The Center For Biological Diversity submitted the following letter commenting on the proposed Hunters Point gas well drilling exploration in Suisun Marsh. The letter is sent on behalf of The Center and 11 other Bay Area groups: Friends of the Earth, Fresh Air Vallejo, Sunflower Alliance, San Francisco Baykeeper, Sierra Club Redwood Chapter, Climate Protectors, Benicians for a Safe and Healthy Community, 350 Bay Area, Communities for a Better Environment, Good Neighbor Steering Committee of Benicia, and Natural Resources Defense Council.
The two-page cover letter addressed to the San Francisco District Army Corps of Engineers, is followed by 30 pages of detailed comments, downloadable here as a PDF. The letter opens with the following summary comment:
…Approving new gas development would cause significant harm to air and water quality, the surrounding ecosystem, and the climate. Issuing permits for new fossil fuel development is fundamentally incompatible with a safe and healthy future. We urge the Army Corps to consider the attached comments, which discusses why the application for this Project is grossly inadequate and does not meet the minimum standards of state and federal environmental laws. We strongly urge the Army Corps to reject this dangerous and short-sighted Project and work instead to protect communities and the environment from industry pollution. At minimum, the Army Corp must not approve this Project without a full environmental impact study, at least one public hearing, and further opportunities to submit comments on this harmful Project. […continued…]
Do you want to see a gas drilling operation in the Suisun Marsh?
I know I don’t.
The Army Corps of Engineers is in the process of evaluating a request for exploratory drilling in the marsh. There is an existing well, which has been plugged, that Sunset Exploration would like to do exploratory drilling in. Of course if the exploration shows that the gas is worth pursuing then that would involve putting in a bigger drilling operation and putting in an 8,821 foot pipeline to connect with an existing pipeline.
I don’t think either of these things are appropriate in the biggest marshes on the West Coast.
Your comments on this project are due on February 26. More info below.
You can download my sample letter with the required information for comments. I suggest that everyone oppose this and ask for a public hearing. You don’t have to use my words. Some variation may be appropriate. I have also attached a letter from Monica Brown.
Project: Hunter’s Point Natural Gas Well Drilling Project
Applicant: Robert Nunn of Sunset Exploration located at 10500 Brentwood Boulevard, Brentwood, California, through its agent, Hope Kingma of WRA, Inc.
PUBLIC NOTICE NUMBER: 2011-00065N
PUBLIC NOTICE DATE: January 25, 2021
COMMENTS DUE DATE: February 26, 2021
The project also needs approval from the Executive Officer, California Regional Water Quality Control Board, San Francisco Bay Region, 1515 Clay Street, Suite 1400, Oakland, California 94612, Your comments can be directed to them by the close of the comment period, February 26.
Approvals will also be required from other agencies including Solano County, but wouldn’t it be nice to stop this dead in its tracks.
Public interest factors which may be relevant to the decision process include: conservation, economics, aesthetics, general environmental concerns, wetlands, cultural values, fish and wildlife values, flood hazards, floodplain values, land use, navigation, shore erosion and accretion, recreation, water supply and conservation, water quality, energy needs, safety, food and fiber production, mineral needs, considerations of property ownership, and, in general, the needs and welfare of the people.
Comments are also used to determine the need for a public hearing and to determine the overall public interest in the project.
Your comments may include a request for a public hearing on the project prior to a determination on the Department of the Army permit application; such requests shall state, with particularity, the reasons for holding a public hearing.
Instead, utilities and energy companies are continuing to invest heavily in carbon-polluting natural gas. An exclusive analysis by USA TODAY finds that across the United States there are as many as 177 natural gas power plants currently planned, under construction or announced. There are close to 2,000 now in service.
All that natural gas is “a ticking time bomb for our planet,” says Michael Brune, president of the Sierra Club. “If we are to prevent runaway climate change, these new plants can’t be built.”
It also doesn’t make financial sense, according to an analysis by the Rocky Mountain Institute, a Colorado-based think tank that focuses on energy and resource efficiency. By the time most of these power plants are slated to open their doors, the electricity they’ll provide will cost more to produce than clean energy alternatives.
