Editor’s note: A longer version of the following letter was sent to the Searsport Planning Board on Feb. 12. Islesboro Islands Trust hired the consulting firm Good Harbor Techmark to analyze the safety implications of a proposal by DCP Midstream to construct a 23-million-gallon liquid propane tank in Searsport.
Thank you for the opportunity to present before you, members of the planning board and members of the community, the findings of our all-hazards risk assessment for the proposed liquefied petroleum gas (LPG) storage facility at Mack Point in Searsport, Maine.
Before agreeing to take on this project, I recognized how polarizing the development had become and the great burden it placed on each member of the planning board and local officials throughout the county. I, and my team, had as our objective to provide you with independent, objective findings and a report that will enable you to make an informed decision based on the risks associated with the project. Throughout this entire process, we remained independent and objective as we communicated clearly to multiple parties, including our client, the Islesboro Islands Trust.
We do not believe the currently proposed design and site is suitable for the risk associated with bulk quantities of LPG:
• The proposed location is simply too small. The proximity of infrastructure and redundant safety measures in such a confined area reduce the prospect of their survival should an incident occur. Furthermore, the close proximity to U.S. Route 1 and the entrance and exit points to the facility by bulk tankers increase the risk.
• Cost sharing is not formally established. With all the uncertainty surrounding the necessary resources needed for operations and incident management, definitive agreements between DCP’s various operating companies, Searsport and the county must be established. Specific details regarding issues including life-cycle cost and training must be agreed upon now, particularly when mutual aid is involved. Making verbal agreements now with the expectation of formalizing these agreements later is not sufficient.
• The fact that the viability of the market has changed has implications for security considerations. Even after our report was published, we continue to see industry reports about energy independence from foreign imports. For example, the Propane Gas Association of New England recently released a report forecasting the decreased demand in New England into the future. Only two ships arriving at the Newington, N.H., terminal in the next two to three years are even forecasted. The implications of the changing import market for security considerations are significant, and the facility’s security risk profile could be significantly altered as a result.
The planning board has a unique opportunity to decide whether to allow this development to move forward or not. The planning board must make that decision based on its own criteria including the overall safety and security implications on the community, not just on the prior approval of other regulating bodies.
Throughout the course of this project, some gaps have been identified with the findings of various federal agency reviews, including those of the Corps of Engineers. In addition, the regulatory reviews may be more limited than the considerations the planning board should take into account.
Over the course of my career, I have witnessed the imperfections or limitations of regulatory agencies and regulations themselves. Regulations and regulatory reviews can be reactionary and focused on responding to past incidents, rather than looking forward. The planning board has a more encompassing mandate and the responsibility of ensuring the proposed facility meets development guidelines and does not adversely impact the resources of the town and health and safety of the community.
At the end of the day, your decision comes down to this: Are you willing to assume the responsibility for using lower safety and security standards than would be required by federal standards for an LNG facility?
LPG is different than LNG but not in ways that make it safer or more secure. The only reason there is no federal rule for LPG is an oversight due to the few LPG facilities like this.
You do not want to look back, years from now, after a disaster and wish you had done more, wish you had put the safety and security of your citizens first. You may think that a disaster is a very remote possibility, that nothing like this has ever happened before. That’s the way we thought before Oklahoma City. That’s the way we thought before 9/11. Just because it has not happened before does not mean it will not happen. If the physics allows it to happen, then you have to act as though it will.
As we conclude in our assessment, permitting should be denied for the project as currently proposed as it provides too great a risk to the community. In the event of an incident at the site some time in the future, it will be too late to decide that the site was too small, or the cost-sharing and mutual aid agreements inadequately defined, or the changing market conditions not appropriately accounted for.
Richard A. Clarke is principal investigator for Good Harbor Techmark, based in Norwell, Mass.