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CORALations, Inc July 25, 2023 14:20 1 of 3

SUBMITTED Copy/Paste ELECTRONICALLY

Kimberly D. Bose
Secretary
Federal Energy Resources Commission
888 First Street NE
Washington DC 20426

Re: Protest to NFEnergía LLC's a/o NF Energy y/o Genera PR's application for the pipeline in the MFH
Facility and intervention deadline request, Docket No. CP23-518-000. #noalgasoductoNF.

Dear. Ms. Bose:

I am the Director of CORALations, a non-profit coral conservation organization founded in Puerto Rico in
1995 and based in the traditionally underserved, environmental justice community of Culebra, Puerto
Rico. I am not an attorney but saw that protest comments can in fact be filed on behalf of an organization
and have no other option but to file them online before the deadline today. If this is not possible, please
take these as my own personal comments.

This is to protest (#noalgasoductoNF) the above-referenced application and intervention deadline request
for the following reasons:

-Notice was issued for these comments, only 5 days before comments were due.

-Comments are due on July 25, 2023, Puerto Rico Constitution Day. This comment period appears to
coincide with a busy summer holiday, the last long weekend before children return to school in August.

-Environmental Justice leaders of Puerto Rico are likely attending the National Environmental Justice
Advisory Council (in-person) Meeting (NEJAC) that is being held in San Juan, Puerto Rico July 25-July
27, 2023. This is a rare occurrence EJ leaders would likely not miss.

-The 200ft connector proposed will link to close to five miles of coastal LNG pipeline at least according to
WAPA TV, which showed the pipe passing through multiple, overburdened, densely populated, coastal
environmental justice communities, still recovering from past hurricanes and with no assurances the
pipeline or pipelines being connected to, would even be safe. Likely none of this was evaluated with
respect to climate change. No data has been provided to communities and as mentioned before, no time
was given for communities or their advisors to weigh in on this.

-The 200 ft connection would possibly create a pipeline that moves near a number of hazardous
combustible tank fields, not to mention possibly through or directly adjacent to or connecting with the
unlawfully constructed New Fortress Energy facility. On June 14, 2022, the D.C. Circuit Court of Appeals
affirmed your agency's assertion of jurisdiction over that terminal and dismissed New Fortress’ claim that
the San Juan LNG terminal was beyond FERC's regulatory authority. Here there's been no planning

PO Box 750 Culebra PR 00775 coralations@gmail.com


CORALations, Inc July 25, 2023 14:20 2 of 3

greenwashing if you will of fast-track permits - here the hazardous facility was constructed without
FERC's oversight.

-The project moves in the coastal zone of Puerto Rico and requires a Federal Coastal Zone Certification
from the Government of Puerto Rico. The five days of public notice does not comply with the social justice
standards that apply to the Puerto Rico Coastal Zone Management Plan.

-New Fortress Energy has many subsidiaries in Puerto Rico apparently entwined in LNG projects as well
as with the US Army Corps of Engineers. EJ communities need more than a few days as well as local and
federal legal experts to evaluate this.

-This is proposed on a coastline designated as critical habitat for listed corals and in an area graced with
multiple UNESCO Heritage sites. This bay sees massive cruise ship navigation, cargo ship navigation, an
airport and fly zone, more than one fishing association, marinas, and less than 5,000 feet away, the
Capital of San Juan.

-On October 23 of 2009 the Caribbean Petroleum(CAPECO) explosion traumatized the same
communities directly affected by this connection. While the explosion offered regulatory agencies the
opportunity for lessons learned, it is not apparent what, if any, lessons were learned by regulatory
agencies. The 200ft connector creates a pipeline that moves around multiple combustible tank farms
that hold highly flammable materials that also ring these communities.

-Stakeholders have not had any opportunity prior to this application being filed with your agency to voice
concerns for any record. The affected EJ communities have not been informed or given adequate
opportunity to comment on threats and / or how such impacts would be minimized.

-The expansion of fossil fuel infrastructure is contrary to local and federal energy policy. Constructions like
this must have a broad environmental evaluation, we demand public hearings in the community.

Thank you,

Mary Ann Lucking #noalgasoductoNF, #queremossol


Director
CORALations

or

Mary Ann Lucking #noalgasoductoNF, #queremossol, should you not accept organizational comments
through this electronic venue.

PO Box 750 Culebra PR 00775 coralations@gmail.com


7/25/23, 2:40 PM Gmail - FERC eComment Receipt in CP23-518-000

CORALations Culebra <coralations@gmail.com>

FERC eComment Receipt in CP23-518-000


1 message

eFiling@ferc.gov <eFiling@ferc.gov> Tue, Jul 25, 2023 at 2:38 PM


To: coralations@gmail.com, efilingacceptance@ferc.gov

Thank you for using FERC's eComment System. Your comments have been added to the record for CP23-518-000 and
will be available in the Commission's Online eLibrary System at http://www.ferc.gov/docs-filing/elibrary.asp.

If there is an error or any other issue with your submission, please contact the efiling help line at 866-208-3676. You may
also email ferconlinesupport@ferc.gov (for assistance only – we do not accept comments on proceedings via email).

For more information on FERC procedures, we invite you to review the Citizen Guides at http://www.ferc.gov/for-
citizens/for-citizens.asp.

FERC Dockets and Registry

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