By 2023, the U.S. Energy Information Administration estimates the average cost of producing a megawatt hour of electricity will be $40.20 for a large-scale natural gas plants. Solar installations will be $2.60 cheaper and wind turbines will be $3.60 cheaper.
Catastrophic effects ahead unless we make changes
The world needs to reduce its carbon emissions rapidly – by 50% within the next decade – or face the prospect of a global temperature rise of more than 2.7 degrees within decades, said Michael Mann, a professor of atmospheric sciences at Pennsylvania State University.
That’s enough warming to kill off the coral reefs, melt large parts of the ice sheets, inundate coastal cities and to yield what Mann calls “nearly perpetual extreme weather events.”
“By any definition, that would be catastrophic,” he said.
We’re seeing the start of it now. There’s strong data to suggest that global warming is already causing changes in the jet stream and other weather systems. That can cause hurricanes to slow down and wreak devastation in single areas for longer, said Marshall Shepherd, director of the atmospheric sciences program at the University of Georgia.
“With Dorian, we saw it stall over the Bahamas. We saw that with Harvey in Houston and Florence in the Carolinas,” he said.
More gas = more carbon dioxide
Adding dozens of new natural gas plants in the coming decades is going in the exact opposite direction of what we need, clean energy advocates say.
“If the current pipeline of gas plants were to get built, it would make decarbonizing the power sector by 2050 nearly impossible,” said Joe Daniel, a senior energy analyst with the Union of Concerned Scientists, a nonprofit based in Cambridge, Massachusetts.
An analysis by the Rocky Mountain Institute published Monday looked at 88 gas-fired power plants scheduled to begin operation by 2025. They would emit 100 million tons of carbon dioxide a year – equivalent to 5% of current annual emissions from the U.S. power sector.
The institute calculated the cost of producing a megawatt-hour of electricity of a clean energy portfolio in each state that would provide the same level of power reliability as a gas plant. It determined that building clean energy alternatives would cost less than 90% of the proposed 88 plants.
It would also save customers over $29 billion in their utility bills, said Mark Dyson, an electricity markets analyst who co-authored the Rocky Mountain Institute paper.
“If you look at how things pencil out, we’re at a tipping point,” he said. “Here’s evidence that the switch from gas to clean energy makes economic sense and is compatible with utility companies’ need for reliability.”
More power plants coming to a state near you
USA TODAY compiled its own list of 177 planned and proposed natural gas plants through August, using data from S&P Global Market Intelligence, which tracks power plants that have been officially announced, and the Sierra Club, which tracks proposed plants.
Of those, 152 have a scheduled opening date of between 2019 and 2033, though only 130 have specific locations chosen. An additional 25 are part of companies’ long-term planning processes and don’t have estimated opening dates yet.
The plants are a mix of large-scale installations meant to provide lots of electricity much of the day and smaller plants used for short periods when demand for energy is particularly high.
Texas has the most proposed plants, with 26. Next is Pennsylvania with 24, North Carolina with 12, Florida with 10, California with nine and Montana with eight.
Not all will be built. Power companies are required to estimate future needs and plan as much as 15 years out, and this list includes plants which the companies may eventually decide they don’t need.
But the numbers show that greenhouse gas-producing natural gas is still on the table for many power producers, despite warnings that the energy sector needs to be quickly moving away from carbon-producing power sources.
Another concern raised by clean energy advocates is that once built, natural gas plants typically have a 30-year lifespan. Many of these plants will end up as “stranded assets,” unused because they’re too expensive to run, while consumers will still be on the hook for the cost of the construction, said Daniel.
It’s also true that power companies are building out solar and wind generation. Over the next two years, clean energy is expected to be the fastest-growing source of U.S. electricity generation, according to the U.S. Energy Information Administration.
Even so, that will only bring the share of wind and solar in the United States electricity market to slightly under 11%.
By 2020, EIA expects natural gas will make up about 36% of U.S. electricity generation. In comparison, coal is at 23%, nuclear at 20% and hydroelectric at 7%.
Why are we still building natural gas plants?
If natural gas plants contribute to global warming and most of them are going to be more expensive, why are so many still on the drawing board? The reasons are varied.
