National
LNG
Workshop
Notes
July
20,
2004
1.
Status
of
LNG
a.
National
Overview
In
North
America,
there
are
approximately
49
LNG
terminals
in
various
stages
of
the
approval
process
(
i.
e.,
existing
with
approved
expansions,
approved,
proposed,
or
planned).
Approximately
36
of
these
facilities
are
in
the
United
States,
with:
 
5
existing;
 
about
10
proposed
or
planned
offshore
(
USCG/
MARAD
jurisdiction);
 
approximately
20
proposed
or
planned
onshore
(
FERC
jurisdiction);
and
 
about
6
for
which
offshore/
onshore
planning
has
not
yet
been
determined.

Regionally
speaking,
of
the
proposed
and
planned
terminals
whose
onshore/
offshore
status
has
been
determined,
16
are
in
the
Gulf
of
Mexico,
5
are
in
the
Northeast,
and
4
are
in
the
Southwest.
Considering
this
potential
distribution
of
LNG
facilities,
along
with
the
different
levels
of
ocean
and
coastal
development
in
each
region,
the
direct,
indirect
and
cumulative
impacts
would
vary
widely
among
them.

Furthermore,
as
a
number
of
the
currently
planned
or
proposed
LNG
facilities
are
in
competition
with
each
other
in
specific
locations,
not
all
of
them
will
be
approved.
However,
taken
in
tandem
with
the
host
of
water­
intake
facilities
already
existing
in
US
waters,
including
desalinization
plants
and
power
plants,
this
additional
water
use
by
the
LNG
industry
poses
real
concerns
for
marine
resource
management.

While
potential
impacts
from
LNG
construction
and
operation
vary
on
a
site­
by­
site
basis,
general
conclusions
may
be
drawn
for
onshore
and
offshore
facilities.
For
example,
onshore
facilities
may
result
in
greater
impacts
than
offshore
facilities
because
more
productive
and
sensitive
habitats
are
found
inshore.
Furthermore,
onshore
facilities
commonly
require
dredging
to
establish
shipping
channels
(
40
ft.
requirement).

Questions
have
arisen
nationally
as
to
whether
or
not
the
impact
of
LNG
facilities
on
some
managed
fisheries
may
affect
the
stock
assessments
and
management
regimes
for
those
affected
fisheries,
possibly
resulting
in
lowered
harvest
levels.
To
reduce
the
need
for
such
measures,
the
Gulf
of
Mexico
Fishery
Management
Council
has
taken
the
precautionary
approach
and
recommended
closed­
loop
over
open­
loop
systems.

b.
Regional
Status
and
Concerns
i.
Southeast
(
for
more
information,
please
refer
to
Ric
Ruebsamen's
presentation)
 
Last
year
many
proposals
were
received
for
the
region,
and
all
16
of
them
are
off
the
coast
of
Texas
and
Louisiana
(
in
these
states,
both
the
culture
and
economy
support
LNG
growth).
Considering
approved
and
proposed
facilities
with
oncethrough
heating
systems,
1
billion
GD
(
gallons/
day)
would
be
used,
resulting
in
serious
cumulative
impacts.
 
The
NMFS
Southeast
Fisheries
Science
Center
(
SEFSC)
analyzed
the
possible
impacts
of
LNG
facilities
in
the
Southeast
using
the
Port
Pelican
project
as
a
case
study.
Given
the
limited
data
available
to
run
the
models,
the
SEFSC
determined
that
the
resulting
impacts
were
probably
conservative
and
that
the
true
impacts
could
be
as
much
as
2
to
8
times
higher.
2
 
We
need
to
learn
how
facility
operations
might
be
adapted
to
offset
these
impacts.
For
example,
by
constructing
in
deeper
water,
some
nearshore
impacts
could
be
minimized.
While
the
shallowest
depth
for
construction
of
an
offshore
facility
is
50
feet,
the
El
Paso
Energy
facility
in
the
Gulf
of
Mexico
is
proposed
in
approximately
300
feet
of
water.
 
In
the
Gulf,
there
is
lots
of
existing
pipeline
infrastructure
and
thus
greater
capacity
to
carry
additional
natural
gas
than
may
be
available
elsewhere.
This
explains
some
of
the
growth
seen
in
the
Gulf
for
LNG
facilities.

ii.
Northeast
(
for
more
information,
please
refer
to
Chris
Boelke's
presentation)
 
In
this
region,
siting
of
LNG
facilities
poses
great
concerns.
Exclusion
zones
around
proposed
LNG
facilities
could
result
in
navigation
restrictions
that
could
impact
harbor
and
fishing
activities.
 
