Casa Pueblo `Vía Verde` INGLES
Casa Pueblo de Adjuntas PUERTO RICO: Northern Gas Pipeline Environmental and socio-economical risks Dr. Arturo Massol-Deyá Casa Pueblo de Adjuntas Technical and Scientific Commission Adjuntas, PUERTO RICO 00601 www.casapueblo.org [email protected] 787.829.4842 tel/fax 787.579.5070 mob About Casa Pueblo de Adjuntas Casa Pueblo is a community-‐based organization with over 30 years of service contributing towards sustainable development in Puerto Rico in the areas of economic development, environmental protection, educational programs, and agriculture. Casa Pueblo has been nationally and internationally recognized, including through the award of a 2002 Goldman Prize, equivalent to an Environmental Nobel Prize, to its Director Dr. Alexis Massol-‐
González. Our concern regarding the potential impact of a major natural gas pipeline proposal led us to assemble a Scientific and Technical Commission to study the potential environmental, social and economical impacts of the project. This Commission has now been studying this project for more than nine months. Key References: Alexis Massol González, Edgardo González, Arturo Massol Deyá, Tinti Deyá Díaz, Tighe Geoghegan 2006. Bosque del Pueblo, Puerto Rico: How a fight to stop a mine ended up changing forest policy from the bottom up. Policy that works for forests and people no. 12. International Institute for Environment and Development, London. Massol-González, A., A. Andromache-Johnnidis, A. Massol-Deyá. 2008. The Evolution of Casa Pueblo, Puerto Rico: From Mining Opposition to Community Development. Gatekeeper, 137b:1-‐ 20. Government Proposal: Natural Gas Pipeline Project ‘Vía Verde’ The Puerto Rico Electric and Power Authority (PREPA) proposes to construct and install a 24-‐inch diameter steel natural gas pipeline approximately 92 miles long with a construction right-‐of way (ROW) of 150 feet wide. The pipeline will transverse the island of Puerto Rico from the EcoEléctrica Liquid Natural Gas Terminal in the municipality of Peñuelas, to the Cambalache thermoelectric power plant in the municipality of Arecibo, then east to the Palo Seco power plant facility in the municipalities of Toa Baja and San Juan. To avoid compliance with basic regulatory standards and ignore procedural safeguards for the construction of such a high-‐risk project, the governor of Puerto Rico, Luis Fortuño, declared a state of energy emergency designed to maintain secrecy, fast-‐track the permit process and thwart full public participation in the discussion of the project. PREPA owns and operates the electric generating and distribution facilities serving all of Puerto Rico. This monopoly has employed strong-‐arm tactics to push this project forward while depriving citizens of their constitutional rights to due process in accounting for public concerns, rejecting expert testimony, and subverting all public efforts to accurately assess the environmental impacts of the pipeline, and the risks to human health and safety. While doing so, PREPA has also ignored alternative sources of energy or alternative means to supply natural gas to its plants, and has staged a multimillion-‐dollar media campaign to misinform decision makers and mislead the public (e.g. the pipeline will not harm forest or wetlands; almost 50% reduction in energy costs [22 cents KW-‐hr to 12 KW-‐hr; natural gas as a clean renewable source with 64% reduction in air emissions). Instead of diversifying electric power sources with renewable alternatives, this pipeline will only serve to substitute petroleum fuel dependency for natural gas dependency. The implications of this proposal for the future of Puerto Rico are too detrimental to accept. We need to break the dependency on fossil fuels while promoting economic development of the island with self-‐sustaining resources. Opposition to the Project: Public opposition to the project is significant with 70% of the citizens of Puerto Rico oppose the construction of the pipeline (El Nuevo Día -‐ March 2011). On May 1, 2011, over 30,000 people in Puerto Rico marched to protest the ‘Vía Verde’ gas pipeline. Different sectors of Puerto Rican society have expressed their opposition to this project, including church groups, cultural organizations, academics, labor unions, community groups, and Puerto Ricans on the U.S. mainland. Technical and scientific evaluations presented to the U.S. Army Corps of Engineers (USACE) -‐ San Juan Office by professional organizations, community groups, union members, archeologists, and academics have evidenced the following: • ‘Vía Verde’ is not a viable alternative since its exclusive source of gas is EcoElectrica (this, according to the proponents in their superficial local Environmental Impact Statement). EcoElectrica has admitted to the Fish and Wildlife Service (FWS) that they lack the required natural gas send-‐out capacity infrastructure, and the necessary permits from FERC to supply gas to PREPA’S three northern plants. Endorsing the ‘Vía Verde’ pipeline project without having sufficient gas for its operation is absurd, negligent, and suspicious. EcoElectrica has acknowledged that acquiring these permits and modifying its facilities could take 10 years. This