Coalition of Communities for Environmental Justice

Environmental Justice is our Goal

Richton, MS

Richton Salt Dome Issue

April 10, 2008

Overview

1. U.S. Dept. of Energy plans to core out the Richton, MS salt dome with

50,000,000 gallons ofwater per day from the Pascagoula River over a five year

period.

2. The resulting Salt slurry will have a salt content 10 to 12 times higher than the

salinity in the Mississippi Sound.

3. The Dept. of Energy is planning to pump the slurry by pipeline south ofHom

Island, 12 miles off the Jackson County, MS coast line and dump the concentrated

salt water into the Hom Island shipping channel over a five year period.

Impact Oil the Pascagoula River Basis

1. The removal of 50 million gallons ofwater per day has the potential to cause

irreversible damage to the pristine Pascagoula River Basin. Today there are 23

endangered or rare species of fish, amphibians and birds that inhabit this 80+ mile

stretch of un-inhabited river basin

2. Initiating the extraction ofthe water from the Pascagoula River may destroy these

protected wildlife in direct violation of Federal Law

3. The wetlands, swamp and tidal lands may also be irreversibly harmed

4. The Pascagoula River Basis is the ONLYsuch river shed left in the United States.

The Pascagoula River has no man-made dams, locks or channels and as a result is

in pristine condition just as it was 10,000 years ago

5. Removal of this volume of water will result in the Gulf of Mexico being wicked

up into the Pascagoula River, where the salt water will cause irreparable harm to

the natural fresh water condition ofthe River Basin

Impact Oil the Gulf of Mexico

1. The Richton Salt Dome slurry is estimated to total 94,000,000,000,000 (94 Billion

Gallons of highly concentrated saline solution. Salt content will run 8-12 times

higher than the natural saline content of t.he Mississippi Sound.

2. The saline slurry will kill all marine life that it envelopes: Shrimp, fish, oysters,

crabs, larvae, eggs, etc. The potential harm is beyond calculation

3. The saline slurry will create a dead zone that could grow to well over 200 miles X

10 miles by 20 feet deep

4. The lowered water levels of the Pascagoula River will provide a natural wicking

effect as more ofthe saltier Gulf Water is drawn further up river endangering over

300 indigenous species of plants plus fresh water wild life

5. The tidal Estuarine (sub-tidal), Riverine Estuary, (sand), Rivreine Estuary (muddy

sand), Tape Grass Beds, Large Tidal Creek; Estuariene Intertidal Meshhaline

Marsh, Oligohaline Marsh, Tidal Freshwater Marsh, Tidal Fresh Water Marsh and

other indigenous areas such as the native Cyprus Swamp, Black Gum Swamp and

Riverine Sand Bars will all be placed into what could become an irreversible

jeopardy by the concentrated salt water invasion and cause permanent harm if not

totally destroyed.

6. To date, the Federal Goverument has spent hundreds of millions of dollars trying

to protect the barrier islands such as Hom, Petit Boise, Round, Ship, Chandeleur,

Cat, Deer and other island along the MS and LA coasts. Further, hundreds of

millions of dollars have been spend in South Louisiana trying to re-generate the

tidal marsh lands that make up the South Louisiana and N. East Texas Coasts.

These areas are crucial in mainland protection against Hurricane Flooding by

acting as a Natural Break Water against storm surges. The resulting destruction of

the plant life in these areas will further endanger the coastal corumunities to future

--hurrieane-damages due to the loss ofthe marsh-lands- due to the heavy salinecontent

of the slurry that is dumped into the Mississippi Sound. The prevailing

currents are from East to West and the concentrated saline solution will be carried

across the upper Mississippi Sound into the tide lands ofMississippi & Louisiana

7. The breeding grounds for a great percentage ofthe nation's salt water sea-foods

including: Fish, Shrimp, Crab and Oysters can be destroyed or irreversibly

damaged due to the impact of94+ Billion Gallons of concentrated saline slurry

being pumped into the Gulf of Mexico for over 1,825 days during the five year life

of the Richton Salt Dome project.