Weaver's
Cove
LNG
Project
(
proposed):
­
The
main
issues
are
dredging
(
36
months)
and
concomitant
EFH
impacts.
­
The
mayor,
Senate,
and
House
of
Representatives
in
Massachusetts
oppose
it.
 
Northeast
Gateway
LNG
Project
(
planned):
­
supported
by
governor
but
raises
fishery
concerns
­
To
clarify,
this
project
is
not
proposed
to
be
located
in
Stellwagen
Bank
NMS.

iii.
Southwest
 
There
are
a
variety
of
habitats,
including
estuarine
habitats,
where
these
facilities
are
proposed
to
be
located.
In
southern
California
(
CA),
however,
deepwater
LNG
ports
pose
less
of
a
concern
for
sensitive
habitats.
 
In
CA,
the
local
community
has
shown
great
opposition,
in
some
cases,
to
the
establishment
of
inshore
LNG
facilities.
In
northern
CA,
a
proposed
facility
in
an
estuarine
area,
an
eelgrass
zone,
was
canceled
due
to
citizen
action.
 
When
assessing
LNG
impacts,
protected
resources,
including
salmonids
and
marine
mammals,
must
also
be
considered.
 
There
are
proposals
to
use
abandoned
oil
and
gas
platforms,
as
well
as
a
proposal
to
build
a
floating
platform
offshore
for
aquaculture
purposes.
All
of
these
cases
pose
ballast
water
concerns,
and
pipeline­
laying
impacts
are
also
important.

2.
Regulatory
Considerations
a.
EPA
316b
Regulations
 
Considering
that
316b
regulations
include
a
stipulation
that
at
least
25
percent
of
the
withdrawn
water
is
to
be
used
for
cooling
purposes,
LNG
facilities,
as
warming
water
structures,
are
generally
not
covered
under
these
regulations.

b.
Licensing
Requirements
and
Considerations.
Licensing
requirements
differ
between
the
CG
and
FERC,
as
the
CG
provides
permits
for
offshore
facilities
and
FERC
for
onshore
facilities.
The
applicants
identify
their
own
impacts.
Currently,
there
are
no
specific
standards
for
siting
related
to
depth.
Instead,
siting
is
chosen
by
the
applicant,
but
MMS
provides
recommendations.
The
EIS
then
determines
if
the
project
is
viable.

i.
Coast
Guard.
 
The
law
requires
1
NEPA
document
in
which
the
CG
is
to
disclose
the
impacts.
 
A
license
includes:
­
EPA
air
permit:
required
for
closed­
loop
systems;
3
­
NPDES
permit:
required
for
open­
loop
systems;
­
Monitoring
plan
that
is
acceptable
to
NOAA
Fisheries
(
the
CG
is
currently
not
involved
in
this
process)
 
The
CG
grants
indefinite
licenses
to
facilities,
with
permit
renewals
occurring
about
every
5
years.
 
When
asked
if
there
any
regulatory
hooks
to
require
monitoring
as
part
of
a
permit,
the
CG
replied
that
they
do
not
know
what
will
happen.
They
will
stop
the
clock
if
legitimate
problems
arise,
but
are
also
on
an
expedited,
fast
track
to
process
deepwater
port
applications
under
the
Deepwater
Port
Act.
 
The
CG
deals
with
water
intake,
air
pollution,
and
onshore
pipeline.
If
NOAA
would
like
to
obtain
information
on
these
issues
by
discussing
them
with
the
industry,
it
is
welcome
to
solicit
the
CG.
 
After
working
toward
the
licensing
of
the
El
Paso
Energy
facility,
they
have
focused
more
on
cost­
benefit
analyses
for
open
and
closed
loops.
 
According
to
the
CG,
the
most
contentious
issue
with
submitted
EIS's
is
the
use
of
open­
rack
vaporizers.

ii.
FERC
 
FERC
requires
post­
construction
monitoring
for
license
issuance.
 
Their
applicants
want
to
expedite
the
approval
and
licensing
process.
 
