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Pueblo de Adjuntas
Dr.
Arturo
Massol-Dey
Casa
Pueblo
de
Adjuntas
Technical
and
Scientific
Commission
Adjuntas,
PUERTO
RICO
00601
www.casapueblo.org
amassol@gmail.com
787.829.4842
tel/fax
787.579.5070
mob
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 EcoElctrica Liquid Natural Gas Terminal in the municipality of Peuelas, 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 Fortuo, 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.
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. Va 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 islands 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 islands 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). Va 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 Va 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. PREPAs claim is impossible to achieve with Va 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 islands 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 Va 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.
Concerns with the USCOE Colonel Alfred Pantanos 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 its 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
Presidents
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
Ricos
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
Ricos
production
of
energy
is
heavily
dependent
on
fossil
fuels.
Due
to
its
dependence
on
oil,
the
Islands
economy
is
subject
to
price
fluctuations
in
global
energy
markets.
Reduce
Puerto
Ricos
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:
"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 alfred.a.pantano@usace.army.mil
with electronic copy to: John M. Hugh, Secretary of the Army (gregory.bowman@us.army.mil) Congressman Luis Gutirrez (Enrique.Fernandez@mail.house.gov) Robert Barron (Robert.b.barron@usace.army.mil) Donald W. Kinard (Donald.W.Kinard@usace.army.mil) Alexis Massol-Gonzlez, Director Casa Pueblo (casapueb@coqui.net)
Write to US EPA:
Judith A. Enck Administrator for EPAs Region 2 Office 290 Broadway New York, New York 10007-1866 enck.judith@epa.gov
with electronic copy to: Carl Soderberg (soderberg.carl@epa.gov) Congressman Luis Gutirrez (Enrique.Fernandez@mail.house.gov) Alexis Massol-Gonzlez, Director Casa Pueblo (casapueb@coqui.net)
The
92
miles
long
pipeline
will
transverse
the
island
from
the
EcoElctrica
Liquid
Natural
Gas
Terminal
in
the
municipality
of
Peuelas,
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
PREPAS
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.