Dear Chairman Kelliher and Commission Members:
It was with great disappointment that we read the Draft Environmental Impact Statement (DEIS) recently issued by the Federal Energy Regulatory Commission (FERC) with regards to the proposed Broadwater Liquefied Natural Gas (LNG) Storage and Regasification Facility which would be constructed in the waters of the Long Island Sound. We have grave concerns about the impact that this permanent structure would have on the long-term health and vitality of the Long Island Sound. Perhaps more importantly, we are concerned with the precedent the approval of this project would create regarding the siting of industrial facilities in waters and on land considered a public trust. As representatives of the State of Connecticut and its residents, we are reiterating our strong and united opposition to the construction of Broadwater. While we understand and appreciate our nation's and this region's need for additional energy resources, we do not believe that the Broadwater project is the best way to meet these needs.
Long Island Sound is held for the citizens of Connecticut and New York under the Public Trust Doctrine. Throughout time, both states have taken this responsibility seriously and have acted to preserve and protect the Sound and its habitat for the benefit of the residents and communities they represent. Connecticut and New York have invested millions of dollars to clean up the Sound and restore habitats both on and off-shore, and it was through a bi-state effort that the Long Island Sound was designated by Congress and the federal government as an estuary of national significance. All of these efforts have been made to ensure that the Long Island Sound would remain a healthy environment for both recreational and economical purposes for present and future generations. It is our contention that for FERC to approve the siting of a facility such as Broadwater, which by all measures would be a permanent fixture in the Long Island Sound, would be a violation of that public trust. The Broadwater facility would require no-access zones which would, in effect, remove a large portion of the waters and seabed of the Long Island Sound from public access. Additionally, this facility would require a permanent mooring system that, even after the retirement of the facility, would remain in the Long Island Sound, irreversibly changing the seabed and eco-system of the area.
In addition to violating that public trust, an approval of this project would most certainly set a precedent for further industrialization of the Sound. We have witnessed this over the last several years with the proposal and approval of several projects, each increasingly larger than the last.
We also have concerns with the Commission's initial determination that the construction and operation of the Broadwater facility would not cause major environmental impacts. In several areas throughout the DEIS, FERC states that impacts would be minor but would occur over the life of the project. It is critical that when considering environmental impacts to any region, especially water resources, that these impacts - - those to water and air quality, biological resources, and species themselves - - be considered cumulatively and in the long-term. The Broadwater facility is planned to be in operation for thirty years and it is difficult to believe that three decades of "minor" impacts will not have a major long-term effect on the health and vitality of the Sound and its eco-system. We have spent billions of dollars to clean-up the Sound - - to protect the environment and the species that call the Sound home. In just the last decade, we have seen the incredible impacts that even the smallest changes in the environment can have on this delicate eco-system. We have witnessed the devastating impacts on shellfish and lobsters that have occurred due to slight changes in the eco-system which were also described as minimal but long-term. As stewards of this estuary, we have committed ourselves to protecting the Long Island Sound, as is our responsibility, and we must express our strong disappointment in FERC's initial determination that this project will not have a significant environmental impact on the Sound.
We are looking forward to participating in the upcoming public process and urge you to take into serious consideration the professional and public comments which are provided to you. We are confident that the information provided to FERC through this public comment period will have a significant impact on the conclusions of the Draft Environmental Impact Statement for the Broadwater project. We appreciate your time, review, and consideration of our comments.
Christopher Dodd Joseph I. Lieberman
Rosa L. DeLauro Christopher Shays
John Larson Christopher Murphy