Does FERC ever question the honesty and integrity of companies such as Sabal? –Sandra Slack

Filed with FERC 11 April 2014. -jsq

When this project process first began, Florida newspapers, such as the ones in Martin County, Gainesville, Ocala, and others, ran the story with a map of the proposed pipeline, from FPL, plainly showing the route running from Alabama straight to Florida completely bypassing Georgia. The now “preferred” route runs approximately 156 miles, or more through Georgia. Sabal has not been forthcoming, even in their Resource Report 10, as to the reason for the change. Has there been any encouragement from any governmental entity, State or Federal, for Sabal to reroute this pipeline through the state of Georgia? If yes, which entity and why? If no, why did FERC allow Sabal to change routes? Cost would be an invalid answer.

In August and September of 2013, landowners who previously had not agreed to allow Sabal personnel onto their property began receiving letters first from Sabal and then from the law firm of Hunton & Williams of Atlanta, Ga., on behalf of Sabal, using intimidating and threatening language concerning Sabal’s right to use O.C.G.A. 22-3-88, a Georgia INTRAstate eminent domain law, to gain access to the landowner’s property. This law is intended for the taking of property when the natural gas project is an INTRAstate project only (O.C.G.A. 46-4-57). In Georgia, eminent domain means the “taking of land” only. It does not mean nor implies the “Right of Reasonable Access” for surveying. The “Right of Reasonable Access” must be “spelled out” within the law which governs the act of eminent domain as it does in O.C.G.A. 22-3-82 which is for “Petroleum Pipelines”only, both INTERstate and INTRAstate because the siting agency for both is the Georgia Department of Transportation. There is no siting agency, in Georgia, for INTERstate natural gas pipelines; therefore, Sabal has no authority to attempt to use Georgia INTRAstate law as a “scare” tactic. The same can be said about their hired law firm in Atlanta when they used the same tactic but including citing Georgia court decisions which ruled against the landowners. What Hunton & Williams didn’t say was the cited Georgia court decisions were for INTRAstate only cases and involved 1 INTRAstate electric company, 1 city, and 1 county. No mention of an INTERSTATE NG pipeline company versus a Georgia landowner because there are none. This type of tactic/action is unethical and probably illegal. It is surprising that FERC would condone and allow this type of behavior by an applicant.

Should FERC approve this project and issue to Sabal a Certificate of Public Convenience and Necessity, along with the certificate is the authority for Sabal to invoke eminent domain under the NGA and FERC. Sabal will take untold acres of land from Georgia landowners for easements and access roads in return for a one time mere penance. Georgians will lose the right to use this “taken land” as they see fit but yet must continue to pay full property tax on that land. Because Sabal changed the original route from the Transco Station 85 in southwest Alabama and ran at a southeasterly angle straight to Florida bypassing Georgia completely to a route that runs from the Hillibee Expansion in Alabama through Georgia to Florida and by FERC allowing this change, it could be asserted that FERC may be in violation of Executive Order 13406 entitled Protecting the Property Rights of the American People signed on June 23, 2006 by then President George W. Bush. The EO states,

“It is the policy of the United States to protect the rights of Americans to their private property, including by limiting the taking of private property by the Federal Government to situations in which the taking is for public use, with just compensation, and for the purpose of benefiting the general public and not merely for the purpose of advancing the economic interest of private parties to be given ownership or use of the property taken”.