According
to
FERC,
few
of
the
proposed/
planned
facilities
will
have
seawater
intake.

c.
Coordination
with
the
States.
Coordination
with
the
states
in
the
NEPA
process
is
necessary
regardless
of
whether
facilities
are
onshore
or
offshore.
It
may
be
difficult,
however,
to
fit
state
compliance
into
the
already
tight
Coast
Guard
schedule,
considering
its
statutory
deadline
of
less
than
1
year.
Below
are
some
considerations
for
improved
state
coordination.
 
In
some
states,
such
as
California
and
Massachusetts,
the
CG
has
a
joint
EIS/
EIR
process.
 
The
CZMA
consistency
requirement
might
satisfy
state
requirements/
concerns.
 
State
efforts
should
come
before
federal
efforts,
or
at
least
simultaneously.
 
Perhaps
we
should
step
away
from
individual
state
programs
and
talk
about
this
with
NGA
or
CSO.

3.
Technologies
Available
for
Reducing
Impacts
(
for
more
information,
please
refer
to
Carey
Johnston's
presentation)
There
is
no
one
panacea
technology
to
minimize
environmental
impacts
nationally,
and
thus
we
must
undertake
site­
specific
analysis.
a.
Water
Intake
Arrays
 
Water
intakes
tend
to
be
closer
to
the
surface
because
warmer
water
regasifies
liquified
nitrogen
more
efficiently
than
colder
water.
However,
NOAA
encourages
intake
to
occur
lower
in
the
water
column,
with
the
assumption
that
fewer
organisms
are
found
there
and
entrainment
impacts
will
be
minimized.
 
Regarding
changes
in
larval
distribution
in
the
water
column,
the
intake
array
can
be
placed
at
multiple
levels,
to
avoid
higher
densities
of
organisms.
 
Existing
offshore
technologies
allow
water­
intake
velocity
and
amounts
to
be
minimized
or
regulated.
4
 
Since
entrainment
impacts
vary
throughout
the
year,
variable­
speed
motors
for
water
intake
can
be
used.

b.
Water
Discharge
Arrays
 
The
output/
discharge
array
in
some
cases
is
often
lower
down
in
the
column
where
the
water
is
cooler,
which
might
minimize
the
impact
of
temperature
changes,
but
could
still
impact
benthic
fauna.
 
Applicants
seek
to
restore
water
temperature
to
ambient
temperature
within
a
500
meter
radius
(
safety
zone).

c.
Open
and
Closed
Loop
Systems
 
Compared
with
open­
loop
systems,
closed­
loop
systems
tend
to
operate
with
less
efficiency
and
emit
air
pollution.
Depending
on
the
distance
to
shore
and
the
fuel
source,
the
air
quality
impacts
vary.
NMFS:
Despite
these
considerations,
ExxonMobil
has
chosen
a
closed
loop
over
an
open­
loop
system
for
two
facilities
in
the
Gulf
of
Mexico.
Both
are
to
be
located
in
estuarine
passes,
areas
of
special
concern.
 
Unique
system
proposed
at
GOM
Energy
Bridge
(
the
only
one
presently
like
it):
­
Applicant
could
be
subject
to
316b
regulations
because
the
project
proposes
to
use
more
than
25%
of
water
for
cooling.
­
Even
if
a
closed
loop
is
chosen,
approximately
60
million
gallons/
day
would
be
used
for
cooling
the
vessel
and
for
warming
the
LNG.
Thus,
contrary
to
what
many
thought,
closed­
loop
systems
do
not
mean
zero
water
use,
and
do
not
always
minimize
water
intake.
 
Re­
heat
devices
that
use
waste
heat
from
nearby
industrial
facilities
serve
as
a
regasification
alternative.
 
A
system
that
switches
between
open
and
closed
loop
might
also
help
to
minimize
entrainment
impacts.
 
Temperature
impacts
differ
between
once­
through
and
closed­
loop
systems.

