The Jordan Cove proposal - an LNG terminal in Coos Bay, with a 223-mile pipeline to carry the gas inland - is presented as being essential to meet current and future energy needs in Washington, Oregon, California, Nevada and Arizona. Important questions come to mind:

• Where within those five states are there now serious energy shortages, and where are future shortages projected to develop or worsen?

• What role is LNG expected to play? If energy shortages exist or are projected, several strategies to deal with the problem are available. Existing energy distribution systems might be changed or updated, conservation measures could be implemented, or wind and solar energy capacity might be added. Has a regionwide analysis shown a need for LNG if such measures were implemented? If so, how much, and where exactly, would LNG augmentation be required?

• If LNG is needed to augment the regional energy supply, we need to ask how best to supply and integrate it. LNG is a mobile resource from worldwide sources that could technically use any number of West Coast ports. Which ports, together with attendant pipeline systems, would provide the most economically viable and environmentally benign entries into the existing energy grid?

The good news is that there is machinery designed to answer those questions in a manner that is understandable to the general public. That machinery is described in the federal National Environmental Policy Act's regulations.

The bad news is that the Federal Energy Regulatory Commission, the lead federal agency handling the Jordan Cove LNG permitting process, has apparently chosen not to follow these regulations.

The plethora of multi-volume thousand-page documents notwithstanding, the basic concept of an environmental impact statement is really quite simple and logical.

The lead federal agency (FERC in this case) has to identify and describe the need that calls for some action; identify all reasonable alternative actions that could meet the need; describe the direct, indirect and cumulative environmental impacts of each alternative; identify which alternative is environmentally preferable; and select an alternative to implement. Nothing in the regulations requires the agency to select the environmentally preferable alternative, provided that the final decision is not arbitrary and capricious given the data contained in the EIS.

Yet at a recent meeting in North Bend to discuss the upcoming EIS, Paul Friedman, project manager for FERC, was quoted as saying the proposed LNG terminal ``is located here because this is where the proponents chose to locate it,'' and, ``We don't look at the application in terms of need.''

What Friedman is saying is that FERC intends to issue, by design, a document that is inadequate, misleading and flies in the face of existing rules and regulations.

Instead of a rational discussion of need, and an objective and systematic analysis of various alternative ways to meet that need, FERC is apparently willing to accept the wishes of a private company as a fait accompli. The agency appears to be preparing to dummy up a document that will masquerade as meeting the letter of the National Environmental Policy Act while being diametrically opposed to the spirit and intent of the act.

An environmental impact statement on the Jordan Cove LNG proposal is simply premature at this time. It is clear that what is really needed is not a Jordan Cove EIS, but rather a programmatic EIS discussing the role of LNG in the entire multistate region and directly addressing the three questions posed above. Only then would we, and FERC, be in position to objectively evaluate the merits of the Jordan Cove proposal.

From a larger perspective, there are similar site-specific impact statements that have been or are being prepared for several other proposed LNG terminals in California and at the mouth of the Columbia River. If these other projects all take the narrow view and are the result of private industry proposals without comprehensive federal overview and regional coordination, this is decision-making at its most absurd.

We are being hoodwinked, and rather badly at that. We deserve better. We should demand that a programmatic EIS be prepared and processed before any site specific permits are issued.

Ron Sadler of North Bend retired after 33 years with the Bureau of Land Management, where he managed the preparation of numerous environmental impact statements. He has acted as an expert witness in federal court on matters related to the National Environmental Policy Act.