CCA Testimony on TORP Open Loop LNG Terminal

Posted on June 15, 2006

Department of Homeland Security – Coast Guard

Department of Transportation – Maritime Administration
Public Hearing
TORP Terminal LP

Bienville Offshore Energy Terminal

Mobile, Alabama
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 shell and tube vaporization technology for the Bienville Offshore Energy Terminal proposed by TORP Terminal LP 63 miles south of Mobile Point, Alabama.
Coastal Conservation Association has reviewed the issue of vaporization systems using a constant flow of fresh seawater and concluded that the concerns voiced by the National Marine Fisheries Service, the Gulf States Marine Fisheries Commission and the Gulf of Mexico Fishery Management Council, among others, are simply too great to be ignored.  
CCA rejects assertions that LNG facilities using such reheating technology 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 Gulf at all depths at all times of year.
CCA is opposed to systems using millions of gallons of fresh seawater every day 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. Sea life pulled into such systems will be subjected to significant pressure and temperature changes. The long-term effects on the marine ecosystem are likely to be profound and far-reaching.
Particularly relevant to this debate is the recent release of a draft guidance document from the National Marine Fisheries Service on March 21 in which the agency declared…
“Closed-loop systems are the ‘best available technology and a best practice’ for avoiding or minimizing impacts on the marine and coastal environment.”
The risk to our marine resources is significant and unnecessary. Conservationists are aware of the very real need to supply energy to the country, but that does not require us to risk unknown damage to populations of marine species when there are other viable technologies that can balance our energy needs with our responsibility to protect the marine ecosystem as fully as possible.
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.
There are reasonable alternatives that do far less damage to the marine environment, alternatives that do not represent such a huge gamble. CCA is adamant that TORP Terminal LP not be allowed to gamble with our marine resources and that a permit for this shell and tube reheating 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.