There are a number of “CAP” organizations (Citizens Against the Pipeline) that have risen up against the PennEast Pipeline since it’s been proposed. One of them is DT-CAP – the Delaware Township chapter. Their submission states:
The Delaware Township Citizens Against the Pipeline, Inc. (DT-CAP) is a New Jersey not-for-profit furthering the following mission:
“To preserve and protect an irreplaceable community rich in farming and historic culture; to prevent the destruction of endangered species’ habitats and fragile watershed ecosystems; to defend our thriving agricultural and recreational economies; to safeguard our citizens’ proactive investment in conserved and preserved farms and woodlands; and to oppose PennEast pipeline as it will irrevocably impact the safety and integrity of our human environment.”
Our constituents include numerous property owners located within the path of the proposed pipeline route identified in PennEast’s January 13, 2015 Notice of Intent to Prepare an Environmental Impact Statement for the Planned PennEast Pipeline Project, Request for Comments on Environmental Issues, and Notice of Public Scoping Meetings (NOI). Additionally, our constituents include numerous property owners located within the path of the preferred alternative route, submitted to FERC on January 16, 2015. Members of DT-CAP participated in the open meetings conducted by PennEast in Delaware Township on September 29, 2014 and at South Hunterdon High School on November 13, 2014, and have attended additional public meetings and requested further information directly from PennEast regarding this application. Accordingly, DT-CAP is an interested party in this matter and direct notification to DT-CAP is required.
First, please be advised that DT-CAP does not support either the “preferred alternative route” or the proposed original route due to the detrimental impacts both routes will cause to the environment, watershed, local economies, homeowner property rights, and taxpayer investments in the preserved and conserved lands of Delaware Township. DT-CAP opposes any additional natural gas pipelines in Delaware Township.
PennEast has not identified how the pipeline would be located with respect to the existing utility easement within Delaware Township. It is DT-CAP’s understanding that “co-location” is misleading in that the existing electrical utility easement must be widened, and in some locations, the pipeline may be near and not within the existing easement for power lines. Additionally, the existing above-ground utility within this easement is maintained in a different manner than is required for underground pipelines, and does not currently have the subsurface impacts which would occur when locating a pipeline. Therefore, co-location is inadequate to reduce negative environmental impacts. Additionally, the widening or nearby location of the pipeline as well as temporary constructions areas will impact lands currently not utilized for utility easements, and will have negative impacts on groundwater quality, farmland, and numerous additional resource values within Delaware Township. Additionally, the proposed alternative route requires the taking of property rights from property owners not in support of this project.
Second, the location, timing, and number of scoping meetings are inadequate and inconsistent with FERC regulations for the EIS scoping process.
The proposed alternative route has been submitted to FERC on January 15, 2015, only 12 days prior to the one and only scoping meeting to be held in New Jersey and only 28 days prior to the deadline for written comment as stated in the NOI. The January 27, 2015 New Jersey scoping meeting is not situated within the project area. And the announcement for the scoping meeting identifies the original route, with no reference to the proposed alternative route. Landowners and interested parties have not been provided adequate time to evaluate the proposed alternative route. The NOI must be re-issued to identify the proposed route and to provide further opportunity for public input. The coping period must be significantly extended with additional meetings scheduled, including meetings within the project area, and including at least one meeting scheduled in Hunterdon County, New Jersey.
DT-CAP and its members are prejudiced by PennEast’s failure to engage in a meaningful opportunity for discussion. PennEast submitted the proposed alternative route after announcing its intent to conduct scoping. PennEast provided inadequate time for scoping and inadequate advance notice of scoping meetings. And PennEast is engaging in scoping without identifying whether there are known safety and engineering constraints which would necessitate a widening of the existing utility easement, which is narrower in Delaware Township than it is in other affected municipalities. These errors cause material prejudice to those interested parties seeking to provide meaningful input during the scoping process.
Their submission is below: