Docket Nos. CP19-502-000, CP19-502-001

I concur on today’s order as it is consistent with FERC precedent.  I believe strongly that applicants, environmental groups, and communities are entitled to consistent, predictable outcomes from the Commission.  With that said, I am concerned with our approach to mitigating impacts on communities, especially those already enduring negative impacts from industrial development.

Commonwealth LNG is located on the Chenier Plain, an almost treeless, flat marsh surrounded by the Sabine Wildlife Refuge on the Calcasieu Ship Channel and the Gulf of Mexico.  The facility will be adjacent to the existing Calcasieu Pass LNG Terminal and the proposed CP2 LNG Terminal, and just over 2 miles away from, and within view of, downtown Cameron, Louisiana.  Cameron is a small town of approximately 219 people, 36% of whom live below the poverty level, which is a higher percentage than the parish in which the town is located.  The facility will be directly north, and within view of, Holly Beach, a recreational area on the Gulf that serves nearby residents and tourists, who make valuable economic contributions to the area.  This is a significant burden for any community to bear, and I have deep reservations about the consolidation of these negative visual impacts on this small town. 

With that said, the diligent work of our staff did not identify any other disproportionately high and adverse health or environmental impacts to this environmental justice community.  Furthermore, Commonwealth LNG cites its community engagement in the area and provides mitigation consistent with our precedent for the severity of its impacts.[1]  I believe as a general matter applicants should make efforts to improve community outcomes at large and I especially view efforts to recruit job applicants within the community to be of great value.  Specifically in areas in which there are developing and cumulative impacts, I believe such measures may be necessary.

For these reasons, I respectfully concur. 

[1] Compare Commonwealth LNG, LLC, XXX FERC ¶  XX,XXX at P68 (2022) (describing the Facility Lighting Plan and tree planning to reduce visual impacts) with Annova LNG Common Infrastructure, LLC, 169 FERC ¶ 61,132, at P 51 (2019) (describing the Facility Lighting Plan to reduce visual impacts); Venture Global Plaquemines LNG, 168 FERC ¶ 61,204 at Appendix, Environmental Condition 1 (requiring proposed mitigation plans), Plaquemines LNG Final Environmental Impact Statement, CP17-66-000 at 4-64 (describing the Facility Lighting Plan to reduce visual impacts). 

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