The new docket number is CP15-558.

I urge everyone who opposes this pipeline to declare to FERC that they wish to be an intervenor. The stoppenneast.org site and Facebook page will have in-depth instructions on how to do that.

In a nutshell, declaring that you are an intervenor reserves several rights for yourself, including being notified of all documents delivered in relation to the project, and also the right to be part of any legal proceedings (or bring them yourself). There is no real downside to being an intervenor.

You have about 3 weeks to declare yourself as a “timely” intervenor. If you file within that time period you’re pretty much guaranteed in. If you file as an intervenor late it’s much more involved and you can be denied by FERC. So get it in early! There are already dozens of intervenors declared (myself included).

The full application link is at the end of this post.  I urge everyone to go through it with a fine tooth comb.  I have just started, and I can tell you that the application is just terrible.  The scoping documents were sloppy, missing information, misleading and plain wrong in many cases.  The same is true of the application.  In the first ten minutes of looking I found that in one area they mislabelled Goat Hill Road as George Washington Road and confused the Delaware River with the Hudson River.

I wouldn’t trust these people to put together a kid’s bike, let alone a 100 mile long high pressure natural gas super highway.

Intervenor Declaration Quick Reference

For those who are FERC-savvy, the process is the usual FERC rigamarole. You must be eRegistered with FERC. Once you are, you need to do:

Get to Doc-less intervenor Page

Login -> eFiling -> General -> Intervention -> doc-less Motion to Intervene -> Next

Fine the docket

From there you:

Enter Docket CP15-558 -> Hit Search Button -> Select Blue Cross -> Next

Text declaring your wish to be an intervenor

The next screen is where you put in your declaration to intervene.  It can be as simple as saying:

“I reside in a township impacted by the PennEast pipeline and have a number of concerns related to the project.  As such I wish to declare myself as an intervenor”.

You can add as little or as much as you like, but you don’t need to put your whole opposition to the pipeline here.  If you you’re a directly impacted landowner or an abutter you should say so.  If you have other concerns you want made known in your declaration add them as well.

Remember this is just a declaration to intervene, you can eFile later on with all of your specific objections.

After that hit Next.

Specify organization or business

Select “As an Individual” -> Next button

Contact Info

Write in your email -> Add As Signer Button -> Next button

Submission Description

Just hit Next Button

Last Page

This is a summary page.  Hit “Submit” button and your motion will be submitted.  If you did this within the 21 day limit you’ll be an intervenor.  You will get an email shortly as receipt of your filing.

After this you can continue to eFile and make your case against the pipeline at your leisure.

Next Steps

For convenient reference, here’s the full application along with resource reports and appendices. I’ll be putting a perma link on the menu bar when I get the chance.

http://elibrary.ferc.gov/idmws/file_list.asp?document_id=14380457

An important aspect of natural gas pipelines is the Potential Impact Radius, or PIR.  This is defined as:

“Potential impact radius (PIR) means the radius of a circle within which the potential failure of a pipeline could have significant impact on people or property”.

What does significant mean here?  Well the actual definition is based on survivability:

“PIR is the distance beyond which a person standing outside in the vicinity of a pipeline rupture and fire would have a 99% chance of surviving”

The formula for PIR is pretty simple – it’s based on pipeline diameter and pressure:

PIR = 0.69 * (maop * d^2)^0.5

(here the “^” symbol means “raised to the power of).  In English this is:

To determine PIR, start with diameter of the pipeline squared, times the maximum allowable operating pressure.  Raise that the power of 0.5, multiply the result by 0.69, and there you go.

For the PennEast pipeline maop = 1480, and diameter = 36″.

This results in a PIR of 955. This means if the pipeline breaches at point X, everyone in a circle of 955′ radius (radius, not diameter!) of the pipeline will have less than 99% of surviving e.g. could die.  Note that the we’re talking about an exponential equation, so it means as you get closer to the pipeline you have an exponentially worse chance of surviving.  In the case of PennEast, at 500′ you would have little effective chance of surviving.

Fun fact: the model assumes no whether or geographical conditions, just a perfectly flat surface with no wind or other weather conditions.  Wind and topography can have a major impact and means damage can occur significantly beyond the official PIR. See the top picture for the potential differences between PIR and actual impact radius.

Some fun facts:

My house is 180′ from the proposed route pipeline centerline.  So me and my family are toast.

Hewitt Park – 800′ from center line.

Hunterdon County Library Southern Branch – 725′ from center line.

West Amwell Elementary – 1750′.  So they’re good so long as the wind is not blowing to the North East that day.