FERC, of course, is a Federal Agency which actually has the authority of eminent domain and when FERC approves a project and issues a Certificate of Public Convenience and Necessity, FERC is actually delegating its’ eminent domain authority, under the NGA, to the Applicant, in this matter, Sabal Trail Transmission. Sabal, being a licensee of the Federal government, is therefore an extension of the government and FERC in particular. On September 16, 2008, the Office of the Attorney General sent a Memorandum for All Department and Agency Heads in regards to the implementation of EO 13406. Under the heading: Instructions for Implementing Order and Compliance Monitoring Provisions, the State of Georgia nor its’ citizens will have “public use” and will not be part of the “benefiting public”. Also, under the same above heading are provisions that does not prohibit takings by the government; however, in the case of the State of Georgia and its’ affected landowners of this pipeline, (a) Does not apply. (b) Sabal is not a common carrier and the people of Georgia will not have a public utility. (c) Does not apply. (d) Does not apply. (e) Does not apply. (f) Does not apply. (g) Land will not be purchased for pipeline; therefore, does not apply. (h) Does not apply. (i) Does not apply. BUT, FERC allowing Sabal to “take” merely for the purpose of advancing the economic interest of PRIVATE PARTIES will be applied and therefore, in violation of EO 13406, because there are other readily available routes such as the Gulf of Mexico and the Station 85 straight to Florida route. Also, there is a clear alternative to this pipeline. A query to the U.S. Attorney General Office of Land Acquisition Section, Environmental and Natural Resources Section may very well give the answer. Also, there will be a violation of the 5th amendment of the Constitution. Who is it that says the compensation for a person’s land is “just”? Sabal decides what amount is fair? Sabal has told landowners that in, “unspecified studies,” that the presence of gas pipelines on their property does not decrease property value. This is totally untrue. An editorial in the March/April 2011 issue of Right of Way magazine written by Mr. H. Kirby Albright, who has 30 years experience in property matters, states

“the presence of natural gas pipelines does have a substantial impact on market value-specifically on properties that are on or adjoin the line-once full and complete information about the implications of the gas transmission line are made known to the purchasers and known in the market place”.

This only confirms what property owners already know. In one example of this proposed pipeline, one landowner has already lost a sale of 100 acres because it had to be disclosed to the buyer the potential of a pipeline would run through the said property. The purchaser declined the property the day before the closing was to take place. Does FERC ever question the honesty and integrity of companies such as Sabal? And please explain to the affected landowners, in your EIS, how this pipeline that runs through the state and the compressor station(s), in Albany, are a public convenience and is a real necessity for the citizens of Georgia.

Sabal has property appraisal contractors to appraise the land to be taken and to tell Sabal how much money to offer the landowner for the right-of-way which, as we know, will be very little. Landowners do have the option of taking Sabal to a Court. In Vector Pipeline LP v 68.55 Acres of Land, a 2001 decision, the court said “burden of proving the value of the land taken is on the landowner”. In ANR Pipeline Co. v. 62.026 Acres of Land, (2004) and in Guardian Pipeline LLC v. 950.80 Acres of Land, (2002), the courts, including the 7th Circuit Court said “the burden was on the landowners to show what the fair market value was”. In United States v. 33.5 Acres (1986), the 9th Circuit Court, where the government “takes only part of a property….the owner must be compensated both for that which is physically appropriated and for the diminution in value to the remaining non-condemned property.” The U.S. Supreme Court holds that generally the condemnee is entitled to the “fair market value” at the time the property is taken. Sabal is a licensee of the U.S. government and granted eminent domain power by the U.S. government and therefore, should be ready to defend the meager amount they will offer to landowners in a Court should the landowner choose to take Sabal to court. Affected property owners, who can afford to do so, will be encouraged to file suit against Sabal for the fair market value of the taken land and for the decreased value of the remaining property, should that apply.

Sable has said it will pay the State of Georgia 450 to 470 million dollars in taxes over a period of 60 years. This is an average of 7.6 million per year. According to the U.S. Census Bureau, the 2013 population of Georgia was 9,992,167 and will be well over 10,000,000 when the pipeline is operational. The amount Sable will pay will be less than 76 cents per person per year. Georgia’s population will increase in the future and as it does, the “cents” per person Sabal will pay will decrease. Please do not use these pennies as a justification for public convenience or necessity, for it would be laughable. It is obvious, for the State of Georgia affected landowners, this pipeline is nothing more than a PRIVATE economic development for a PRIVATE entity and its’ PRIVATE profits, and has nothing to do with the public convenience or necessity or public use for the citizens of Georgia and FERC knows it to be true.