8. The potential harm from this debacle is incalculable with the loss or destruction of

the nation's only remaining, untouched natural watershed: The Pascagoula

River Basin. The loss of endangered species, wild life, flora, fauna, aquatic-life;

the loss of fresh, tidal and salt water grass lands and marshes, the loss of fresh

water plant grass beds, is assured. The resulting destruction ofbreeding grounds

for salt and fresh water marine species from the poisoning of concentrated saline

water could well cause irreversible damage to the marine life, as well as the

economy provided by the sea food industry, sport fishermen, and tourists.

9 One noted PhD Marine Biologist with over 40 years experience whose entire

career has included hands on research and management of Marine Research

activities along eh MS Gulf Coast stated to the Petitioner that the impact studies

upon which the decision was made to proceed with the Richton Salt Dome saline

project were invalid as they were based upon 20+ year old data that was not

credible.

He further stated that the project could well be a potential disaster and that no aquatic

sea life Salt or Fresh Water could survive exposure to the concentrated saline

solution.

SUMMARY

Previous Hearings held by the Dept. of Energy for the Richton Salt Dome project were a

farce. Proposed follow on hearing are also a sham attempt to placate the out rage being

expressed by the citizens of the MS Gulf Coast over the potential harm that the Richton

Salt Dome Project will cause the Pascagoula River Basin, the Barrier Islands, the Tidal

Marsh and Grass lands, the breeding grounds ofthe fresh water and salt water sea life,

and the destruction of all sea life that come into contact with the concentrated salt water,

and the possible eradication of endangered species in the Pascagoula River Basis already

protected by Federal Law.

It is the position of this petitioner that the United States Government cease and desist all

further work on the Richton Salt Dome Project including design, funding, engineering,

pipeline construction, and any & all other activities associated with this project.

Cessation of these activities should begin innnediately by all parties associated with this

project including but not limited to: The United States Dept. of Energy, The MS Dept. of

Environmental Quality, The MS Board of Marine Resources, The United States Federal

Park Service, the State ofMississippi and the United States Federal Government until

such time as these government agencies can prove beyond a reasonable doubt that

dumping the described concentrated salt water slurry into the Mississippi Sound andJor

the Gulf of Mexico will not kill or harm the natural sea life of the gulf waters, the

Mississippi Sound, the Pascagoula River and its estuaries, bayous, grasses, marsh lands

(salt and fresh water) and the Flora, Fauna, Marine Life ofthe Pascagoula River Basin

including the endangered species listed herein.

PETIONER:

Robert M. Hardy- President

Protect Our Coast, Inc.

Protect Our Coast, Inc.

P.O. Box 1941

Pascagoula, MS 39568

228-769-1692

Protect Our Coast, Inc. is a Non Profit 501 (3) C Corporation

Fed Tax ID

Richtollll Salt Dome Issue

April HI, ZOOS

EXHIBITl

The Richton Salt Dome debacle is a train wr.eck headed straight at Pascagoula, Gautier, &

Ocean Springs, MS. If our government is hell bent on changing our Gulf Coast into the

equivalent ofIsrael's Dead Sea or the Great Salt Lake in Utah then God help us for we

will reap what we sow. The Pascagoula River might be able to heal itself over time, but

we just may be creating a dead zone in the Gulfthat might last for hundreds of

years. And at our present rate of crude oil consumption, how many weeks or months of

petroleum products will the increase in our strategic reserves provide? A couple of

months at best.

When asked about this issue, the official response was a copy of the press release that

said (I) President Bush wants it, (2) its good for national defense, and (3) it will provide a

few jobs in Richton. But at what Cost? Folks, we are getting hosed and ifthis program

continues we will have no one to blame but ourselves when the damage is done.

