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accidental oil spills which have plagued the California and Florida coasts and the coast of the Gulf of Mexico for a number of years; and

Whereas, It would take only one major oil spill to ruin the entire economy of a vast resort, boating and fishing area for many years; and

Whereas, The proposed construction of such terminal is subject to the approval of the United States Army Corps of Engineers, now, therefore,

Be it resolved by the General Assembly of thc State of New Jerscy (the Senate concurring):

1. The United States Army Corps of Engineers is memorialized to withhold approval of the plans for the proposed construction of an off-shore floating oil terminal for the unloading of oil tankers in the Delaware bay off the coast of New Jersey.

2. Each member of the United States Senate and the United States House of Representatives elected from the State of New Jersey is urged to give his full support to the purposes of this resolution.

3. The Clerk of the General Assembly is directed to cause a duly authenticated copy of this resolution to be sent to the Secretary of the Army, to the Chief of the Bureau of the United States Army Corps of Engineers, to the appropriate district offices of the United States Army Corps of Engineers, and to each member of the Congress of the United States elected from the State of New Jersey.

ASSEMBLY CONCURRENT RESOLUTION No. 101, STATE OF NEW JERSEY
Introduced August 5, 1969, By Assemblymen Cafiero, Hurley, Curcio,

Brown, Jabie, Apy, Azzolina, Aikins, and Coleman
A Concurrent Resolution memorializing the United States Army Corps of Engineers to

withhold approval of the plans for the proposed construction of off-shore pipelines
for the unloading of oil tankers off the coast of New Jersey.

Whereas, The proposed construction of off-shore pipelines for unloading oil tankers in New Jersey would present a serious danger to the tourist business in the New Jersey coastal areas; and

Whereas, A leak in such a pipeline would also virtually destroy the fishing industry in our State; and

Whereas, The recreational advantages of the shore areas contiguous to the proposed pipeline are necessary to maintain an orderly and continued development of fishing and boating along the coastal regions of New Jersey; and

Whereas, The proposed construction of such off-shore pipelines is subject to the approval of the United States Army Corps of Engineers; now, therefore,

Be it resolved by the General Assembly of the State of New Jersey (the Senate concurring):

1. The United States Army Corps of Engineers is memorialized to withhold approval of the plans for the proposed construction of off-shore pipelines the unloading of oil tankers off the coast of New Jersey.

2. Each member of the United States Senate and the United States House of Representatives elected from the State of New Jersey is urged to give his full support to the purposes of this resolution.

3. The Clerk of the General Assembly is directed to cause a duly authenticated copy of this resolution to be sent to the Secretary of the Army, to the Chief of the Bureau of the United States Army Corps of Engineers, to the appropriate district offices of the United States Army Corps of Engineers, and to each member of the Congress of the United States elected from the State of New Jersey.

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SEADOCK,

Houston, Tex., March 29, 1973.
Hon. ERNEST F. HOLLINGS,
Senate Commerce Committee,
U.S. Senate,
IV ashington, D.C.

DEAR SENATOR HOLLINGS: I am submitting Seadock's views on the issues relating to S. 80, the “Offshore Marine Environment Protection Act of 1973".

Seadock has been organized as a Texas corporation in order to develop, construct and operate a common carrier facility capable of receiving crude petro

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leum in very large crude carriers and deliver it to refining centers located between Lake Charles, Louisiana, and Corpus Christi, Texas. Twelve companies, Amoco Oil Company, Atlantic Richfield Company, Cities Service Oil Company, Continental Oil Company, Crown Central Petroleum Corporation, Dow Chemical U.S.A., Exxon Company, U.S.A., Gulf Oil Corporation, Mobil Oil Corporation, Phillips Petroleum Company, Shell Oil Company, and Texaco, Inc., have associated in SEADOCK to implement this project. Seadock currently envisions a mooring and unloading facility about 22 miles off the coast of Texas in the vicinity of Freeport on the Outer Continental Shelf, The unloading system would be connected to an onshore storage facility by pipelines. Delivery of the crude petroleum from the onshore terminal site to area refineries would be made by new or existing pipelines.

