Peter Huhtala's Letter to ODOE

Peter Huhtala
Astoria, Oregon 97103
huhtala@teleport.com

June 21, 2005

Phil Carver
Oregon Department of Energy
625 Marion St NE
Salem, OR 97301
philip.h.carver@state.or.us

Re: LNG Rules Under Discussion

Dear Mr. Carver,

Thank you for the opportunity to comment on topics related to liquefied natural gas (LNG) transport, import, storage, chemical separation, regasification, compression and distribution that should be addressed by rulemaking by the Oregon Department of Energy.  I urge you to continue with the process of developing standards for Carbon Dioxide emissions, standards to evaluate the need for LNG import terminals, and standards relating to the impact on communities from security measures necessary for LNG terminals and the tankers required for delivery to these terminals.

Carbon Dioxide standards should be reasonably similar to existing standards for other facilities.  A related standard that insists on near zero release of methane during all LNG import-related activities should be considered.  Part of the rationale for minimizing Carbon Dioxide emissions is the greenhouse effect perpetrated by this gas.  Methane, although it is dissipated more quickly, is widely considered to be a twenty-times more harmful greenhouse gas.

The need for LNG import terminals to be located on shore in Oregon must first be considered in relation to our ability to meet our heating and cooking consumption of natural gas with projected supply over the next decade.  Speculative construction and projected construction of gas-fired electric power plants should be excluded from consideration.  There is no end to the demand that could be in a sense artificially created by such plants.  They are not part of a comprehensive state or even regional energy plan, and to use these plants to justify LNG import to Oregon would be a disservice to our communities.

In accessing need, standards should first favor conservation measures and development of renewable energy sources.  If Oregon’s consumption of natural gas (exclusive of electrical generation) clearly can be shown to outpace conservation measures and alternatives, and all reasonable outside sources of gas are exhausted, then the needs assessment may proceed to the next step.  At this point there should be a clear standard that would allow on-shore LNG import terminals only if all off-shore locations proved to be impossible to site.

It is essential in my view to develop a new standard that protects communities from adverse economic and social consequences.  LNG import is a unique type of operation that involves risks that if not impeccably avoided could involve disastrous consequences to life and property.  These risks include both accidents and intentional acts.  If this country and this region decide to rely to an increasing degree on LNG import for an essential percentage of our energy needs, the opportunity to disrupt our energy systems by attacking LNG distribution becomes very attractive to our enemies.

To mitigate the current inherent risk of LNG transport, shipments to the Everett, Mass., involve security measures that cost about $80,000 per shipment, with roughly half that cost attributed to state and local efforts.

The extraordinary risk LNG import brings would stresses both water-based and land-based services, including police, fire, and emergency medical responders.  To responsibly accommodate such facilities in their vicinity Oregon cities and counties would need to elevate these services as well as fire fighting and medical infrastructure.

Companies proposing to locate LNG import terminals should be required to pay for all security costs from the time a tanker enters Oregon waters until it departs, as well as security related to LNG storage.  They should also pay for the increase in personnel and infrastructure needed to anticipate response to even a low probability event.

Security measures may also adversely impact other uses of Oregon waterways, including commerce, commercial fishing, recreation and tourism.  An applicant should be required first to prove that there is no alternate location, including off-shore,  that would result in less social and economic disruption.  Compensatory mitigation should be required for all adverse impacts that can not be avoided.

In order to demonstrate the reality of the risk associated with LNG import, and the local preparation necessary to reduce the risk and respond to accidents or intentional actions that may compromise the transport or industrial processes, I am submitting as part of these comments a May 2005 report by Good Harbor Consulting, LLC.  I wish to incorporate here in its entirety LNG Facilities in Urban Areas as prepared under the guidance of Principal Investigator Richard A. Clarke.  (This report is also available for download at http://pstrust.org/lng/index.htm) 

Thank you again for the chance to comment. 

Respectfully submitted,

Peter Huhtala