Obviously, the threat to the MS Gulf Coast is of no concern in Washington DC. This

debacle high lights the U.S. Government and the Dept. of Energy's gross incompetence

and it is obvious that the entire project is fueled by special person's and companies' own

self interest. Crude Oil is worthless unless it is converted into Gasoline, Kerosene,

lubricant oil, etc. So who is really behind this pending disaster? It has to be the Oil

Companies. Why do you think that Congress has an approval rating ofabout 14%? Its

because of the elitist mentality that has infected our officials and the professional

bureaucrats in Washington. The Bureaucrats' primary focus is to CYA and stay at the

trough, while the politicians focus is to get re-elected.

In addition there is a conflict of interest on the part of at least one elected official that

borders on criminal malfeasance. See Exhibit 1 to this document. This is compounded

by the fact that the Oil Monopoly in the United States own a substantial amount ofthe

known oil reserves and stand to benefit by selling the crude oil to the U.S. Government

under the guise ofthe Richton Dome Project. Then, by having access to the crude oil,

they stand to gain on the manufacturing end of the program by reaping record high prices

as they sell the finished product at to the end user.

In addition, if the Petroeum Reserve is because of a potential Hurricane, as one of the

arguments for this project suggests, when (not if) the next hurricane hits Pascagoula, The

Dept. of Energy shouldn't be planning on using Chevron to process the Crude for about 6

months or so.

GROSS INCOMPETENCE

The Dept. of Energy has had almost 25 years and has spent $800 Billion dollars since its

inception following the Oil Embargo ofthe Jirnmy Carter era. And what do we have to

show for it? Nothing. A zero policy, with no viable alternative energy program, a frozen

nuclear power program that is 20 years behind the curve, and no firm policies on Detroit

and the Automobile Industry.

In other words, NOTHING.; "But we are going to start working on it now because....well

our failure over the past 25 years is really no one's fault; and besides its all history, isn't

it?"

By potentially killing a huge area ofthe MS Sound, the idiots who have come up with

this plan show that they could care less about Pascagoula, Jackson County and the wider

Gulf Coast.

DOES THE GOVERNMENT PROCESS REALLY CARE?

The Richton Salt Dome project parallels the same caliber of "compassionate, forward

thinking" government professionals that have allowed our local industries to discharge

1,560,000,000 pounds of Carcinogens and Toxicants into our air, water, land fills, deep

wells in Jackson County or hauled out of state over the past 12 years. In 2006 we had

reported over 2.4 million pounds of of carcinogens that were released for every man,

woman and child in Jackson County. That's 34.7 pounds; compared with Hinds County at

1.4 pounds per person. And interestingly enough, Jackson County now is in the top I (J%

ofOmcer Incident CInd Cancer Death rates, per capita, out of3,171 counties in the

United States. The top10%. Mississippi is in the top 5 states in the U.S. with its per

capita Cancer Rates, and Jackson County is 147% higher than Mississippi. As an

example in Colmer Middle School, with about 28 faculty, 6 teachers have cancer as of

today. So the bottom line is that our government is responsible for allowing the permits

that authorize the release ofthese carcinogens and as a result every 1.5 days a person dies

of cancer in Jackson County seven days per week.

It's not enough that we are killing off our citizens. Let's endanger the marine life and

aquatic flora and fauna in the MS Sound and the Pascagoula River well. The potential

impact won't be like an oil spill that you can clean up. The potential disaster from this

debacle might be forever.

Protect Our Coast, Inc.

