PRE-PUBLICATION DRAFT NOT FOR PUBLIC DISTRIBUTION RIO GRANDE VALLEY AT R I SK FROM FR ACKED-GA S EX PORT T ER M I N A LS 2 0 1 9 U P DAT E CONTENTS Summary for Financial Institutions 2 Liquefied Fracked Gas Export 3 Three Terminals Too Many 4 Climate Disaster 5 Indigenous Rights Violations 7 Community and Health Impacts 8 Ecosystem Damage 9 Banking on LNG 10 Demands 12 Endnotes 13 PHOTO: KITE AERIAL PHOTOGR APH BY J.S. AND S.W. ABER; ALL RIGHTS RESERVED. Summary for Financial Institutions Three proposed LNG terminals in the Rio Grande Valley in South Texas pose significant reputational risks to any bank or investor. The projects would significantly and negatively affect Indigenous rights, community health, endangered species, and the global climate. PROJECT NAME COMPANY TEXAS LNG TEXAS LNG ANNOVA LNG EXELON CORPORATION RIO GRANDE LNG AND RIO BRAVO PIPELINE NEXTDECADE Key Risks Climate Disaster Community and Health Impacts »» The three terminals would do the same damage to the »» These LNG terminals would emit thousands of tons of climate as approximately 61 coal plants. harmful pollutants into the air, impacting the health of »» These terminals predominantly liquefy fracked gas, and nearby low-income Latinx communities. would contribute to expansion of fracking in the Eagle Ford »» The facilities would significantly degrade the local fishing, and Permian shale basins. shrimping, and ecotourism industries, which make up large »» Complying with the Paris Agreement’s goal of limiting parts of the local economy. global warming to 1.5° Celsius requires an end to all »» The projects are formally opposed by the City of South expansion of fossil fuel infrastructure. Padre Island, the City of Port Isabel, the Town of Laguna Vista, Long Island Village, the Laguna Madre Water District, Ecosystem Damage the South Padre Island Business Owners Association, the »» These terminals are greenfield projects that would pave over Texas Shrimp Association, and the National Park Service. wetlands and divide a national wildlife refuge. »» Construction and operation would destroy habitat for Reputational Risk to Financial Institutions multiple endangered species. Habitat loss, noise, and ship »» Civil society groups have already garnered significant traffic would mean “permanent and significant” impacts to attention in speaking out against banks advising these the endangered ocelot. projects, and the pressure will continue. »» Pressure from activists and Water Protectors pushed BNP Indigenous Rights Violations Paribas to step away from Texas LNG, and ultimately from »» The Texas LNG terminal site contains a sacred burial site all fracked gas LNG terminals and pipelines. of the ancestors of the Carrizo/Comecrudo Tribe of Texas. This burial site is recognized by the National Park Service. »» Texas LNG failed to consult with the Carrizo/Comecrudo Tribe. 2 R I O G R A N D E V A L L E Y 2 0 1 9 R A I N F O R E S T A C T I O N N E T W O R K Liquefied Natural Gas Export Fossil gas (also called natural gas) is 95% methane. This LNG — liquefied “natural” gas — is conventional or greenhouse gas has a warming potential 87 times higher than unconventional gas cooled at around -160°C and condensed carbon dioxide over 20 years. While the combustion of gas into a liquid in terminals situated on the coast or offshore. may produce about half of the carbon dioxide (CO2) produced From there, the liquefied gas can be shipped on tankers to by burning coal, the climate benefits of gas compared to be exported, regasified and burned on the other side of the coal often become non-existent when looking at its entire planet.9 In addition to being an extremely energy-intensive lifecycle, and in particular at methane leakage all along the process, creating such long supply chains means even more supply chain. A study conducted by NASA concluded last year opportunities for methane to escape into the atmosphere. that the significant increase in methane concentration in the LNG thus adds about 20% more emissions than would be 1 2 atmosphere is mainly attributable to the oil and gas industry. 3 Moreover, as described further on page 5, gas infrastructure generated from transport through short-distance pipeline and combustion.10 locks in emissions outside of the carbon budget.4 Fracking provides access to trillions of cubic feet of fossil Hydraulic fracturing, or fracking, is an unconventional gas, largely concentrated in North America, and LNG brings extraction method used to force oil and gas out of shale rocks an “easy” solution for the massive export of these previously by injecting high-pressure fluids. Fracking is an extremely water-, inaccessible hydrocarbons. Companies are thus racing to build energy- and chemical-intensive process. It generates even dozens of LNG export facilities across Canada and the United higher levels of greenhouse gas emissions than conventional States, to be connected to a maze of pipelines that are fed from extraction of fossil gas and poses great risks of water, soil shale basins. More than 20 of these facilities are proposed in the and air pollution. Fracking has already been banned in many U.S., in addition to four existing