August 2020, Vol. 247, No. 8


Alaska LNG Faced Challenges from Within State

By Larry Persily, Alaska LNG Project Updates

(Editor’s Note: This is the final installment of PGJ’s look at the state of Alaska’s efforts to develop an LNG project.)   

Amid the state-led push for Alaska’s LNG project, the loudest challenges to the project’s environmental impact statement (EIS) within Alaska came from the city of Valdez and the Matanuska-Susitna Borough, both of which promoted sites within their own municipality as preferable to building the LNG terminal in Nikiski. 

Diagram for the Alaska LNG Project. (Illustration: Alaska LNG Project)

The project team selected Nikiski in 2013, when the North Slope producers were leading the effort. The final EIS rejected the Valdez and Matanuska-Susitna Borough challenges, which the Federal Energy Regulatory Commission (FERC) repeated in its order.

“The Port MacKenzie Alternative (in the Matanuska-Susitna Borough) would not provide a significant environmental advantage over the proposed Nikiski site,” the authorization said, citing more challenging ice conditions in the channel for LNG tankers serving Port MacKenzie and the greater risk to endangered beluga whales from marine traffic.

“With respect to the Anderson Bay site (Valdez), liquefaction facilities at this location would require extensive civil design work and terracing,” the FERC order said, referring to the massive earth-moving work required to create a flat, buildable site for the LNG plant.

“While the Anderson Bay Alternative would avoid impacts associated with construction of a pipeline across Cook Inlet (to Nikiski), development of the Anderson Bay liquefaction site would result in greater marine impacts” than building at Nikiski, FERC said in its order.

The commission also noted that safety zones around loaded LNG carriers moving through Valdez Narrows “would restrict other vessel traffic.” Valdez is home to the trans-Alaska oil pipeline shipping terminal, which generates substantial tanker traffic.

The commission also rejected an alternative pipeline crossing route in Cook Inlet, proposed by property owners in the vicinity of the project’s preferred pipeline landing site on the Kenai Peninsula. The property owners had argued for moving the pipeline landing into what they identified as a less-sensitive habitat area.

Wetlands Issue

Several federal agencies that cooperated with FERC on the environmental review raised concerns over the number of wetlands that would be filled for construction and operation of the pipeline and its facilities.

After construction is finished, the project will permanently change 8,225 acres (3,329 hectares) of wetlands, with 6,220 acres (2,517 hectares) affected by granular fill such as gravel or crushed rock. Alaska Gasline Development Corporation (AGDC) proposes to leave fill material in place at multiple work sites, rather than scrape or dig up the fill to return the areas to wetlands.

“The conversion of wetlands to uplands through granular fill placement would affect adjacent wetlands by fragmenting them into smaller sections and changing natural drainage patterns,” the FERC order said. “Wetlands in the Arctic Coastal Plain and Arctic Foothills subdivisions are known to store large quantities of carbon, which provide carbon sequestration on a massive scale. Wetland loss from granular fill placement in these areas would reduce the capacity” to hold carbon out of the atmosphere.

“Compensatory mitigation would likely be required by the (U.S. Army) Corps of Engineers to offset the loss of wetland,” FERC said. That could include restoration, establishment of new wetlands, enhancement or preservation, adding that AGDC is consulting with the Corps and other resource management agencies “to determine the appropriate form of mitigation offsets.”

Wetlands also came up in an April 10 letter from the U.S. Fish and Wildlife Service to FERC. The agency noted that AGDC does not plan to remove fill material from more than a third of the wetland acreage used as temporary work pads during pipeline construction.

“Given that the fill placed in these wetlands will not be removed, the impact to these wetlands is more accurately characterized as permanent than temporary,” the Fish and Wildlife Service letter said. “The natural functions of these wetlands, including wildlife habitat, would be permanently lost even when the work pads are no longer needed.”

Noting that “standard wetland mitigation practice includes reclaiming wetland functions when the purpose and need for working in the affected wetlands is no longer required,” the agency recommended that AGDC reconsider its plans to leave fill in place or “acknowledge the temporary work pads as permanent.”

The Fish and Wildlife Service letter also addressed “string bogs … characterized by peat deposits, acidic waters and layers of thick sphagnum moss formed over thousands of years of wetland succession,” which “are very susceptible” to damage. Although the pipeline would cross less than 1 mile of string bogs in 19 separate locations, the letter said, “the proposed crossings would damage the peat substrate of the bogs, accumulated over thousands of years, resulting in permanent and irreversible impacts to string bog habitats.”

The letter further explained, “Since string bogs form over centuries and their restoration is not feasible, the service recommends avoiding the permanent loss of this unique wetland habitat by selecting an alternate pipeline alignment that avoids string bogs, or minimizing impacts to this wetland habitat by using vertical support members to elevate the pipeline.”

