule gives the planned in-service date for the project as late 2007. Page 4-141 predicts the completion of the new Brightman Street Bridge at 2008, and states AThis delay in the construction of the Brightman Street Bridge could affect the schedule for beginning operation of the proposed LNG terminal.@ The latest completion date for the new bridge is 2010. There is no date proposed for the complete demolition of the old bridge, except that it cannot happen until the new bridge is fully operational. With an existing horizontal opening of only 98 feet, there is no possibility that any ships would be able to reach the terminal upstream until the complete demolition of the old bridge is accomplished. The DEIS needs to address this inconsistency.
Page 2-11 mentions states that AA LNG vessel of this size would typically have a total length of about 950 feet, a beam (width) of about 145 feet, and a loaded draft of about 37.5 feet.@ But the report never says for certain that this is the size of the vessels that will be delivering up the Taunton River, yet the report states on page 2-24 that the channel would be dredged to a target depth of 37 feet below mean lower low water (MLLW). Is this in error or is it the intent of Weaver's Cove to only bring ships in at high water? This is an unacceptable margin of error.
Page 4-210 contains the statement:
AWeaver=s Cove Energy anticipates that the sides of the LNG ships
could occasionally contact the fender system panels.@ of the
new Brightman Street Bridge. We request that the Massachusetts
Highway Department be specifically consulted as to whether this
is an acceptable condition, particularly in terms of the current
bridge design and the ability to absorb impact from ships much
larger than those that are now using the river, or were using
the river, prior to and during the new Brightman Street Bridge
design.
Navigational simulations have been conducted for emergency situations,
but not yet for high winds. It is high winds that have contributed
to many of the collisions with the old Brightman Street Bridge.
As stated on Page 2-8: "LNG ships have a distinctive appearance
compared with other transport ships. An LNG ship has a high
freeboard because of the comparatively low density of the cargo.
Because of the high freeboard, when compared with vessels such
as an oil tanker, wind velocity can adversely affect the maneuverability
of the ship, particularly at slow speed, such as during docking."
We are equally concerned with passage through the 200 foot
bridge opening at the new Brightman Street Bridge. Since the
LNG ships are high in the water with a great sail exposure, deliveries
must be prohibited during high wind conditions. Returning the
empty ship through the bridge opening will also be a dangerous
maneuver. The wind will have a more dramatic affect on an empty
ship, sitting high in the water. Tug boats may not be able to
safely steer these ships through the bridge opening during high
winds, just as they have been unable to control empty barges
in the past. The failure to perform navigational simulations
for high wind conditions is a fatal flaw in this DEIS.
The four Sediment Core Locations maps, presented on pages 4-17 to 4-20, omit the immediate area of the Brightman Street Bridge, both old and new. Sediment cores from both of these locations should have been included in the DEIS. The east side of the channel at the site of the old Brightman Street Bridge is identified in Figure 2.4.1-4 on page 2-25 as needing to be dredged to 37 feet below MLLW. MassHighway will remove the old Brightman Street Bridge, and its supports, to below the authorized depth of the channel. The bridge project, however, is not responsible for dredging the channel to restore the 400 foot channel width. Weaver's Cove needs to clearly commit to the dredging required after the old bridge is removed from the Taunton River.
The DEIS fails to adequately discuss the potential impacts of proposed open bucket dredging on the estuary and its dependent species. Further, the plan to dredge continually ignores spawning and migration periods for sensitive species common to the river. The current Brightman Street Bridge replacement project, while involving no dredging, must schedule its construction and demolition activities with consideration for the alewife run (March 15 to June 15) and the downstream migration of juvenile alewife (September and October). The proponent must address this issue prior to any permit being issued (a number of other species and habitats would have to be considered in relation to the proposed dredging).
The proponent should address, in detail, the potential impacts to the fish population in the Lower Taunton River / Mt. Hope Bay associated with the typical LNG ship's intake of 11 to 14 million gallons of ballast water during offloading operations (page 2 9). The impacts associated with prop wash must also be addressed in detail.
The DEIS also fails to address consistency with Massachusetts Coastal Zone Management (MCZM) policies. A determination of consistency should be made prior to permitting, not prior to construction. This is particularly important as this portion of the Taunton River is already on the state's (MA) 303d list of impaired waters.
SURFACE TRANSPORTATION
The highway interchange at
North Main Street and Route 79 is substandard. It does not meet
current federal highway design standards for interchanges on
divided highways. The prior use of the interchange by Shell
Oil delivery trucks, over 10 years ago, does not absolve the
Weaver's Cove proponent from mitigating responsibilities to upgrade
this interchange. SRPEDD requests that the proponent agree to
prepare an interchange improvement study, an engineering design
and fund the reconstruction of the interchange to today standards.
The LNG facility should not be allowed to open until a new interchange
is in place.
The potential closing of I-195 over the Braga Bridge to traffic
while a LNG vessel travels under the span is unacceptable. The
DEIS has inadequately discussed this issue and the possible ramifications.
If the ship transports are restricted to high water periods
in the Taunton River, as stated earlier in this letter, the impact
on interstate highway traffic flow needs to be measured.
LAND USE AND WATERFRONT REDEVELOPMENT
The City of Fall River has developed several planning documents including a "Harbor and Downtown Economic Development Plan." The city has taken many steps toward achieving the visions set forth in this plan, including a park and recreation area to the south of the Weaver's Cove site, accommodations for cruise ships, and a plan to convert Route 79 into a boulevard. The Weaver's Cove site has been identified as a prime location for a hotel or conference center or office park.
The proposed land use of an LNG facility is clearly incompatible with the city's vision for its waterfront, regardless of the safety concerns associated with the LNG terminal.
We appreciate the opportunity to comment and are confident that you will conduct a complete and balanced review.
Sincerely,
Stephen C. Smith
Executive Director
Cc: Mayor Edward Lambert
Taunton River Wild & Scenic River Study Committee
Commissioner John Cogliano, Massachusetts Highway Department
Edmund J. Medeiros, SRPEDD Commissioner, Fall River
James Hartnett, SRPEDD Commissioner, Fall River
Joseph Quin, SRPEDD Commissioner, Somerset
John Ferreira, SRPEDD Commissioner, Somerset
George Hovorka, SRPEDD Commissioner, Fall River Area
Lisa Pitta, SRPEDD Commissioner, Fall River Area
Congressman Barney Frank
Congressman James McGovern
State Senator Joan M. Menard
Representative Robert Correia
Representative Patricia A. Haddad
Representative David B. Sullivan
Representative Michael Roderigues