ones.11 5 countries and localities because of its environmental and public health impacts.6 However, despite dangerous impacts and Just as emissions from oil and gas should be going into a public opposition, fracking still accounts for 90% of planned oil substantial decline, this liquefied fracked gas is beginning to and gas expansion in the United States, which could unlock 120 flood the global markets. Studies have shown that complying billion metric tons of CO2 emissions by 2050 — equivalent to the with the Paris Agreement’s goal of limiting climate change to lifetime CO2 emissions of nearly 1,000 coal plants. Moreover, 1.5°C requires an end to all fossil fuel expansion, meaning the adding in estimations of methane leakage could increase the North American fracking and LNG boom may be the single climate effect of U.S. oil and gas emissions by up to 24%. largest obstacle to tackling climate change today and in the 7 8 decades to come.12 R A I N F O R E S T A C T I O N N E T W O R K R I O G R A N D E V A L L E Y 2 0 1 9 3 Three Terminals Too Many Proposals for enormous LNG terminals spotting the Gulf Coast The Texas LNG site is the smallest at 625 acres — still immense, are clustered around existing ports and ship channels. In South at four times the size of Disneyland.13 The sprawling Rio Grande Texas, near the Mexican border, fossil fuel corporations plan LNG site, at 984 acres, is bigger than New York City’s Central to transform the coastal landscape of the Rio Grande Valley Park.14 And Annova LNG’s site would span about 731 acres.15 from one of the last pristine areas of Texas coastline, a haven In addition is the land needed for a new pipeline, which would for wildlife, fishing and recreation, into an industrial LNG export stretch over 137 miles to the Agua Dulce gas hub near Kingsville, hub. Three companies are moving forward with plans to build Texas.16 This gas hub connects to multiple other pipelines and is greenfield LNG export terminals on undeveloped land along a point-of-sale for gas from the Eagle Ford shale basin, where the Port of Brownsville, near Port Isabel and South Padre Island, extraction through fracking has been impacting the health of Texas. other Texas communities for over a decade.17 The projects would also export gas fracked from the Permian Basin in West Texas, Three LNG export terminals are proposed by different the second largest oilfield in the world, where drilling has already companies at the Port of Brownsville: caused sinkholes and unstable ground.18 »» Texas LNG, from a company of the same name; »» Annova LNG, owned by the Fortune 100 energy giant With the proposed sites of Rio Grande LNG and Texas LNG Exelon; and immediately adjacent to one another, and Annova LNG exactly »» Rio Grande LNG and the associated Rio Bravo Pipeline, opposite on the other side of the Brownsville Ship Channel, the owned by NextDecade. cumulative impacts of all three projects must be considered, as well as the impacts of each project individually.19 At the time of publication, all of these terminals are in the final permitting stages, but have yet to make a Final Investment Decision. 4 R I O G R A N D E V A L L E Y 2 0 1 9 R A I N F O R E S T A C T I O N N E T W O R K Climate Disaster According to a study led by Oil Change International, the Between the three terminals planned in the Rio Grande Valley, carbon contained in the fossil fuel fields and mines currently the Port of Brownsville would be prepared to liquefy and export under production is sufficient to take the world beyond 2°C 5.1 billion cubic feet of gas every day.22 With each of those of warming. Even if we immediately stopped extracting coal, terminals exporting at full capacity, burning just one year’s worth burning these oil and gas reserves would take us beyond 1.5°C of the gas exported from Brownsville would create greenhouse of warming. Thus, to keep to the Paris Agreement’s goal of gas emissions equivalent to the annual emissions from 26 coal- limiting temperature rise to 1.5°C above pre-industrial levels fired power plants.23 20 or, at maximum, well below 2°C, it is essential to leave the vast majority of hydrocarbon deposits in the ground and wind down Liquefying and shipping the gas on tankers is energy-intensive, production of some reserves before they are fully exploited. and adds approximately 20% more CO2 emissions.24 Then there Not only must we stop extracting fossil fuels, but we also must is the leakage problem: if just 3.8 percent of the gas meant for stop building new infrastructure aimed at enabling expansion these terminals in a given year escapes into the atmosphere of these reserves. As Fatih Birol, executive director of the before being burned (a commonly observed leakage rate), the International Energy Agency puts it: “We have no room to build Rio Grande Valley’s LNG terminals would be doing the same anything that emits CO2 emissions.”21 annual climate damage as 61 coal plants.25 PHOTO: ALEXANDER GERST / ESA / NASA R A I N F O R E S T A C T I O N N E T W O R K R I O G R A N D E V A L L E Y 2 0 1 9 5 Destructive LNG and Fracking Cycle = More fracked gas export terminals More fracking Climate Impacts of Fracked