From: Subject: Date: To: AlexanderScott, Nicole (RIDOH) Nicole.AlexanderScott@health.ri.gov RE: Revised FERC letter - feedback due by 2 July 25, 2018 at 4:18 PM Bozzi, Laura (RIDOH) Laura.Bozzi@health.ri.gov, Byrns, Michael (RIDOH) Michael.Byrns@Health.ri.gov, Drix, Julian (RIDOH) Julian.Drix@health.ri.gov, Menard, Rita (RIDOH) Rita.Menard@health.ri.gov, DiPippo, Peter (RIDOH) Peter.DiPippo@health.ri.gov , Rajotte, James James.Rajotte@health.ri.gov, Alston, Kenny (OHHS) Kenny.Alston@ohhs.ri.gov, Dumont, Dora (RIDOH) Dora.Dumont@health.ri.gov, Novais, Ana (RIDOH) Ana.Novais@health.ri.gov, HallWalker, Carol (RIDOH) Carol.HallWalker@health.ri.gov, Garneau, Deborah (RIDOH) Deborah.Garneau@health.ri.gov, Poucher, Sherry (RIDOH) Sherry.Poucher@health.ri.gov, Dixit, Seema (RIDOH) Seema.Dixit@health.ri.gov, Simoli, Mike (RIDOH) Mike.Simoli@health.ri.gov Cc: Novais, Ana (RIDOH) Ana.Novais@health.ri.gov, Powell, Sandra (RIDOH) sandra.powell@health.ri.gov, Menard, Rita (RIDOH) Rita.Menard@health.ri.gov Yes, Laura and Mike. First, I want to say that you all did really excellent work with bringing together the final version of the letter. I am extremely pleased with how you brought it together, and thank you all for your thoughtfulness, and for your great leadership, Laura. As of this afternoon, I have learned the outcome relayed to me on behalf of the Governor today, once I began advancing the excellent letter we were going to submit. Because there is concern about wanting to avoid too much involvement of the State in federal legal processes. At this time, every state agency in the Governor's administration has been asked not to submit a letter. In spite of that disappointment, I want to express that there is benefit in making sure that the message you have all put together so well is one that begins to educate leadership of our sister state agencies. Please know the importance and benefit of the seeds you have helped plant and we will continue to go forward together. Please don't hesitate to reach out to me with any questions or input. THANK YOU VERY MUCH! Lastly, while our meeting together is Aug 14th, please have one or two meetings with each other to discuss in advance, then there can be a quick conversation with me by the time of the 14th. Nicole E. Alexander-Scott, MD, MPH Director Rhode Island Department of Health Three Capitol Hill, Room 401 Providence, RI 02908 (401) 222-1018 - office (401) 222-6548 - fax nicole.alexanderscott@health.ri.gov Rita Menard Executive Assistant to the Director (401) 222-1018 rita.menard@health.ri.gov Public health saved your life today! CONFIDENTIALITY: This message and all attachments may contain information that is confidential and/or proprietary to the Department of Health, including personal health information, and disclosure or distribution to anyone other than the intended recipient is prohibited. If you believe you have received this information in error, please notify the sender by replying to this email and immediately delete this message without disclosure. Thank you. -----Original Message----From: Bozzi, Laura (RIDOH) Sent: Wednesday, July 25, 2018 2:29 PM To: Byrns, Michael (RIDOH) ; Drix, Julian (RIDOH) ; AlexanderScott, Nicole (RIDOH) ; Menard, Rita (RIDOH) ; DiPippo, Peter (RIDOH) ; Rajotte, James ; Alston, Kenny (OHHS) ; Dumont, Dora (RIDOH) ; Novais, Ana (RIDOH) ; HallWalker, Carol (RIDOH) ; Garneau, Deborah (RIDOH) ; Poucher, Sherry (RIDOH) ; Dixit, Seema (RIDOH) ; Simoli, Mike (RIDOH) Subject: RE: Revised FERC letter - feedback due by 2 Hi Michael, I understand that Dr. Alexander-Scott will be in touch with this group soon regarding the letter. On the Invenergy hearings: The next meeting of the HIA Team is on August 14 at 3PM. We can try to schedule another meeting earlier, if you think that's necessary. necessary. Also, looking at the issue areas RIDOH will be commenting on -- Air Emissions, Water Supply, Traffic, and Noise -- we'll need to pull in some other RIDOH expertise to the meetings, as those issue areas aren't fully covered by the HIA team. Thanks, Laura -----Original Message----From: Byrns, Michael (RIDOH) Sent: Wednesday, July 25, 2018 1:44 PM To: Bozzi, Laura (RIDOH) ; Drix, Julian (RIDOH) ; AlexanderScott, Nicole (RIDOH) ; Menard, Rita (RIDOH) ; DiPippo, Peter (RIDOH) ; Rajotte, James ; Alston, Kenny (OHHS) ; Dumont, Dora (RIDOH) ; Novais, Ana (RIDOH) ; HallWalker, Carol (RIDOH) ; Garneau, Deborah (RIDOH) ; Poucher, Sherry (RIDOH) ; Dixit, Seema (RIDOH) ; Simoli, Mike (RIDOH) Subject: RE: Revised FERC letter - feedback due by 2 Hi Laura, Could you send out the final draft of the letter when it is available? Also, we need to schedule another meeting of this group in the relatively near future. I, or