Category Archives: Permit

Public Interest: What is the Public Interest?

Natural gas facilities and public apprehension

I see a number of the U.S. natural gas related projects progressing—presented, community involvement, permitting, engineering, construction, and process operation—but, as for public input, I fail to see or recognize where public input is considered—enabling or stopping these projects.

It’s a no-win game for public comments

Since, it is a no-win or just not-be considered Community peoples’ comments related to environmental concerns; as a result, a simple solution might simply be this:

  1. Request U.S. EPA to complete a potential hazards analysis for natural gas industrial process planned for community; it follows; under the Community Right-to-Know Act benefit to health and welfare of community and people;
  2. As a result, U.S. EPA publish (no peer review process here just the facts published as discovered) finding of potential hazard(s) as discovered and don’t waste U.S. EPA time and effort with curative action planning—just public publish the U.S. EPA hazard(s) findings absent conclusions. Because the public has the right to know hazards within their community as discovered!
  3. It follows, all other natural gas permit granting agency(s) can make their own decisions what does “public interest” means or not mean with no influence from U.S. EPA other than Community people have received notice about hazard(s) potentials within their community as created by proposed natural gas related facility.

Let the documents do the presentation

Let’s look at an actual permit process SIERRA CLUB, Petitioner, v. FEDERAL ENERGY REGULATORY COMMISSION, Respondent. No. 15-1133 – DC15-1133SierraClub.pdf, http://www.ferc.gov/legal/court-cases/briefs/2016/DC15-1133SierraClub.pdf (last visited Feb 14, 2016)

Apparent to me

With these natural gas projects within the U.S. the Community and Citizen’s input carry little weight for- or against-project permit granting; therefore, don’t waste your time arguing with any permit agency, but just public for all community public learning what are the hazard(s) that are introduced into their Community surround.

It’s the Community people right to know: Community Right-to-Know Act. Even if they can’t stop the permit process, construction, and natural gas facility processing.

Posted: 2/14/2016 1:36:24 PM

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Who says, the Community counts?

Community listens

The Tacoma three proposed industries:

  1. Natural gas distribution pipe system;
  2. LNG Facility; and
  3. Methanol Facility.

Community speaks

Tacoma and surrounding Communities speak for- and against-arguments that relate to Tacoma proposed natural gas industries to be operated within Port of Tacoma Washington.

Who listens to Community speak?

The issue, who listens to Community concerns and just what are those persons willing to do that address the Community concerns? At what cost to Community health and welfare expense?

Apparently, Federal Way Washington listens and has created a Community action plan related to Tacoma proposed Methanol Facility.

Just a bump-in-the-road

Just a simple citizens of Community have had their opportunity to voice concerns but now it is time to move forward with natural gas industries, construction, and processing begins.

Time to stop these industries

The question remains, just who, name the decision making individual(s) that has the authority and responsibility to halt industry construction and operation; as a result, industrial facility operations that could potentially harm Tacoma and surrounding Communities.

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Tacoma Methanol SEPA EIS: My Review

I must understand the process first

The Washington State Environmental Policy Act (“SEPA”) and the Environmental Impact Statement (“EIS”) are just a little difficult to grasp for Tacoma Community People’s resulting benefits received back from these review process(s)–SEPA and EIS?

We will never know what difference any public comments made to influence the Tacoma Methanol Plant SEPA EIS process; unless we–the public–are allowed to read all of them.

I’m still not sure I understand the benefit of these public comments submitted. Seems-to-me the SEPA EIS decision makers have the final say as just what is necessary for our Tacoma Community SEPA EIS study finding. See, John Sherman, How It Works: Tacoma Methanol Plant Environmental Impact Stuff (Jan. 26, 2016) (revised, footnote ed., added content), (WordPress pdf file t20160126a) online at https://johnesherman.files.wordpress.com/2016/01/t20160126a2.pdf (visited Jan. 26, 2016).

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Published Jan. 26, 2016 : Revised ed. :: 0705 PST

Industry: Chemicals: Community Knows What When?

Communities have potential hazards, people must know

in my community, Tacoma Wash., under review is a methane-to-methanol industrial plant proposed to be constructed here then operated and it will become the biggest methane-to-methanol operating plant in the world once built and processing methane (natural gas).