Gas Terminals P RO PO S E D I N RIO G R ANDE VALLEY = 3 fracked gas 61 coal-fired export terminals power plants Annova LNG, Texas LNG, Rio Grande LNG and Rio Bravo Pipeline Investing today in Rio Grande Valley’s LNG terminals would lock would also be responsible for driving an increase in fracking. in massive climate pollution for decades to come, while the The Eagle Ford and Permian shale basins, which would feed IPCC’s groundbreaking report from October 2018 shows global the Rio Grande Valley’s terminals, are climate time bombs: emissions should be roughly halved by 2030 to stay in line with projected production through 2050 from the Permian Basin the 1.5°C target.28 Any financial institution that is taking the alone could use up ten percent of the global carbon budget for climate crisis seriously must not support these projects. 26 a 50/50 chance of limiting global warming to 1.5°C.27 6 R I O G R A N D E V A L L E Y 2 0 1 9 R A I N F O R E S T A C T I O N N E T W O R K Indigenous Rights Violations The legacy of Indian displacement in Texas is one of the most This is also concerning because, while Texas LNG did contact thorough examples of land dispossession in the Americas. some Indigenous tribes for its Cultural Resources report, it failed Throughout Texas’ history, sovereignty and land rights have been to consult with the Carrizo/Comecrudo Tribe. International denied to virtually all Indigenous peoples. business and human rights standards include the right to Free, Prior, and Informed Consent by Indigenous Peoples on projects Development of Texas LNG in particular poses a threat to that impact their traditional lands.32 FERC, project developers Indigenous peoples, which the company has failed to address. and financial institutions involved in the Texas LNG project The U.S. National Park Service, in its official comments to should ensure that the Carrizo/Comecrudo Tribe has the right the federal agency regulating the project, noted that “[t]he to give or withhold their free, prior and informed consent with proposed Texas LNG terminal site contains one of the premier regards to development on their sacred grounds. prehistoric archeological sites in Cameron County, the Garcia Pasture Site. The Garcia Pasture Site (41CF8), which is listed While there have been no archeological studies in the immediate on the National Register of Historic Places, has known burials, construction sites of Rio Grande LNG and Annova LNG, patterns discrete shell working areas, and contact period artifacts.” of burials in the area show a need for more collection and Meanwhile, no existing tribe or nation with ancestral ties to this assessment of data with tribal guidance. It is likely that there coastal region in Texas has federal tribal recognition. are burials in these construction sites but because there are 29 no studies, and because none of the local tribes qualify for The Carrizo/Comecrudo of Texas, a tribal group also known protection under the Native American Graves Protection and as the Esto’k Gna originating from the South Texas Rio Grande Repatriation Act, current laws are too weak to ensure cultural Delta, is one such tribe with ancestral ties to the land Texas LNG protection. More archaeological and cultural data needs to be proposes to bulldoze for an LNG export terminal. The Garcia collected and assessed before any construction permits are Pasture Site is the burial site of the Carrizo/Comecrudo Tribe’s granted, lest construction of Rio Grande LNG, Annova LNG, and ancestors, and therefore is culturally significant and constitutes Texas LNG continue the colonial legacy of cultural destruction. 30 sacred grounds to the Tribe. The protection of cultural sites is a human rights issue under the United Nations Declaration on Banking the development of these highly controversial projects the Rights of Indigenous Peoples. And yet, though the Garcia means being complicit in violations of Indigenous rights; after Pasture area is a culturally important sacred site, because the banks’ experience with the Dakota Access Pipeline, they should Carrizo are not federally recognized they have no legal rights in be wary of the reputational risks involved. 31 the matter of its development. PHOTOS: JUAN MANCIAS, CHAIRMAN, CARRIZO COMECRUDO TRIBE OF TEXAS; S AV E RVG F R O M L N G R A I N F O R E S T A C T I O N N E T W O R K R I O G R A N D E V A L L E Y 2 0 1 9 7 Community and Health Impacts As is often the case with industrial fossil fuel development, the If built, the three proposed LNG terminals in the Rio Grande communities that would feel the negative impacts of these Valley would significantly degrade the local fishing, shrimping, terminals are largely low-income people of color.33 These LNG and ecotourism industries. Nearby South Padre Island, a terminals would be constructed between the Laguna Madre well-known destination for its sport fishing, bird-watching, communities and next to Brownsville, Texas, a rural community and pristine beaches, would have its beauty and its economy that is 94 percent Hispanic or Latinx. Nearly 28 percent of the compromised by flaring towers hundreds of feet tall, the release Brownsville-Harlingen