Department of Health
Three Capitol Hill
Providence, RI 02908-5097
TTY: 711
www.health.ri.gov

October 26, 2015
Kimberly D. Bose, Secretary
Federal Energy Regulatory Commission
888 First Street NE, Room 1A
Washington, DC 20426
ATTN: Nathaniel J. Davis, Sr., Deputy Secretary
RE: Fields Point Liquefaction Project, Docket PF15-28-000

The Rhode Island Department of Health (RIDOH) is responding with this letter to the Request for
Comments on Environmental Issues, published by the Federal Energy Regulatory Commission (FERC)
on September 25, 2015, with respect to Docket No. PF15-28-000 for National Grid LNG, LLC’s
proposed Fields Point Liquefaction Project. RIDOH requests to be deemed a cooperating agency, with all
the rights and opportunities to participate in FERC’s review of this project preserved thereby.
RIDOH recommends FERC conduct a robust review of the project that fully incorporates public
health perspectives and reviews potential public health concerns.
The Request for Comments specifies many topic headings to be covered in the environmental
document, including but not limited to: land use; water resources; cultural resources; air quality and noise;
socioeconomics; public safety; and cumulative impacts. All of these areas of subject-matter review affect
population health outcomes. For this reason RIDOH recommends including a Health Impact Assessment
as a component of the environmental review, which is within the scope of National Environmental Policy
Act regulations and would result in a more thorough review of the project, one commensurate with
protecting the public’s health.
The following comments outline a broad scope of the potential public health concerns that should
be included within the Health Impact Assessment, as well as some specific recommendations on topics
related to health security. With respect to overall health security, the proposed project’s impact on the
surrounding community’s ability to reduce hazard vulnerability, correct place-based inequities
influencing health, increase sustainability within the local area, and improve the collective resiliency of
residents should be assessed and included for review.
As Director, my strategic priorities for RIDOH are to address the social and environmental
determinants of health, to eliminate health disparities in Rhode Island by promoting health equity, and to
ensure access to quality services, especially for vulnerable populations. Public health’s data-driven
approach may offer valuable insight to identify areas of concern and analyze the ways in which
underlying social and environmental determinants of health impact disparities in health outcomes and
overall population health. RIDOH recommends that this approach, which would utilize and analyze
relevant public health data, be applied to reviewing the cumulative impacts of the proposed project.

State of Rhode Island and Providence Plantations

 From a place-based public health perspective, cumulative impacts and public safety impacts
should be assessed at multiple levels, from close proximity (0.5, 1 and 2 mile radius from the facility), to
neighborhood level and citywide level of analysis. There are a number of underlying factors (i.e.,
geographic, socioeconomic, and environmental) that should be included in assessments of cumulative
impacts. Health protection alongside the prevention of disease should be included within this portion of
the review.
Geographically, the proposed facility is in an industrial area with a concentration of facilities
listed in the EPA’s Toxic Release Inventory (TRI), facilities requiring Risk Management Plans (RMP),
and Treatment, Storage, and Disposal Facilities (TSDF) that handle hazardous materials. According to
EPA data accessed through the EJSCREEN tool, the 1 mile radius from the proposed facility is in the 97th
percentile in the state, the 98th percentile in the region, and the 95th percentile nationally for proximity to
RMP facilities. For TSDF Proximity, the 1 mile buffer is in the 98th percentile for the state, 99th
percentile for the region, and 99th percentile nationally.
Another geographic factor that is critical for analysis in the environmental review is the
concentration of healthcare facilities and critical health system infrastructure within close proximity to the
proposed project. Rhode Island’s only Level 1 Trauma Center is located in the Rhode Island Hospital
complex, which includes Hasbro Children’s Hospital and is adjacent to Women and Infants Hospital.
There are many additional primary care, specialty care, pediatric healthcare, and Federally Qualified
Health Centers within this area of interest at varying degrees of proximity to the site location of the
proposed facility. Providence Community Health Center’s administrative building and Chaffee Health
Center are within the half mile radius parcel map produced by AECOM for the pre-application materials.
RIDOH recommends that careful attention be paid to any potential impacts to this critical healthcare
infrastructure, including both for the cumulative impacts of construction and normal operation of the
facility, and for any potential increased risk for accidents or emergency situations. Inclusion of public
health analysis for emergency preparedness and response is further detailed in the health security
comments below.
Socioeconomically, the one mile buffer around the proposed facility is 75% minority population,
which compared to the statewide average of 24% places the area in the 91st percentile, and compared to
the regional average of 21% is in the 93rd percentile. It is 56% low-income (85th percentile for the state),
17% linguistically isolated (88th percentile for the state), and 31% have less than high school education
(86th percentile for state). The combined socioeconomics for the neighborhoods of Upper and Lower
South Providence and Washington Park are 82% minority population (93rd percentile for the state), 64%
low-income (91st percentile for the state), 24% linguistically isolated (92nd percentile for the state), and
33% have less than high school education (87th percentile for state).
These socioeconomic statistics are of important public health interest as significant social
determinants of health. RIDOH has ample data on poor health outcomes, elevated health risks, and racial
and ethnic health disparities within the City of Providence and in particular within the neighborhoods of
Upper and Lower South Providence and Washington Park, which are in closest proximity to the proposed
project. RIDOH’s 2014 Asthma Claims Data Report used health insurance claims data to produce
detailed hot spot maps for asthma prevalence, emergency department visits, and hospitalizations, which
all show asthma hot spots and elevated asthma risk in this focus area, at some of the highest levels in the
state. Providence has the highest asthma-related pediatric hospitalization rates in the state, and asthma is
elevated in low-income individuals and Black/African American and Hispanic/Latino communities.
RIDOH is funding 11 Rhode Island non-profit organizations and local governments at various
levels to support innovative approaches to improving health outcomes. The Department of Health and
these grantees have created Health Equity Zones – defined geographic areas where high rates of obesity,
illness, injury, chronic disease or other adverse health outcomes will be improved by coordinated
strategies to reduce and manage chronic diseases, promote healthy lifestyles, improve birth outcomes,
assure healthy child development, and create environments where healthy choices are easier to make. It is
State of Rhode Island and Providence Plantations