Likewise, I have an interest in the potential people hazards to me and other people within my Tacoma Community. Therefore, I must promote the U.S. EPA to do its environmental hazards review for my Community and all other U.S. Communities; as a result, publish all hazards discovered to all people within every effected Community. No exceptions.

See, John Sherman, Hazards: Chemicals: Who Will You Tell Just Wehn? Why?, (Jan. 23, 2016) (pdf document) online at https://johnesherman.files.wordpress.com/2016/01/t20160123a.pdf or http://bit.ly/1OFf13n (visited Jan. 23, 2016).

let’s hope that the U.S. EPA does take an active environmental review of the proposed methane-to-methanol plant operating hazards and publishes each hazard discovered as discovered.

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Published Jan. 23, 2016:1030 PST

I think I have EPA: EPCRA standing because

Let me think of the reasons

First, I must have a direct interest, or affected by potential for future injury, future harm created by operating Port of Tacoma Washington methane-to-methanol plant. I need have conditions that I might be adversely affected in future years, as also others within my Community; Just thinking, I think I do. I think I have the necessary interest and standing for my thinking of future actual harm to me and my Community.

See, John Sherman, Do I Have Standing U.S. EPA: EPCRA Considers What for Who?, (Jan. 21, 2016) (wordpress pdf document), online at https://johnesherman.files.wordpress.com/2016/01/t20160121a.pdf (visited Jan. 21, 2016).

Question: Tacoma City involvement

I question, conflict-of-community people(s) interests as Tacoma City Government is involved with the environmental review process for all hazards that will become present within Port of Tacoma if the methane-to-methanol plant is constructed and operating? Constructed and operated by private, not public, business venture.

Let’s hope the U.S. EPA and its EPCRA does a good job

The Community Right-to-Know Act policy intent, I believe, is to protect—people, lives, air, water, community, and absent living in fear and promoting a better environment tomorrow than today.

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Published Jan. 21, 2016 : 1340 PST

Environmental process: policy created rule

The U.S. Environmental Policy First

Even though, we have had rules how the U.S. Environmental Impact Statement (“EIS”) is applied today; but there exists the background policy that first created U.S. environmental oversight; let’s not forget what was intended by the early policy writers.

See generally, John E. Sherman, First, Environmental Policy then Rules Aligned with Policy, (Jan. 19, 2016) (pdf document) online at https://johnesherman.files.wordpress.com/2016/01/t20160119a.pdf (visited Jan. 19, 2016).

Local governments clearly cannot allow industrial facilities to be situated within urban areas, regardless of the evolution of land use over time. Industry and government need to bring proper financial support to local communities so they can provide medical and other necessary services to reduce morbidity, mortality and material loss in the case of industrial accidents.[supra, at 1, n. 3 Lessons Learned]

For this reason, when a community EIS is undertaken all surrounding hazard(s) must be considered with written published public analysis EIS report results. For two reasons, (1) So interested and effected persons may review the completeness of the EIS hazards study report; and (2) The community (people) may use the EIS report; as a result, to benchmark their specific environmental hazards and risks concerns as allowed and promoted by Citizens guide to the NEPA[See, supra, n. 6]

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Published Tue., Jan. 19, 2016 : 1445 PST

Let’s review our right to know -v- methanol

Community Right-to-Know sounds logical

On the other hand, does anybody really want the community (people, stakeholders) to understand what hazards are potential within their communities?

See, Sherman, John, Tacoma People Have Access Rights: Read the Planning Plans: How to Mitigate Community Industrial Accidents, (Jan. 17, 2016) (WordPress pdf file t20160117b) online at https://johnesherman.files.wordpress.com/2016/01/t20160117b.pdf (visited Jan. 17, 2016).

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Published Jan. 17, 2016 1444 PST Tacoma WA

Methane process facts missing

Logical decisions need facts first

We have some methane gas processing industries proposed for Tacoma Washington, Port of Tacoma, area. This industry is moving ahead with permits and construction planning, but still missing is stakeholders (community people’s) fact information published prior to requesting stakeholder’s comments about these projects.