Energy companies say gas is more reliable than renewables and cheaper and less carbon polluting than the coal it often replaces.
But renewable energy advocates say the incentives for utilities and energy producers aren’t always in line with those of consumers.
For regulated utilities, one of the easiest ways to make money is to invest capital in large building projects, such as natural gas plants. Regulators allow utilities to set rates so that they get a return on invested capital of about 10%, Dyson said. That gives energy companies an incentive to build as much as possible.
In contrast, utilities that procure wind and solar power via commonly available purchase contracts earn no returns for these projects.
“There’s a perverse incentive for some utilities to build as big as they can, rather than to build as smart as they can,” said Ben Inskeep, an analyst with EQ Research, a clean energy policy consulting firm in Cary, North Carolina.
Companies also focus on reliability. Duke Energy, a power company based in Charlotte, North Carolina, has more than 7 million customers. As it transitions away from coal, it has embraced natural gas, announcing last week that it was considering as many as five new gas plants.
Today 5% of Duke Energy Carolinas’ electricity comes from solar, a percentage it plans to increase to between 8% and 13% by 2034, according to its most recent filing with state regulators. The state has almost no wind energy because of laws restricting the placement of wind turbines.
“We know our customers and communities want cleaner energy, and we’re doing our part to deliver that,” said spokeswoman Erin Culbert.
But she emphasized that Duke doesn’t believe solar and wind can be cost-effective and reliable enough to meet all its customers’ energy needs.
“Continued use of natural gas is key to our ability to speed up coal retirements, and its flexibility helps complement and balance the growing renewables on our system,” she said.
Government regulators favor gas
Another hurdle for renewable energy, some supporters say, is a combination of state-level rate-setting requirements and regional market rules that have led to a compensation structure for companies that favors coal and natural gas.
Who sets those rules depends on where the plant is.
In states where retail utilities own their own power generation facilities, the rates are approved by public utility commissions. Commissioners are typically appointed by state governors.
The process is less clear in the Midwest, Northeast, Mid-Atlantic, California, and Texas, where utilities buy and sell their power through organized markets run by regional transmission organizations.
These are run by boards that by law must be independent. They are typically composed of people from the business and energy world and are chosen by complex systems. In some cases they are voted on by existing board members.
The boards set the rules, which are then approved by the Federal Energy Regulatory Commission.
Ultimately these commissions and boards are supposed to decide what’s cost-effective for both the companies and ratepayers, said Scott Hempling, an adviser to regulators, law professor at Georgetown University in Washington, D.C., and author of two books on public utility law and regulation.
“A utility’s preference for profit is neither surprising nor wrong. But it’s not the utility’s job to balance its self-interest against the customers’ interest. It’s the job of regulators to constrain the private profit impulse with public interest principles,” he said.
It’s not news that there is bias towards profit, which can disadvantage customers. “The question is why it’s allowed to persist,” he said.
There are signs that what clean energy advocates have called an automatic rubber stamp for natural gas is beginning to change.
In April, the Indiana Utility Regulatory Commission denied a permit for a southern Indiana utility named Vectren South to build a $780 million natural gas plant. The regulators weren’t convinced the utility had chosen the best option to ensure its customers weren’t in danger of being “saddled with an uneconomic investment” in the future, it said.
In Michigan last year, local utility DTE won a bruising battle to build a 1,100 megawatt natural gas plant that will open in 2022 and cost nearly $1 billion. Critics complained the projections DTE used to make its case to regulators made wind and solar look less attractive.
The three members of the Michigan Public Service Commission, who are appointed by the governor, ended up approving the project. But the board’s 136-page opinion was not complimentary toward the utility, noting it was “concerned” about the constraints DTE built into the models it used to estimate whether renewable energy would be a viable alternative.
Some utilities choose clean energy
Not every utility company is ignoring warnings about the planet’s health, or customers’ pocketbooks.
Michigan utility Consumers Energy decided last year not to build new natural gas plants and instead focus on a combination of energy efficiency, renewable energy and batteries, which it says will be cheaper for customers.