4.
Identifying
Scientific
Gaps
(
for
more
information,
please
refer
to
Tom
Minello's
presentation
and
the
Thompson
memo:
`
Potential
Impacts
of
Liquid
Natural
Gas
Processing
Facilities
on
Fishery
Organisms
in
the
Gulf
of
Mexico')
The
discussion
focused
on
impacts
from
entrainment,
with
impingement
serving
as
less
of
a
concern
because
flow
rates
can
minimize
this
impact.
Due
to
the
host
of
stresses
already
impacting
fishery
resources
and
considering
the
probable
mortality
of
practically
all
entrained
organisms,
how
does
this
water
use
impact
populations?
Not
only
do
we
lack
the
data
to
make
this
determination,
we
also
lack
the
resources
to
investigate
the
question.

a.
Data
Limitations.
SEAMAP
survey
data
are
not
collected
to
evaluate
water­
entrainment
facilities.
Thus
using
SEAMAP
data
for
this
purpose
has
serious
limitations.

b.
Imprecise
Information
Citations
 
At
times,
special
interests
use
SEAMAP
data
improperly,
with
significant
implications
to
regulatory
decisions,
business
decisions,
and
trust
resources.
Misleading
conclusions
about
impacts
result,
making
it
harder
for
resource
agencies
to
verify
the
quality
of
impact
assessments,
because
time
must
be
spent
verifying
basic
references.

5.
Addressing
Uncertainty
and
Cumulative
Impacts
5
General
Approaches
 
Employ
precautionary
approach
 
Compile
complete
list
of
1)
what
we
know,
and
2)
our
data
requirements
 
Consult
scientific
information
reports
­
see:
the
latest
USGS
reports
for
information
on
desalinization
plants;
MMS'
socioeconomic
model
for
assessing
impacts
of
offshore
O&
G
activities
(
under
modification
to
include
LNG
impacts);
SEFSC
larval
recruitments
study;
DOE
research
program;
­
examine
site­
specific
information
and
assess
impacts
from
individual
facilities

only
way
to
begin
assessing
cumulative
impacts;
­
promote
expansive
literature
review.
A
lot
of
work
that
has
been
done
is
not
available
on
the
Internet
and
librarians
do
not
know
about
it.
 
Consult
with
independent
contractors
(
Weaver's
Cove
example)
who
are
often
involved
in
preparing
EIS
documents
and
assessing
cumulative
impacts.
 
Consult
with
academia
and
regional
science
centers,
although
they
often
have
resource
constraints
and
lack
discretionary
funds
to
conduct
research.
Similarly,
the
CG
lacks
discretionary
funds.
­
Might
follow
Atlantic
States
Marine
Fisheries
Commission
(
ASFMC)
approach,
working
with
EPA
or
Sea
Grant
(
matching
funds)
to
design
a
special
project
that
addresses
a
priority
need.
 
Develop
state
partnerships
and
bring
the
private
sector,
communities,
and
agencies
together
in
discussions.
­
Request
more
transparency
from
applicants.
The
entire
range
of
uncertainty
needs
to
be
presented.
­
When
appropriate,
approach
the
industry
in
the
future
and
inform
them
of
new
technologies
or
findings
that
may
provide
strong
support
for
retrofitting.
Developers
are
often
cognizant
of
the
situation
and
environmental
requirements,
and
some
would
be
willing
to
retrofit.
With
this
in
mind,
we
need
to
tell
the
industries
about
the
likelihood
of
better
data
in
the
future,
which
might
encourage
them
to
include
the
best
technology
now
and
prevent
retrofitting
later,
or
the
same
best
technology
can
help
to
make
retrofitting
easier
and
cheaper.

a.
Modeling
i.
Estimating
Population
Level
Impacts
 
Current
approaches,
needs,
and
considerations
­
Data
availability
and
quality
determine
both
the
models
you
are
able
to
use
and
the
level
of
sophistication
you
can
attain.
For
most
species,
it
is
not
possible
to
run
estimated­
loss
models.
­
At
the
NMFS
Southeast
Fisheries
Science
Center
(
SEFSC),
models
with
realistic
estimates
were
run
for
red
drum,
menhaden,
and
red
snapper,
and
the
range
of
impacts
provided.
­
The
outputs
of
these
models
show
high
variability,
caused
in
part
by
lack
of
data
and
also
by
small
changes
in
the
stage
being
modeled
(
not
so
much
due
to
model
limitations
as
to
natural
variability).
The
models
indicate
that
population
levels
are
highly
sensitive
to
changes
in
early
life
stages.
Additionally,
variability
as
a
natural
component
of
life
is
always
expected,
and
impacts
depend
on
natural
mortality
rates.
­
These
models
do
not
consider
age­
dependent
survival
rates,
which
are
important
for
obtaining
a
better
understanding
of
the
overall
population
response
to
impacts.
6
In
this
respect,
the
use
of
age­
structured
production
models
would
be
most
appropriate.

