Please, if you haven’t already begun, please start commenting on the DEIS. See here for more details:
Just spend 5 minutes looking at the DEIS on your computer and I guarantee you will find something wrong.
Here’s comments on two winners I found today during lunch. Take some time out during lunch, or a break period, or while your kids are watching Teen Titans or whatever. Take ten minutes, find a DEIS error and send it in.
And if you’re at a loss, feel free to re-use these comments or any others that you agree with.
Unacceptable notice periods to farmers
I am writing on behalf of HALT PennEast on the PennEast Draft EIS, docket CP15-558. HALT PennEast is an intervenor in this proceeding, and has a number of concerns about impacts to landowners if this project is approved.
On page D-2, “Agricultural Impact Minimization Plan”, Section 1.3 on Communication states:
“Prior to construction, PennEast will provide landowners and tenant farmers of active agricultural lands with as much advance notice as possible, but not less than 24 hours prior to entry”.
A 24 hour minimum notice period for construction is completely and totally unacceptable for personal and commercial agricultural lands. Planned routine construction activities should have no less than 90 days prior notice for agricultural areas to allow farmers to plan their crops and land use appropriately , and a minimum of 10 days notice for unforeseen occurrences.
This completely unacceptable notice period demonstrates that this DEIS is severely underestimating impacts of this proposed project to the region and is not a realistic estimate in any way, shape, or form. This DEIS should be withdrawn until such time as it is reasonably complete, accurate, and realistic.
Inaccurate Distribution List
I am commenting on the Draft EIS (DEIS) on behalf of HALT PennEast and West Amwell Citizens Against the Pipeline. Both are intervenors on this docket CP15-558.
Appendix A of the DEIS is supposed to contain the distribution list of agencies, organizations, individuals, and intervenors in this matter. However, a cursory review shows many of the parties who should be on this list as missing or incorrectly named.
For example, both West Amwell Citizens Against the Pipeline and Home Owners Against Land Taking: Penneast (HALT PennEast) are missing from this list, and other names are captured incorrectly.
This means that a number of organizations and individuals who were supposed to receive notice of the DEIS in fact may not have been notified. This is a violation of due process rights.
FERC and Tetra Tech must revisit this list in its entirety and ensure it’s accurate and complete. In addition, given the errors and omissions it must extend its comment period to allow missed organizations or individuals a minimum 45 days of time to review and comment on the DEIS from the time when they are actually notified by FERC.