Public Comments 2017 (112-

The New Progressive Alliance periodically makes Public Comments by itself or with other organizations to federal agencies and legislative bodies in the United States and Canada in support of the Unified Platform. They are reproduced here in full and also briefly mentioned with our other activities in the Annual Reports and on our website under "News." 

  • Public Comment 112: January 2017 - WA state SW Clean Air Agency on proposed Methanol Refinery
  • Public Comment 113: January 2017 - WA state Cowlitz County deny local land use permits to Northwest Innovation Works’ Kalama proposed methanol refinery
  • Public Comment 114: February 2017 - BLM on Spring Creek Coal EIS
  • Public Comment 115: February 2017 - Senate Banking Committee on SEC Nominee Walter Clayton
  • Public Comment 116: February 2017 -  Beyond Extreme Energy FERC Appointments

 

Public Comment 112: January 2017 - WA state SW Clean Air Agency on proposed Methanol Refinery

January 4, 2017

Washington state

SW Clean Air Agency

Subj: Air Discharge Permit 16-3204

The New Progressive Alliance at http://newprogs.org/  urge you to deny Northwest Innovation Works’ Air Discharge Permit for the proposed methanol refinery in Kalama, Washington.

The primary reason to deny Air Discharge Permit 16-3204 is the pollution it would cause. Other reasons are utility costs for both electricity and natural gas would increase and it is a bad business plan.

1.      Increased Pollution

Documentation for the below comes from the following sources.

In December 2014, Columbia Riverkeeper and the Northwest Environmental Defense Center submitted 319 pages of comments to the FERC and the state EIS scoping processes at Kalama, urging “the Port to prepare an EIS that fully and accurately discloses the wide reaching impacts of the proposed methanol export facility.”

In April 2016 the New Progressive Alliance urged the Washington state Draft Environmental Impact Statement to be updated to address the Kalama Natural Gas to Methanol Refinery increased dangers and pollution from fracking and natural gas, would use a lot of power which would be reflected in higher electricity rates, water use and contamination, and is founded on a bad business plan.

  • This would be the largest methanol refinery in the world.
  •  It would dump up to 53 tons of toxic and hazardous pollutants into the air annually and emit over a million tons of carbon dioxide a year.
  • Methanol is flammable in liquid and gas states, and it is considered highly toxic to humans and animals. Just one gallon of spilled methanol depletes the oxygen from 198,000 gallons in the Columbia River. 
  • A Methanol Plant also produces waste that includes heavy metals, volatile organic compounds, various air pollutants, nickel, copper, and zinc oxide from the catalysts used in the refining process.
  • Air pollution that includes carbon dioxide, carbon monoxide, nitrogen oxide, sulfur dioxide, volatile organic compounds, and fine particulate matter.
  • They will burn 30 percent of the huge amount of natural gas used, adding to local pollution.
  • The Kalama methanol refinery will emit over a million tons of carbon dioxide a year.
  • Kalama methanol refinery’s air pollution risk is massive. They propose to emit up to 53 tons (106,000 pounds) of toxic and hazardous pollutants into the air annually. By comparison, Emerald Kalama Chemical released six tons of toxic and hazardous pollution in 2015, according to the EPA.
  • The plant also could emit up to 62 tons (104,000 pounds) of very fine particulate matter — dust and soot particles — annually. Fine particulate matter can enter into the respiratory system and cause long term health impacts. 
  • The plant would buy gas extracted by fracking. Specifically this plant would use at least 300,000 dekatherms of fracked gas per day (270,000 as raw material plus at least 30,000 for power generation) – one third as much gas as the entire state of Washington. Fracking, a dangerous technique for getting natural gas out of shale, has been linked to serious health risks, groundwater contamination, and other environmental impacts. Fracking companies refuse to even reveal the chemicals they are "fracking" with, nobody is monitoring the pollution to water and our aquifiers, and nobody is factoring the release of methane as a GHG. Of the 750 chemicals that can be used in the fracking process, more than 650 of them are toxic or carcinogens, according to a report filed with the U.S. House of Representatives in April 2011. For more documentation on Fracking see “The Environment,” #5, at http://www.newprogs.org/the_environment_under_the_democratic_republican_uniparty
  • The Kalama Refinery would be fed by a new 3.1-mile, 24-inch diameter natural gas pipeline that will divert natural gas from the existing Northwest Pipeline. The New Progressive Alliance in the below documentation shows the danger of transporting fossil fuel, especially by pipes. For documentation on transporting fossil fuels by pipes and other means  see “The Environment,” #12, at http://www.newprogs.org/the_environment_under_the_democratic_republican_uniparty
  • For pollution the Methanol Refinery discharges 200 gallons of wastewater per minute. The Methanol Refinery would also make a huge demand on water resources, using more than 2,500 gallons of water per minute or about 4 million gallons a day for cooling and gas forming, 90 percent of which is consumed during the process or lost as vapor to the atmosphere. It makes no sense that Kalama sell off millions of gallons of its fresh water every day when farmers and fishermen operated under emergency drought restrictions last summer. For more documentation on the dangers to fresh water   see “The Environment,” #14, at http://www.newprogs.org/the_environment_under_the_democratic_republican_uniparty

