PSE LNG Greenhouse Gas Emissions Report Review. Todd Hay, PhD Advocates for a Cleaner Tacoma (ACT)

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1 PSE LNG Greenhouse Gas Emissions Report Review Todd Hay, PhD Advocates for a Cleaner Tacoma (ACT) 1

2 Project Overview PSE + Puget LNG, LLC are building an 8 million gallon LNG facility LNG = Liquefied Natural Gas, cooled to -260 F + Cost = $310 million, up from $275 million, Rate-Payers will likely pay $133 million 2

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5 As of Aug 10,

6 Primary LNG Plant Purposes Frederickson Generating Stations TOTE Maritime Marine Transportation Fuel Peak-Shaving Electricity Generation, Replacing Diesel 6

7 Possible Secondary LNG Plant Purposes By Truck Truck Consumption By Ship Bunkering - Non-TOTE Marine Transportation Fuel Truck Transportation 7

8 What is this Study? Oversight Agency - Puget Sound Clean Air Agency (PSCAA) Called - SEIS = Supplemental Environmental Impact Statement Requirement SEIS required for PSCAA s Notice of Construction Permit Focus - Lifecycle Greenhouse Gas Emissions 8

9 What are Lifecycle Greenhouse Gas Emissions? Greenhouse Gases Drivers behind global warming & climate change Gases Include Carbon Dioxide (CO 2 ) Methane (CH 4 ) Nitrous Oxide (N 2 O) Fluorinated Gases (multiple) 9

10 What Does Lifecycle Mean? 10

11 Timeline Oct 22 Public Hearing Preparation UPS, 6:30pm 8:30pm Oct 30 PSCAA Public Hearing Rialto, 2pm 5pm, 6:30pm 10pm Nov 21 Comment period closes 11

12 Issues with the SEIS 12

13 Global Warming Potential (GWP) Natural Gas is primarily Methane (greater than 90%) A measure of greenhouse gas potency, measured v. CO 2 Averaged over 100 years typically 32 tons 2016 Study 1 ton (100-year) = 28 tons 2013 UN Study 25 tons 2007 UN Study Methane CH 4 Carbon Dioxide CO 2 13

14 Global Warming Potential (GWP) Natural Gas is primarily Methane (greater than 90%) A measure of greenhouse gas potency, measured v. CO 2 Averaged 1. over Not 100 Using years Best typically Available Science SEIS uses 2007 value, should use 2016 GWP Value = 1 ton (100-year) Methane CH 4 32 tons 2016 Study 28 tons 2013 UN Study 25 tons Carbon Dioxide CO UN Study 14

15 100-year GWP is Not Sufficient UN IPCC 12 years to fix our energy fuel, or dire results GWP is also measured at a 20-year value, not just 100-year 1 ton (20-year) = 96 tons 2016 Study 84 tons 2013 UN Study 72 tons 2007 UN Study Methane CH 4 Carbon Dioxide CO 2 15

16 100-year GWP is Not Sufficient UN IPCC 12 years to fix our energy fuel, or dire results GWP is also measured at a 20-year value, not just 100-year 2. SEIS should 96 be tons using 20-year GWP Value due to urgency of climate change per UN report 1 ton (20-year) = 72 tons 2016 Study 84 tons 2013 UN Study 2007 UN Study Methane CH 4 Carbon Dioxide CO 2 16

17 B.C. Fracked Gas is Claimed to Leak Less Claimed B.C. methane leakages rates are based on 3 references Reviewing references indicates that the leakage rates may not be warranted SEIS completely misses 3 recent studies showing significant underreporting 17

18 B.C. Fracked Gas is Claimed to Leak Less Claimed B.C. methane leakages rates are based on 3 references 3. Assumed methane leakage rates need to be reanalyzed and likely significantly revised upwards Reviewing references indicates that the leakage rates may not be warranted SEIS completely misses 3 recent studies showing significant underreporting 18

19 All Fracked Gas Must Come From B.C. B.C. leakage rate potentially 8 times smaller than U.S. rate If using U.S. gas, GHG emissions are worse than when no LNG plant In 2017, PSE received 26% of its gas from the U.S. Map of U.S. Gas Pipelines No guarantees that the gas will strictly come from B.C. 19

20 All Fracked Gas Must Come From B.C. B.C. leakage rate potentially 8 times smaller than U.S. rate 4. Source of gas from B.C. is a faulty assumption, SEIS should assume that some percentage of gas will be from U.S. and adjust emissions accordingly If using U.S. gas, GHG emissions are worse than when no LNG plant In 2017, PSE received 26% of its gas from the U.S. Map of U.S. Gas Pipelines No guarantees that the gas will strictly come from B.C. 20

21 Assumes Extra Customers That Don t Exist SEIS assumes Puget LNG already has other customers and so claims credit for emissions reductions Truck Consumption To date, TOTE Maritime is the only secured forprofit customer Non-TOTE Ship-to- Ship Bunkering Truck-to-Ship Bunkering 21

22 Assumes Extra Customers That Don t Exist SEIS assumes Puget LNG already has other customers and so claims credit for emissions reductions 5. SEIS should provide an analytical scenario where only existing, secured customers are included Truck Consumption To date, TOTE Maritime is the only secured forprofit customer Non-TOTE Ship-to- Ship Bunkering Truck-to-Ship Bunkering 22

23 Gas Provided as Only Peak Shaving Option SEIS only analyzes gas as alternative for diesel-driven peak-shaving Peak Shaving is only for 10 years, then all gas goes toward for-profit operations Frederickson Gas Peaker Clean, renewable alternatives exist: Tacoma Power wholesale Battery Storage Australia 100MW Battery System 23

24 Gas Provided as Only Peak Shaving Option SEIS only analyzes gas as alternative for diesel-driven peak-shaving 6. SEIS should include an analysis of alternative, cleaner Peak-Shaving technologies Peak Shaving is only for 10 years, then all gas goes toward for-profit operations Frederickson Gas Peaker Clean, renewable alternatives exist: Tacoma Power wholesale Battery Storage Australia 100MW Battery System 24

25 Analysis Forgets Fracking Sand/H 2 O Trucks Fracking wells use very large amounts of sand and water Recent sand record for a well = 50 million pounds ~ 600 truck loads SEIS does not include the emissions for trucking all of that sand and water 25

26 Analysis Forgets Fracking Sand/H 2 O Trucks Fracking wells use very large amounts of sand and water Recent sand record for a well = 50 million pounds ~ 600 truck loads 7. SEIS needs to be expanded to include the emissions from the fracking sand and water trucks SEIS does not include the emissions for trucking all of that sand and water 26

27 Maritime Methane Slippage Likely Underestimated Maritime Vessels release some amounts of unburned methane Called Methane Slippage Unclear what slippage rate is used during the analysis 27

28 Maritime Methane Slippage Likely Underestimated Maritime Vessels release some amounts of unburned methane 8. Methane Called Methane slippage Slippagerate and corresponding emissions need to be properly documented and incorporated into the SEIS Unclear what slippage rate is used during the analysis 28

29 SEIS is Missing Information More than a dozen locations indicate that data is missing Difficult to determine if actual data was ever incorporated Complete analysis of the SEIS is difficult in its current state 29

30 SEIS is Missing Information More than a dozen locations indicate that data is missing 9. A revised, complete SEIS should be provided and a new, full public comment period provided Difficult to determine if actual data was ever incorporated Complete analysis of the SEIS is difficult in its current state 30

31 Questions? 31