Since this process started in earnest, some 9 months ago, there have been, on average, 2 pipeline/compressor explosions/incidents per month in the U.S. The American Gas Association says, on their website, that in 2004, the latest year of statistics, 60% of gas line incidents, were caused by excavation. Excavation has not been listed as a factor in the aforementioned explosions/incidents. Spectra has one of the worst safety records in the gas industry, yet when Spectra/Sabal personnel are quizzed about past incidents, specific to Spectra, they deny, downplay, or insist they were not employed by Spectra when the incident occurred. This is the worst non-transparent and unsafe practices company in the industry and they want to run a pipeline through people’s property and close to their homes. Sabal wants to run the pipeline within 50 feet of an already existing 60 year old Kinder/Morgan NG pipeline on many, many land- owner’s property and, in some cases, within 100 feet of their home they tell the homeowners “how safe it is.” Spectra’s only concern is for their own pipeline. The following is an account of a spokesman for Spectra/Williams, owners of the Gulfstream Pipeline. Christopher Stockman of Gulfstream is quoted in the Anna Maria Island News saying:

During construction of the Port Dolphin pipeline, an accident 25 feet from the Gulfstream pipeline, which has natural gas flowing through it, could be disastrous, he said.

Does FERC believe that Gulfstream should attempt to impede competition but, homeowners and property owners should have their lives, their families’ lives, their property placed in jeopardy by Sabal’s pipeline?

The negative impact on the environment this project will bring to South Georgia is yet to be determined, but negative it will be. In Sabal’s Draft Report 10, they state that the Station 85 route would disturb many wetlands, has too many water body crossings, and will have a substantial increase in impacts to sensitive land use and environmental features. Yet, the primary route they have chosen runs through at least 2 South Georgia counties (Lowndes/Brooks) that the entire county could be considered wetlands. The land use along the primary route is just as sensitive and the environmental features will be no less, just as impacted as along the other route. They fail to list the “significantly different impacts” of the primary and other routes.

In one example of how unreliable Sabal’s information to FERC has been, again in their Draft Report 10, they said, in the major route alternatives section, one being “the Station 85 Route, is associated with an INCREASE in utility corridor co-location”. They said in the Station 85 Route section, “that the alignment DECREASES the extent of co-location with existing utility infrastructure. Which is it?

In Dougherty County, a deviation was proposed to Sabal in order to lessen the number of landowners that would be impacted. This deviation was rejected by Sabal “because it would add 1 mile to the route” and increase cost. Mr. Fahrenthold, of Sable, has boasted, at county commission meetings, about how much mileage Sable has saved by choosing the present route. He did not mention how much cost Sabal has saved. In Draft Report 10, Tables 10.5-4 and 10.5-5A, Sabal has added over 1.3 miles of deviations, yet they refuse to add 1 mile in Dougherty County. Yes FERC, Sabal is a compassionate outfit.

In the Sabal Trail Project Meeting briefing dated January 2, 2013, Ms. Dziergowski of the FWS, stated, she “has asked STT to evaluate the potential for the project to impact those At-
Risk Species that are recommended for federal listing under the Endangered Species Act” and “would provide a written response to STT’s written consultations”. Because FERC and FWS are aware that the STT consultants are contractors for and paid by STT, it stands to reason, FERC and FWS understands STT’s “written consultations” will have nothing to do with objectivity but slanted in favor of Sabal. While Sabal is “digging” through timber land, wetlands, and under rivers, STT will be destroying the habitat for several Federal and State protected species. For example, the Woodstork: This prehistoric bird is small in numbers and depends on wetlands for its survival. The Swallow Tailed Kite: A migratory bird, beginning to return to South Georgia after many years of being absent. The Red Cockaded Woodpecker: Dependent on Pine and Hardwood trees. Very few of these birds remain. The Bald Eagle: the majestic symbol of the U.S. and depends on our rivers, forest, and open fields. This bird is ever decreasing in numbers due to man’s dismissal of its importance. The Rafinesque’s Big-eared Bat: Their habitats consist of mostly forested areas near water. They help to control the insect population. The Gopher Tortoise: This docile reptile requires sandy soil for burrows and unique vegetation. The burrows can be up to 33 feet in length but very shallow from ground surface. A pipeline requires heavy equipment and the heavy equipment can crush this species and others even in their burrows. The burrows serve not only for nesting purposes but also winter protection. Various other reptiles and animals also “winter” in these burrows. As a side note, the Gopher Tortoise is the OFFICAL State of Georgia reptile. The tortoise requires long leaf pine forest and wiregrass habitat which is disappearing and Sabal will devastate their situation and despite Sabal’s propaganda, there is no plan in place to relocate this environmental asset nor any other animal, reptile, or any species. One of the reptiles that a burrow provides shelter for is the Black Indigo Snake: This shy, non-poisonous snake is extremely instrumental in controlling rodent and other more populous snakes including poisonous ones. Several different species of clams and mussels are endangered which depend on rivers and river banks, examples of these are: The Purple Bankclimber, Oval Pigtoe, Shinyrayed Pocketbook, Fat Threeridge, and Gulf Moccasinshell: All of these exist in the Flint and Withlacoochee rivers. So, yes, there probably will be problems with river crossings by Sabal. The Alabama Shad, Goldstriped Darter, Spotted Bullhead, and the Bluestriped Shiner all reside in the Flint and Withlacoochee rivers, with the Alabama Shad swimming upstream from “brackish” water to spawn in the Flint and Withlacoochee. Endangered and protected plants which depend on wetlands and other types of habitat include: Cooley’s Meadowrue, Canby’s Dropwort, American Chaffseed, Greenfly Orchid, Pond Spice, Carolina Bogmint, Yellow Flytrap, and the Hooded Pitcherplant all of these plants are very delicate and highly susceptible to disruption, and habitat disturbance by an unwanted and completely unnecessary pipeline running through the state of Georgia. The number of other protected species are too numerous to list here but, all of the species are far too fragile to be encroached upon. The Live Oak tree, while not on any “protected” list, is vital to the overall Ecosystem and is the OFFICAL tree of Georgia. Some of these trees are in the 200 to 300 year old range or more. Several species of birds and animals depend on these trees for food and shelter. It should be mandatory for Sabal to by- pass these trees should any be in their path of destruction.