The companies associated in SEADOCK share the conviction that the transportation system represented by the use of very large crude carriers and deepwater terminals such as I have described, are both environmentally superior and economically preferable to current methods for handling a growing volume of petroleum imports to the United States. As a result of its preliminary studies, Seadock believes that the construction of these facilities is entirely feasible today. Seadock has, therefore, begun detailed engineering and environmental studies designed to provide an understanding of the problems associated with these facilities, and the broad impact of their construction and operation, Since we believe that the nation can begin to realize the benefits of these facilities as soon as they can practically be placed in service, SEADOCK intends to be in a position to make permit applications by the latter part of this year.

In addition to simply providing facilities for handling volumes of imports beyond the capabilities of existing U.S. ports, Seadock's facilities would provide benefits in several important ways. First, the use of very large crude carriers will reduce the cost of transporting crude oil from the Middle East by about 30 percent when compared to the most efficient sized vessel capable of using existing ports. Second, less than one-eighth as many ship calls to U.S. ports would be required if the nation's imports could be delivered in very large crude carriers rather than ships which could use existing ports. The smaller number of vessels and the fact that these vessels use terminals like Seadock located well offshore, away from congested harbors and narrow channels, significantly reduces the chances for accidental collisions and groundings, the major causes of accidents which might result in environmental damage. These more efficient transportation systems would also have a positive effect on the U.S. balance of payments. We believe that if the U.S. does not determine to provide deepwater port facilities like Seadock very soon, transshipping facilities will be developed either in the Caribbean or in Canada in order to capture a portion of the economic benefits provided by larger ships. In fact, several of these transshipping terminals are already in operation, and while they do provide economic benefits, the environmental advantages related to modern offshore ports and reduction in ship traffic in existing harbors will not be achieved. Therefore, Seadock believes that it is important for the Congress to promptly establish a means for permitting and regulating offshore deepwater terminals. Further, the authority for granting permits should be vested in a single federal agency in order to provide a means by which a national decision can be made which will achieve a balance of the nation's environmental, social, economic, and energy needs.

Specifically with regard to Senate Bill 80, Seadock feels that the proposed act fails to properly provide the necessary legislative basis for the establishment and proper operation of offshore terminal facilities. It is noted that S. 80 does not place in the National Oceanic and Atmospheric Administration the power to permit the construction of and regulate the operation of offshore terminal facilities. Rather, NOAA would possess only the power to prevent construction of such facilities when, after public hearing, it determined the environmental inadvisability of such construction. It seems that activities of NOAA would simply duplicate the work of a “lead agency” required under the National Environmental Policy Act. Seadock is of the opinion that the National Environmental Policy Act already makes provision for proper consideration of environmental factors and for the protection of the marine environment. What is needed is the delegation to a single federal agency of the responsibility to consider all aspects, including environmental, social, economic, and national energy requirements and, in proper cases, to permit the construc

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tion of deepwater, offshore terminaling facilities capable of handling very large crude carriers. This would permit all of the benefits thereof to accrue to the nation under circumstances where operation of such facilities is reasonably regulated by such federal agency.

Seadock also understands that several legislative proposals affecting various aspects of offshore terminal development and operation have been introduced or are in the drafting stage. Implementation of these several legislative proposals will result in fragmentation, potential conflict and duplication. SEADOCK urges that all proper aspects of such terminal construction and operation be covered in a single comprehensive enactment enabling smooth administrative and regulatory control over such facilities. SEADOCK will be following with interest the hearings you have scheduled on S. 80 and as our studies progress, we may wish to submit more detailed comments for the Committee's record. It would be appreciated, therefore, if we could be notified when the Committee establishes a date for closing its records on S. 80.

Sincerely yours,

R. H. CHITWOOD, Chairman, Seadock Management Committee.

STATEMENT OF SOUTHERN CALIFORNIA EDISON CO. Southern California Edison Company is pleased to present its comments concerning the proposed legislation on the site selection, construction, and operation of offshore artificial structures to be located in the coastal waters, S. 80.

