There’s a famous Bible quote that says “But everyone who hears these words of Mine and does not act on them is like a foolish man who built his house on sand”. PennEast and their longtime friends at Concentric Energy Partners should look it up sometime.
This morning, PennEast delivered a “rebuttal” to the NJ Rate Counsel’s submission on the DEIS. The bulk of this rebuttal is yet another report from Concentric Energy Partners. Why they continue to use Concentric when FERC has rejected all of their reports is beyond me, but we should count ourselves lucky there 🙂
This latest Concentric report contains a huge number of citations as usual. They cite California Energy Board, Pennsylvania PUC, NJ Board of Public Utilities, Massachusetts Department of Public Utilities, and many others. Those citations are made to show that certain information is invaluable to determining whether pipelines are needed or not in a given region. It goes on for pages and pages.
They’re all fine citations in their own right.
The problem is the foundation they are based on.
Specifically, Concentric’s entire argument about “need” for this pipeline is based on this section, page 6:
One benefit that PennEast provides is the opportunity for LDCs and other shippers to replace natural gas supplies purchased in one production area (e.g., the Gulf Coast) with less costly supplies in another production area (e.g., the Marcellus Shale). Shippers on PennEast, including Consolidated Edison, PSEG Power, South Jersey Gas, and UGI Energy Services, specifically cite the opportunity to lower gas costs for customers as a reason for contractually committing to capacity on PennEast.
PennEast shippers have also cited many other reasons for making long-term contractual commitments for this capacity, including:
- (i) reliability (cited by New Jersey Natural Gas and South Jersey Gas);
- (ii) supply and pipeline diversity (cited by Elizabethtown Gas, New Jersey Natural Gas, Texas Eastern, and Consolidated Edison);
- (iii) flexibility (cited by PSEG Power, South Jersey Gas, Texas Eastern, and Consolidated Edison);
- (iv) price stability (cited by New Jersey Natural Gas and South Jersey Gas); and
- (v) expansion opportunities (cited by Elizabethtown Gas and South Jersey Gas). 14
This is all lovely, and on its face it would seem very damaging to those who assert we don’t need this pipeline.
But here’s the problem: These are throw-away assertions from the shippers with NOTHING TO BACK THEM UP.
There are no studies. There are no projections. There are no models cited. There is no analysis of their existing systems. There’s not a damn thing. All there is a bunch of PR spun up by the PennEast owners marketing departments with no facts to back it up.
In fact, we know these assertions are empty because many people have researched this topic in detail (here’s my own):
Analysis of PennEast Purpose and Need in the FERC Draft Environmental Impact Statement
and also especially:
You might notice in particular that the PennEast owners, who are also shippers, state in no uncertain terms in their SEC filings that their existing operations are already resilient, redundant, and sufficiently varied, and that they are highly satisfied that their gas networks are in good shape.
We also note from many areas that rates in NJ have dropped like a stone over the past few years, and we are basically as close to zero as we’re ever likely to get.
And then of course there is also the NJCF study conducted by Skipping Stone:
You remember, the study with actual data behind it.
So don’t be worried about the pages and pages of citations by Concentric. While they’re beautiful in their own right, and I’m sure PennEast page Concentric a ton of money for it, in the end those citations mean nothing if Concentric (and PennEast’s) basic facts are empty, baseless assertions.
Keep building your castle in the sand, PennEast. There’s a storm coming, and you’ll see how just how well that foundation holds up to the N’easter of opponents against you.
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