The FERC order did not address the letter.

In addition to wetlands, the project would affect permafrost. “The project would result in significant long-term to permanent impacts on thaw-sensitive permafrost [about 6,218 acres 2,516 hectares)], thaw-stable permafrost [about 3,499 acres (1,416 hectares)],” the final EIS said.

Wildlife Habitat 

The FERC order also cited habitat protection concerns. “Although the final EIS found that drawing definitive conclusions about the impact of the project on caribou movement is not possible at this time, it concluded that the project’s permanent impacts on sensitive habitats, along with the project location at the center of the Central Arctic Herd’s range, would contribute to significant impacts on the Central Arctic Herd.”

Federal agency review for the EIS determined that the project, from the North Slope to Cook Inlet, would “adversely affect six species (spectacled eider, polar bear, bearded seal, Cook Inlet beluga whale, humpback whale, and ringed seal),” FERC noted, and “is likely to adversely affect designated critical habitat for two species (polar bear and Cook Inlet beluga whale).”

Construction work, including operating rock pits and building temporary access roads, “would affect animal behavior by temporarily disturbing or displacing wildlife, fish and marine life or obstructing their movement,” the order said.

In addition, FERC said, “Pipeline construction would increase external competition for subsistence resources from non-locals, including from project employees.”

The increased competition for subsistence resources important to local residents “would continue during (project) operation,” FERC said. “Each of these general impacts could adversely affect individual or community harvest rates.”

However, the final EIS concluded, “With the implementation of various best management practices, AGDC’s commitments, and our recommendations, most impacts on wildlife would be less than significant.”

In a letter to FERC more than three weeks before the commission approved the Alaska project on May 21, Chad Padgett, state director of the U.S. Bureau of Land Management (BLM), expressed concern over the “limited consultation process” with tribes over historic preservation issues.

More Concerns

“Of particular concern to the BLM is the limited consultation process. … FERC has indicated … that tribes have been contacted; however, this does not constitute required consultation.” The required level of tribal consultation from FERC has “been largely absent from the process up to this point,” he said.

In a letter to FERC a few days before Padgett’s letter, State Historic Preservation Officer Judith Bittner, of the Alaska Department of Natural Resources, also expressed concern that consultation “for such a large and complex project” has been inadequate.

The Environmental Protection Agency (EPA) raised its own issues with FERC a month before the commission vote. The EPA letter cited several concerns, including inadequate dust-control monitoring for the project.

“We have concerns that this assumption of 100% control (fugitive-dust emissions during construction) may underestimate the actual emission of fugitive dust from project construction during the winter months, when the surface is dry,” wrote Andrew Baca, director of the Pacific Northwest regional administrator’s division. EPA recommended that the project’s fugitive-dust control plan be extended to year-round monitoring.

The Fish and Wildlife Service on April 10 also questioned plans for burying the pipeline beneath waterways and AGDC’s plans for soil vegetation at the end of construction.

The main pipeline would cross 553 waterbodies over its 807-mile (1,299-km) length, with the 62-mile (100-km) Point Thomson line crossing an additional 106 waterbodies, according to FERC. The Fish and Wildlife Service questioned how deep the pipeline would be buried in floodplains and recommended deeper burial under waterways subject to meandering or erosion of the stream bottom.

Deeper burial “would allow the channel to migrate freely across the meander belt without exposing a shallow buried pipe, which would require potentially expensive long-term protection measures and potentially degrade fish and wildlife habitat,” the agency said.

The FERC order did not specifically address the Fish and Wildlife letter.

While the Fish and Wildlife Service commended AGDC “for setting revegetation goals that include site stability and restoration of wildlife habitat,” the agency also expressed concerns “regarding the ability to achieve timely and successful revegetation and site restoration without plans for salvaging the topsoil for a larger portion of the project footprint.”

Of particular concern, the agency said, are areas of permafrost or with a shorter growing season, and areas with a thin topsoil layer.

“Once these soils are disturbed (removed, mixed with mineral soils/overburden, and then replaced), the natural recolonization process may take considerable time before there is sufficient plant cover to minimize or prevent thermal erosion, subsidence and ponding,” the agency said.

AGDC’s revegetation plan indicates that seeds and fertilizer will be spread over the pipeline construction area “to enhance revegetation,” Fish and Wildlife said. “While soil fertilization of a disturbed site may initially increase plant growth, once the nitrogen is absorbed, vegetation will die back, and natural recovery may still take decades.”

To improve the outcome, the agency recommended the project increase its efforts to salvage and reapply topsoil “wherever practicable.”

Author: Larry Persily publishes the newsletter Alaska LNG Project Updates. He was the federal coordinator for the Alaska Natural Gas Transportation Projects, 2010-2015.

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