It should be stated at the outset that Edison recognizes that these hearings involve matters of tremendous public interest and legitimate Congressional concern. Edison is aware of, and is responding to, the need for protecting the coastal zone and the resources and marine life therein. We also recognize the absolute necessity for an adequate and reliable electric energy supply for our national welfare.

Kaison is a California corporation which generates and distributes electric energy to meet the needs of over seven million people in Central and Southern California. At the end of 1972, the Edison system generating capacity totalled approximately 12,500,000 kW. It is currently estimated that Edison's customers will require an additional 7 million kW of generating capacity for the remainder of the 1Fio's and another 15 million kW in the 1980's.

Iemand for electric energy is increasing at a faster rate than the electric vitility industry's ability to obtain clearance to increase supply. Edison, as well as other electric utility companies is greatly concerned about the increasing prospect of critical power shortages during peak load periods. This nation is facing an energy crisis. This crisis has resulted, in a significant respect, from utilities not being permitted to develop new generating resources and fuel supplies needed to meet their customers' demands for electric energy because of protracted certification procedures.

1. DUPLICATE CERTIFICATION REQUIREMENTS SHOULD BE AVOIDED Duplicate and redundant certification requirements can serve no useful purpose in the furtherance of environmental objectives. Edison presently has five steam generating stations on its system utilizing circulating water conduits which extend up to 2,600 feet offshore. A brief examination of the administrative reviews required prior to the siting, construction and operation of these conduits amply demonstrates that existing certification requirements are more than adequate to insure appropriate consideration of any environmental impact which may result. For example, prior to construction, the following agencies are directly involved in considering the need for, and environmental impact of, the construction and operation of such offshore facilities :

1. State Public Utilities Commission;
2. Environmental Protection Agency ;
3. Regional Water Quality Control Board ;
4. State Water Resources Control Board ;
5. State Lands Commission;
6. US Army Corps of Engineers;

7. Atomic Energy Commission (on nuclear plants);
8. U.S Coast Guard ;
9. California Coastal Zone Commission;
10. State Department of Parks and Recreation (where appropriate);

11. National Oceanic and Atmospheric Administration, Department of Commerce;

12. Bureau of Land Management, Outer Continental Shelf Office, Department of the Interior;

13. Bureau of Sport Fisheries and Wildlife, Department of the Interior;
15. State Department of Fish and Game;
16. State Department of Navigation and Ocean Development;

17. State Department of Water Resources, State Water Resources Control Board;

18. Council on Environmental Quality (Federal). In addition, environmental reports are required to be filed with:

1. Atomic Energy Commission (on nuclear plants);

2. State Lands Committee who, in turn, forwards copies of the statement to approximately forty public and private agencies for comments, including the Environmental Protection Agency, Federal Power Commission, and the Department of the Interior's Bureau of Sport Fisheries and Wildlife; and,

3. U.S. Corps of Engineers. It is abundantly clear that before a final permit would be issued for construction of an offshore facility, such as the circulating water conduits mentioned above, which would be included under the provisions of S. 80, a comprehensive review of the possible environmental impact is required by numerous agencies charted with the responsibility of protecting the public interest. Ample opportunity for public participation is provided at various stages of this certification process.

II. EDISON SUPPORTS EFFORTS TO INSURE THAT ALL APPROPRIATE AGENCIES HAVE AN

OPPORTUNITY TO REVIEW ENVIRONMENTAL ASPECTS OF OFFSHORE STRUCTURES

Edison is vitally concerned with any legislation which could compound the complexity and number of studies, public hearings and permit requirements currently associated with the construction of new power plants.

The stated purpose of this Bill, S. 80, is to provide for the protection of the marine environment. It requires certification from the Secretary of the Department in which the National Oceanic and Atmospheric Administration is operating, prior to the construction and operation of any offshore facility, as defined in Section 303(b). Such certification would be in addition to any other requirements imposed by federal, State or local laws, regulations, or ordinances, including but not limited to, the National Environmental Policy Act of 1969 (NEPA).