At river crossings, Sabal has said they will “dig” up to 100 feet vertically and then “bore” horizontally beneath the river beds. The Floridan aquifer, that supplies the drinking water for this area, will be contaminated both from the “digging” and “boring” because, in this area, the aquifer is only 35-40 feet below ground surface. The aquifer could also be irreparably contaminated from a future pipeline material failure or incident. This type of contamination could cause unforeseen illnesses in the future. Spectra Energy is not a very good steward of the environment as we all know from their past record.

Natural Gas usage for the entire State of Florida for the calendar year 2012 (last year for statistics according to the American Gas Association) was as follows: For the state and its’ 55 electric utilities and 45 gas utilities: 1 trillion, 318 billion, 700 million cubic feet. Of that, Residential use was: 14 billion, 400 million cubic feet. Commercial: 54 billion, 600 million cubic feet. Industrial: 98 billion, 100 million cubic feet. Electric Power Generation: 1 trillion, 151 billion, 500 million cubic feet. The amounts of natural gas provided by FGT pipeline was and is 3 billion, cf/d or 1 trillion, 095 billion, cf/y. Gulfstream pipeline provided and does provide 1 billion, 300 million, cf/d or 474 billion, 500 million, cf/y. Total natural gas production for the state in 2012 was 19 billion cubic feet. Total natural gas reserves, at the end of 2011 was 6 billion cubic feet (proven), for a total accessible 1 trillion, 594 billion, 500 million cubic feet. Total excess was 275 billion, 800 million cubic feet. Should Sabal Trail Transmission be allowed to construct this pipeline and all the above other providers remain stable, the totals will be as follows: For the years 2017-2020, Sabal Trail will provide 800 million cf/d or 292 billion cf/y. All other above sources, assuming they remain stable, will provide 1 trillion, 595 billion, 500 million cf/y. Total accessible natural gas for the years 2017-2020 will be 1 trillion, 886 billion, 500 million cf/y. Total excess for 2017-2020 will be 568billion cf/y. In 2021, when the capacity is raised in this pipeline to 1 billion, 100 million cf/d or 401 billion, 500 million cf/y plus the providers above, assuming all remain stable, the total accessible natural gas will be 1 trillion, 996 billion cubic feet. Total excess will be 677 billion, 300 million cubic feet. For all electrical power generation companies, in 2012, used 1 trillion, 151 billion, 500 million cubic feet of natural gas. Total accessible cubic feet minus residential, commercial, and industry use, was 1 trillion, 427 billion, 400 million. Total excess for power generation was 275 billion, 900 million cubic feet. In 2017-2020, if Sabal’s pipeline is in place and operational, total accessible cubic feet for electrical power generation will be 1 trillion, 719 billion, 400 million with a yearly excess of 567 billion cubic feet. From 2021 forward, after Spectra/NextEra increases the capacity of this pipeline, the total accessible cubic feet for electrical power generation will be 1 trillion, 828 billion, 900 million. The excess will be 677 billion, 400 million cubic feet per year. While it is understood that the figure of 1 trillion, 151 billion, 500 million cubic feet, for electrical power generation, is transient because Florida Power & Light has “modernized” 2 of its’ 14 power plants to all natural gas. A 3rd plant, Riviera Beach, is slated to come on line in 2014 and a 4th, Port Everglades, to come on line in 2016; however, the cubic feet usage will not increase dramatically. Although, FPL does use natural gas in most of the units at