 

2.      Higher Utility Costs for Electricity and Natural Gas

The Kalama Natural Gas to Methanol Refinery would use a lot of power which would be reflected in higher electricity rates, increased dangers and pollution from fracking and natural gas, water use and contamination, and is a bad business plan.

Methanol refining requires a lot of electricity. The plant would use 200 megawatts of electricity daily - equal to the amount of electricity used by ALL Cowlitz County residents. The plant would also use 1/3 as much gas as the entire state of Washington. These demands would most likely increase gas and power costs for Washington residents and businesses.

 

3.      The Kalama Natural Gas to Methanol Refinery is a bad business plan.

Northwest Innovation Works, owned by the Chinese Government and British Petroleum, wants to build this Methanol Refinery even though it has never built or run a methanol refinery. Indeed, the proposed technology has never been used to make methanol commercially.

The plan uses America for cheap energy and to dump pollutants, ships methanol for thousands of miles overseas to China, and then China uses it to make plastics which are then shipped back across the ocean to the United States.

The United States signed the United Nations Agreement COP 21 in 2015. The agreement states “Each party shall…provide…a national inventory report of anthropogenic emissions by sources and removals…of greenhouse gases…” (Article 13, paragraph 7)  This means reporting so we will be compared with other countries. Therefor the United States will be in a poorer position for future bargaining just because of this one Methanol Refinery.

As China’s economy cools, it remains to be seen whether the huge profits that analysts envision for Northwest methanol exports are sustainable. In fact, the world methanol market has been oversupplied as recently as 2008, when many plants were just starting up. While the new proposed refineries would meet a near-term demand for cheap methanol in China, it remains to be seen what the Pacific Northwest will have gained after the gold rush fever abates. What it will have lost because of pollution, water depletion, and electricity usage is clear.

 

Conclusion:

Please consider the total pollution, the higher electricity rates, and this bad business plan and reject Air Discharge Permit 16-3204.

 

Public Comment 113: January 2017 WA state Cowlitz County deny local land use permits to Northwest Innovation Works’ Kalama proposed methanol refinery

January 16, 2017

 

Hearing Examiner The Honorable Scheibmeir

The Honorable Ron Melin

Cowlitz County

MelinR@cowlitz.wa.US

The New Progressive Alliance at http://newprogs.org/  urges you to not issue local land use permits to Northwest Innovation Works’ Kalama methanol refinery because of increased pollution, higher utility costs, it would support a bad business plan, and it will hurt U.S. interests because of United Nations commitments.

1.      Increased Pollution

Documentation for the below comes from the following sources.

In December 2014, Columbia Riverkeeper and the Northwest Environmental Defense Center submitted 319 pages of comments to the FERC and the state EIS scoping processes at Kalama, urging “the Port to prepare an EIS that fully and accurately discloses the wide reaching impacts of the proposed methanol export facility.”

In April 2016 the New Progressive Alliance urged the Washington state Draft Environmental Impact Statement to be updated to address the Kalama Natural Gas to Methanol Refinery increased dangers and pollution from fracking and natural gas, would use a lot of power which would be reflected in higher electricity rates, water use and contamination, and is founded on a bad business plan.