Although Edison encourages and supports efforts to insure that all appropriate agencies have an opportunity to review the environmental aspects of offshore structures, we believe that the participation of these agencies must be coordinated into one lead agency, such as the Atomic Energy Commission in the case of nuclear generation. This would provide a greater degree of assurance that there would be a reasonable balance between environmental impact considerations and the necessity for an adequate and reliable source of electric energy.

Fragmented reviews of construction permit applications and duplicative certification procedures are not in the total public interest. Thoughtful deliberation of the proposed construction by all interested parties, with final decision by the lead agency, will serve to expedite the decision-making process on an application for construction of an offshore facility without sacrificing essential environmental standards.

III. CONCLUSION We believe that any legislation on the construction and operation of artificial offshore structures must take into account existing permit requirements and not create just one more obstacle in the certification procedures with no appreciable benefit to either the environment or total public interest. The lead agency concept would insure appropriate deliberation of all aspects of the pr

posed construction, e.g., need vis-a-vis environmental impact, and provide for an informed decision. Duplicative certification requirements, including environmental statements, should be avoided.

Thank you for the opportunity to present this statement.

Projectio

Two PROPOSALS FOR MEETING THE NORTHEASTERN U.S. PETROLEUM NEEDS

IN THE COMING DECADE

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(A Statement Prepared On Behalf Of Bayside Pipeline Co.,
by Mathematica, Inc.)

MATHEMATICA, INC.,

March 2, 1973.
Hon. WARREN G. MAGNUSON,
Chairman of the Senate Commerce Committee,
old Senate Office Building,
Washington, D.C.

DEAR SENATOR MAGNUSON : Mathematica is pleased to submit this testimony in the public interest on behalf of our client, Bayside Pipeline Company, relating to Bill S-80.

Our testimony will address the economic and environmental considerations surrounding offshore terminal facilities for Very Large Crude Carriers (VLCC's) and two proposals for meeting Northwestern United States Crude demands in the coming decade. Respectfully sbumitted,

L. D. MAXIM.

C. L. BRAZIE.
PREFACE

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Mathematica, Inc. is a research and consulting firm located in Princeton, New Jersey. The company specializes in systems analysis, economics, operations research and allied areas. The testimony is presented on behalf of our client, Bayside Pipeline Company.

This statement describes two alternatives for supplying the crude oil to the Delaware River and Arthur Kill oil refineries necessary to keep pact with the growing demand for petroleum products in the northeast. The relevance of this statement to Bill S-80 is that both proposals involve the construction and operation of offloading facilities for "supertankers" (i.e., tankers of 200,000 dwt. or more). Our testimony supports the contention that supertankers and associated terminal facilities provide the most economical and least environ. mentally damaging methods for providing the required crude. The central points of our testimony are as follows:

(1) There will be dramatic growth (by a factor of 2-5) in crude oil imports to the Delaware River and Arthur Kill refineries to support Northeastern U.S. energy needs by 1985.

(2) Supertankers and associated terminal facilities are an economically and environmentally sound means of meeting this demand.

(3) The concern of environmental groups that supertanker terminals will present a greater oil spill hazard than existing procedures (lightering) in the Delaware Bay is misplaced.

(4) Bayside Pipeline Company has developed two proposals for meeting Northeastern United States demand in the future. These are:

(A) An offshore mooring and pumping facility to be located 25 miles from the mouth of the Delaware Bay and connected by pipeline to Greenwich Township, New Jersey. Concern over oil spills and induced industrialization has led the State Legislature and Governor Cahill to oppose this plan.

(B) A transshipment facility, located in the Bahamas, to be operational in 1974, that will receive supertankers and transship with smaller tankers which can enter the Delaware Bay. This alternative allows the economies of scale of supertankers without the environmental penalty of lightering. Bayside is currently implementing this plan.

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