someone else from RIDOH, will need to testify on the Invenergy Burrillville application. The first hearing that we are scheduled to provide an advisory opinion for is the August 23 meeting on air emissions (see attached). I was surprised to see that DEM isn't scheduled to provide an opinion at that hearing. It would be good to have a couple meetings so that we can discuss this at different stages of our preparation and/or on different specific issues. Thanks, Mike -----Original Message----From: Bozzi, Laura (RIDOH) Sent: Tuesday, July 24, 2018 12:01 PM To: Drix, Julian (RIDOH) ; AlexanderScott, Nicole (RIDOH) ; Menard, Rita (RIDOH) ; DiPippo, Peter (RIDOH) ; Rajotte, James ; Alston, Kenny (OHHS) ; Dumont, Dora (RIDOH) ; Novais, Ana (RIDOH) ; HallWalker, Carol (RIDOH) ; Garneau, Deborah (RIDOH) ; Poucher, Sherry (RIDOH) ; Dixit, Seema (RIDOH) ; Byrns, Michael (RIDOH) ; Simoli, Mike (RIDOH) Subject: Revised FERC letter - feedback due by 2 Hi all, Based on our meeting yesterday, attached is a revised letter to FERC. Please send me any last comments by 2pm today. Thanks, Laura -----Original Message----From: Bozzi, Laura (RIDOH) Sent: Monday, July 23, 2018 1:45 PM To: Drix, Julian (RIDOH) ; AlexanderScott, Nicole (RIDOH) ; Menard, Rita (RIDOH) ; DiPippo, Peter (RIDOH) ; Rajotte, James ; Alston, Kenny (OHHS) ; Dumont, Dora (RIDOH) ; Novais, Ana (RIDOH) ; HallWalker, Carol (RIDOH) ; Garneau, Deborah (RIDOH) ; Poucher, Sherry (RIDOH) ; Dixit, Seema (RIDOH) ; Byrns, Michael (RIDOH) ; Simoli, Mike (RIDOH) Subject: RE: FERC letter - reminder Hi all, Please find attached the draft letter to FERC, for discussion this afternoon. I'll bring hard copies to the meeting for all. Thanks, Laura -----Original Message----- -----Original Message----From: Bozzi, Laura (RIDOH) Sent: Monday, July 23, 2018 10:28 AM To: Drix, Julian (RIDOH) ; AlexanderScott, Nicole (RIDOH) ; Menard, Rita (RIDOH) ; DiPippo, Peter (RIDOH) ; Rajotte, James ; Alston, Kenny (OHHS) ; Dumont, Dora (RIDOH) ; Novais, Ana (RIDOH) ; HallWalker, Carol (RIDOH) ; Garneau, Deborah (RIDOH) ; Poucher, Sherry (RIDOH) ; Dixit, Seema (RIDOH) ; Byrns, Michael (RIDOH) ; Simoli, Mike (RIDOH) Subject: FW: FERC letter - reminder Hi all, Given that we'll have just a short hour to discuss the comment letter to FERC, I wanted to share now the initial draft components of the letter with Mike B's comments. I'm working on a revised draft (and hoping to send it to you all prior to the meeting). I anticipate that we will still need to discuss as a group the guiding position and strategy RIDOH will take with respect to the EA. See you at 4pm. Best, Laura -----Original Message----From: Byrns, Michael (RIDOH) Sent: Friday, July 20, 2018 4:07 PM To: Bozzi, Laura (RIDOH) ; Drix, Julian (RIDOH) ; Poucher, Sherry (RIDOH) ; HallWalker, Carol (RIDOH) ; DiPippo, Peter (RIDOH) Subject: RE: FERC letter - reminder Hi Laura, I tried to provide some constructive criticism to strengthen the letter if the Director does send it. My questions are not intended to be rhetorical, they are things I think you want to clearly answer. The safety section is well written and focused, although I don't know enough about that section to evaluate the technical details or significance of those findings. The other sections also need to be direct, clear, and specific about what we want from them. You probably want a stronger case for why this project is an EJ issue. A slight increase in local traffic (offsetting decreases elsewhere) could result from anything industry or government does. I don't think that is enough to argue that EJ considerations should slow this project. I talked to Ruth Gold, who handled the air permitting at DEM. DEM's take is that there really isn't much changing from a pollution perspective, and thus this isn't a project that should trigger EJ concerns, since it isn't adding to the burden that is already there. She said that the biggest pollution concern might be fugitive dust emissions during construction, but those are covered by regulations and can trigger a fine. Given the politics of this project, she imagines that they will go above and beyond what is required in order to make sure to prevent that. Overall, DEM seems happy with the way this has been handled so far. Hope this helps, Mike -----Original Message----From: Bozzi, Laura (RIDOH) Sent: Thursday, July 19, 2018 7:39 AM To: Drix, Julian (RIDOH) ; Poucher, Sherry (RIDOH) ; HallWalker, Carol (RIDOH) ; Byrns, Michael (RIDOH) ; DiPippo, Peter (RIDOH) Subject: Re: FERC letter - reminder Thanks Julian. All- Attached is a compilation of contributions for a few other sections. Please also review and send any comments. I'm away at a conference until Monday, so I'll revise the draft then