area’s residents live below the federal of millions of gallons of effluent water, and the brown haze that poverty line, the fourth highest rate of any metropolitan area would come with the thousands of tons of air pollution.43 In the in the United States.35 The region already struggles with major Rio Grande Valley, nature tourism alone leads to 6,600 part- health disparities, and these proposed LNG facilities would and full-time jobs.44 An LNG terminal, on the other hand, creates emit thousands of tons of harmful pollutants into the air.37 mostly temporary construction jobs, and typically only a few Across the United States, nearly 1.78 million Latinx already live hundred permanent jobs.45 The largest terminal proposed for in counties that face a cancer risk above the Environmental the Rio Grande Valley would only create about 200 permanent Protection Agency’s level of concern from toxins emitted jobs, while its effects would put many more livelihoods in by oil and gas facilities.38 Industrial ozone smog burdens jeopardy.46 These economic concerns, along with the threat to Latinx communities with 153,000 childhood asthma attacks the environment and public health, have prompted many city and 112,000 lost school days each year. Siting dangerous councils and community groups to formally oppose the projects, new infrastructure in a low-income community of color — including the City of South Padre Island, the City of Port Isabel, particularly along the Gulf of Mexico, where environmental the Town of Laguna Vista, Long Island Village, the Laguna Madre racism has been part and parcel of industrial growth — is a Water District, and the South Padre Island Business Owners classic example of environmental injustice. Association.47 There is an acute risk of explosions at the three proposed Some of the companies behind these projects have also terminals and the Rio Bravo pipeline, exacerbated by the employed questionable conduct that adds insult to the serious proximity of communities and, extraordinarily, by a SpaceX injury of their proposed terminals. Annova LNG and Rio Grande rocket launch site being located just six miles from the three LNG have both pushed for billion dollar tax incentives from proposed terminal sites.41 A NextDecade-funded report that communities, seeking to avoid paying property taxes to one of found that the SpaceX launch site poses no special dangers did the poorest counties in Texas.48 34 36 39 40 little to allay community concerns.42 P H O TO S : S AV E R G V F R O M L N G ; A L I S O N K I R S C H / R A N 8 R I O G R A N D E V A L L E Y 2 0 1 9 R A I N F O R E S T A C T I O N N E T W O R K Ecosystem Damage All together, the terminal sites would cover 2,340 acres, Endangered ocelots and Aplomado falcons roam this area, including paving over hundreds of acres of wetlands. Fourteen but LNG construction, bright lights, tall structures, air pollution, liquefaction trains, eight storage tanks, and hundreds of miles ship and vehicle traffic, and wastewater would fundamentally of new pipeline would be built for these three projects. The alter the ecosystem beyond repair.53 Laguna Atascosa development and operation of the gas infrastructure, as well as National Wildlife Refuge is the natural habitat of one of just two the constant navigation of tankers shipping the gas across the populations of ocelots left in the United States, across which ocean, would severely harm and fracture the wildlife corridor there are a total of 60 or fewer individuals.54 The 2018 final concentrated in the Rio Grande delta and around the ship environmental impact statement for Texas LNG states that channel, and would further divide a national wildlife refuge. the impacts on ocelots would be “permanent and significant” 49 50 because of habitat destruction, as well as increased vehicle The terminals are proposed on greenfield sites right on the strikes.55 The U.S. Fish and Wildlife Service has already invested edge of the Bahia Grande unit of the Laguna Atascosa National millions of dollars into ocelot conservation by protecting their Wildlife Refuge, which the U.S. Fish and Wildlife Service calls “one ability to migrate to Mexico, and these terminals would also cut of the largest and most successful coastal wetland restoration off their only remaining wildlife corridor out of Texas.56 A 2019 projects in the United States.”51 The 21,700-acre refuge is a safe Defenders of Wildlife report on the threat of the three planned haven for a range of species and native vegetation, as well as LNG projects to the ocelots finds that “Current commitments a crucial storm barrier for weather events that are increasing in to mitigation by the companies developing the projects are frequency and strength with climate change. inadequate to offset harm to ocelots.”57 52 P H O T O S ( C LO C K W I S E F R O M TO P ) : L A R R Y D I T TO / DA N I TA D E L I M O N T. C O M ; E L I T R AVO / S H U T T E R S TO C K R A I N F O R E S T A C T I O N N E T W O R K R I O G R A N D E V A L L E Y 2 0 1 9 9 Banking on LNG Banks that provide financing to construct these infrastructure Star State has added more wind energy capacity than any projects (including