Lowes Shopping Center in PA, near Lehigh River: the whole shopping center plus Route 33 falls within 900′.

When you talk to people who have experience with FERC and past pipeline battles, they’ll often tell you about problems with the FERC process and attitude. You’ll hear about boilerplate cut and paste language in evaluations. You’ll hear about timelines created to help the pipeline in the ground faster. For the environment…well, forget it, we’ll get the environmental impact analysis in sometime later. You hear that FERC will bend over backwards to help companies get their gas flowing as fast as they can.

We’re seeing this now, live and in color, with FERC and PennEast. Those of us watching the docket and reading the meeting minutes between PennEast, FERC, Tetra Tech, and NJDEP and other agencies are seeing the broken process unfolding before our eyes.

The good news is that have allies in this process, and FERC is seeing many monkey wrenches thrown into the works they have never had to worry about before. FERC may have gotten away with this in the past, but the times, they are a’changing, and together we’re going to make them change.

First, some background in the latest issues. PennEast has met with the NJDEP on several occasions in the months of July and August to discuss the project. Many issues came out of those meetings, which were documented in meeting notes filed to the FERC docket for PennEast. There were, in fact, so many substantial issues that the citizens’ groups organized against the pipeline in New Jersey got together and drafted a letter detailing those concerns (I’m proud to say that I was able to pitch and help with that effort). We sent it off a few weeks ago and are looking to meet with the NJDEP in person to discuss all of our concerns and see what we can do to help them. I’ll be covering more of that in coming weeks, but suffice to say that we’re seeking to work closely with the NJDEP to ensure our environmental safe guards are honored. And meanwhile, let’s all cheer them on for all of their efforts to date.

More recently, the NJDEP meetings between PennEast and FERC were discussed in a meeting between FERC, PennEast, and the firm contracted to perform the Environmental Impacte Statement (EIS) on the project, Tetra Tech. The full meeting minutes are available here:

http://elibrary.ferc.gov/idmws/common/opennat.asp?fileID=13988551

The purpose of this meeting was to discuss when PennEast plans to formally file with the FERC, and issues that need to be corrected before they file, and issues that are still up in the air or may have significant impacts to them. A number of pieces of these meeting notes caught my eye, including the ones listed below. These are verbatim from the meeting minutes:

• Survey status
  • Access to New Jersey parcels continues to be a problem; however, survey status is above 50% for wetlands, cultural, and RTE species
• Project Schedule
  • Expect to submit application in mid-September, may slip from September 18th filing
  • Expect to receive Certificate in August 2016
• NJDEP and Green Acres
  • PennEast has conducted several meetings with NJDEP to discuss process and review route
  • NJDEP doesn’t appear to understand the FERC process; have requested opportunity to review RRs prior to 7(c) application
  • Medha proposed conducting a separate meeting with NJDEP to try (again) to explain process and differentiate between EA and EIS
  • Certificate will be conditional on surveys being completed
• Concerned about timeline with regards to Green Acres review which can take 12-18 months and requires township participation
  • 100 percent of municipalities in New Jersey are being uncooperative.  PennEast stressed willingness to compensate and mitigate for impacts to Green Acres parcels

What’s going on here is that FERC does not, as a general rule, follow its own regulations properly. They are charged under the National Environmental Policy Act (NEPA) with thoroughly evaluating any project that will have a significant impact to the environment. For large projects like PennEast they have to create what’s called an Environmental Impact Statement (EIS). This quantifies and clearly states all of the impacts the project will have on the environment, both temporary from construction and permanent ones from subsequent operation. The project also has to justify it’s Purpose and Need – it has to state how this project will benefit the people of the United States.

Under NEPA, FERC has to then weigh the project justification against the environmental impact, and evaluate whether the impact is worth the benefits.

That’s what FERC is charged to do under the law. Unfortunately, they appear to take a number of short cuts along the way, and we’re seeing that live right now with PennEast.

First, they are required to create a full EIS, and study the area and its issues as deeply as possible e.g. determine the true impact. They often do not do that. FERC allows companies to file incomplete EIS’, and FERC accepts them. To make this technically legal they make finishing the surveys and EIS a condition of their approval – they have to finish their surveys and reports before the company can begin construction.

However, this is all just boilerplate. Once FERC approves a project, no one seems to check the EIS later to see if it’s really complete, and the surveys are meaningless because no one evaluates them. This takes NEPA from being a critical tool for evaluating environmental impact to being just a lot of paperwork that has to be filed.

