COMMENTS ON THE FEDERAL ENERGY REGULATORY COMMISSION NOTICE OF INQUIRY RELATIVE TO THE COMMISSION SEEKING NEW INFORMATION AND ADDITIONAL STAKEHOLDER PERSPECTIVES TO HELP THE COMMISION EXPLORE WHETHER IT SHOULD REVISE ITS APPROACH UNDER THE CURRENTLY EFFECTIVE POLICY STATEMENT ON THE CERTIFICATION OF NEW NATURAL GAS TRANSPORTATION FACILITIES TO DETERMINE WHETHER A PROPOSED NATURAL GAS PROJECT IS OR WILL BE REQUIRED BY THE PUBLIC CONVENIENCE AND NECESSITY, AS THAT STANDARD IS ESTABLISHED IN SECTION 7 OF THE NATURAL GAS ACT.

DOCKET No. PL 18-1-000

COMMENTS PROVIDED BY:

ALICIA GARDENER, CHAIRPERSON

QUINCY DEMOCRATIC CITY COMMITTEE

58 SOUTH STREET, #202

QUINCY, MA 02169 MAY 26, 2021

The comments provided in response to this NOI are specific to Section A. Potential Adjustments to the Commission’s Determination of Need (DON) and Section E. The Commission’s Consideration of Effects on Environmental Justice Communities.

Comments on Section A, A1 Should the Commission consider changes in how it determines whether there is a public need for a proposed project?

The QDCC believes that in the determination of public need the determination of local need should be prioritized. In many cases concerning projects of this scale, the determination of public need is based on national or regionally distant needs rather than how the risks/benefits will be realized locally. DONs of a distant area within the United States as a whole or beyond the US borders should not outweigh the needs of or benefits to a local area most likely to be impacted by a given project. Failure to prioritize local needs and/or benefits will undoubtedly continue to place the greatest burden of a proposed project on individuals and communities least likely to substantially benefit. Our community is wrestling with such an imbalance as a result of the Algonquin Gas Transmission facility in our adjacent community of Weymouth, MA.

Comments on Section E, E1 Should the Commission change how it identifies potentially affected environmental justice communities? Why and if so how? Specifically, what criteria should the Commission consider?

In addition to the Commission’s use of the USEPA EJSCREEN tool which includes a variety of environmental indicators and demographic data, the QDCC believes the Commission should explore the use of data and tools on the U.S. Centers for Disease Control and Prevention, National Center for Environmental Health, Environmental Public Health Tracking (EPHT) Program and the CDC/Agency for

Toxic Substances and Disease Registry (ATSDR) Social Vulnerability Index (SVI) tool. In addition to a host of health and environmental data contained in the EPHT portal, the ATSDR social vulnerability index provides other indicators that can influence health. The EPHT portal houses data at varying levels of geography (e.g., county) and some of the EPHT state grantee partners have health data available at the census tract level (e.g., MA). The ATSDR SVI uses U.S. Census data to determine the relative social vulnerability of every census tract in the U.S. and then ranks each based on 14 social indicators. These tools used in concert with one another highlight residential areas that may be particularly vulnerable to impacts of projects proposed for FERC consideration and thus would be of great value in providing objective data.

Comments on Section E, E4 When evaluating disproportionally high and adverse effects on environmental justice communities, should the Commission change how it considers population specific factors that can amplify the experienced effect, such as ecological, visual, historical, cultural, economic social of health factors? If so, how? Should the Commission change how it considers multiple or cumulative adverse exposures and historical patterns of exposure to pollution or other environmental hazards? If so, how? How can the Commission obtain high quality information about cumulative impacts (e.g., data on cancer clusters and asthma rates)?

The Commission should change how it considers population-specific factors to best determine the potential impacts on a given population versus reliance on risk assessment estimates that consider risks based on a formula that suggests populations that are vulnerable (e.g., the very old, the very young) are taken into account. Having health and environmental data specific to a potentially impacted community such as data available from the CDC/ATSDR environmental public health tracking portal and their social vulnerability index tool would allow for more accurate assessments of current health status and anticipated future environmental health risks, notably in environmental justice communities. Without taking into consideration the current health status of a population it is impossible to predict how existing disease might be exacerbated.

The QDCC also believes that the Commission should take into account historical patterns of exposure and cumulative risks on a given population. In fact, if this approach had been taken in evaluating the potential impacts of the then proposed Algonquin Gas Transmission facility in the Fore River area of

Weymouth, MA it would not likely have approved this project. Many health and environmental studies had historically been done in that area by public health officials demonstrating significant elevations in chronic disease (e.g., lung cancer and other respiratory diseases) as well as the presence of other industrial facilities. It is worthwhile to note that many years ago the Fore River area was proposed for the siting of a rotary kiln incinerator. At that time the state of MA Executive Office of Human Services and the Executive Office of Environmental Affairs denied a permit for the facility after concluding that higher rates of disease among residents of the area coupled with the enormous risks the population would suffer in the event of an accident did not support the siting of the proposed facility in that area.

Consideration of this type of historical environmental and health information should have played an important role in FERC’s decision making relative to the Algonquin facility. Our Quincy Point and Germantown neighborhoods (both designated by the state as environmental justice areas) lie in the area of most likely impact in terms of suboptimal air quality and in the event of an accident. The QDCC believes this facility poses an unacceptable risk for our neighbors that should have been considered more carefully in FERC’s decision making.