This a comment filed today from West Amwell Citizens Against the Pipeline. It talks about FERC improperly accepting PennEast’s marketing language about “collocation” (hint: it’s not), talks about the realities of the real route and how greenfield it actually is.
And finally goes on to point out that PennEast partners are already contemplating expanding the line. So if PennEast is built, we should look forward to years and years of additional pipelines, looping projects like the Leidy Line Southeast Expansion, Compressor station upgrades and all the rest.
This is not “collocation”. This is a brand new natural gas super-highway being contemplated that will start out as 4-lanes of hell and then be upgraded to 12 lanes or more in coming years. All through the most pristine portion of New Jersey and PA you could imagine.
September 8, 2016
Honorable Norman Bay, Chair
Federal Energy Regulatory Commission
888 First Street, NE
Washington, DC 20426
Re: Docket CP15-558-000 – Proposed PennEast Pipeline Project
Dear Chairman Bay, FERC Commissioners and FERC staff,
I am commenting on the PennEast Draft Environmental Impact Statement (DEIS) on behalf of West Amwell Citizens Against the Pipeline (WACAP), which is an intervenor in this matter.
The DEIS states in section 2.2.1, page 2-4:
Where feasible, the pipeline was collocated with existing easements and rights-of-way (e.g., roads and utility lines). About 44.3 miles (26.8 miles in Pennsylvania and 17.5 miles in New Jersey), or about 37 percent, of the 115.1-mile-long pipeline route would be constructed adjacent to existing rights-of-way.
This language is vague and mis-leading and does not convey the actual characteristics of PennEast’s preferred route. Further, this is not written as a neutral agency evaluating a project in good faith. Rather, it appears that FERC is furthering PennEast’s own marketing statements and position.
WACAP believes a more accurate description of the route would be:
This is a greenfield route, the majority of which, about 63%, is not collocated with any existing easements or rights-of-way. In addition, a significant percentage of the areas where collocation is achieved occurs outside of existing uses of the easement. So the actual environmental impact is far greater than a 37% collocation would normally indicate.
In other words, the route is green field, is not predominantly collocated, and there are problems in many areas where collocation is achieved.
Specifically, there are many areas where PennEast is technically all or partially within a utility easement, but the proposed construction and final ROW are wholly outside of the portion of the easement that is actually used by the utility. For example, on Baldpate Mountain (a highly sensitive ecological environment), a very wide utility ROW exists on the order of 275’ wide. However, the existing maintained “cut” for the power lines is only 100’-125’ wide. PennEast will be wholly outside of the existing cut. So while this is technically colocation within an easement, it is not colocation in terms of environmental impact. The construction and on-going operation will be effectively in a greenfield area.
The same is true of the entire route through West Amwell Township. PennEast’s ROW is a minimum of 90’ away from the high voltage power lines, and thus the existing power line cut will be doubled or more.
The EIS must be changed to reflect the reality of the route. This is not a seemingly benign, collocated route with minimal damage to the environment. This is a greenfield, brand-new route through our region.
Further, the DEIS fails to consider future development that may occur if this greenfield route is approved. All impacts are assumed to be limited to those of PennEast, and no follow-on projects. However, experience has demonstrated that once a route is established, other pipelines, looping projects such as the Leidy Line Southeast Expansion, etc inevitably follow. The DEIS must include this factor in its determinations. This is a new major natural gas utility corridor that is being contemplated, and the DEIS should reflect that.
This is also not a theoretical exercise. One of PennEast’s owners, South Jersey Industries, have already indicated that they are contemplating expansion to the line. During the SJI Q1 2016 Earnings Call with analysts, SJI CEO and President Michael Renna stated:
“First, yes, we do have a business development group that reports up through Greg Nuzzo, so we’re evaluating different opportunities in the space. I think that there are opportunities for expansion of PennEast potentially down the road, as well. So I’m very bullish on the opportunities that we have in front of us.”
This is a 20% owner of PennEast stating on the record that they are contemplating expansion of PennEast even before the initial construction has been approved. Given that one of PennEast’s owners has publicly stated that they are already considering expansions to PennEast, the DEIS must consider this impact in the DEIS.
Just because the PennEast owners are structuring their construction in stages does not mean that the environmental impacts can be segmented. PennEast’s intentions here are quite clear. They are attempting to open up a new major natural gas pipeline route that will be expanded many times in coming years, just as other pipelines are expanded. The DEIS must take this into account when considering the impact to our region.