The company, which has more than 4 million customers, plans to use 90% clean energy by 2040, said Brandon Hofmeister, senior vice president for governmental, regulatory and public affairs.
When the utility was putting together its existing energy plan, it took a new approach, balancing the cost to consumers and to the Earth.
“Honestly, there was some pushback. There were several pretty tense meetings,” Hofmeister said. “You’d hear someone ask in a meeting, ‘Is that really the right thing to do for Michigan and the planet?’”
A similar story played out in Indiana, one of the nation’s top 10 coal-producing states. A few years ago, Northern Indiana Public Service Company, based in Merrillville, Indiana, was getting ready to retire its old, expensive coal-fired power plants. An analysis in 2016 said they should be replaced with natural gas plants.
To be on the safe side, Joe Hamrock, president and CEO, checked again last year.
“We knew this is moving pretty fast and we needed to take a new look. A 30-year bet on a gas plant is a long time,” he said.
When his team sat down to look at the 90 project proposals that had come in, the answer came as a shock – natural gas wasn’t even in the picture anymore.
“The surprise was how dramatically the renewables and storage proposals beat natural gas,” Hamrock said. “I couldn’t have predicted this five years ago.”
The company is now set to retire all its coal-fired power plants, which produce 65% of its electricity today, and replace them all with renewables. In nine years, it expects to get 65% of its electricity from renewables and 25% from natural gas.
What will U.S. energy look like in the future?
Electricity generators counter that it’s impossible to get entirely away from natural gas because solar and wind are intermittent. When it comes time to turn on the lights, consumers can’t wait for the sun to come up or the wind to blow.
“We believe that natural gas has a role in a clean future because we believe it will be needed to balance out renewables,” said Emily Fisher, general counsel for the Edison Electric Institute in Washington, D.C. EEI is the trade association that represents investor-owned electric utilities in the United States.
“But we’ve also got to make sure the power supply stays affordable and reliable,” she said.
Electricity generators have a point, say energy analysts who aren’t necessarily in the pro-renewable camp. But those same analysts suggest a lot less natural gas is needed than we’re using today.
“The cheapest way to reduce carbon is to replace coal with a combination of renewables and as little natural gas as you can get by with to keep the lights on,” said Arne Olson, a senior partner with Energy and Environmental Economics, a San Francisco-based energy consulting firm that works with multiple states to craft energy plans.
That makes getting to the goals of the Paris Agreement on climate change – cutting greenhouse gas emissions at least 26% below 2005 levels by 2025 – not quite so daunting. The United States initially pledged to join the agreement but President Donald Trumpsaid in 2017 that the nation would not uphold the deal.
In fact, the electric industry is already undergoing a major restructuring. Largely because of the rapid rise of cheap natural gas, coal went from producing almost 45% of U.S. electricity in 2010 to a predicted 23% next year, according to EIA data.
The energy sector has shown it can move quickly when the prices are right, said Dyson of the Rocky Mountain Institute. And, he said, it’s imperative that a similar shift happen now with natural gas – and fast.
“Constructing these gas plants is incompatible with a low carbon future,” he said.
By Justin Mikulka • Wednesday, April 10, 2019 – 13:27
Congressional discussions over climate change have reached such a low point that during this week’s House hearing on the national security risks of climate change, former Secretary of State John Kerry, who was testifying, broke down and just asked his Republican questioner, “Are you serious?”
Kerry’s incredulous question was in response to Republican Rep. Thomas Massie, the GOP star of the House Committee on Oversight and Reform hearing, which also featured testimony from former Secretary of Defense Chuck Hagel. Kerry’s and Hagel’s testimonies were followed by several hours of, at times, excrutiating questioning from committee members.
Republicans made a big show of the fact that Massie has an engineering degree from the Massachusetts Institute of Technology. The conflict with Kerry arose when Massie tried to undermine Kerry’s testimony on climate change because he has a political science degree from Yale.
Massie said, “I think it’s somewhat appropriate that somebody with a pseudoscience degree is here pushing pseudoscience in front of our committee today.”
If science degrees are important to Massie, he must have somehow missed the thousands of climate scientists around the world who have studied, published, tweeted, marched, and repeated that climate change is real, caused by humans, and having major impacts now.