issue alone should be cause enough to reject this proposal. ‘Vía Verde’ is not feasible. • Most of the $500 million investment in this project is to provide fuel to the Cambalache Power Plant in Arecibo, which produces less than 1.5% of the total energy demand of Puerto Rico. Alternatively to this proposal is the complete conversion of the Costa Sur (1,360 MW) and Aguirre (1,492 MW) power plants to natural gas (through the use of a short buoy system in Aguirre). This option would produce approximately 60% of the total electric energy consumed by the island while doubling the entrance points of natural gas to the island. Adding to this the current 15% of electric energy produced at EcoElectrica would lead to a situation where 75% of the island’s electricity is produced by natural gas. We contend that this would be a more cost-‐effective alternative without incurring the colossal investment for the pipeline (both Costa Sur and Aguirre are ready to operate with natural gas) or the massive impacts to the island’s water production resources and the permanent risk to over 200,000 citizens. (Note: In the municipality of Guayama AES uses coal to generate 15% of the total energy produced on the island). • ‘Vía Verde’ is not economically justified. According to a study performed by two specialists from the University of Puerto Rico, Mayaguez Campus, in the best case scenario ‘Vía Verde’ will provide savings of only one cent per kilowatt-‐hour. In its propaganda, PREPA suggests that the savings are in the order of 12 cents per kilowatt-‐
hour. PREPA’s claim is impossible to achieve with ‘Vía Verde’. • As recognized by FWS, studies have shown that this project will have an environmental impact larger than any other project carried out in Puerto Rico in decades. • The pipeline will cut a swath across the Cordillera Central starting at sea level and reaching 3,000 feet, causing more than 8 million cubic meters of earth to be displaced. Since this project is to be constructed through an area of high precipitation, it will cause landslides, erosion and sedimentation that in turn will affect multiple bodies of water, lakes, and the fishing industry. • The project will impact more than 1,500 acres of forests, causing permanent habitat fragmentation. • It will impact the habitat of 34 endangered species, including the fragmentation of 5,400 acres used for nesting by the Guabairo (Antillean Nightjar). • More than 235 rivers and streams will be impacted, including the Critical Conservation Zone of the northern Karsts, which produces 25% of the water consumed in Puerto Rico. Environmental impacts on minimum flows during dry seasons have not been established, but could be significant, for the island’s most important watershed. • More than 369 acres of wetlands will be permanently impacted. • Archeological and historical sites will be impacted along the 92-‐mile route of the project. • Specialists have emphasized six high hazard areas -‐-‐-‐seismicity, landslides, flooding, tsunami, fires, and facilitated corrosion by natural acid drainage along 8 km of the Humata soil formation-‐-‐-‐ with potential to damage the pipe along its route. • The pipeline crosses near schools, universities, churches, public beaches, factories, and densely transited freeways, and puts the health, life and property of over 200,000 people at risk according to risk analysis using the guidelines of the Committee for Pipelines and Public Safety, Transmission Pipelines and Land Use: A Risk-‐Informed Approach – Special Report 281 (Pipeline and Hazardous Material Safety Administration, USDOT). • The project fails to comply with 49 CFR 192.903 requirements for a high consequence area, such as Levittown, whose calculated potential impact radius would range from 129 m at a nominal pressure of 650 psi, to 192 m at a MAOP of 1440 psi (as filed by Spectra Energy at FERC for Jersey City, NJ). • A study conducted by environmental law clinics from the University of Puerto Rico Law School, Interamerican University Law School and Vermont Law School urged USACE to deny permission for the construction of the ‘Vía Verde’ gas pipeline because the government has been unable to supply the necessary information to the federal agencies to appropriately evaluate the impact of the project, which does not comply with the requirements of the Clean Water Act, nor the Endangered Species Act. Given the magnitude of this project USACE must demand a Federal Environmental Evaluation of the project. It must also require its proponents to prepare an EIS that includes a complete analysis, and must permit and facilitate the open participation of citizens during the process of preparing the EIS. ‘Gaps’ in the ongoing evaluation process Documentation pertinent to the evaluation of the natural gas pipeline project was recently transferred to USACE offices in Jacksonville, FL. This action was accompanied by the issuance of a public statement that claimed this step was taken “because it is of interest and the nature of the project” (El Nuevo Día 11 de mayo de 2011). This disingenuous claim represents yet another step to hide from public scrutiny and avoid an open and transparent public discussion on the project’s merits and costs. This action