 
General
Ways
to
Address
these
Limitations
­
Use
standardized/
same
tests
when
comparing
results
because
assumptions
can
dramatically
change
them.
­
The
standard
modeling
technique(
s)
used
should
show
the
associated
uncertainty
by
providing
the
expected
point
estimate(
s),
as
well
as
the
range
of
outcomes
and
distribution.
­
Need
to
run
risk
and
sensitivity
analyses
­
Lab
experiments
serve
as
another
method
for
model
validation.

1.
Assessing
and
predicting
economic
impacts
at
cooling
water
intake
structures
(
for
more
information,
please
refer
to
presentation
given
by
Ashley
Allen
and
Erik
Helm)
 
Quantifying
impacts
of
impingement
and
entrainment
­
The
sampling
data
included
550
Phase
II
and
~
600
Phase
III
facilities.
­
The
analysis
was
conducted
not
only
at
the
population/
ecosystem
level,
but
also
at
the
individual
level.
­
Regarding
the
data,
there
was
a
lot
of
variability
due
to
extrapolation
(
e.
g.,
sampling
done
at
one
specific
time
of
the
year
was
extrapolated
to
get
an
annual
estimate
of
density).

 
Monetizing
the
benefits
associated
with
reducing
environmental
impacts
­
According
to
the
models
used,
benefits
were
projected
as
follows:
o
commercial
benefits:
$
3.5
million/
year;
o
recreational
benefits:
$
79
million/
year;
o
non­
use
benefits:
$
250
million/
year
(
this
figure
was
not
used
in
the
final
analysis
because
of
insufficient
evidence
to
support
the
claim
that
a
fish
population
change
was
occurring.
EPA
may
use
these
non­
use
values
for
its
316b
Phase
III
rulemaking).
­
To
apply
this
same
technique
for
LNG
the
original
question
should
be
asked
differently
(
i.
e.
if
you
do
not
install
appropriate
technologies,
how
many
fish
are
going
to
die?).
In
addition,
this
model
would
provide
for
the
analysis
of
LNG
impacts
on
a
facility­
by­
facility
basis.

b.
Monitoring
 
Currently,
environmental
parameters
are
not
being
measured,
but
these
first
steps
are
expected
to
take
place
with
monitoring.
Most
data
currently
collected
are
climatological.
 
There
is
no
strong
set
of
monitoring
standards
or
protocol
to
recommend
to
the
industry.
 
Quality
control
needed:
­
Monitoring
programs
must
be
well­
designed
(
i.
e.,
hypothesis­
driven),
comprehensive
(
set
out
to
answer
the
specific
questions
we
have),
and
conducted
by
experts
­
A
tracking
system
of
monitoring
programs
should
be
established,
to
monitor
the
right
sites,
ask
the
right
questions,
and
consider
cumulative
impacts.
 
Monitoring
requirements
should
include:
­
Baseline
information­
gathering
and
post­
construction
monitoring
programs.
Baseline
monitoring
can
be
conducted
to
assess
both
near­
field
and
far­
field
impacts,
since
the
7
same
population
may
be
affected
along
a
geographic
gradient
(
i.
e.
larvae
inshore,
adults
offshore).
­
Entrainment
monitoring
­
Sampling
on
temporal
and
spatial
scales
to
detect
seasonal
differences
and
changes
in
vertical
distribution
­
Monitoring
of
cool
water
plumes,
to
determine
how
far
they
extend
and
their
associated
impacts
 
Part
of
the
objective
for
monitoring
should
be
to
evaluate
how
well
impacts
are
being
minimized
with
the
possibility
of
adjusting
aspects
of
the
facilities
in
the
future.

c.
Mitigation
i.
Mitigation
possibilities:
 
Replace
organisms/
species
lost
 
Replace
habitat
 
Compensate
the
fishing
industry
 
Employ
operational
measures,
for
example,
those
that
require
entrainment
monitoring
(
if
many
organisms
are
seen
then
shut
down
water
uptake,
or
use
automatic
shut­
down).
To
determine
best
operational
measures,
pre­
monitoring
data
(
if
available)
can
be
used.
ii.
It
is
difficult,
if
not
impossible,
to
restore
organisms
and
habitats.
The
costs
associated
with
their
mitigation
and
the
losses
to
the
fishing
industry
must
therefore
be
estimated,
an
action
that
would
make
it
less
costly
to
go
with
the
closed
loop
up­
front.
