DEIS Commenting

The whole region is buzzing with the news that the PennEast DEIS is out.  The issuance of the Draft Environmental Impact Statement is a critical moment in the project timeline.  Not just for PennEast, but for us as well.  The 45-day comment period on the DEIS forms the technical legal record and is the basis for any objections against FERC or the project if the worst happens.

So it is really, really, really important that we get as many people commenting on this as we can.

We are gearing up seminars across the region to teach people how to comment technically on the docket, and educate them on potential topics to talk about.  The seminars are being held at the following times and locations:

DEIS Comment Workshops                 

Tuesday, August 2, 7-9 pm
Prallsville Mills
33 Risler St, Stockton, NJ

Tuesday, August 2nd, 6:30 PM-8:30PM
Towamensing Fire Dept.,  
State Rte. 209 (near the Intersection of Trachsville Hill Rd.)
Towamensing Twp, PA

Thursday, August 4, 6:30-9 pm*
The Holland Township Municipal Building
61 Church Rd., Milford, NJ

Monday, August 15, 7-9 pm*
Stony Brook-Millstone Watershed Association
31 Titus Mill Rd., Hopewell, NJ

Workshop Agenda

The agenda for all these workshops are identical and simple.  The overarching purpose is to help people exercise their rights and learn how to physically comment on the docket, to teach people how to comment effectively, and to provide some sample topics to speak to.

To that end, this will be a hands on workshop.  Bring your Laptop/Tablet with you!  We will be showing people how to comment on the docket electronically, live and in color. We will walk individuals through the commenting process, now to login to FERC, post eComments and how to post larger documents.

If you don’t have a computer, don’t panic!  We have plenty, and you can use ours to get your comments in.

We will have wi-fi.  So don’t worry about that either.

So the agenda will be simple:

  • Description and live demo of how to comment
  • Brief discussion of major categories to consider commenting on
  • Go write your comments!

You say you already know how to comment to FERC?

Have you been doing this PennEast thing for well-nigh two years now?  Can you navigate the FERC site in your sleep (and have nightmares of doing exactly that?).  Have you memorized “CP15-558”?  Then feel free to dive right in and comment.

You can get the DEIS files at http://pipeinfo.org if you haven’t done so already.  It’s 20x faster than FERC and it has yet to go down, ever.

Some tips on commenting:

  • Identify yourself and your interest to FERC right at the top. The format I use is:
    My name is XXXX, I am a [Intervenor][and Impacted Landowner][Concerned resident] regarding docket CP15-558-000 for the PennEast Pipeline.  I live in the town of [Town, State].   I am commenting on the PennEast Draft Environmental Impact Statement (DEIS).

    In other words – if you an intervenor or impacted landowner, say so.  It raises your status up.  And also be CRYSTAL CLEAR that you’re commenting on the DEIS.

    Here’s a sample:

    My name is Mike Spille, I am an intervenor and impacted landowner regarding docket CP15-558 for the PennEast pipeline.  I live in the town of West Amwell, NJ.  I am commenting on the PennEast Draft Environmental Impact Statement.

    The “No-Action” alternative in the DEIS is overly narrow, has no citations of fact, and does not conform to NEPA regulations and precedents.  In fact, the No-Action alternative is a bare four paragraphs in length.  The only “fact” referenced is the existence and names of the shippers on the project. And no other facts or citations are offered to back up any of the assertions there in.

    In fact the No-Action alternative is nothing but empty rhetoric. This does not constitute the “hard look” that NEPA calls for.  This is empty boilerplate with no substance.  This DEIS should be withdrawn by FERC, and not offered again until it actually satisfies NEPA and truly takes a “hard look” at all aspects of the project, including the No-Action Alternative.

