Last Friday, May 1, 2020, PennEast filed a response to FERC’s April 1, 2020 Data Request on docket CP20-47-000.

As you might expect, while reading the response the image of the Keystone Kops tripping over themselves in pursuit of a villain came to mind.

The request was pretty simple, so I thought PennEast had a shot to get it at least mostly right.  What FERC said was that the abbreviated filing on this docket talked only about the Certificated Route on CP15-558, but didn’t include emissions information for the 4 PA Route changes on their amended Certificate from 2019.  OK – so submit new tables for those four changes, and they’re done – easy peasy lemon squeezy.

But no – of course not.  The response is muddled, confusing, inaccurate, contradictory with both itself and with other responses, and is riddled with errors.  I filed a Motion to the docket trying to describe all the issues (and as it is, I probably missed some – it’s that bad).

My submission is here:

MichaelSpille-CP20-47-MotionToAnswerAndAnswer-6.PDF

Here are some of the issues:

1. PennEast starts out  on the wrong foot.  Rather than saying they were responding to the request to include data on the CP19-78 2019 changes, they go into a torturous description of how they got there.  The end result is you have no idea what exact data they are supplying – will it be the original route from 2018?  The 2019 one?  A jumble of those plus the current amendment application?  Who knows!
2. PennEast botches nearly all of their table references.  Most of the tables say things like “Table Error! No text of specified style in document-5.2 Revised Conformity Determination”.  Yeah, no one proofed the damn thing and it’s filled with technical errors.  Some tables aren’t referred to at all and just sit out there, lonely and confused.
3. PennEast adds in data about Phase 2.  Even though it wasn’t asked for, PennEast supplied it anyway – a whole bunch of theoretical impacts from Phase 2.  And of course, a bunch of it is wrong.  For one, the construction pollutant numbers are not consistent with those of Phase 1.  Argh!
4. PennEast leaves out a bunch of tables because “hey, we don’t think they changed”.  Um…..
5. PennEast quietly takes out the Columbia-TCO connection at Hellertown.  Without fan fare, warning, or otherwise saying what they’re doing, they quietly indicate that the Columbia-TCO connection has moved to Church Road.  This changes the Purpose and Need of Phase 2 entirely, making Phase 2 look even less beneficial than it was.  This information is buried in a footnote despite being a major change.
6. The Operational Emissions tables are filled with errors!  Tons of them.  Anywhere they couldn’t copy and paste from the Final EIS or the abbreviated filing, they muffed the calculations.  They double count stuff, they get the number of compressors wrong, they get basic math wrong, and fugitive emissions and venting seem to be basically random!
7. They get docket references wrong.  FERC 101 and they flubbed it.
8. They don’t understand their own changes at the Kidder Compressor Station, so they fake it.  Yes.

In all, this Response is astounding.  It is clear that PennEast rushed this out the door to meet deadlines, and sacrificed any sort of accuracy for speed.  And why?  It ain’t like they’re going anywhere anytime soon.