Department of Homeland Security – Coast Guard
Department of Transportation – Maritime Administration
TORP Terminal LPBienville Offshore Energy – LNG Terminal
Docket number USCG-2006-24644

Coastal Conservation Association is a grassroots organization with almost 100,000members in 17 state chapters dedicated to the conservation, promotion and enhancementof the present and future availability of coastal resources for the benefit and enjoyment ofthe general public. CCA has been active in local, state and federal fishery managementissues for more than 30 years.

We are here today to oppose the use of open-rack vaporization technology for theBienville Offshore Energy Terminal proposed by TORP Terminal LP in the Gulf ofMexico, approximately 63 miles south of Mobile Point, Alabama.

CCA exists to ensure good stewardship in the use of the resources entrusted to us. Weacknowledge the positive modifications to the reheating system proposed by TORP,specifically its claims that no chemicals or additives will be discharged into the Gulf. This is a significantly improved system from previously proposed open-loop LNGterminals that would have chlorinated millions of gallons of seawater water daily anddumped them back into the ocean.

However, grave concerns remain due to the inherent destructive characteristics of usingfresh seawater to reheat super-cooled LNG. The TORP open-rack vaporization systemwill still require more than 100 million gallons of seawater per day. Any organisms, eggsor larvae pulled into the system will still be subjected to potentially lethal changes intemperature and pressure.

CCA’s base objection with this project and any other open-loop LNG project remainsunchanged: the glaring lack of data on the potential impacts a system like this will cause.Decisions like this one, made decades ago with a similar lack of information on longtermconsequences, resulted in the degradation of the Florida Everglades and the greatwetlands of Louisiana. Experience proves that we often pay a great price tomorrow, inpursuit of expediency today.

CCA rejects assertions that open-loop LNG facilities will have minimal adverse impactson marine resources. There is simply not enough data to make that claim. CCA isconcerned about impacts to the entire marine ecosystem, from predators to plankton. Noscience has yet been produced that can demonstrate minimal impacts to that wide rangeof organisms. No one knows what the true impact will be.

It is a founding principle of CCA to err on the side of caution in conservation matterswhere the science is not currently adequate to determine long-term results.We recognize the alterations TORP has proposed for its terminal, but we also recognizethe ongoing risk to our marine resources from these open-loop facilities. No one knowshow drastically they could change the entire ecosystem of an area. Therefore, CCAmaintains its position that a permit for an open-loop system be denied.

Thank you for the opportunity to present our concerns over this application and toprovide comments.