in order to share with the director in the afternoon. ________________________________ From: Drix, Julian (RIDOH) Sent: Thursday, July 19, 2018 1:14 AM To: Poucher, Sherry (RIDOH); Bozzi, Laura (RIDOH); HallWalker, Carol (RIDOH); Byrns, Michael (RIDOH); DiPippo, Peter (RIDOH) Subject: Re: FERC letter - reminder Hi all, here are some sections to add into the mix for the FERC letter. It is mostly focused on socioeconomics/environmental justice with some limited parts for cumulative impacts. I also included a couple paragraphs addressing the first section of the EA, including the FERC NEPA process with cooperating agencies, and the section on future plans and abandonment. We discussed these areas in our meeting, but I don't think they were assigned to anyone. Sorry I won't be here to help with the edits! Have a great meeting with the Director, I look forward to reading the final letter when I return. See you all in August! Best, Julian -Julian Rodríguez-Drix Asthma Control Program, Manager Division of Community, Health & Equity Rhode Island Department of Health 3 Capitol Hill, Room 409 Providence, RI 02908 (401) 222-7742 Julian.Drix@health.ri.gov ________________________________ From: Poucher, Sherry (RIDOH) Sent: Wednesday, July 18, 2018 12:49:30 PM To: Drix, Julian (RIDOH); Bozzi, Laura (RIDOH); HallWalker, Carol (RIDOH); Byrns, Michael (RIDOH); DiPippo, Peter (RIDOH) Subject: Re: FERC letter - reminder Here's my brief review of Alternatives. Any comments/criticisms are welcome. Sherry ________________________________ From: Drix, Julian (RIDOH) Sent: Wednesday, July 18, 2018 12:23 PM To: Bozzi, Laura (RIDOH); HallWalker, Carol (RIDOH); Byrns, Michael (RIDOH); DiPippo, Peter (RIDOH); Poucher, Sherry (RIDOH) Subject: RE: FERC letter - reminder Hi all, I was up until 2:30 am last night working on my section for the letter, it's not ready quite yet but I will definitely have something ready to share with you later today. With respect to our role in commenting on a (non-regulatory) public health and health equity perspective our sister state agencies engaged on the project within very limited regulatory scope, but FERC as the lead agency in the NEPA review has the primary responsibility to fully review and assess the project. I believe we have grounds for some strong public health concerns around the environmental justice issues that have been raised, and I don't think that FERC has adequately addressed the requirements in the federal Environmental Justice Executive Order for federal agency actions. I'll have more detail on this in the section I'm working on, and it will of course require review and decision from the Director on what to include and how it should be worded. Best, Julian From: Bozzi, Laura (RIDOH) Sent: Wednesday, July 18, 2018 10:57 AM To: HallWalker, Carol (RIDOH) ; Byrns, Michael (RIDOH) ; Drix, Julian (RIDOH) ; DiPippo, Peter (RIDOH) ; Poucher, Sherry (RIDOH) Subject: RE: FERC letter - reminder Michael and all - In addition to Carol's comment, my understanding of the RIDOH process is that we bring our recommendations to the Director, and ultimately she makes a decision on the agency's response. We're likely not going to come to consensus amongst ourselves, which means that we're able to provide the director with different approaches to consider. My plan is to construct a letter based on the information I receive from you all, and to provide this to the Director for us to discuss Monday afternoon. Best, Laura From: HallWalker, Carol (RIDOH) Sent: Wednesday, July 18, 2018 10:50 AM To: Byrns, Michael (RIDOH) >; Bozzi, Laura (RIDOH) >; Drix, Julian (RIDOH) >; DiPippo, Peter (RIDOH) >; Poucher, Sherry (RIDOH) > Subject: RE: FERC letter - reminder Hi Mike and All, My two cents about this, it is our job to be certain we have looked at all aspects of the Port from a public health perspective and to make sure that our Director is protecting the public's health. We are not opposing or supporting the project, but we are responsible to enforce laws and regulations that protect health and ensure safety, as such, do we have recommendations, policies or plans in place to do that for the Port? Respectfully, Carol Hall-Walker, MPA Associate Director of Health Rhode Island Department of Health Division of Community Health & Equity Three Capitol Hill, Room 408 Providence, RI 02908 401-222-5935 carol.hallwalker@health.ri.gov [cid:image003.jpg@01D1239A.C94AE700] [gray and blue logoc] CONFIDENTIALITY: This message and all attachments may contain information that is confidential and/or proprietary to the Department of Health, including personal health information, and disclosure or distribution to anyone other than the intended recipient is prohibited. If you believe