other plants which were already in use prior to the end of 2012, FPL also uses a diverse mixture of fuel. Other than natural gas, FPL uses nuclear, coal, solid waste, bagasse, wood, landfill gas, paper by-product, steam, and solar. FPL presently has 3 solar sites which are in the following sites: Martin Next Generation Clean Energy Center, this site uses “mirrors” to heat fluid-filled tubes to produce steam for the turbines to produce electricity for approximately 11,000 homes. Desoto Next Generation Solar Energy Center uses PV technology for its “follow the sun” panels and produces enough electricity for 3,000 homes. Space Coast Next Generation Solar Center at Kennedy Space Center uses PV solar panels to produce enough electricity for 1,100 homes. At night or overcast days, there is natural gas back-up for the sites. FPL currently has 5 other sites which are sited and permitted for solar power. FPL also has 2 nuclear facilities, St. Lucie and Turkey Point and does use natural gas for a unit at Turkey Point; however, these two facilities provide the electrical power for 1.9 million of FPL’s 4.7 million customers which are located in 35 Florida counties that FPL services. FPL uses between l billion, 500 million CF/d and 2 billion CF/d of natural gas per day for electrical generation and using the average of 1 billion, 750 million CF/d which equals 628 billion, 650 million CF/y. There was 1 trillion, 427 billion, 300 million cubic feet available for electrical generation. The other4 major electrical generation and gas suppliers, Duke Energy, Gulf Power, Tampa Electric, and Florida Public Utilities, used a total of 522 billion, 850 million cubic feet in 2012 with an excess of over 275 billion cubic feet remaining. These companies, also uses a very diverse mixture of fuel other than natural gas. Duke for example, has 4 coal fired plants but, has an RFP for a natural gas fired plant to begin construction in the latter part of 2014. TECO presently has 1 natural gas fired plant the others, uses fuel mixture resources. Florida Public Utilities serves only 2 north Florida counties with electricity and gas, while the rest of the counties it serves with natural gas and propane.

From their own documents, the following: The Gulfstream pipeline, owned by Spectra Energy, provides 1 billion, 260 million cubic feet per day. Enough to produce electricity for 4.5 million homes per day. The Florida Gas Transmission pipeline provides 3 billion cubic feet per day. Enough to produce electricity for 12 million homes per day. Florida Power & Light has 2 nuclear plants and 1 gas fired unit (at Turkey point) to produce enough electricity for 2 million homes per day. This is a total of 18 million homes. Should Sabal be allowed to provide another 1 billion, 100 million CF/d this will be enough to produce electricity for another 4 million homes for a total of 22 million homes. More natural gas for more homes than Florida has people. Florida’s population is just slightly more than 19 million. Nearly every individual, including babies and toddlers, would have to have their own home and a beach house to require this amount of natural gas. Spectra Energy, Sabal Trail, NextEra Energy, or Florida Power & Light cannot legitimately justify this massive increase of natural gas to Florida. The justification of modernizing 3 or 4 power plants is rather weak at best. Should FPL “throw a hissy fit” over needing more natural gas, there is a much better solution than Sabal’s pipeline. The alternative to Sabal’s NOT NEEDED pipeline will satisfy 100% of the people of Alabama, 100% of the people of Georgia, and approximately 98% of the people of Florida. It is known as Port Dolphin.