You are an MIT grad. This is ridiculous and you have made a fool of yourself.
For example, @MichaelEMann is a real scientist, as are the ~97% of climate scientists who consider climate change real, anthropogenic, and a possible existential threat. https://t.co/3vuI2pNSCe
During this hearing, Massie wasn’t alone in displaying bizarre logic to attack science and the reality of climate change. Rep. Paul Gosar (R-AZ) apparently thought holding up a fossil disproved that humans are causing climate change.
“Climate change has been changing all through the life of this planet. I’ve got a fossil right here from Western Wyoming — a desert — but that once was under an ocean,” he said.
That was the sum total of his argument.
Not to be outdone, Rep. Greg Steube (R-FL) took issue with Kerry’s statement about global warming making existing weather events more extreme by noting: “I remember growing up and having hurricanes in Florida.”
It all led to Secretary Kerry at one point expressing his frustration to committee chairman Elijah Cummings (D-MD), saying, “Mr. Chairman, this is just not a serious conversation.”
And it was not when Republicans were part of it. However, when Hagel and Kerry both spoke, they made clear the point that climate change is a real national security threat and requires action. Meanwhile, the Republicans on the committee indicated they intend to do nothing but continue a long history of delay and denial on climate change.
Hagel and Kerry Agree: Climate Change Threatens National Security
Hagel and Kerry spent their time delivering a sober analysis of the risks climate change poses to national security — a position which they repeatedly stressed during the hearing. “Climate change is already affecting national security,” said Kerry.
Kerry also noted in his opening statement that this has been the position of every federal administration for the last 28 years. He pointed to the first Bush administration, which said in 1992, that climate change was “already contributing to political conflict.”
“We don’t need to wait for more sophisticated climate models to project the security consequences of climate change,” Hagel said in his opening statement. “The impacts of climate change are clearly evident today.”
Both Hagel and Kerry spoke extensively about the current and future threats posed by a changing climate and had plenty of examples to make the case.
Among the many threats, Hagel discussed rising sea levels, extreme weather, and the lack of military readiness. Kerry raised the issues of climate migration, global pandemics, water scarcity, and extreme weather’s current contribution to radicalism, which he said would continue to create instability that would be “manna from heaven for extremists.”
Perhaps the best single example of how climate change is impacting security in the U.S. can be found at Norfolk Naval Base in Virginia. This base — the largest American military base — already is dealing with flooding and sea level rise. At one point in the hearing, former defense secretary Hagel mentioned the need to potentially relocate the base in the future due to sea level rise.
And yet when Republicans in the hearing had a chance to respond to this rather alarming fact, they spent that time mostly ridiculing the idea that any of this should even be discussed.
Gas Is a ‘Bridge Fuel,’ Secretary Kerry?
John Kerry was a strong advocate for dealing with climate change throughout the hearing and acknowledged the significant strides freshman Rep. Alexandria Ocasio-Cortez, who sits on the House Committee on Oversight and Reform, has already taken to advance the issue in her short congressional tenure.
Sec. John Kerry: “Congresswoman Ocasio-Cortez has in fact offered more leadership in one day or in one week than President Trump has in his lifetime on [climate].”
However, Kerry also proceeded to repeatedly champion a supposed climate change solution espoused by the fossil fuel industry and did so using industry talking points, referring to natural gas as a “bridge fuel” to climate-friendly energy sources.
While saying that natural gas would be “a component of our energy mix for some time to come,” Kerry justified this position with a flawed argument for gas.
“Gas gives us a 50 percent gain over the other fossil fuels in the reduction of emissions, so it’s a step forward,” he said.
The concept of natural gas as a “bridge fuel” to renewable sources has been debunked repeatedly. And as methane flaring, leaking, and venting in the fracked oil and gas supply chain continue to increase rapidly, the climate impacts of fracked gas can be similar or worse than other fossil fuels.
Kerry and Hagel adeptly explained the serious national security threats posed by climate change. However, calling natural gas part of a long-term solution to preventing catastrophic climate change isn’t a serious conversation either.