FERC snubs Jordan Cove (The World, Oct. 12) was an article that detailed Federal Energy Regulatory Commission’s refusal, for the third time, to initiate formal discussions of the Jordan Cove liquefied natural gas proposal. It prompted a somewhat disingenuous response from the Oregon International Port of Coos Bay that, “We are somewhat puzzled by that.”

It is quite clear gross legal and procedural defects in the Jordan Cove Environmental Impact Statement preclude moving forward with the decision process.

The National Environmental Policy Act provides extensive guidelines as to what a valid EIS is to look like.

NEPA states a standardized format is to be used. The Jordan Cove EIS utilizes a bastardized format with no explanation as to why.

NEPA states an explicit explanation of the need for the proposed project be provided. The EIS dismisses this requirement in a single sentence: “Need is not an environmental issue to be addressed in this document.”

NEPA requires the EIS contain a section entitled Affected Environment, which provides a baseline description of existing conditions in the area to be affected by the proposed project. Such a baseline is essential if a meaningful analysis of cumulative effects is to be completed. The EIS does not contain that section.

NEPA regulations state the EIS section entitled Analysis of Alternatives is the heart of the EIS process. It requires all reasonable alternative actions receive a degree of analysis similar to that devoted to the proposed action: Even though the EIS identifies eight reasonable alternative actions early in the document, the section on Analysis of Alternatives makes no mention of any of them and concentrates totally on the Proposed Action, in direct violation of one of the major precepts of the EIS process.

The Jordan Cove EIS is so grossly deficient it precludes moving ahead with the decision process in a legally defensible manner.

And it gets worse. The U.S/ Army Corps of Engineers is taking comments regarding dredging permits required for the proposed LNG terminal. They are relying on the Jordan Cove EIS to document compliance with NEPA. Without augmentation or supplementation, it is doubtful the Corps will be able to comply with their own internal environmental operation principles.

The Jordan Cove EIS was conceived, in a manner violating both the letter and intent of NEPA, to justify a proposal and to speed its journey through the regulatory process. Now, because of its legal and regulatory deficiencies, it might well doom the project.

Ron Sadler

North Bend