CA Air Resources Board Submits Filed Comments -- And L.A. Times Comments Editorially -- on LB LNG Draft Environmental Impact Document

From an air quality perspective, all emissions associated with the project must be included in the analysis. Directly associated emissions are those that would not occur "but for" the project. With the proposed LNG project, vessel emissions of visiting tankers are direct emissions. These emissions must be counted in determining the impact of the proposed project and whether the impact has the potential to have a significant adverse affect on air quality.[footnote]

[footnote text: Counting vessel emissions in an LNG project is directly analogous to counting vehicular emissions that are part of an overall project in a land-bued project. Courts have struck down the CEQA [CA Environmental Quality Act] analysis in cases where such vehicular emissions were not addressed. [citation omitted]...The mere fact that a project may comply with an applicable regulatory standard for a stationary source dose not negate the need to consider the emissions from all vehicular sources associated with the project. [end footnote text]

We understand that South Coast Air Quality Management District's (SCAQMD) regulations require the offset of emissions from the stationary aspects of the proposed project. However, all emissions associated with LNG carders and support vessels operating within California Coastal Waters do not appear to be addressed...

...It is not clear from the discussion in the Draft EIS/EIR that all emissions from marine operations within the boundaries of California Coastal Waters have been considered. It also appears that the estimated NOx emissions of 46 tons per year may be underestimated. ARB staff's review of a competing proposed California LNG project using LNG carriers and support vessels fueled exclusively on boil-off LNG and natural gas indicates that estimated NOx emissions from madna operations are significantly greater. [footnote: cites draft EIR/EIS for Cabrillo Port LNG Deepwater Port, Oct. 2004] Therefore, the draft EIS/EIR should provide more detail in describing how emissions were calculated. As discussed above, we believe that emissions within California Coastal Waters can reach the California coastline and add to the air pollution burden of downwind regions (e.g., South Coast Air Basin) and should be addressed in the Draft EIS/EIR as required by CEQA.

For purposes of this project, ARB staff believes it is appropriate to mitigate the emissions from marine operations that occur within 25 nautical miles from the California mainland coastline. We believe this will address the majority of emissions from the proposed project and maximize the potential on-shore benefits. Possible mitigation measures that may be applicable and should be considered include, but are not limited to, retrofit of the engines of vessels that regularly operate in California Coastal Waters with selective catalytic reduction or the conversion from diesel fuel to natural gas. Although ARB has not established relevant significance criteria, these emissions clearly exceed the "significance threshold" of 55 pounds per day for NOx emissions that the SCAQMD, the District most affected, has established.

[M]ost LNG on the world-wide market has higher energy content than the natural gas to which California is accustomed. Available date indicates that significant differentials in energy content of natural gas can adversely affect the operation and emissions of stationary and mobile sources that are fueled on natural gas (e.g., higher energy content natural gas typically generates higher levels of oxides of nitrogen (NOx) emissions). We understand that Sound Energy Solutions (SES) has proposed to remove portions of the natural gas liquids (NGLs) from the LNG in order to meet the SoCal Gas Rule 30 specifications for pipeline natural gas and the LNG specifications for motor vehicle fuel established by ARB. (Please note: ARB does not have LNG specifications but rather compressed natural gas (CNG) specifications for motor vehicle fuel.) However, meeting these standards does not ensure that the quality of the natural gas after removal of NGLs will not adversely impact the quality of natural gas that is consumed in the South Coast Air Basin.

Historically, natural gas in the South Coast Air Basin has on average an energy content of about 1020 BTU/scf and a wobbe number of about 1332. [footnote omitted] This is significantly lower than the upper range of energy content and wobbe number that is allowed under the existing SoCal Gas Rule 30 specifications. Also, it is possible to comply with the existing ARB CNG specifications with natural gas that has higher BTU and wobbe values than the existing averages for the Basin. If the proposed project were to produce natural gas at the higher end of the range of these specifications, NOx emissions could increase in the South Coast Air Basin. Therefore, the draft EIS/EIR should recognize the historic quality of natural gas used in the South Coast Air Basin and assess possible impacts, if any, that may result from the use of LNG-derived natural gas. If significant adverse impacts are identified, mitigation measures should be implemented (e.g., require further NGL's removal to a level that would not significantly increase the average energy content or wobbe number of natural gas in the South Coast Air Basin). In regards to the mitigation of emissions that are associated with the proposed project, we believe all emissions that could adversely affect California's air quality should be mitigated to the extent feasible.

Most of the impacts on air quality associated with the various projects would be attributable to emissions from mobile sources (e.g., construction equipment, terminal operating vehicles, marine vessels, trains, trucks, and on-road vehicles). Ongoing programs administered by the EPA, the CARB, and the SCAQMD would lessen those emissions by encouraging, and in some cases mandating, measures such as alternative fuels, reformulated diesel fuels, cleaner engines, and ride-sharing. In addition, the proposed project would make an alternative cleaner burning fuel (i.e., LNG) more available for distribution locally to fuel LNG-powered vehicles. As a result, there is a potential for air quality benefits associated with the proposed project because LNG-powered vehicles have lower emissions than diesel-powered vehicles.

Nevertheless, the cumulative projects represent additions of potentially significant and unavoidable emissions in the SCAB [South Coast Air Basin].

As discussed in section 4.9.7, a Health Risk Assessment of toxic air contaminant emissions on humans was conducted for the Long Beach LNG Import Project in accordance with SCAQMD Rule 1401. The Health Risk Assessment concluded that the proposed project would not individually exceed cancer risk level significance thresholds established by the SCAQMD for toxic air pollutant health impacts; however, the total carcinogenic risk in the SCAB and the Port areas currently exceeds thresholds of significance based on data gathered in the MATES II Study.

Therefore, even though project-specific toxic air pollutant health impacts would not be significant, it is likely that the incremental increase in the cancer risk level for toxic air pollutants as a result of the proposed project would contribute to an existing cumulatively significant health impact in the south-central Los Angeles area, the harbor area, and near freeways.