  • This would be the largest methanol refinery in the world.
  •  It would dump up to 53 tons of toxic and hazardous pollutants into the air annually and emit over a million tons of carbon dioxide a year.
  • Methanol is flammable in liquid and gas states, and it is considered highly toxic to humans and animals. Just one gallon of spilled methanol depletes the oxygen from 198,000 gallons in the Columbia River. 
  • A Methanol Plant also produces waste that includes heavy metals, volatile organic compounds, various air pollutants, nickel, copper, and zinc oxide from the catalysts used in the refining process.
  • Air pollution that includes carbon dioxide, carbon monoxide, nitrogen oxide, sulfur dioxide, volatile organic compounds, and fine particulate matter.
  • They will burn 30 percent of the huge amount of natural gas used, adding to local pollution.
  • Kalama methanol refinery’s air pollution risk is massive. They propose to emit up to 53 tons (106,000 pounds) of toxic and hazardous pollutants into the air annually. By comparison, Emerald Kalama Chemical released six tons of toxic and hazardous pollution in 2015, according to the EPA.
  • The plant also could emit up to 62 tons (104,000 pounds) of very fine particulate matter — dust and soot particles — annually. Fine particulate matter can enter into the respiratory system and cause long term health impacts. 
  • The plant would buy gas extracted by fracking. Specifically this plant would use at least 300,000 dekatherms of fracked gas per day (270,000 as raw material plus at least 30,000 for power generation) – one third as much gas as the entire state of Washington. Fracking, a dangerous technique for getting natural gas out of shale, has been linked to serious health risks, groundwater contamination, and other environmental impacts. Fracking companies refuse to even reveal the chemicals they are "fracking" with, nobody is monitoring the pollution to water and our aquifiers, and nobody is factoring the release of methane as a GHG. Of the 750 chemicals that can be used in the fracking process, more than 650 of them are toxic or carcinogens, according to a report filed with the U.S. House of Representatives in April 2011. For more documentation on Fracking see “The Environment,” #5, at http://www.newprogs.org/the_environment_under_the_democratic_republican_uniparty
    • The Kalama Refinery would be fed by a new 3.1-mile, 24-inch diameter natural gas pipeline that will divert natural gas from the existing Northwest Pipeline. The New Progressive Alliance in the below documentation shows the danger of transporting fossil fuel, especially by pipes. For documentation on transporting fossil fuels by pipes and other means  see “The Environment,” #12, at http://www.newprogs.org/the_environment_under_the_democratic_republican_uniparty
    • For pollution the Methanol Refinery discharges 200 gallons of wastewater per minute. The Methanol Refinery would also make a huge demand on water resources, using more than 2,500 gallons of water per minute or about 4 million gallons a day for cooling and gas forming, 90 percent of which is consumed during the process or lost as vapor to the atmosphere. It makes no sense that Kalama sell off millions of gallons of its fresh water every day when farmers and fishermen operated under emergency drought restrictions last summer. For more documentation on the dangers to fresh water   see “The Environment,” #14, at http://www.newprogs.org/the_environment_under_the_democratic_republican_uniparty
  • The acute health and air impacts from high-concentration short-term exposure to pollutants through refinery flaring, are not worth the risk to our communities. The EIS estimates flare operations will involve six shutdowns (requiring 2 hours of flaring each), six start-ups (requiring 12 hours of flaring each), and four process upsets (requiring 4 hours of flaring each) per year. In addition, the facility plans to flare between 48 to 60 hours while the catalysts are prepared for initial use and every few years thereafter. Flaring can cause acute impacts (e.g. respiratory and eye ear and nose irritation) when people are exposed to very high levels of pollutants over a short period of time (a few minutes or hours).
  • The methanol refinery would emit over a million tons of greenhouse gases each year.  NWIW admits that the technology exists to reduce greenhouse gas emissions by about 86%, but NWIW does not want to spend the money.

 

  • 2.      Higher Utility Costs for Electricity and Natural Gas

            The Kalama Natural Gas to Methanol Refinery would use a lot of power which would be reflected in higher electricity rates, increased dangers and pollution from fracking and natural gas, water use and contamination, and is a bad business plan.

Methanol refining requires a lot of electricity. The plant would use 200 megawatts of electricity daily - equal to the amount of electricity used by ALL Cowlitz County residents. The plant would also use 1/3 as much gas as the entire state of Washington. These demands would most likely increase gas and power costs for Washington residents and businesses.

