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AGDC responds to rehearing, stay requests
Alaska Gasline Development Corp. ‘corrects misstatements and mischaracterizations of the record’ included in rehearing requests Kristen Nelson Petroleum News
The Alaska Gasline Development Corp. has responded to requests for rehearing from the Matanuska-Susitna Borough and a request for rehearing and stay of the Federal Energy Regulatory Commission’s order on the Alaska LNG Project from the Center for Biological Diversity and Earthjustice on behalf of Chickaloon Village Traditional Council, Northern Alaska Environmental Center and Sierra Club (see story in June 28 issue of Petroleum News).
In a July 17 filing AGDC said the motion for a stay from the Center for Biological Diversity et al “should be denied as moot” because under FERC’s regulations issuance of authorization to proceed with construction is precluded until the time for a rehearing request has passed or FERC has acted on the merits of the rehearing request.
AGDC said it wouldn’t try to respond to all the arguments made by the Center for Biological Diversity, but would respond to what it characterized as “overbroad and unsupported claims” that FERC had done an inadequate analysis and to a few issues where the record and/or the law was “mischaracterized.”
AGDC noted the time spent in preparing the more than 55,000 pages of data in the application and the more than 45,000 pages of responses to 1,910 data requests from FERC during the review process and said the “contention that FERC has not properly examined potential impacts of the project and identified appropriate mitigation measures is not an accurate portrayal of the extensive analysis performed by its Staff and reflected in the FEIS.”
Some specific issues AGDC said one issue raised by the Center, the contention that FERC did not explain how an 806-mile mainline pipe could release only 272 tons per year of fugitive CO2 equivalent emissions while the one-mile Prudhoe Bay line is estimated to release 29 tons per year, was based on an argument that there was a “linear correlation” between the length of the pipes and emissions.
AGDC said FERC explained that the potential for fugitive emissions is based on a number of factors, with “no direct linear correlation between pipeline length and fugitive emissions” because those emissions “occur from unintended leaks where gas can escape,” and the opportunity for such unintended leaks is greater from a one-mile line with gas entering and leaving at each end than emissions potential per mile of a long mainline “that has substantially fewer connections, inlets, outlets or other components where gas can escape.”
AGDC said FERC used guidance from the Interstate Natural Gas Association of America to estimate potential leak emissions, methodology which “uses the length of the pipeline, assuming cathodic protection, along with the number of metering stations to estimate the annual fugitive emissions.”
AGDC also discussed a contention that FERC understated acres of wetlands that may be impacted, noting that FERC addressed reasons for different estimates reported by AGDC to FERC and to the U.S. Army Corps of Engineers, including differences in how FERC and the Corps count permanent vs. temporary impacts; that FERC addresses waters of the U.S. and Cook Inlet crossing estuarine acreage separately; that the Corps permit excludes ice road and ice pad acres from totals; and that the Corps permit is based on a preliminary jurisdictional determination of wetlands within the project footprint area.
AGDC said FERC did not ignore the differences but reviewed them and concluded the differences “would not change its conclusion regarding impact significance.”
Other issues which AGDC addressed include dredging impacts and upstream and downstream indirect impacts.
Matanuska-Susitna Borough AGDC said the Matanuska-Susitna Borough continues to challenge several aspects of FERC’s analysis of the relative merits of siting the liquefaction facility at Nikiski rather than at Port MacKenzie and said it would not address the borough’s continued disagreement with FERC’s conclusion.
AGDC did address the borough’s contention that if the liquefaction facility was sited at Port MacKenzie gas could be delivered through Enstar’s system by reversing the flow of the Beluga Pipeline.
FERC said in the FEIS that it didn’t have information on the “feasibility or practicality” of that approach.
AGDC said the borough attached to its request for rehearing one page from a 2016 Regulatory Commission of Alaska hearing in which the president of Enstar said the company “is able to reverse the flow of the Kenai Pipeline System and has often transported gas for industrial users from the Beluga Field through Anchorage to Nikiski.”
AGDC said information from a hearing four years ago “falls way short of establishing that ENSTAR can deliver the quantities of gas that the project contemplates to the Kenai Peninsula.”
The borough’s “reliance on this tidbit of testimony when it has had several years to demonstrate the viability of its suggested alternative is itself telling,” AGDC said, and called FERC’s conclusion that there is no information on the record on the feasibility of the borough’s proposed alternative of serving the Kenai Peninsula “continues to be correct.”
AGDC also said the borough “misconstrues the facts concerning air emissions.”
FERC found there would be more emissions with a Port MacKenzie site because of the increased distance vessels would need to travel to reach Port MacKenzie.
The borough argues these increases are offset by decreased emissions from a shorter pipeline to Port MacKenzie, “based on their analysis of associated pipeline compression changes,” AGDC said.
While the line to Port MacKenzie would be shorter, the same number of compressor stations would be required, AGDC said, so there is no offset.
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