those that act as financial advisors to the other state and is expecting huge growth in solar in the coming projects), or that provide other financial support for companies year.64 As in other parts of the state, Rio Grande Valley presents building LNG terminals, share responsibility for the impacts on an opportunity to continue this trajectory and grow the state’s climate, communities, and wildlife. Banks have financed top renewable energy portfolio. companies building LNG import and export terminals around the world with $46 billion since the Paris Agreement, led by Meanwhile, the future for LNG export remains murky, with the JPMorgan Chase, Société Générale, and SMBC Group. And glut of proposed projects threatening oversupply.65 Proposed last year, banks increased their overall financing to the top LNG terminals are not guaranteed to get built or even reach a Final companies. Investment Decision (FID), given the large number of LNG export 58 59 projects proposed in the U.S.66 NextDecade, the company All three of these proposed projects are clearly subject to the behind the proposed Rio Grande LNG and Rio Bravo Pipeline Equator Principles, in virtue of their capital costs being well projects, has been forced to address this concern: above $10 million each. They appear to each be Category A 60 projects (the highest risk category), in virtue of the diverse and While the quantum of proposed projects around the world irreversible impacts detailed in this report. Société Générale, indicates a much larger surplus than projected, many as an Equator Principles Financial Institution serving as proposed projects are unlikely to take an FID and contribute financial advisor to NextDecade, should classify Rio Grande to global supply for a number of reasons, including feed gas LNG and the Rio Bravo Pipeline as Category A. In fact, Equator issues, regulatory challenges, environmental opposition, and Principles Financial Institutions should be aware that there is a uncompetitive capital costs and pricing.67 61 strong argument that none of the three proposed terminals is Ironically, if built, these new LNG terminals and the associated compliant with the Equator Principles at all.62 pipeline would also be threatened by climate change. Any An industrial, smoggy future perpetrated by LNG export does future regulations that force early closure of carbon-heavy not have to be the fate of the pristine Rio Grande Valley. The infrastructure as a way to mitigate climate change would make sunshine in the Rio Grande Valley not only makes its beaches these projects prime candidates to become stranded assets. desirable, but also powers the largest solar roof in Texas.63 Over Also, their placement on the Gulf Coast means these projects 100,000 Texans currently work in renewable energy. The Lone would be at risk from extreme weather events, including storms, Banks that have already withdrawn from LNG export projects in the Rio Grande Valley: √ √ Sumitomo Mitsui Financial Group (SMBC Group) P H O T O : A LVOV / S H U T T E R S TO C K 10 R I O G R A N D E V A L L E Y 2 0 1 9 R A I N F O R E S T A C T I O N N E T W O R K PHOTO: AV I GATO R F O RT U N E R / S H U T T E R S TO C K that will become increasingly frequent with climate change. financial advisor to the Rio Grande LNG project, with the Overall, the financial viability and prudence of Rio Grande LNG, Australian company Macquarie Capital.74 In February 2019, Texas LNG, and Annova LNG are far from guaranteed. Rio Grande LNG announced that it is seeking to add another advisor to the project.75 Some global banks are starting to wake up to the risks of fracked gas and LNG. Recognizing the climate impact of the LNG terminals in the valley would threaten the health and vitality sector, BNP Paribas, Europe’s second largest bank, announced of surrounding communities, endanger animals and damage in late 2017 that it would not finance pipelines and LNG export ecosystems, destroy irreplaceable cultural assets, and usher terminals that transport or are supplied by “a significant in climate chaos — all in an area that is already burdened by volume of unconventional gas.” The bank committed to stop disproportionate levels of poverty and sickness, and that is supporting all shale pipelines and LNG terminals in North increasingly drier and hotter from climate change.76 Big banks America, as well as the companies owning or operating them.69 have no business funding LNG-fueled destruction in the Rio 68 Grande Valley. This announcement came just months after a delegation from the Rio Grande Valley, including Indigenous leaders and Water Protectors, traveled to Paris to speak out against the relationship between BNP Paribas and Texas LNG. At the time, BNP Paribas was acting as financial advisor to the Texas LNG project. The 70 delegation garnered significant attention in France, speaking at rallies, on popular radio shows, and at the bank’s shareholder meetings.71 In reaction to this campaign and its new policy, BNP Paribas effectively announced it will not finance the development of Texas LNG.72 This occurred after Japanese bank SMBC Group “The shale gas export market in the United States is growing