Second, they sometimes allow the company to go into projects almost blind. They are supposed to physically survey, on the ground and in person, a substantial majority of the route. However they often approve of projects that are missing large amounts of surveys. These surveys are usually missing because property owners who are affected refuse the company access to their land. Here again they use loop holes to circumvent the intent of the regulations. In these cases they grant approval, which gives the company eminent domain powers. They can then condemn the properties and have free reign to survey them at all, and the property owners cannot object.

However, these surveys are again just paperwork. The route at approval time is fixed. If they find something significant from the surveys they can’t change the route. And often disaster happens as a result. This has happened on past projects, where mitigation of environmental impact failed because the companies had insufficient survey data, and they couldn’t change the route once eminent domain was granted and they found out what was really there.

Looping back to the meeting minutes – PennEast, Tetra Tech, and FERC are all complaining that NJDEP is stubbornly insisting on enforcing regulations both at the NJ state level, and also on the federal level as stewards of the Clean Water Act in New Jersey, and as part of the FERC process. NJDEP is resisting the “short-circuiting” of the process that FERC does as a matter of course in their business. And FERC is stating bluntly that they’ll allow an incomplete application and just make surveying a condition of their approval (which as I indicated is empty and meaningless).

Yet another issue is timing. Energy companies are always rushing to get these projects approved because they want first-mover advantage in the market and delays cost them a great deal of money. And FERC supports this rushing. The problem with that is that the regularly miss very serious environmental and other issues and cause far more damage in real life once construction begins than their studies indicate. Here PennEast is claiming that they will formally file in late September 2015 – and get approval from FERC in August 2016. This means PennEast is pushing to get approval in a bare 11 months. This is an incredibly short time for an EIS of a 100+ mile long project along a green fields route. And here again they are complaining that Green Acres evaluations alone can take 12-18 months – and require township cooperation. As you probably know 100% of the impacted towns in NJ have passed resolutions against PennEast. PennEast is asking FERC to help them work around these regulations so they can get their pipe in the ground as quickly as possible.

All of this are gross violations of the letter and spirit of NEPA, and an horrible abuse of eminent domain. NEPA is supposed to be used to fully define a project’s true impact before eminent domain is ever granted. Eminent domain should never be granted without full knowledge of what’s being attempted and what harms it will create. Yet FERC routinely does exactly this.

But things don’t have to be this way, and we intend to change it.  FERC has acknowledged that the landscape has changed in the past few years, and they need to change with it.  Court cases are being won against them and precedents are being set.  And the opposition against PennEast has been both powerful and effective.

Looking forward – the opposition to PennEast are putting out letters for the NJDEP and other organizations. Get copies as they come out, sign them, and forward them to the NJDEP to show your support for their stance and actions.

And Write your legislators. They need to hear our voices in unison. Tell them about the meeting minutes and how FERC is trying to subvert NEPA right out in the open for everyone to see.

As PennEast is close to officially filing their application, now is the time to turn up the heat even higher and let them know we’re watching, we’re taking action, and we won’t let up for an instant.

True Safety Standards

In its regulatory filings PennEast has indicated that they’ll be following the minimum federal standards for pipeline construction, and they even have thrown in a couple of bones to make the pipeline even safer: they’ve pledged to put in slightly safer pipe in rural areas, and to also inspect every weld they do. Which is above and beyond the federal regulations (and says a lot about those regulations I might add).

According to their web site, PennEast says “[we] will incorporate the best safety practices from construction through operation…Safety is PennEast’s highest priority when designing pipelines. PennEast is adopting design features and operating practices that meet or exceed stringent industry and regulatory standards”.

As it turns out, that’s not really true. At least not in the state of New Jersey.

In NJ, the Board of Public Utilities has done extensive analysis of Federal pipeline safety standards, and have found them to be lacking. As a result they have enacted far stricter guidelines in order to help guarantee that we have far safer pipelines than what the federal government allows. I’ll be detailing those guidelines and the reaction of industry below, but before I do there’s one more thing you ought to know.

PSEG, Elizabethtown Gas, NJ Natural Gas, and South Jersey Gas have all enthusiastically embraced these stricter guidelines as a huge step forward in ensuring public safety. They’ve applauded the BPU for enacting such great legislation.  The guidelines require all pipeline be built to Class 4 specifications regardless of population density, require 4′ as the minimum depth of cover, and require stringent oversight of workers.

And, as the majority owners in PennEast Pipeline LLC, they won’t be following any of the rules, ’cause, ya know, federal guidelines supercede state ones in interstate pipeline projects.

Please, write to all four companies and tell them that you’re going to hold them to the NJ standards they have pledged themselves too, and that, in the unfortunate event that this pipeline gets built, they will pledge to use these regulations to govern installation along the entire 100+ mile route.