 

3.      The Kalama Natural Gas to Methanol Refinery is a bad business plan.

Northwest Innovation Works, owned by the Chinese Government and British Petroleum, wants to build this Methanol Refinery even though it has never built or run a methanol refinery. Indeed, the proposed technology has never been used to make methanol commercially.

  • The plan uses America for cheap energy and to dump pollutants, ships methanol for thousands of miles overseas to China, and then China uses it to make plastics which are then shipped back across the ocean to the United States. Foreign corporations and government shouldn’t be allowed to take over private land, pollute our air, and exploit our water and natural resources.
  • Northwest Innovation Works has never built or run a methanol refinery and the proposed technology has never been used to make methanol commercially, yet NWIW proposes to build the largest methanol refinery in the world.

As China’s economy cools, it remains to be seen whether the huge profits that analysts envision for Northwest methanol exports are sustainable. In fact, the world methanol market has been oversupplied as recently as 2008, when many plants were just starting up. While the new proposed refineries would meet a near-term demand for cheap methanol in China, it remains to be seen what the Pacific Northwest will have gained after the gold rush fever abates. What it will have lost because of pollution, water depletion, and electricity usage is clear.

 

4.      This will hurt United States interests because of the 2015 United Nations Agreement COP21.

 

The United States signed the United Nations Agreement COP 21 in 2015. The agreement states “Each party shall…provide…a national inventory report of anthropogenic emissions by sources and removals…of greenhouse gases…” (Article 13, paragraph 7)  Transporting methanol thousands of miles to China will increase the project’s annual greenhouse gases substantially. This means reporting so we will be compared with other countries. Therefor the United States will be in a poorer position for future bargaining just because of this one Methanol Refinery.

 

Conclusion:

Please do not  issue local land use permits to Northwest Innovation Works’ Kalama methanol refinery because of increased pollution, higher utility costs, it would support a bad business plan, and it will hurt U.S. interests because of United Nations commitments.

 

 Public Comment 114: February 2017 - BLM on Spring Creek Coal EIS

February 13, 2017

 

The Honorable Irma Nansal

Bureau of Land Management

            The New Progressive Alliance at http://newprogs.org/  urges you to reconsider the Spring Creek Coal Environmental Impact Statement.

Coal and fracking companies do not deserve a continuing series of good deals at the expense of the American taxpayers. The New Progressive Alliance has written the BLM in June 2012, May 2013, August 2013, June 2015, and August 2016 on this matter and now we are writing again.

Last month, a new report from the Bureau of Land Management found major problems with the federal coal leasing program, including massive taxpayer losses through sweetheart deals for coal companies. The report also showed how coal companies have failed in their legal duty to reclaim mined farms, ranches, and public lands; and how federal coal management has failed to account for the climate impacts of coal leasing.

Interior Secretary Sally Jewell said at the time: “We have a responsibility to ensure the public – including state governments – get a fair return from the sale of America's coal, operate the program efficiently and in a way that meets the needs of our neighbors in coal communities, and minimize the impact coal production has on the planet that our children and grandchildren will inherit. The only responsible next step is to undertake further review and implement these commonsense measures.”

But at the same time that the BLM pointed out these major problems and called for taking a step back to institute reforms, the bureau was moving forward with leasing an additional 205 million tons of coal to Cloud Peak Energy’s Spring Creek Mine for export to Asia. Cloud Peak does not even need this coal right now—it already has more than 13 years of stockpiled coal reserves. Cloud Peak Energy currently has years of leased reserves at Spring Creek. And though they've been operating for decades, they've fully reclaimed less than 10% of mined lands. The BLM has no business giving coal to a company that doesn’t need it any time soon—especially under a system everyone knows is broken.

In addition to environmental concerns, coal makes less and less sense economically. China is cancelling coal orders and building new coal plants. More than 15 independent and governmental reviews of federal coal leasing have found massive taxpayer losses due to the undervaluing of publicly-owned coal. This problem was significant enough to warrant a full-scale national review, which to date has also found issues with reclamation and the way coal leasing is dealing with climate change.