rapidly with about 40 applications for export terminal construction permits. However, the carbon footprint of unconventional shale gas produced in the United States and exported to Asia is worse than that of a coal-fired power plant...” similarly put an end to its advisory mandate for NextDecade’s Rio Grande LNG project.73 - Laurence Pessez Head of Corporate Social Responsibility, BNP PARIBAS77 Pressure continues against another French bank, Société Générale, which in 2017 took over from SMBC Group as R A I N F O R E S T A C T I O N N E T W O R K R I O G R A N D E V A L L E Y 2 0 1 9 11 Demands The companies behind these three terminals are all planning to make Final Investment Decisions on the projects in 2019. Acknowledging the risks of these projects — including risks to local communities and ecosystems, the climate, and their own reputations — banks should publicly commit to withdraw or to not provide any direct or indirect financial services for the development or operation of Texas LNG, Annova LNG, Rio Grande LNG and Rio Bravo Pipeline, or any such gas infrastructure projects planned in the Rio Grande Valley.78 P H OTO : TO B E N D I LW O RT H / R A N 12 R I O G R A N D E V A L L E Y 2 0 1 9 R A I N F O R E S T A C T I O N N E T W O R K Endnotes 1 Gunnar Myhre, Drew Shindell et al., “Anthropogenic and Natural Radiative Forcing,” In: Climate Change 2013: The Physical Science Basis, Contribution of Working Group I to the Fifth Assessment Report of the Intergovernmental Panel on Climate Change, 2013, p. 714. 2 Robert W. Howarth, “A Bridge To Nowhere: Methane Emissions And The Greenhouse Gas Footprint Of Natural Gas,” Energy Science & Engineering, April 2014. 3 “NASA Confirms Methane Spike Is Tied to Oil and Gas,” United Nations Framework Convention on Climate Change, 19 January 2018. 4 “Burning the Gas ‘Bridge Fuel’ Myth: Why Gas is Not Clean, Cheap, or Necessary,” Oil Change International, 30 May 2019. 5 Ibid. 6 “Local Resolutions Against Fracking,” Food & Water Watch, 28 July 2017; Read the decision from the Permanent People’s Tribunal advising a global ban on fracking: “Session on Human Rights, Fracking and Climate Change - Advisory Opinion,” Permanent People’s Tribunal, 12 April 2019. 7 “Drilling Towards Disaster,”Oil Change International, January 2019, p. 19. 8 Ibid, p. 20. 9 “Liquefied Natural Gas (LNG),” U.S. Department of Energy’s Office of Fossil Energy, accessed May 2019. 10 K. Anderson and J. Broderick, “Natural Gas and Climate Change,” University of Manchester, commissioned by Friends of the Earth Europe, 17 October 2017. 11 “LNG,” Federal Energy Regulatory Commission, updated 17 May 2019. 12 “Drilling Towards Disaster,” Oil Change International, January 2019. For more on why gas is not a climate solution, see “Burning the Gas ‘Bridge Fuel’ Myth: Why Gas is Not Clean, Cheap, or Necessary,” Oil Change International, 30 May 2019. 13 “Disneyland’s History,” Just Disney, accessed 20 September 2016; “Texas LNG Project Final Environmental Impact Statement Volume I,” Docket No. CP16-116-000, FERC/ EIS-0288F, Federal Energy Regulatory Commission, March 2019, p. ES-2. 14 “Rio Grande LNG Environmental Impact Statement Volume I,” Docket Nos. CP16-454-000, CP16-455-000, FERC/EIS-0287F, Federal Energy Regulatory Commission, April 2019, p. ES-2; S.Jhoanna Robledo, “Because We Wouldn’t Trade a Patch of Grass for $528,783,552,000,” New York Magazine, 26 December 2005. 15 “Annova LNG Brownsville Project Final Environmental Impact Statement Volume I,” Docket No. P16-480-000, FERC\EIS: 0291F, Federal Energy Regulatory Commission, April 2019, p. ES-1. 16 “Rio Bravo Pipeline,” Rio Bravo Pipeline, accessed May 2019. 17 “Agua Dulce Natural Gas Hub,” A Barrel Full, accessed May 2019; Jim Morris, Lisa Song, David Hasemyer, “Big Oil, Bad Air: Fracking the Eagle Ford Shale of South Texas,” The Center for Public Integrity, 18 February 2014. 18 Matthew DiLallo, “The 5 Companies Dominating the Permian Basin,” The Motley Fool, 16 July 2016; Deborah Byrd and Eleanor Imster, “A Large Swath of Texas is Heaving and Sinking,” EarthSky, 27 March 2018. 19 As acknowledged by FERC; see, e.g., “Rio Grande LNG Project: Final Environmental Impact Statement, Vol. 1,” 26 April 2019, pp. ES-15 to ES-18. 20 Greg Muttitt, “The Sky’s Limit - Why The Paris Climate Goals Require a Managed Decline of Fossil Fuel Production,” Oil Change International, September 2016. 21 Adam Vaughan, “World Has No Capacity To Absorb New Fossil Fuel Plants, Warns IEA,” The Guardian, 12 November 2018. 22 “Long Term Applications Received by DOE/FE to Export Domestically Produced LNG from the Lower-48 States (as of March 29, 2019),” U.S. Department of Energy, 29 March 2019. 23 5,100,000,000 cubic feet / day)(0.0551 metric tons CO2 / 1,000 cubic feet natural gas)(365 day / year) = 102,568,650 metric tons of CO2 per year. According to the EPA, on average coal-fired power plants emit 3,893,003.27 metric tons of CO2 each per year. 102,568,650 / 3,893,003.27 = approximately 26.35 coal plants. Equivalencies provided by the EPA GHG Equivalencies Calculator - Calculations and References, accessed 30 May 2019. 