The remainder of this post is my FERC comment on this topic, and includes some real eye-openers (they certainly were to me!).

FERC Filing

After studying PennEast’s filings, I believe there is far more that PennEast could do to ensure the safety of the community in regards to this pipeline.

The New Jersey Board of Public utilities has done a thorough analysis of Federal Law in the matter of pipeline safety, and has determined that the federal statutes do not provide an adequate level of safety for the public. As a result they have enacted far more stringent rules in the state.

The NJ regulations state in part:

” The State system for designing pipelines based on the class location in relation to population density, found at N.J.A.C. 14:7-1.3, requires all pipelines installed after the effective date of the proposed amendments to be designed to Class 4 pipeline location standards, the highest standard for similar pipelines designed under the Federal classification system at 49 CFR 192.5. This may result in some costs for pipeline operators, although most have voluntarily chosen to meet higher standards than Federally required. To the extent that costs are incurred, the Board has determined that these costs are justified in order to ensure safety”.

In this section the Board of Utilities has ruled that the class location system is not adequate, and mandates that Class 4 pipeline be used in all locations as of this time.

The statutes continue onto the depth of cover of pipelines:

“The Board’s rules governing minimum cover of mains and service lines found at N.J.A.C. 14:7-1.12 are more stringent than corresponding Federal regulations at 49 CFR 192.327 and 192.361. N.J.A.C. 14:7- 1.12(a) and (b) require 36 inches cover over distribution mains and 48 inches cover over transmission pipelines, respectively, in comparison with Federal regulation requirements, at 49 CFR 192.327, of 24 inches cover over distribution mains and 36 cover over transmission pipelines.

…

To the extent that this rule requires an operator to install pipelines at increased depths of cover, there will be some costs incurred. However, the Board has determined that these costs are justified as a measure of damage prevention and to ensure the protection of people, property, and the environment, especially in densely populated areas”

Here the BPU has determined that federal statutes are not adequate for our state, and that a minimum cover of 4′ be used for all transmission pipelines.

Follow the strictest guidelines that will protect our families and friends

I submit that if PennEast is interested in truly designing and constructing a safe pipeline, that they should conform to all of the NJBPU regulations, and specifically should use Class 4 pipe exclusively throughtout the route; that a minimum of 48″ of cover be used over the pipeline in all locations; and that the remaining NJ Board of Public Utilities regulations be adopted as well.

PennEast members have already endorsed these rules

I will further note that when these rules were up for re-adoption, that the four major NJ companies involved in natural gas utilities in the state were invited to comment, and they did.

The full text is available here:

Click to access NGPRreadoption_20090212.pdf

Those companies were:

– South Jersey Gas Company
– Pivotal Utility Holdings d/b/a Elizabethtown Gas, a wholly owned subsidiary of AGL Resources
– New Jersey Natural Gas
– Public Service Electric and Gas Company

I would like to highlight some comments here:

COMMENT: We support the readoption of Chapter 7, and commend the Board for many of the proposed amendments which provide additional clarity and understanding while strengthening pipeline safety within the state. (SJG)

RESPONSE: The Board appreciates this comment in support of the rule.

COMMENT: We fully support the basic principles of ensuring continued pipeline safety and damage prevention, an appreciate the effort demonstrated by the Bureau of Pipeline Safety staff in preparation of the rule. (PSE&G) (ETG)

RESPONSE: The Board appreciates this comment in support of the rule

COMMENT: We concur with the amendment to N.J.A.C. 14:7-1.3 as written. All of our natural gas pipelines are currently Class 4 design and operation, and we agree with the requirement that all new pipelines constructed after the effective date of this rule shall meet the design standards for a Class 4 pipeline location. (SJG)

RESPONSE: The Board appreciates this comment in support of the rule

COMMENT: Proposed N.J.A.C. 14:7-1.6(a) and (b), which require oversight by qualified welding inspectors, should apply to transmission lines only. The character of transmission lines, especially their potential leak failure mode, makes them much more appropriate for this level of scrutiny. In addition, the rule should be modified from “ensure oversight” to “ensure quality.” Oversight implies viewing the welder as he or she welds, which is an not efficient or effective form of quality control. Quality tests and checks are normally included to ensure quality and include 100% X-ray’s to ensure weld integrity. (PSE&G) (ETG)

COMMENT: We are in general agreement with the proposed depth of cover requirements at N.J.A.C. 14:7-1.12 for distribution mains, transmission pipelines and service lines which are installed after the effective date of this rule

RESPONSE: The Board appreciates the commenter’s support for the depth of cover requirements.