Port Dolphin would be a Deep Water Port located 28 miles, at sea, off the coast of Tampa. LNG laden ships would dock at this port and off load and after returning the liquid gas back into vapor, send it through a 42 mile (because of routing) pipeline to a land based connection. Only 4 miles of pipeline would be on land. This port would provide 1 billion, 200 million CF/d, which is actually, 100 million CF/d more than Sabal’s pipeline would provide in 2021. 30% of this gas would be dedicated to TECO and 70% would be for other prospective customers. While there is certainly some legitimate marine environmental concerns, should an accident occur, it would be the owners of the port(Hoegh LNG) who would be at risk not the people nor their families nor their property as Sabal’s pipeline, most certainly does. Gulfstream, (Spectra) adamantly opposes this project, for no other reason than the competition and possible decrease in their profit; however, Gulfstream has “graciously” offered to allow Dolphin to connect to their existing pipeline as long as it is out to sea underwater while knowing the two pipelines are not compatible. Gulfstream has refused Dolphin to connect to their on shore connection.

Gulfstream objects

The proposed pipeline route is also problematic for the Gulfstream Natural Gas System, which operates an open access interstate transmission pipeline that extends underwater from Mobile Bay, Ala. to Port Manatee, then over land to Palm Beach County.

The company cannot prevent other companies like Port Dolphin from using its pipeline, Gulfstream spokesman Christopher Stockton said, comparing the pipeline to a railroad track used by various railroad lines.

Port Dolphin’s pipeline would be a non-open access "pipeline for its exclusive use.

While economic competition may be a factor, Gulfstream says it objects to both the proposed Port Dolphin pipeline route, which comes within 25 feet of Gulfstream’s onshore pipeline, and Port Dolphin’s proposal to connect with Gulfstream’s onshore pipeline for other reasons.

"They’re proposing to tap our line, but we would like them to tap it in a particular place offshore instead of on land because of safety and environmental issues," Stockton said.

During construction of the Port Dolphin pipeline, an accident 25 feet from the Gulfstream pipeline, which has natural gas flowing through it, could be disastrous, he said.

"As the source of 35 percent of the state’s natural gas pipeline capacity, Gulfstream is critically concerned with the safety to its system which could be compromised by the Port Dolphin proposal," Gulfstream’s lawyers wrote in a letter to the Coast Guard and the Maritime Administration on April 21.

"Gulfstream opposes and protests the proposal to allow its narrow right-of-way in the Port Manatee area to be used for the unneeded construction and operation of the proposed Port Dolphin pipeline. And Gulfstream will not agree to the point of interconnection selected by Port Dolphin."

Port Dolphin responded in a May 6 letter to the Maritime Administration that its "proposed onshore route, which crosses and briefly parallels Gulfstream’s main line within Port Manatee property, is consistent with commission policy and precedent. The commission prefers routes in which two or more pipelines are co-located and often share rights-of-way, and the Draft Environmental Impact Statement follows this well-settled policy. Gulfstream’s suggested interconnection with Port Dolphin under the Gulf of Mexico is not in the public interest.

“The offshore interconnection would eliminate all possible onshore interconnections, including the planned interconnection with TECO/Peoples Gas, the interconnection with Gulfstream, and a possible interconnection with Florida Gas Transmission Co. in Manatee County," Port Dolphin’s lawyers wrote.

Manatee County’s engineering firm has recommended that Port Dolphin build its pipeline within the existing Gulfstream pipeline corridor to avoid the route taking the pipeline through the county’s beach sand mining area, an option opposed by Gulfstream.

FERC, please take note of Gulfstream’s, (Spectra’s) hypocrisy in the above paragraphs. Particularly the sentence that says, that “the construction and operation of Port Dolphin’s pipeline is UNNEEDED.” This pipeline running through 3 states is needed? Don’t think so.

Port Dolphin was scheduled to begin construction in the middle of 2012 but “word” of a possible 3rd land based pipeline to Florida began to circulate and Hoegh LGN decided to put a hold on Port Dolphin until the status of the Sabal Trail pipeline is known. Hoegh told investors in a 2012 report:

Any potential decision by a third party to build a new pipeline from the main gas grid in the United States to Florida would entail a significantly increased risk of impairment. Such a decision is outside Höegh LNG’s control and could potentially be made in 2013.