BLM should factor these things into its consideration, and shouldn't lease more coal at Spring Creek until the broken coal leasing system is fixed and Spring Creek steps up reclamation efforts.

Thank you for your consideration.

 

Public Comment 115: February 2017 - Senate Banking Committee on SEC Nominee Walter Clayton

February 15, 2017

To: Members of the Senate Banking Committee

 

Dear Senators:

 

You face crucial issues in your consideration of the nominee for Chair of the Securities and Exchange Commission (SEC), Walter “Jay” Clayton. As the primary agency regulating U.S. securities trading markets, the SEC’s actions have far-reaching implications for Main Street Americans who deserve strong investor protection and a growing real economy supported by stable and reliable markets.  

Mr. Clayton’s background is as a Wall Street corporate lawyer and dealmaker representing many of the largest financial institutions in our society. Such a corporate background is not unique among past SEC chairs and commissioners, and the wisdom of a seasoned practitioner could be useful in the position. But Mr. Clayton’s decades of service to Wall Street raises serious questions about his ability to lead an agency dedicated to investor protection and the public interest. Accordingly, it is particularly urgent that you thoroughly question Mr. Clayton as to whether his background may bias him toward the interests of Wall Street insiders such as those he has worked with for many years. These interests often conflict with those of ordinary investors, and indeed, all those who depend on fair and well-functioning capital markets (including our state and local governments).

 

Our economy is still recovering from the devastating effects of the 2008 financial crisis. The inadequate oversight of SEC-regulated institutions and markets was a major contributor to that crisis. While the SEC has made progress to reform and re-vitalize itself, it still has not fully addressed the serious issues revealed in the crisis. New challenges are also emerging as financial markets continue to evolve toward more complex investment products and trading technologies.

 

The response of the new Administration to this unfinished business has been to call on regulatory agencies to tear down even those improvements that have been made since 2008. As the head of an independent regulatory agency, Mr. Clayton will still have the freedom to act to protect the public when the evidence shows that uncontrolled Wall Street practices endanger economic security, capital formation, and the savings of ordinary investors. But it is crucial that you thoroughly question and examine him to find out whether he will be willing to do so.

 

Such questioning should be guided by the mission of the SEC, which is to “protect investors; maintain fair, orderly, and efficient markets; and facilitate capital formation,” as well as to promote a market environment that is worthy of the public's trust.”[1] Based on this directive, the American public and its representatives in Congress justifiably expect the SEC and its leadership to hold corporations accountable, to ensure those financial services under the jurisdiction of the SEC operate under fair and robust rules, and afford no special treatment to any entity or person.

 

The SEC is also charged with ensuring that shareholders have access to timely and complete disclosure of not only financial information but also a company’s policies and activities. The underlying premise of the agency is that markets function better as investor confidence improves and that part of that confidence is built on providing investors with information that they, and not just industry, deem material. Additionally, shareholders are increasingly calling for more information on environmental, social, and governance (ESG) issues like climate change, human rights, tax, political spending and lobbying activity, CEO pay, and workforce matters. The SEC Chair must be responsive to these demands and utilize increased technological capabilities to make this information readily available to shareholders and to the public.

 

Disclosure is far from the only pressing challenge facing the SEC. Critical rules responding to the weaknesses in oversight revealed in the financial crisis remain unwritten or unimplemented. Unfinished rules should be prioritized and those rules that have been put in place should not be rolled back unless there is broad consensus on a better way to manage the risks they are intended to address. In addition, there is an important regulatory agenda to improve investor protections in a variety of areas marked by rapid growth and technological change.

 

While rulemaking is central to the agency’s mandate, rules are only effective insofar as they are enforced. It is essential that the Chair of the SEC be willing to take all steps necessary to enforce the law and the rules regardless of how wealthy, powerful or well-connected a firm or person might be. While using all of the Commission’s powers to enforce the law civilly, the Chair of the SEC must also be willing to refer lawbreakers to the Justice Department whenever appropriate for criminal prosecution. This is how a fair, serious, and ardent regulator sends the critically important message that no one is above the law.

 

Among other issues, you should press Mr. Clayton on whether:

 

1)      He will implement and enforce the law as currently written including systemic risk provisions such as the Volcker Rule and derivatives regulation, reporting of “CEO to worker pay ratios,” whistleblower protections and rewards programs, risk-retention requirements, and reforms to proxy access rules.