P.O. Box 1943

Pascagoula, MS 39568

228-769-1692

Robert Hardy- President

RicJ!:lltol1 Salt Dome Issue

Apl'iJllll, 2008

EXUIBIT2

Mississippi's governor, Haley Barbour, has shut down all discussion on the Richton Salt

Dome and has stated that he does not believe that taking 50 million gallons of water each

day out of the Pascagoula River for five years will endanger the pristine river's water

shed with its Cypress and Black Gum swamps, river grass beds, or the 33 endangered

species that live there. Nor will the discharge of 94 Billion gallons of concentrated saline

slurry dumped into the Mississippi Sound harm the Shrimp, Fish, Crabs, Oysters, sea

beds, breeding grounds, estuaries or the Pascagoula River. When local residents called

the governor's staff to express their outrage, they were told that the governor fully

endorses the project and that if they had a problem, they needed to call Washington, D.C.

His position is under the guise of "Economic Development".

POLITICAL NEPOTISM AT ITS WORSE

Governor BarbOlJli' is a principle and owner of the Washington DC lobbying firm,

Barbour, Rogel'S & Griffin. A Vice President in this lobbying group is theformer

ChiefofStaffofthe Dept. ofEnergy, Eric Burgeron. Remember, the Dept. of Energy

has the grand idea of buying I billion barrels of crude oil that has been taken from the

ground, hauled half way around the world and then put back into under ground reservoirs.

Hence, the "need" for the Richton Salt Dome debacle. Many ofthese reservoirs already

exist, but rest assured we are looking at a multi-billion project and there is a ton of money

to be spent. To start the project, the government already has spent $25 million oftax

payers' money to buy the land under which the salt dome lies.

FOLLOW THE MONEY:

In 2007, Barbour, Rogers & Griffm received $17.4 million from their Clients. That's

$68,125/day or $9,083I1:1olllr. And although Gov. Barbour's interests are supposedly in a

blind trust; that trust paid him over $300,000 in 2006. Could we have a conflict of

interest?

The public record from Barbour's lobbying firm's web site shows that they were paid

$3.25 million by companies that have a vested interest in Oil Refineries, Pipelines, OilTankers

and companies that broker (buy and sell) crude oil along with petro-chemical

manufactures.

Blllt Wait!!! The plot thickens.

While we are waiting for a "new round ofpublic meetings" so that the Dept. of Energy

can listen to our concerns and outrage, ostensibly to give serious consideration to our

local input, On March 7, 2008 the DOE announced their intention to release a Bid

Request for five year $25 million dollar project. This project is entitled "Technical and

Analytical Support services to Strategic Petroleum Reserves." For anyone interested, the

reference is SOL DE-RPOI-08FE70069 POC Benjamin Lardizabal, Contracting Officer,

202-287-1479, [email protected];Linda& Linda Sapp, Contract

Specialist. 202-287-1518, [email protected] .

It would appear that the Dept. of Energy in Washington D.C. is not waiting for a final

judgment from DOE based upon the input of the good folks from Jackson County over

the next few weeks. Rather it looks like a done deal from this end, and our Governor has

a vested interest in this project.

Again, follow the money, folks. The trail stinks. Don't be fooled into thinking that

another round of"hearings" by the Dept. of Energy will have any impact on the Richton

Salt Dome debacle. This is a back-office done deal and the citizens of Jackson County are

going to pay the price ifwe don't unite and demand that our elected representative

intercede in Washington to pull the plug on this farce. Our only recourse may be through

the courts. A non profit corporation, Protect Our Coast, luc. has been formed for this

very purpose.

Protect Our Coast, Inc.

P.O. Box 1943

Pascagoula, MS 39568

228-769-1692

Robert Hardy- President

Richton Salt Dome Issne

Aprillll, 2008

Exhibit 3

THREAT TO ENDANGERED SPECIES

Overview

Impact 011 the Pascagoula River Basin

1. The removal of 50 million gallons of water per day has the potential to cause

irreversible damage to the pristine Pascagoula River Basin. Today there are 31

endangered or rare species of fish, amphibians and birds that inhabit this 80+ mile

stretch of pristine undeveloped river basin. Initiating the extraction ofthe water

from the Pascagoula River may destroy these protected wildlife in direct violation

of Federal Law. The wetlands, swamp and tidal lands may also be irreversibly

harmed

The following endangered species are listed in the Pascagoula River Basill habitat as

published by the MS Museum of Natural History:

Gulf Sturgeon

One Toed Amphiuma

Logger Head Turtle

Green Turtle

Gopher tortoise

Yellow Blotched Map Turtle

MS Red Belly Turtle

Ringed Map Turtle

Peregrine Falcom

Rain Bow Snake

Kemp's or Atlantic Ridley

Brown Pelican

Inflated Heelsplitter

Delicate Spike

Red Cockaded Woodpecker

Florida Panther

Dark Gopher Frog

Bewick's Wren

Louisiana Black Bear

Southern Hog Nose Snake

Black Pine Snake

Piping Plover

Eastern Indigo Snake

Iron Color Gopher

Manatee

Pyramid Pigtoe

Rabbits Foot

Endangered Fresh & Saltwater Flora

The lowered water levels ofthe Pascagoula River will provide a natural wicking effect as

more of the saltier Gulf Water is drawn further up river endangering over 300 indigenous

species of plants plus fresh water wild life. Among this plant life which plays a critical

role in the aquatic habitat and spawning beds for fresh water and salt water wild life

include

The tidal Estuarine (sub-tidal)

Riverine Estuary, (sand)

Rivreine Estuary (muddy sand)

Tape Grass Beds

Large Tidal Creek

Estuariene Intertidal Meshhaline Marsh

Oligohaline Marsh

Tidal Fresh Water Marsh

and other indigenous areas such as the native Cyprus Swamp, Black Gum Swamp ai1d

Riverine Sand Bars will all be placed into what could become an irreversible jeopardy by

the concentrated salt water invasion and cause permanent harm ifnot totally destroyed.

THE BARRIER ISLANDS AND SALT MARSHES OF MS & LA.

To date, the Federal Government has spent hundreds of millions of dollars trying to

protect the barrier islands such as Horn, Petit Boise, Round, Ship, Chandeleur, Cat, Deer

and other island along the MS and LA coasts. Further, hundreds of millions of dollars

have been spend in South Louisiana trying to re-generate the tidal marsh lands that make

up the South Louisiana and N. East Texas Coasts. These areas are crucial in mainland

protection against Hurricane Flooding by acting as a Natural Break Water against storm

surges. The resulting destruction of the plant life in these areas will further endanger the

coastal communities to future hurricane damages due to the loss ofthe marsh lands due to

the heavy saline content of the slurry that is dumped into the Mississippi Sound. The

prevailing currents are from East to West and the concentrated saline solution will be

carried across the upper Mississippi Sound into the tide lands of Mississippi & Louisiana

SUMMARY

Previous Hearings held by the Dept. of Energy for the Richton Salt Dome project are

highly suspect due to the timing and location immediately following Hurricane Katrina..

Is the proposed follow on hearing also a sham attempt to placate the out rage being

expressed by the citizens ofthe MS Gulf Coast? Is the threat for potential harm that the

Richton Salt Dome Project will cause the Pascagoula River Basin, the Barrier Islands, the

Tidal Marsh and Grass lands, the breeding grounds ofthe fresh water and salt water sea

life, and the destruction of all sea life that come into contact with the concentrated salt

water real? If so how can the possible eradication of endangered species in the

Pascagoula River Basis already protected by Federal Law be allowed to happen?

The Mississippi Sound, the Pascagoula River and its estuaries, bayous, grasses, marsh

lands (salt and fresh water) and the Flora, Fauna, & Marine Life of the Pascagoula River

Basin including the endangered species listed herein are sufficient reason to halt this

criminal activity that has been endorsed by elected officials and individuals who have

gained, financially and who have expressed their utter contempt to the well being of our

local habitat and the expressed wishes of the citizens of Jackson & George County, MS .

