The Alaska Gasline Development Corp. said in January that it had completed answering 801 questions posed by the Federal Energy Regulatory Commission on AGDC’s application for a Natural Gas Act Section 3 permit for the Alaska LNG project. The application was submitted last April.
AGDC noted in its Jan 22 statement that FERC said in December that when it had all the information it would issue a notice scheduling the environmental review and the date when a final environmental impact statement would be issued.
“AGDC expects FERC will determine they now have the information necessary to complete their analysis and will soon publish a schedule” in the Federal Register outlining activities leading up to the final EIS, AGDC said in January.
But on Feb. 15 FERC sent another data request, this one with 289 questions.
“This enclosure includes several requests for information that have been made multiple times during the pre-filing review phase, as well as in the current application review, for which an adequate response has not yet been received,” FERC said, adding, in bolded text: “You should be aware that the information described in the enclosure is necessary for us to continue preparation of the draft environmental impact statement.”
The FERC letter said there were also requests based on information provided by AGDC since the application was filed, such as supplemental filings and responses to previous data requests and requests based on recent stakeholder comments.
“AGDC has already provided FERC with the information the corporation believes is necessary for the agency to complete the draft EIS,” Jesse Carlstrom, AGDC’s communications manager, told Petroleum News in a Feb. 16 email. “However,” he said, “AGDC is committed to working collaboratively with FERC to address the agency’s concerns and will provide a schedule for submitting responses to their additional questions no later than March 7, 2018.”
As to how the additional FERC requests will impact the schedule for permitting the project, Carlstrom said: “AGDC remains committed that FERC will have the information the agency needs to prepare the draft Environmental Impact Statement in 2018. AGDC plans to continue advancing the Alaska LNG project and will respond to FERC’s request for clarification.”
ClarificationWhat is FERC requesting?
“FERC is now requesting clarification on previous responses and requesting more detailed information normally provided during the State of Alaska permitting process,” Carlstrom said.
He said that “in earlier responses to FERC, AGDC indicated it is unnecessary to provide these studies at this point in the application because this detailed information is normally provided during the State of Alaska permitting process.”
FERC said AGDC had previously stated “that because these studies are not required by the state or other entities, AGDC will not provide the information,” but, the letter continues, “FERC’s regulations implementing the National Environmental Policy Act require applications filed under the Natural Gas Act to include the information identified in” federal regulations and “applicants must conduct any studies or provide any information that the Commission staff considers necessary or relevant to determine the impact of the proposal on the human environment and natural resources.”
The letter went on to say that “any response from AGDC that states, ‘the information is not required by the state or other agency and will not be provided’ will be considered incomplete and reissued,” with incomplete responses and reissuance of requests for information affecting the schedule for completing environmental review for the project.
FERC said it also “anticipates additional data requests on the safety, reliability, and engineering design, including questions regarding compliance” with federal regulations of the U.S. Department of Transportation and the U.S. Coast Guard.
AlternativesThe Matanuska-Susitna Borough told FERC in early January that AGDC had not studied Port Mackenzie as an alternative, but instead studied another site.
FERC is now asking for “an environmental and engineering analysis of the site” identified by the borough, and the pipeline route to that site, including specified information so that FERC “can conduct a quantitative comparison between AGDC’s proposed and alternative liquefaction sites,” including size in acres; availability for purchase or long-term lease; requirement for any additional stabilization; any additional utility or road infrastructure that would be required; effects on waterway congestion and safety; effects on commercial and recreational use of waters; dredge volumes necessary; marine mammal or other species associated with the site; effects on residential occupation or use of areas; mainline pipeline length; number of waterbodies crossed by modified mainline; National Wetland Inventory mapped wetlands crossed by modified mainline; compression requirement in horsepower; and waters of the United States within the site.
AGDC is also asking for “documentation of recent consultation with the Matanuska-Susitna Borough to support the analysis.”
FERC also wants AGDC to revisit Valdez as a site for the liquefaction facility, noting that the 1988 final EIA for the Trans-Alaska Gas System found the pipeline route to Valdez preferable to the route to Cook Inlet.
FERC said AGDC indicated that because the Delta and Gulkana rivers were designated as Wild and Scenic Rivers in 1980, that the Valdez route was precluded.
FERC disagreed, saying the TAGS final EIS evaluated the Wild and Scenic Rivers issue and concluded the route would not cross the portion of those rivers designated as wild and scenic and directed AGDC to provide a routing analysis avoiding the designated portions of the Delta and Gulkana rivers. As with Port Mackenzie, FERC provided a list of information required for a quantitative comparison: length of pipeline; length adjacent to existing rights of way; gravel requirements; forestland crossed; discontinuous permafrost; wetlands crossed; waterbodies crossed; and waterbody crossings more than 100 feet in length.
FERC is also requiring more information on the Denali National Park and Preserve preferred alternative alignment. The agency said AGDC told it additional field survey costs were not warranted.
The agency did not address the cost factor directly but said: “FERC uses three criteria when evaluating an alternative: whether or not it meets the project objective, whether it is technically and economically feasible, and whether it offers a significant environment advantage over the proposed route.”
FERC also inquired if a route alternative identified by the Knik Tribe in 2015 was still applicable and practicable, directed AGDC to coordinate with the tribe to see if their concerns had been addressed and if not, “provide an engineering and environmental analysis of the alternative route identified by the Knik Tribe to address their concerns.”