you have received this information in error, please notify the sender by replying to this email and immediately delete this message without disclosure. Thank you. From: Byrns, Michael (RIDOH) Sent: Wednesday, July 18, 2018 10:33 AM To: Bozzi, Laura (RIDOH) >; Drix, Julian (RIDOH) >; DiPippo, Peter (RIDOH) >; Poucher, Sherry (RIDOH) >; HallWalker, Carol (RIDOH) > Subject: RE: FERC letter - reminder Hi Laura, I've been looking more at the air, water, and soil aspects of this project, along with the bigger picture, and I am having a hard time opposing this project. It seems to me that DEM, CRMC, and FERC have done a good job of evaluating the conventional pollution aspects and that we can't really say anything about the air, water, and soil pollution without criticizing our sister agencies, which would be unfair in my opinion. It seems like any increase in air emissions from construction and operations at the facility and increased electrical demand will be more than offset by reductions as a result of fewer trucks driving down I95. Although most of the air pollution benefits will be felt in MA, I don't think we can discount them and they will help poor, minority communities there. Impacts on soil and water seem to be negligible. Although it wasn't my section, I think this project is a good thing from a global warming and national security perspective. As I mentioned in the meeting, my impression is that the availability of this backup energy can help with the transition to bringing less reliable renewables into the grid. I also think that even fracked natural gas is better for the environment, global warming, and national security than importing LNG from Russia or Saudi Arabia. If that volume of LNG is available for use in Europe or China, perhaps it can help them move away from much less efficient coal, and at least it won't be travelling so far and we won't be relying on countries we shouldn't be supporting. For global warming, it doesn't matter where fuels are burnt, so increases in CO2 and methane emissions in the US aren't an issue if they are offset by decreases elsewhere. I think the only argument for it contributing to warming is that it might make local gas prices lower and thus lead people to burn more of it, but that is also a major positive for the health of our vulnerable poor. I think that leaves the disaster preparedness element and issues with the process. From FERC's (and DEM's) perspective, the concentration of environmental problems in this area and issues of environmental justice, are only a problem if this project adds new dangers. That only seems to be an issue if an explosion at this plant would affect nearby communities, and even then only if that explosion is more likely when this facility is completed than it is today. I don't think it is really fair to oppose it based on what it might make more likely years in the future. Ultimately this is their land, and this project is unlikely to be much worse than any other uses they are likely to find for it. I definitely agree that this process could have been handled much better from a public relations point of view, but I don't know whether that is enough to warrant a letter. I am certainly open to hearing other opinions on these issues, and it's possible that my perspective is tainted (we had a lot of interns and alumni at Marathon). However, based on my understanding of the issues, I don't think we will want to talk at any length about the section of the letter that I was supposed to be working on. Thanks, Mike From: Bozzi, Laura (RIDOH) Sent: Wednesday, July 18, 2018 10:21 AM To: Byrns, Michael (RIDOH) >; Drix, Julian (RIDOH) >; DiPippo, Peter (RIDOH) >; Poucher, Sherry (RIDOH) >; HallWalker, Carol (RIDOH) >; HallWalker, Carol (RIDOH) > Subject: FERC letter - reminder Hi folks - Please remember to send me your sections of the letter to FERC regarding the LNG facility by noon today. Thanks, Laura -Laura Bozzi, PhD Climate Change Program Manager Center for Healthy Homes & Environment Environmental Health Rhode Island Department of Health 3 Capitol Hill, Room 206 Providence, RI 02908 401-222-7757 laura.bozzi@health.ri.gov www.health.ri.gov/programs/climatechangeandhealth [cid:image001.jpg@01D1A699.9DF21470] [cid:image002.jpg@01D1A699.9DF21470] CONFIDENTIALITY: This message and all attachments may contain information that is confidential and/or proprietary to the Department of Health, including personal health information, and disclosure or distribution to anyone other than the intended recipient is prohibited. If you believe you have received this information in error, please notify the sender by replying to this email and immediately delete this message without disclosure. Thank you.