  • Try to keep one major overarching topic per submission.  In the past FERC and PennEast have taken people’s lengthy submissions covering many topics, and ignored half of them.  Don’t let that happen to you!  Pick a topic (safety, water, what have you) and stick to just that topic for your submission.  Then make another one.  And another one.
  • If you get stuck in writing, don’t sweat it.  We all get writers block.  But the good news is that we’re not writing a best selling novel.  We’re writing stuff for bureaucrats to read.  So they won’t mind if you’re not the next Steven King.

    On tip if you’re stuck: bullet points.  Just put out bullets of the major points you want to make.  If you can’t get past the bullets, then just submit those.  But you’ll be surprised – many times the act of putting bullets down in writing gets the juices flowing and you’ll find that stress melting away and a natural way forward.

Comment topics

If it helps, here are the major sticking points for me in regards to the DEIS and the PennEast proposal as a whole.  These aren’t definitive by a long shot – these are just the things I see as obvious candidates for comments.

  • The DEIS is incomplete and it is unfair to put it before citizens in such a state
  • The comment period is too short, especially during summer vacation seasons
  • FERC outages exacerbate the short comment period!
  • There is no demonstrated public need for this project.  Numerous studies show this project is being undertaken for the private gain of 6 companies and not for the good of the people of NJ and Eastern PA.
  • The DEIS indicates a 2017-inservice date when PennEast themselves have admitted they cannot be inservice before 2018.
  • 70% of impacted landowners in NJ have refused all attempts at surveying their land.  This implies 70% of the land or more in NJ will have to be seized via eminent domain.  70% eminent domain is an atrocious figure that should be appalling to any agency, and doubly so given the demonstrated lack of public need
  • Direct economic tourism impact on Lambertville/Frenctown/Millford and other towns not being considered adequately
  • Indirect tourism impacts (hikers, bikers, equestrians, etc) also not considered adequately, including major areas such as Appalachian Trail, Baldpate, Lehigh River, Delaware River, etc. not considered adequately
  • Impact on conservation programs (who will preserve land if companies like PennEast can take it?) not addressed by DEIS
  • Traffic considerations during construction (school bus routes, small roads and bridges, few alternative road choices) not addressed properly in DEIS
  • Personal impacts!  Their house, their farm, their business, their families, their lives
  • Impacts to local features near them (Baldpate, Goat Hill, Gravel Hill, Alexuaken Creek Preserve, Copper Creek Preserve, Delaware River, Swan Creek Reservoir, on and on…)
  • Drinking water,  wells, septic.  Drinking water,  wells, septic.  Drinking water,  wells, septic.  Drinking water,  wells, septic.  Drinking water,  wells, septic.   (you get the idea)
  • Concerns about Arsenic and Radon not addressed in DEIS
  • Trenching through people’s driveways, farm access roads not addressed in DEIS
  • Deliberate nearness of proposed route to homes, route no adequately defended in DEIS
  • Deliberately ignoring NJ safety rules in favor of inadequate Federal standards – we get a pipe that has a 50% smaller safety margin then we would otherwise have
  • Major studies controverting PennEast studies are not mentioned in the DEIS (Delaware Riverkeeper Network, NJCF/Stony Brook Millstone WaterShed Association, West Amwell Citizens Against the Pipeline, Skipping Stone, Labyrinth Consulting and others).
  • The Tetra Tech employees researching the DEIS are under qualified and the DEIS is obviously not done competently
  • Cumulative impacts are not properly considered (Southern Reliability Link, Garden State Expansion, BL England conversion, Blue Mountain resort Expansion, Marc II Pipeline, future Spectra plans
  • The “No Action” Alternative is incomplete, has no citations or facts, and does not conform to NEPA.
  • The other Systemic Alternatives are incomplete, have no citations of fact, and do not conform to NEPA
  • No market studies were included in the DEIS, only the existence of shippers (the infamous Concentric “you could have saved $890 million if we had a time machine” report is not mentioned anywhere in the DEIS).

There now.  That should get you started.

Go to it!

 

Published by

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 two cats Ponce de Leon and Xavier.

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