24 “Life Cycle Greenhouse Gas Perspective on Exporting Liquefied Natural Gas from the United States,” U.S. Department of Energy National Energy Technology Laboratory, 29 May 2014, pp. 11 and A-4. The U.S. Department of Energy found that when shipping LNG from New Orleans to Europe, natural gas power plant operations account for 415.3 kg CO2e/MWh of GHG emissions (approximately 414.3 kg CO2e/MWh with methane leakage from power plant operations subtracted). Liquefaction, tanker transport, and regasification add 63.6, 28.4, and 45.3 kg CO2e/MWh respectively (approximately 63.6, 23.1, and 6.2 kg CO2e/MWh with methane leakage subtracted). (63.6+23.1+6.2)/414.3 = 22.4% difference. Conservatively rounded to 20%. This is supported by findings in K. Anderson and J. Broderick, “Natural Gas and Climate Change,” University of Manchester, commissioned by Friends of the Earth Europe, 17 October 2017, p. 39. 25 Using the IPCC AR5 20-year GWP of 87 (with climate-carbon feedbacks and methane oxidation). 3.8% * 5.1 billion cubic feet per day * 19,260 tons methane per billion cubic feet * 365 days * AR5 20-year GWP of 87 = 118,528,331.94 metric tons of CO2e. This value / 3,893,003.27 metric tons CO2/power plant = 30.45 more coal plants. ((5,100,000,000 cubic feet / day)(96.2%)(0.0551 metric tons CO2 / 1,000 cubic feet natural gas)(365 day / year)(120%))/ 3,893,003.27 metric tons of CO2 per year from an average coal plant = 30.41 coal plants + 30.45 coal plants = 60.86 coal plants. These calculations use a 20-year timeframe because of the immediacy of climate change. A Cornell University study finds an average 3.8% methane emission rate at conventionally drilled wells in the U.S., while shale gas leakage rates could be as high as twice that. Robert Howarth, “Methane Emissions and Climatic Warming Risk From Hydraulic Fracturing and Shale Gas Development: Implications for Policy,” Energy and Emission Control Technologies, Volume 2015:3, p. 45. 26 “Summary for Policymakers,” In: Global Warming of 1.5°C, International Panel on Climate Change, October 2018, p. 14. 27 “Drilling Towards Disaster,” Oil Change International, January 2019, pp. 26-27. 28 In line with the scenario that does not rely on carbon capture and storage technology, which remains far from being proven at scale. “Special Report: Global Warming of 1.5°C,” International Panel on Climate Change, October 2018. 29 Letter from National Park Service Re: Texas LNG, Port of Brownsville, TX, Docket No. PF15-14-000, Draft Resource Reports, United States Department of the Interior, 5 February 2016. R A I N F O R E S T A C T I O N N E T W O R K R I O G R A N D E V A L L E Y 2 0 1 9 13 30 Bekah Hinojosa, “Rio Grande Valley Native Lands Under Threat by LNG Companies,” Sierra Club Lone Star Chapter, 21 November 2016. 31 “United Nations Declaration on the Rights of Indigenous Peoples,” United Nations, 13 September 2007. 32 See, for example: “United Nations Declaration on the Rights of Indigenous Peoples,” United Nations, 13 September 2007; “Performance Standard 7 - Indigenous Peoples,” International Finance Corporation, 1 January 2012. 33 See, for instance: Dara O’Rourke, Sarah Connolly, “Just Oil? The Distribution of Environmental and Social Impacts of Oil Production and Consumption,” Annual Review of Environment and Resources, Vol. 28: 587-617, November 2003; “Coal Blooded: Putting Profits Before People,” NAACP, November 2012. 34 “Quick Facts: Brownsville City, Texas,” United States Census Bureau, accessed May 2019. 35 Michael B. Sauter, “Low Income, High Unemployment Contribute to These US Cities High Poverty Rates,” USA Today, 19 September 2018. 36 Melissa McEver, “Researchers Examine Health Disparities in RGV,” The Brownsville Herald, 23 April 2008. 37 “Rio Grande LNG Environmental Impact Statement Volume I,” Docket Nos. CP16-454-000, CP16-455-000, FERC/EIS-0287F, Federal Energy Regulatory Commission, April 2019, Table 4.11.1-7. 38 Lesley Fleischman, Declan Kingland, Christopher Maxwell, Elena Rios, “Latino Communities at Risk: The Impact of Air Pollution from the Oil and Gas Industry,” Clean Air Task Force, League of United Latin American Citizens, National Hispanic Medical Association, September 2016, p. 2. 39 Ibid. 40 Barbara Lee, “A Katrina Retrospective: Structural Inequality, Environmental Justice and Our National Discourse on Race,” Huffington Post, 25 May 2011. 41 Rebekah Hinojosa, “Our Communities, LNG, and SpaceX Do Not Make Good Neighbors,” Lone Star Chapter Sierra Club, 1 May 2017; Bekah Hinojosa, “LNG and SpaceX Should Not Be Neighbors,” Another Gulf is Possible, 20 January 2019 42 Ibid; Rachel Adams-Heard, “SpaceX Rocket Launch Site Not a Threat for Brownsville LNG Project, Report Finds,” S&P Global, 23 March 2017. 43 “Texas Brownsville LLC Texas LNG Project Resource Report 8,” Natural Resource Group, March 2016; “Annova LNG Brownsville Project Resource Report 1,” Prepared by Ecology and Environment, Inc., July 2016; “TCEQ Stand With the Community: No Air Pollution Permits for LNG,” Save RGV from LNG, October 2016. 44 Kyle M. Woosnam, Rebekka M. Dudensing, Dan Hanselka, Kayode Aleshinloye, “Economic Impact of Nature Tourism on the Rio Grande Valley: Considering Peak and OffPeak Visitation for 2011,” South Texas Nature Marketing Coop, April 2012. 