 the vision of the Department of Health, that communities are engaged in democracy and committed to
equality and diversity. Through these Health Equity Zones we will create and maintain sustainable and
healthy places for all Rhode Islanders to live, work, and learn. It is imperative that alterations to the
community’s landscape by other sectors does not impede the progress being achieved by such initiatives.
Given the high level of existing health burdens in areas adjacent to the proposed facility, RIDOH
requests that the scope of the cumulative impact analysis include any additional impact related to air
quality, emissions, and/or traffic due to construction or operation of the facility. As cited in the Resource
Report 1 submitted by National Grid to FERC (Section 1.9 Cumulative Impact Analysis), the regulations
for the implementation of NEPA (40 CFR, Section 1508.7),
“Although the individual impact of one project may be minor for one or more
resources, the additive or synergistic effects of multiple projects could be
significant. Cumulative impacts associated with the proposed Project could result
from the combined direct and indirect impacts of construction and operation of the
Project facilities with other past, present, or reasonably foreseeable planned
projects that overlap with the geographic scope and timeframe of the proposed
Project.”
RIDOH supports implementing an in-depth cumulative impact analysis, and will work to provide
relevant available data upon request for a cumulative impact review that takes into account existing air
quality and health data. RIDOH is also collaborating with RI Department of Environmental Management
(RIDEM) on an EPA-funded air quality monitoring project that will be analyzing the health impacts of
highway traffic from I-95 in asthma hot spots, particularly in the Thurbers Ave area. The project will be
measuring VOCs, ultrafine particles, and black carbon with stationary and mobile devices, and will be
collecting air quality data that is currently not available through the existing air quality monitoring
network. Other environmental factors that are worth considering in the scope of the review include
coastal flooding, both current and future levels given projected sea level rise, as well as potential storm
surge and wind impacts. The effects of climate change on this project and therefore long-term population
health is a necessary, additional component of the current environmental review. RIDOH recommends
using Rhode Island’s state-developed STORMTOOLS projections, available on ARCGIS.
The final set of topics that RIDOH requests be included in the environmental review fall under
the general heading of “public safety,” of which RIDOH has purview from the perspective of assuring
health security within the context of community health resiliency. Health security involves looking at
issues of achieving and assuring health equity in a community before, during, and after any potential
emergency. Health security is a state in which a community and its people are prepared for, protected
from, and resilient in the face of incidents with health consequences. This applies to the introduction of a
new facility and the risk posed by the various topics covered within this letter.
Although the possibility of an emergency or disaster may be low, the combination of multiple
hazardous facilities, healthcare infrastructure, and vulnerable communities requires extra care and
attention. Potential hazards may include leaks, fires, floods, earthquakes, hurricanes, storm surge,
equipment malfunction, accident, terrorism, and the added risk of secondary offsite incidents including
chemical incidents or explosions from co-located facilities requiring chemical risk management plans.
RIDOH is concerned about the health impacts that would results from a worst-case scenario involving
secondary impacts, which might involve amplified chemical reactions with substances such as chlorine,
ammonium, and heat from flammable materials stored in co-located facilities. The close proximity to the
I-95 highway corridor, and Rhode Island’s level 1 trauma center present an additional risk to the critical
infrastructure needed for responding to any potential disaster situation. With a medically-vulnerable
population and a relatively high percentage of people who are linguistically-isolated in the adjacent
community, considerations around communications in disaster preparedness and response should also be
taken into consideration as part of the environmental assessment and/or a broader emergency/risk
management review.

State of Rhode Island and Providence Plantations

 Given the set of potential risk scenarios, RIDOH requests that FERC consider requiring a Risk
Management Plan for both the proposed liquefaction facility as well as the existing LNG storage facility,
which does not currently have a Risk Management Plan. Ideally, this Risk Management Plan should
include a full and comprehensive Process Hazard Analysis, and take into consideration the potential
scenarios of secondary incidents at neighboring facilities. A detailed analysis of this nature would be
immensely valuable for ensuring the protection of our critical healthcare infrastructure and safety of
vulnerable populations.
The scoping recommendations presented in these comments were developed by a crossdepartmental committee that involved multiple Divisions, Centers, and Programs within RIDOH.
RIDOH looks forward to working collaboratively with FERC, with other state agencies, and with all
interested parties to ensure a thorough and constructive review of the proposed project in accordance to
all applicable state and federal regulations.
Thank you for your attention to this correspondence.

Sincerely,

Dr. Nicole Alexander-Scott, MD, M.P.H.
Director of Health
Rhode Island Department of Health

State of Rhode Island and Providence Plantations