Stop the Depletion of Drinking Water for Industry Project

Dear Sir or Madam:                                   

I am writing to request that an Environmental Impact Statement (EIS) drafted pursuant to the National Environmental Policy Act be prepared before the Mineral Board makes its decision whether or not to approve the current proposed Operating Agreement between the Louisiana Department of Natural Resources and Jefferson Island Storage and Hub facility (JISH), owned and operated by AGL Resources of Atlanta, Georgia.  The Operating Agreement would allow JISH to excavate two salt caverns located under Lake Peigneur at Jefferson Island in Iberia Parish, Louisiana, and store natural gas in the caverns.  I am making this request because of the serious concerns I have over the safety of this proposed operation. 

First, this Operating Agreement would allow JISH to withdraw up to 3 million gallons of fresh drinking water per day from the Chicot Aquifer, a sole-source aquifer for sixteen Louisiana parishes, for an unlimited period of time.  This could result in an irreversible drop in the water table, which could lead to saltwater intrusion in the Chicot Aquifer and the salination and/or drying up of residential and agricultural water wells.  It is unclear whether the Chicot Aquifer would be able to recharge back to its current level.

Second, billions of cubic feet of natural gas will be stored at extreme pressure within a one-mile proximity of 4,000 residents in salt domes with questionable stability.  For instance, unexplained bubbling has been witnessed on the lakes surface for over three years.  Residents have tried to no avail to get a conclusive answer as to the source of the bubbling.  When the United States Geological Survey attempted to sample the bubbling from sources below the surface of the lake, their equipment was stolen.  When the Louisiana Department of Environmental Equality attempted to sample the bubbling from the surface of the lake, their boat was stolen. 

Furthermore, a 1981 report completed by Dr. Kupher after the Diamond Crystal salt mine collapse concludes that the Jefferson Island salt dome contains a shear zone of impurities.  In the near vicinity of the Jefferson Island salt dome, there have been numerous anomalies and failures of other salt domes.  The Weeks Island National Strategic Reserve was decommissioned as a result of an oil spill from cavern failure. Napoleonville residents have not resolved litigation regarding the natural gas leak from the storage cavern in their area, and Dr. Robert Thomm recently produced a report regarding the instability of a storage cavern near the salt mine at Cote Blanche.  Any mention of the shear zone or anomalies cannot be found in any permits related to the creation of salt caverns for natural gas storage, and has not been acknowledged by AGL Resources.   AGL currently operates two natural gas storage caverns under Lake Peigneur which were constructed in the mid-1990s.  The sonar tests on one of these wells was due to be performed last year, but AGL has requested and received an extension to complete these tests.  I would like this test to be completed before the Mineral Board reaches a decision on whether to approve or deny the Operating Agreement, and I would like for these results to be included in the EIS.

In addition, the historically registered Joseph Jefferson mansion and Rip Van Winkle Gardens tourist attractions host thousands of local and international visitors a year, yet stand less than 1,200 feet from the proposed storage caverns.  The grave danger posed to these historic treasures has yet to be addressed by any public or private entity.

Lastly, there are many alternative salt domes that are a safe distance away from populated areas that have not been considered for natural gas storage by AGL Resources.  AGL stated in 2007 that they intend to take advantage of the change in  political conditions in Louisiana to secure a settlement of the lawsuit they filed over LDNRs cancellation of their mineral lease that is favorable to their company.

Currently, an environmental study is being prepared at the request of the attorneys representing the LDNR in anticipation of the Mineral Board%u2019s upcoming decision, but this study does not conform to the requirements under the National Environmental Policy Act and is therefore insufficient.  Because of the grave safety hazards to thousands of Louisiana residents and the risk of the depletion of the Chicot Aquifer, I believe an Environmental Impact Statement at Lake Peigneur and the Jefferson Island salt dome is imperative.  The current permitting process, inclusive of state and federal government agencies, does not account for the human and environmental risks involved in AGLs proposed expansion.