45 “Jobs,” Rio Grande LNG, accessed May 2019. 46 Ibid. 47 Sergio Chapa, “Texas LNG Supporters & Opponents,” San Antonio Business Journal, 17 June 2016. 48 Steve Clark, “LNG Firm Wants Tax Break From County,” The Brownsville Herald, 29 April 2015; Sergio Chapa, “School District Rejects Tax Abatement for Rio Grande LNG,” San Antonio Business Journal, 22 September 2016; The Texas Tribune, “Data: Texas’ Top 5 Poorest Counties All Located in the Rio Grande Valley,” Valley 4 Central, 19 January 2016. 49 “Texas LNG Project Final Environmental Impact Statement Volume I,” Docket No. CP16-116-000, FERC/EIS-0288F, Federal Energy Regulatory Commission, March 2019, p. ES-2; “Rio Grande LNG Environmental Impact Statement Volume I,” Docket Nos. CP16-454-000, CP16-455-000, FERC/EIS-0287F, Federal Energy Regulatory Commission, April 2019, p. ES-2; “Annova LNG Brownsville Project Final Environmental Impact Statement Volume I,” Docket No. P16-480-000, FERC\EIS: 0291F, Federal Energy Regulatory Commission, April 2019, p. ES-1. 50 Ibid. 51 “Laguna Atascosa National Wildlife Refuge Texas - Bahia Grande Unit,” U.S. Fish and Wildlife Service, 29 March 2015. 52 “Bahia Grande Unit,” U.S. Fish and Wildlife Service, 29 March 2015. 53 “Species Profile for Northern Aplomado Falcon,” U.S. Fish and Wildlife Service, accessed 16 September 2016; “Species Profile for Ocelot,” U.S. Fish and Wildlife Service, accessed 16 September 2016. 54 Robert Peters and Melissa M. Grigione, “Potential Impacts of Proposed Jaguar Recovery in the U.S. Southwest Liquefied Natural Gas Facilities On Ocelot Recovery In Texas,” Defenders of Wildlife, 23 April 2019; “Recovery Plan for the Ocelot,” First Revision, U.S. Fish and Wildlife Service, July 2016. 55 “Texas LNG Project Final Environmental Impact Statement Volume I,” Federal Energy Regulatory Commission, March 2019. 56 Robert Peters and Melissa M. Grigione, “Potential Impacts of Proposed Jaguar Recovery in the U.S. Southwest Liquefied Natural Gas Facilities On Ocelot Recovery In Texas,” Defenders of Wildlife, 23 April 2019. 57 Ibid, p. 2 58 “Banking on Climate Change: Fossil Fuel Finance Report Card,” Rainforest Action Network, BankTrack, Indigenous Environmental Network, Sierra Club, Oil Change International, and Honor the Earth, 20 March 2019, p. 62. 59 Ibid. 60 “Equator Principles III, June 2013,” Equator Principles Association, June 2013, pp. 3. 61 “EP Association Members & Reporting,” Equator Principles, accessed May 2019. 14 R I O G R A N D E V A L L E Y 2 0 1 9 R A I N F O R E S T A C T I O N N E T W O R K PHOTO: NADJA1 / SHUT TERSTOCK 62 See an Equator Principles analysis of Texas LNG: “BNP Paribas vs. Communities and Climate,” Rainforest Action Network, Save RGV from LNG, and Les Amis de la Terre France, March 2017, pp. 10 and 12-14. 63 “Rio Grande Valley Home To Largest Solar Roof In Texas,” Alba Energy, 13 October 2015. 64 Rye Druzin, “Texas Wind Generation Keeps Growing, State Remains at No. 1,” Houston Chronicle, 23 August 2018; “Texas Solar Growth Only Behind That of California, Report Finds,” Houston Chronicle, 14 March 2019. 65 Abache Abreu and Eric Yep, “Analysis: LNG Market Risks Oversupply From New Export Projects: CEOs,” S&P Global, 28 May 2019. 66 Rachel Adams-Heard, “Study Sees Only 6 Survivors Out Of List Of US, Canadian LNG Projects,” S&P Global, 12 January 2017. 67 Harry Weber, “NextDecade Says No Immediate Need for Six Trains at Proposed Texas LNG Terminal,” S&P Global, 27 November 2017. 68 “Unconventional Oil & Gas - Sector Policy,” BNP Paribas, 1 December 2017, pp. 6-7. 69 Ibid, p. 7. 70 “Texas LNG Appoints BNP Paribas as Financial Adviser for Brownsville LNG Project, Progresses FERC Pre-Filing Process, and Completes Over 60% of Front End Engineering & Design for Facility,” Global Newswire, 24 August 2015. 71 “BNP Paribas Makes Sweeping Announcement to Cut Business With Tar Sands, Pipelines and LNG,” Rainforest Action Network, 11 October 2017 72 Ibid. 73 “NextDecade Engages Societe Generale and Macquarie Capital as Financial Advisors for Rio Grande LNG,” Business Wire, 2 May 2017. This press release replaced an older version on NextDecade LLC’s website titled, “NextDecade and SMBC Join Forces on Rio Grande LNG Project.” 74 “NextDecade Engages Societe Generale and Macquarie Capital as Financial Advisors for Rio Grande LNG,” Business Wire, 2 May 2017. 75 Taryana Odayar, “Third Adviser Sought for Rio Grande LNG,” IJGlobal, 7 February 2019. 76 Patrick Chalvire, “Analysis: Climate Change Could Leave McAllen and Brownsville With Dangerous Heat,” ValleyCentral.com, 13 July 2016. 77 Translated from: Concepcion Alvarez, “Climate Finance Day : BNP, Crédit Agricole et Société Générale, Comment Les Banques Françaises Prennent Le Virage Vert,” Novethic, 26 November 2018. 78 Financial services include lending, underwriting, advisory services, insurance coverage, and investment (with regards to an institution’s own accounts as well as those of third parties). R A I N F O R E S T A C T I O N N E T W O R K R I O G R A N D E V A L L E Y 2 0 1 9 15 P U B L I CAT I O N DAT E : J U N E 2 0 1 9 RAN.org SaveRGVfromLNG.com Carrizocomecrudonation.com Sierraclub.org FOEeurope.org/france