Tacoma stakeholders (the citizens) need more factual information related to Port of Tacoma new methanol process…, (Facebook post) (Jan. 14, 2016).

Comments second, after all facts published

Let’s get all the facts first before any public stakeholders comments are collected and evaluated for these methane processes permitted within our community.

Methanol conversion process requires lots of water. Why?

We have been told that water is required for process. See, Dunkelberger, S. (2016, January 14). Signature drive seeks to put methanol plant to a vote, Retrieved January 15, 2016, from http://www.tacomaweekly.com/news/view/signature-drive-seeks-to-put-methanol-plant-to-a-vote/
we have not been told about the process that needs the water or what the water contains (chemicals) after this process use?

State-of-the-art methanol process

So, let’s guess what that process might be that requires a lot of water for converting methane to methanol see generally, Efficient Natural Gas-to-Methanol Conversion, ARPA-E. (n.d.). Retrieved January 15, 2016, from http://arpa-e.energy.gov/?q=slick-sheet-project/efficient-natural-gas-methanol-conversion

Absent facts our community will just play the guessing game

ring a hazard into our community: first explain the hazard(s) facts then let our Tacoma community stakeholders make a decision. A decision, as to, allowing or not allowing your industry to operate within our community and it’s for export of our natural resources that once exported and gone will be gone forever.

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LNG Permits: No interest in community interests

How does a typical LNG export permit work?

Let’s take a look at a typical example; for example, Order conditionally granting long-term, multi-contract authorizations to export liquefied natural gas by vessel from the proposed Alaska LNG terminal in Niskiski, Alaska, to non-free Trade Agreement Nations, (collectively, “LNG permit”)1

LNG permit process sounds good for the community and public goods when considering a LNG facitlity and a LNG export facility but is the process really that comprehensive and inclusive of community people input response?

Just a typical LNG permit process presents

I think the LNG permit process is deficient for the public input to make a difference e.g.,

[N]o person shall export any natural gas from the United States to a foreign country or import any natural gas from a foreign country without first having secured an order of the [Secretary of Energy [n. 61] 6 ] authorizing it to do so. The [Secretary] shall issue such order upon application, unless after opportunity for hearing, [he] finds that the proposed exportation or importation will not be consistent with the public interest. The [Secretary] may by [the Secretary’s] order grant such application, in whole or part, with such modification and upon such terms and conditions as the [Secretary] may find necessary or appropriate.

(§ 3(a) Public Interest Standard 1, at 3, (alteration in original)).

Let’s take a look at words

While section 3(a) establishes a broad public interest standard and a presumption favoring export authorizations, the statute does not define "public interest" or identify criteria that must be considered. In prior decisions, however, DOE/FE has identified a range of factors that it evaluates when reviewing an application for export authorization. These factors include economic impacts, international impacts, security of natural gas supply, and environmental impacts, among others. . . .

(§ 3(a) Public Interest Standard 1, at 3, (emphasis added)).

Missing is community right-to-know safety study results or reports required. Our communities have the right-to-know what hazards potential are constructed and operated within our community (people, residential, housing, living, transportation areas)!

How is my community input appreciated?

Reading this actual LNG permit, I fail to see weighting of the community (people) inputs or concerns to any meaningful decision factor in granting this LNG permit.

Therefore, this might just be a same or similar process used at Pierce County, Tacoma, Port of Tacoma, Washington for a future LNG application for an export permit? So, the community should be aware how the public input process works for evaluation of their input into all LNG application permit(s) everywhere.

Works cited

(1) Yousef Rahman, ORDER CONDITIONALLY GRANTING LONG-TERM, MULTI-CONTRACT AUTHORIZATION TO EXPORT LIQUEFIED NATURAL GAS BY VESSEL FROM THE PROPOSED ALASKA LNG TERMINAL IN NIKISKI, ALASKA, TO NON-FREE TRADE AGREEMENT NATIONS, FE DOCKET NO. 14–96-LNG (United States Of America Department Of Energy Office Of Fossil Energy 2015), http://energy.gov/sites/prod/files/2015/05/f22/ord3643.pdf or http://1.usa.gov/1R1XtSi

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