Does FERC follow regulations?

Jeffrey from Bethlehem, PA has been asking a lot of questions about the regulations the FERC is supposed to follow in the pipeline approval process, and if they’re being followed properly.

I am a citizen with no training in interstate natural gas transmission line rules and regulations. My knowledge has come through self-education after PennEast made its announcement to build a pipeline that would go through my town in Pennsylvania. I have done my best to understand the PennEast pipeline proposal and to participate in the process. I have asked many questions to PennEast officials, attended the Open House in my county, attended the Scoping Meeting in the neighboring town, and have read as much as I can from PennEast’s filings, its plans, and about the proliferation of natural gas transmission line proposals in PA. Despite this, I do make errors in trying to understand details and procedures that are unfamiliar to me.

I sent two e-comment yesterdays about third-party contractor for the NEPA review for the PennEast proposal. In reviewing FERC’s _Handbook for Using Third-Party Contracts to Prepare Environmental Documents_ (Rev. Dec. 2014), I did find today that it is possible for applicants in certain circumstances to submit fewer than three contractors (this is stated in Section 1-4). I did not realize this was allowable yesterday in my first e-comment.

My one question on this issue is whether such a justification was presented with the PennEast proposal and if more details could be made available to the public about this issue, in general. I think that _The Handbook_ suggests that fewer than three proposals is not usual because the paragraph where this is mentioned starts with a sentence that begins with the phrase, “In the rare instance…”

Thank you for your consideration of my comments. I know that the NEPA report is very important. For me, if it was at all possible, I would want FERC to have had, at least, three third-party proposals to look at for the selection of the contractor.

This is a great question and it dovetails with other questions I’ve seen people asking about the FERC not doing its job properly. This one in particular really gets to the heart of how and why Tetra Tech was chosen to do the Environmental Impact Statement.

This info might be available somewhere on the FERC site, I’ll do some digging to see if I can find it anywhere.

If not, there’s always the Freedom of Information Act (FOIA Website) as a last resort.

Jeffrey’s submission is available below:

Jeffrey’s submission – FERC Generated PDF

Jeffrey’s submission – FERC Generated PDF Alternate Site

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Mike Spille

I'm a thinker, an analyzer, a synthesizer. Maybe not in that order. I live in West Amwell NJ with my wife Kristina, our two kids Day and Z, our two dogs Fern and Cinna, and three cats Ponce de Leon, Oliver, and Doolittle.

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