Department of Homeland Security – Coast Guard
Department of Transportation –
Maritime Administration
Public Hearings
ConocoPhillips – Beacon Port LNG Terminal

 Coastal Conservation Association Testimony 

Coastal Conservation Association is a grassroots organization with 90,000 members in 15 state chapters dedicated to the conservation, promotion and enhancement of the present and future availability of coastal resources for the benefit and enjoyment of the general public. CCA has been active in local, state and federal fishery management issues for more than a quarter century.

We are here today to formally, and strongly, oppose the use of open-rack vaporization technology for the Beacon Port Liquefied Natural Gas Terminal proposed by ConocoPhillips 50 miles southeast of Galveston, Texas.

CCA fully supports the concerns outlined by both the Gulf States Marine Fisheries Commission and the Gulf of Mexico Fishery Management Council on open-loop facilities. We applaud the National Marine Fisheries Service for strengthening their position against the licensing of open-loop technology for LNG terminals. As the appointed managers of our marine resources, NMFS’ recent declaration that closed-loop systems are the best available technology and a best practice for avoiding impacts on the marine and coastal environment is critical to this debate and should not be ignored.

Far more important than the limited, known impacts of an open-loop system in this location is the glaring lack of data on the potential impacts, currently unknown. Decisions like this one, made decades ago with a similar lack of information on long-term consequences, resulted in the degradation of the Florida Everglades and the great wetlands of Louisiana.

Experience proves that we often pay a great price tomorrow, in pursuit of expediency today.

CCA rejects assertions that open-loop LNG facilities will have minimal adverse impacts on marine resources. There is simply not enough data to make that claim. CCA is concerned about impacts to the entire marine ecosystem, from predators to plankton. No science has been produced yet that can demonstrate minimal impacts to that wide range of organisms. No one knows what the true impact will be because no one knows exactly what is floating in the ocean at all depths at all times of year.

CCA is opposed to open-loop systems for the simple reason that there are still too many questions left unanswered about the impact of not just this one terminal, but several operating all together in the Gulf of Mexico.

What will be the true impact of one of these plants?
No one knows.

What will be the cumulative impact of two, three or more of these giant terminals?
No one knows.

It is a founding principle of CCA to err on the side of caution in conservation matters where the science is not currently adequate to determine long-term results. We have expended enormous amounts of energy and money to save, restore and protect the resources of the Gulf of Mexico. The hundreds of thousands of recreational anglers who have worked to better steward those resources are stunned to see that work jeopardized by the unnecessary use of open-loop technology.

There are reasonable alternatives to open-loop systems that do far less damage to the marine environment, alternatives that do not represent such a huge gamble. CCA is adamant that ConocoPhillips not be allowed to gamble with our marine resources and that a permit for an open-loop system be denied.

On behalf of the 90,000 members of CCA, thank you for the opportunity to present our concerns over this application and to provide comments.