Threat to the Glilf of Mexico & the Mississippi SOlllJmd

It is generally agreed that the once pristine waters ofthe Gulf of Mexico are gradually

changing. A few years back, the waters were clear to a depth of about 4 to 5 meters.

Today, those same waters are pasty and the Gulf of Mexico is gradually becoming a

polluted coastal waterway. The current situation is a combination of natural and human

induced processes. The Gulf of Mexico's diverse and productive ecosystem provides a

variety of valuable resources and services to the region including transportation,

recreation, fish and shellfish, and petroleum and minerals, and as such the effects of

pollution on the shoreline communities, marine mammals, birds, and other aquatic life

within the region cannot be over-emphasized. Spills and dumping from oil tankers that

navigate the Gulf of Mexico waters are among the chief causes of both marine and beach

debris. Nonpoint-source pollution such as debris from inland municipal sewage, waste

disposal facilities and urban and agricultural runoff add to the problem. These materials

often entangle, maim, or kill aquatic creatures. When fish and marine mammals feed on

these synthetic materials, they subsequently enter the food chain. Because circulation

within the Gulf is limited, solid waste and other pollutants float along with the currents

until, eventually, they wash up on shore. This debris thus accumulates along the Gulf

coast, affecting both tourism and coastal habitats.

Examples of alHlual pollutant and nutrient loading in the region are:

* 891,974 tons of nitrogen

* 221,526 tons ofphosphorus

* 100 million tons of dredged sediments

* 2,720 tons oftoxic substances from coastal industrial and municipal sites (four of the

top five states in the U.S. in total surface discharge of toxic chemicals are Gulf StatesAlabama,

Mississippi, Louisiana and Texas)

* 1,040 tons of pesticides from coastal agriculture

* 6,170 tons of produced waters from near-shore oil and gas platforms

Just 1Il few ol:' the listed eilldangered species by the U.s. Dept. of Wild Life & Fisheries

include:

Green Sea Turtle

Kemp's Ridley Sea Turtle

Leatherback Turtle

Small Tooth Sawfish

Humpback & Finback Whales

Hawks Bill Turtle

Logger Head Turtle

Gulf, Pallid and Alabama Sturgeon Species

Dolphins

In addition the Barrier Islands including Hom Island, Round Island, Petit Boise, Cat

Island, Ship Island and others have endangered species listed among them include

the American Alligator, Night Flowering Ruellia, Osprey, and Oyster Reefs.

Other lists of endangered species from the U.S. Government are reflected below

PETIONER:

Robert M. Hardy- President

Protect Our Coast, Inc.

P.O. Box 1941

Pascagoula, MS 39568

228-769-1692

Protect Our Coast, Inc. is a Non Profit 501 (3)-C Corp.

Fed Tax ID 26-1097-156

Other EJlJilllangerd Species for the Pascagolllia River Basin

Published by the United States Govemment

Dept. of Interior, Marine Fisheries &; Wild Life

U.S. Park Service

E Clubshell, black (Pleurobema curtum)

E Clubshell, ovate (Pleurobemo oerovatum)

E Clubshell, southern (Pleurobema decisum)

E Combshell, southern (Epioblasmo penita)

E Crane, Mississippi sandhill (Grus canadensis pulla)

T Darter, bayou (Etheostoma rubrum)

T Moccasinshell, Alabama (Medionidus acutissimus)

T Mucket, orangenacre (Lampsi/is perovo/is)

E Pigtoe, flat (P/eurobema marshal/i)

T Plover, piping except Great Lakes watershed (Charadrius melodus)

E Pocketbook, fat (potamilus capax)

E Stirrupshell (Quadrula stapes)

E Sturgeon, Alabama (Scaphirhvnchus suttkusi)

T Sturgeon, gulf (Acipenser oxvrinchus desotoi)

E Sturgeon, pallid (Scaphirhvnchus albus)

E Tern, least interior pop_ (Sterna antil/arum)

 

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