2)      He will continue and build on the examinations of private funds that revealed significant fraud and expand the Commission’s registration and oversight of those funds to protect investors as required by current law.

3)      He will defend the rights of investors and asset owners through the shareholder resolution process laid out by Rule 14a-8.

4)      He will uphold the definition of materiality as information that investors find relevant, rather than the management of the issuers.

5)      He will take action in cases where new financial products and activities pose risks to investors and the broader financial system.

6)      He will maintain the long SEC tradition of prioritizing strong and effective disclosure for investors.

 

In questioning Mr. Clayton, you must critically assess his capacity for impartial dedication to and prioritization of the public interest given his long history as a Wall Street lawyer whose sole duty was to act as a zealous advocate for his clients’ narrow, private sector interests. In particular, Mr. Clayton has spent a significant portion of his career representing the nation’s biggest banks as a lawyer at Sullivan & Cromwell - the law firm The New York Times referred to as Goldman Sachs “go-to law firm for more than a century.”[2]

His resume includes:

  • Advising Goldman Sachs on the $5 billion investment it received from Warren Buffett’s Berkshire Hathaway during the financial crisis.[3]
  • Advising Bear Stearns during its sale to JPMorgan Chase.[4]
  • Advising Barclays Capital in buying up assets left by the Lehman Brothers bankruptcy during the financial crisis.[5]
  • Representing Ally Financial[6] in connection with the $25 billion settlement related to robo-signing and other foreclosure abuses with the federal government and state attorneys general.[7]
  • Advising the Chinese e-commerce company Alibaba Group on its $25 billion initial public offering, the largest ever IPO.[8]

While this experience has the potential to inform a regulator’s perspective, it can also embed a belief that what is best for Wall Street is best for America. The 2008 financial crash proved this belief to be objectively false. Congress needs and the American people deserve a Chair of the SEC who advocates for the needs of Main Street over the interests of Wall Street.

Moreover, Mr. Clayton’s long list of former clients opens up the possibility of significant conflicts of interest if he becomes Chair of the SEC. He will almost certainly need to recuse himself from significant decision-making processes at the agency. His wife’s ties to Goldman Sachs further complicate the matter. As a result, Mr. Clayton needs to demonstrate beyond any doubt that he will be able to be objective, fair, and willing to hold Wall Street accountable (including his former clients), and not favor policies that allow anyone to profit at the expense of the American people.

We hope and expect you will press Mr. Clayton concerning his willingness to support tough rules and enforcement for Wall Street giants when such action is necessary to protect the broader public. The shortest path to economic growth and job creation is to put Main Street investors’ interests first and ensure that rule of law on Wall Street is enforced and strengthened.

 

Sincerely,

 

AFL- CIO


American Family Voices

American Federation of State, County and Municipal Employees (AFSCME)

Americans for Financial Reform


Better Markets

Center for Popular Democracy

Clean Yield Asset Management

Communication Workers of America

Democracy Matters

Harrington Investments, Inc.

Money Out Voters In (MOVI)


New Progressive Alliance


Public Citizen

WV Citizen Action Group

Zevin Asset Management, LLC

 

 

[1] https://www.sec.gov/about.shtml

2 https://www.nytimes.com/2017/01/04/business/dealbook/donald-trump-sec-jay-clayton.html?_r=0

3 http://www.wsj.com/articles/SB122220798359168765

4 http://www.nytimes.com/2017/01/04/business/dealbook/donald-trump-sec-jay-clayton.html

5 http://www.nytimes.com/2017/01/04/business/dealbook/donald-trump-sec-jay-clayton.html

6 https://www.sullcrom.com/lawyers/Jay-Clayton

7 https://www.justice.gov/opa/pr/federal-government-and-state-attorneys-general-reach-25-billion-agreement-five-largest

8 http://www.nytimes.com/2017/01/04/business/dealbook/donald-trump-sec-jay-clayton.html

 



 

Public Comment 116: February 2017 -  Beyond Extreme Energy FERC Appointments

 

February 17, 2017

Beyond Extreme Energy is proposing to transform the Federal Energy Regulatory Commission (FERC) with the following nine steps.