follows the failure of PREPA and other agencies to address the concerns and questions of community groups, scientists, professional organizations, archeologists, academics, the scientific and technical commission of Casa Pueblo de Adjuntas, the Law Clinic of the University of Puerto Rico Law School, the Sierra Club, and many other organizations. To avoid even the appearance of malfeasance, it is imperative that this project complies with all relevant laws and regulations, completes and publicizes the outcomes of an Environmental Impact Assessment, and hosts public hearings to inform the public and consider their legitimate interest. This has not happened. Concerns with the USCOE Colonel Alfred Pantano’s statement to the press: “All this has to be considered in terms of the impact that the construction of the “gasoducto” will have on the species present. Now, keep in mind that the construction of a “gasoducto” is different from other types of construction. The impact on many of the areas and species within will be short term. It is destructive only during the time of construction, but once it’s done it will not be as if you have humans occupying that area. We are talking about excavating, putting in pipes and covering up the hole again. This is not like constructing tall buildings, condominiums or such things where the environmental impact is permanent.” (Noticel, April 27, 2011). Such statement by a USACE official suggests that Colonel Pantano lacks detailed knowledge of the project. It constitutes a lame effort to brush aside legitimate concerns and factors that should be factored in when considering the environmental impact of such an expansive project. There would be a myriad of negative consequences from such a major construction project that would permanently degrade environmentally sensitive areas, adversely affect endangered species, disrupt communities, and threaten the safety of individuals. Moreover, this statement coupled with the transfer of documents from local USCOE offices to those in Jacksonville, FL raises suspicion about the true motives behind these actions, especially in light of email evidence between USCOE and project consultants BC Peabody (past director of the USCOE Jacksonville Office). Report by the President’s Task Force on Puerto Rico Status (March 2011) Assist Puerto Rico in developing a comprehensive plan for a new energy economy. Puerto Rico has the potential to successfully employ new, clean, renewable energy sources, increase energy efficiency, reduce greenhouse gases, and create green, well-‐paying jobs. Puerto Rico’s economic situation and its geographic location make it well positioned to greatly advance the goal of developing a comprehensive, cost-‐effective energy policy for the Caribbean. As noted above, Puerto Rico’s production of energy is heavily dependent on fossil fuels. Due to its dependence on oil, the Island’s economy is subject to price fluctuations in global energy markets. Reduce Puerto Rico’s dependence on fossil fuels; Create “green job” opportunities; Reduce greenhouse gas emissions and criteria air pollutants; and Attract private capital to Puerto Rico. Key links: www.casapueblo.org www.casapueblo.org/radio www.gutierrez.house.gov (Heading Puerto Rico Gasoducto) Write to the US Army Corps of Engineers: "I hereby formally request that this document in its entirety be considered by the USACE and be made part of the Via Verde Natural Gas Pipeline; SAJ-‐2010-‐02881 (IP-‐EWG) file." Colonel Alfred Pantano District Commander U.S. Army Corps of Engineers P.O. Box 4970 Jacksonville, Florida 32232-‐0019 [email protected] …with electronic copy to: John M. Hugh, Secretary of the Army ([email protected]) Congressman Luis Gutiérrez ([email protected]) Robert Barron ([email protected]) Donald W. Kinard ([email protected]) Alexis Massol-‐González, Director Casa Pueblo ([email protected]) Write to US EPA: Judith A. Enck Administrator for EPA’s Region 2 Office 290 Broadway New York, New York 10007-‐1866 [email protected] …with electronic copy to: Carl Soderberg ([email protected]) Congressman Luis Gutiérrez ([email protected]) Alexis Massol-‐González, Director Casa Pueblo ([email protected]) The 92 miles long pipeline will transverse the island from the EcoEléctrica Liquid Natural Gas Terminal in the municipality of Peñuelas, to the northern thermoelectric power plants. EcoElectrica has admitted that they lack the required natural gas send-out capacity and the necessary permits to supply gas to PREPA’S three northern plants. Endorsing the project without having sufficient gas is absurd, negligent and suspicious. Acquiring these permits and modifying its facilities could take 10 years. This issue alone should be cause enough to reject this proposal. The terminal and storage facilities are under tsunami impact areas. Ecological footprint of the cancelled southern gas pipeline project. This is the nesting habitat of the endangered species Antillean Nightjar (Guabairo). Specialists have emphasized six high hazard areas ---seismicity, landslides, flooding, tsunami, fires, and facilitated corrosion by natural acid drainage along 8 km of the Humata soil formation--- with potential to damage the pipe along its route.