Hoegh knows there is no need for a fourth pipeline. Port Dolphin is fully permitted and would only take a year to construct and be fully operational. FERC is urged to issue a “no action” decision to Sabal Trail Transmission. Port Dolphin will be able to take up the “slack” that FPL perceives.

Port Calypso was another DWP that was to be constructed 10 miles off the coast of Port Everglades and would have connected onshore in the vicinity of FPL’s new Port Everglades natural gas fired power plant. Calypso was to be dedicated to FPL. Although Calypso had its’ Deep Water license and was in the middle of environmental permitting, a high ranking Florida politician killed the project in late 2008. In February of 2009 withdrew its’ DWP license and Calypso LNG, LLC cancelled the project. Had the project been allowed to be completed, Sabal Trail would not exist today in Alabama, Georgia, and Florida.

The Floridan Natural Gas Storage Company, LLC has under construction a natural gas storage facility conveniently located very close to FPL’s Martin County power plant. This storage facility is scheduled to be commercially operational in April 2016. Just in time for the Sabal Trail pipeline completion. It will have the capability of storing 3 billion, 500 million CF/d. It will take gas from FGT and Gulfstream pipelines during off peak periods, liquefy, and store the gas until an electrical or gas utility is required to draw from the stored gas during peak periods. Sabal Trail’s pipeline will not be required to contribute. FGS thinks that the existing 2 pipelines can supply enough to meet requirements and FGS has said as much in one of its brochures:

Storage complements the existing pipeline system and allows us to more efficiently utilize the unused capacity we already pay for by bringing in more gas during the low-demand seasons, storing it and sending it out during peak times – just like states and countries do around the world. Adding pipeline capacity that would be under-utilized for years while waiting for demand to grow is far more expensive than utilizing storage facilities to meet incremental peak-day demand. In-state storage is a more efficient answer.

Florida’s natural gas users paid approximately $700 million for new pipeline capacity in 2008, and that number is projected to grow to over $1.2 billion by 2012. But approximately 43 percent, or more than $500 million, of this pipeline capacity will go unused. In-state storage allows utilities to use capacity that is wasted today. Since utility ratepayers pay for 100 percent of pipeline costs regardless of how much gas is transported, we must better utilize our investment in these existing pipelines.

While a storage facility would complement and enhance the two existing pipelines and make a 3rd pipeline unnecessary, such a facility can also be used for exports of natural gas, hence Spectra/NextEra/Sabal Trail. Spectra/NextEra (the shippers) will probably supply FPL with a small capacity of natural gas (to justify the pipeline) but there is a larger picture. Large trucks and trains can take ISO containers to these facilities to be filled and then taken to a port by truck or by train to be shipped overseas. Spectra/NextEra would, apparently, like to “get in on the ground floor” on exporting natural gas from Florida so when they or another company constructs a “proper” export facility, they will already have the infrastructure in place close to the east coast of Florida to do so. FGS already has 2 exporting clients on board. One will be Advanced Energy Solutions, LLC for 2 billion CF/y and will be shipped from Port Palm Beach, Florida. The other, Carib Energy (USA), LLC for 600,000 LGN gallons per day or 0.06 billion CF/d. BPEC will be the supplier but Spectra/NextEra would be glad to sell to BP at the end of their pipe.

Should a 3rd pipeline absolutely be required, then as stated earlier, Port Dolphin will only take a year to construct and be operational interconnecting with Gulfstream and FGT on shore to supply FPL and even FGS.

In conclusion, a “no action” should be issued to Sabal Trail Transmission for this (to put it in Spectra’s words) unneeded pipeline.

Sincerely,

Sandra Slack

4 thoughts on “Does FERC ever question the honesty and integrity of companies such as Sabal? –Sandra Slack

  1. Outstanding- I am printing and saving this as it is a terrific source for all of us. How odd that Executive Order 13406 came under Bush- a Texan who was so pro oil. What was the reason behind that, if anyone knows? Surely not this situation?

    1. GWB pro-oil? Rather pro-corporations. Gas/ oil/ coal/ nukes–all the same easy-to-be-corporately-controlled fossil fuels–are owned by the 1%. Remember: “A dictatorship would be so much easier” from GWB’s own mouth as captured and disseminated in Michael Moore’s _Fahrenheit 9/11_?

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