We have an urgent crisis on our hands. An extensive number of people and organizations — including scientists and scientific organizations, government and international agencies, NGO’s worldwide, organizations like the World Bank, our own Department of Defense, grassroots and community organizations — agree that if we do not reduce greenhouse gas emissions substantially, civilization as we know it faces severe threats. We must start immediately, with the objective of bringing these emissions close to zero as soon as possible.

The United States, as the largest greenhouse gas emitter historically, can and must be a leader in this work.  That other countries are partly responsible cannot be an excuse for U.S. inaction. In fact, our overconsumption of products created cheaply in other countries has fueled this crisis. Without U.S. leadership and example, solutions will remain out of reach.

FERC is uniquely positioned, given its key role in the energy system, to help bring about this change. And because of the world’s focus on developing a strong climate treaty at the United Nations Climate Conference in Paris in December, the opportunity for progress is RIGHT NOW.

Toward these ends, Beyond Extreme Energy proposes and will advocate and fight for these changes to the mission and practices of the Federal Energy Regulatory Commission (FERC):

1. Enact a moratorium on new gas infrastructure and export terminals until FERC has been reorganized with independent funding and a clearly defined mission of playing a leading role in reducing greenhouse gas emissions, and shifting to renewables and an energy efficient power grid. Permitted gas infrastructure and gas export terminals that are not yet operating must cease construction until the new FERC has emerged, new priorities are in place, and a reassessment has been made about whether the project should go forward.

2. Transform FERC’s approval process and mission. No community wants these disruptive projects because we don’t want toxic chemicals in our air, land and water. We don’t want exploding pipelines and liquefaction factories in our towns and under our farms. We can no longer sacrifice so many for the wealth of a few. We are ready for an economy fired on clean, safe energy. A new FERC can help make that transition.

3. We call for an investigation into the extent to which FERC is influenced or corrupted by the funding it receives from the industries it is regulating.

4. FERC must fully and comprehensively assess the environmental, health and climate effects of a proposed project and of the clean-energy alternatives. Segmentation of projects that obscures the cumulative effects of infrastructure expansion must end immediately. FERC’s claims that an increase in fracking is not “reasonably foreseeable” from its permitted projects is disingenuous and unacceptable.

5. FERC must be guided by a conscious policy of supporting wind, solar and energy efficiency first, with proposals for dirty, climate-heating energy sources scrutinized as to why renewables and/or efficiency should not be required.

6. FERC’s governing body must include members of the public to represent consumers and the environment. In addition, an advisory board of climate and environmental scientists must have a seat at the table during permit considerations.

7. FERC monthly meetings must include time for public comments.

8. FERC must make its website easier to navigate.

9. Congressional hearings should be held on how to transform FERC’s mission and procedures for a world under severe threat from global warming.

 

To achieve this, Beyond Extreme Energy is banding together with the New Progressive Alliance and other organizations around the country to fight Trump's upcoming appointments to the Federal Energy Regulatory Commission (FERC).

 

Right now, FERC is down to two commissioners and can no longer approve fossil fuel infrastructure.

FERC has traditionally  ignored and dismissed community and climate concerns when reviewing industry permits for fracked-gas pipelines and other infrastructure. Research indicates that the agency has rejected ONLY ONE such application, in 2016, in 30 years. FERC is in essence a rubber-stamp agency for the fracked-gas industry.
 
Donald Trump will be able to nominate three Republican commissioners and one other commissioner to the five-member panel over the next six months, one of whom will be a new chair. There are now three vacancies, given the resignation of former chair Norman Bay in the last week of January, and one sitting commissioner’s term expires in June.
 
Within just weeks, FERC could be controlled by Trump. All FERC-sponsored, open community meetings on proposed fracked-gas infrastructure projects could become one-person-at-a-time, behind-closed-door meetings, as has happened already under the current regime in Ohio, New York, New Jersey and Virginia. FERC could institute rigid, compressed timelines for action on permit applications. Landowners fighting eminent domain abuse could face greater pressure from pipeline companies anxious to take their land. FERC staff could be ordered to do even worse jobs on Environmental Assessments and Environmental Impact Statements that deal with threats to community health, safety and climate. The FERC public relations department could actively attempt to portray communities that oppose proposed pipelines in the most negative light. The FERC building security in DC could become more repressive against those who protest there.
 
Trump’s nominations need to be approved by the full Senate. We call upon members of the Senate, especially those on the Senate Energy and Natural Resources committee which has to review those nominations, to speak out about the myriad problems with FERC and press Trump’s nominees about its rubber-stamp history for gas industry expansion.
 
We pledge that when Trump makes his first FERC nomination we will work actively against it and the other nominations, as best and as much as we can, in collaboration with other organizations doing the same.
 
Signed,
 
Advocates for Springfield, NY
Allegheny Defense Project
American Medical Student Association
The AMP Creeks Council
Athens County [Ohio] Fracking Action Network
Aquashicola/ Pohopoco Watershed Conservancy
Berks Gas Truth
Berkshire Environmental Action Team (BEAT)
Beyond Extreme Energy
Buckeye Environmental Network
Catskill Citizens For Safe Energy
Catskill Mountainkeeper
The Center And Library for the Bible and Social Justice
Center for Biological Diversity
Chesapeake Climate Action Network
Citizen Coalition for Wildlife and Environment
Citizens Against the Rehoboth Compressor Station (CARCS)
Citizens For Water
Clean Air Council
Climate 911
CODEPINK for Peace
Columbus Community Bill of Rights
Compressor Free Franklin
Concerned Citizens of Otego, NY
Delaware Riverkeeper Network
Damascus Citizens for Sustainability
Earth Action, Inc.
ECHO Action NH: #FossilFree603
Exact Solar
The FANG Collective
Food and Water Watch
Fore River Residents Against the Compressor Station (FRRACS)
Fossil Free Rhode Island
FreshWater Accountability Project
Friends for Environmental Justice
Friends of the Harmed
Gas Free Seneca
Glenville Environmental Organization
glofernartstudio.org
Greenbelt Climate Action Network
Guernsey County Citizens Support on Drilling Issues
Green America
Health Professionals for a Healthy Climate
Howard County (MD) Climate Action
Keeper of the Mountains Foundation
Lancaster Against Pipelines
LEPOCO Peace Center (Lehigh-Pocono Committee of Concern)
Marcellus Outreach Butler
Milford Doers/Residents of Crumhorn Mtn
Milwaukee Riverkeeper
Mountain Lakes Preservation Alliance
NC WARN
New Haven Leon Sister City Project
New Progressive Alliance
North Jersey Pipeline Walkers
Nuclear Age Peace Foundation
NYH2o
OgreOgress Productions
Ohio Valley Environmental Coalition (OVEC)
Otsego 2000, Inc.
Pennsylvania Alliance for Clean Water and Air
Pennsylvania Earth Guardians
People Over Pipelines
Plymouth Friends of Clean Water
Popular Resistance
Preserve Giles County
Preserve Montgomery County, VA
Preserve Roanoke/Bent Mountain
Protectors of the Planet
Renewable Energy Long Island
Resist the Pipeline
ROAR Against Fracking
Rockfish Valley Investments LLC
Rogue Climate
Roseland Against Compressor Station (RACS)
Safe Energy Rights Group (SEnRG)
Sane Energy Project
SEED
Seneca Lake Guardian, a Waterkeeper Affiliate
Sierra Club Niagara Group
South Coast Neighbors United, Inc.
Stop the Algonquin Pipeline Expanson
Stop the Pipeline
Students for a Just and Stable Future
Sullivan Alliance for Sustainable Development
Sullivan Area Citizens for Responsible Energy Development (SACRED)
Sullivan County Residents Against Millennium (SCRAM)
Sunflower Alliance
Sustainable Loudoun
Sustainable Medina County
SustainUS
Underground Scholar Association
Unitarian Universalist Church of Loudoun, Green Team
Valley Watch, Inc
Waterkeepers Chesapeake
We Are Cove Point
Western New York Peace Center
West Roxbury Saves Energy
West Virginia Highlands Conservancy
Williams Township Concerned Citizens Against the Pipeline
Winyah Rivers Foundation
WV Environmental Council
350 CT
350 Eugene
350 Loudoun
350 Massachusetts Berkshire Node
350 Salem, OR

 

 

 

 

 

 

 

 

 

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