I would like to note that the commenting companies – South Jersey gas, AGL Resources, NJ Natural Gas, and PSE&G – are all part owners in PennEast Pipeline Company LLC and in fact collectively represent a majority ownership. These companies have stated on the record that they believe these regulations are sensible and improve public safety. As such I call for them to mandate that the PennEast pipeline, if approved, be built to these same standards that they have endorsed.

TL;DR

Most of the proposed PennEast pipeline route will use substantially lower safety standards than would be required in dense suburban or urban neighborhoods.  Those of us in rural locations will have thinner walls, the pipe will be buried less deeply in the ground, and will have fewer safety inspections than it will in areas of higher population density.

INTRODUCTION

Pipeline safety has become a hot topic around the PennEast pipeline, and people particularly want to know how this thing is proposed to be built, how safe it might be, and what issues might come up if it is built.  And they’re worried – and rightfully so.  There are rumors that different areas get different treatment.  That rural lives and property are considered to be worth less than those in more suburban or urban environments.  That some of the “Best Management Practices”…aren’t.

So now looks like a good time to address those issues.  I’ll be drawing on PennEast’s filings for this information, along with government regulations that mandate certain practices, and what the industry has been doing to change those regulations.

Right off the bat let me tell you this: the rumors you hear are true. If you live in the country, your life, your family’s lives, and your pets and farm animals, your property, your house, your barns, your pools, your ponds and fire pits – they’re all considered to be worth less than those who live in the suburbs or the city. This is because of “Class Locations”.  Read on for what this means for you.

CLASS LOCATIONS

Decades ago some bright Department of Transportation people decided that we needed to regulate the construction of natural gas pipelines.  In their infinite wisdom they decided NOT to make pipelines as safe as possible.  Oh, no.  That would cost pipeline companies a lot of money.  So instead they chose what’s called a risk model that was based on population density near a pipeline.

A risk model outlines potential risks that a potential project can face, and draws lines where it thinks risks are acceptable, and where they are not.  In places where they aren’t, they dial back the parameters until they’ve found what is acceptable.

The definition of “acceptable” is up to the people drawing up the risk model (and those who approve it).

In terms of natural gas pipelines they decided the big issue at hand would be the impact of a pipeline breach near human population centers.  They figured that out in the country, there’d be a low impact, in suburban areas there’d be somewhat more impact, and in urban areas there’d be a very high impact.

“Impact” is not defined in terms of human life, but generally in terms of economic impact – the damage the accident incurs, and the amount of money it takes to fix it.  As a piece of this individual humans get a (somewhat arbitrary) economic number assigned to them.

They then modeled what “population centers” looked like.  They decided (again, in their infinite wisdom) that there were 4 classes of population they would look at:

Class 1 – Underwater, or with 10 or fewer inhabited dwellings within 220 yards of the pipeline centerline over a 1 mile length.

Class 2 – 11 to 46 inhabited dwellings within 220 yards of the pipeline centerline over a 1 mile length.

Class 3 – 47+ buildings within 220 yards of the pipeline centerline over a 1 mile length, or an outdoor space or building where 20+ people will gather.

Class 4 – A location where they are many 4 story+ tall buildings (e.g. urban).

High Consequence Area – A location that is deemed especially sensitive or important, or where evacuation may be difficult (a school, a busy and often crowded park, a hospital).

In this manner the DOT people modeled population density as it related to natural gas pipelines.  And they decided the more people there were around a pipeline, the safer they would make it.

SAFETY FACTORS BY CLASS LOCATION

Your class location has three important impacts on pipeline construction:

• How thick the pipe is
• How deeply it is buried
• How often it is inspected

As you can imagine, class 1 gets the least protections, class 4 gets the most.

Pipeline thickness

Finding out the thickness of your pipe is difficult.  It relies on a number of factors, so it’s hard to find it online.  The exact thickness depends upon the pressure of the pipeline (PennEast is 1480 psi), the width of the pipeline (36″ for PennEast), the safety factor for the class location, and the quality of steel being used.

We know all of those items except of the grade of steel PennEast will be using.  It’s not clear if we’ll get those numbers as they may be considered privileged information to protect critical infrastructure (e.g. they’re afraid of terrorists knowing).

But we do know the other parameters, and the most important is the safety factor.

The safety factor is somewhat mis-named.  The number itself is not an indication of the safety factor, but actually is an indication of how close they’re allowed to come to the rated stresses for the type of pipe they’re using.  As an example, a safety factor of 100% would be for a situation where a pipeline would be allowed to run up to 100% of its rated strength (note: this is a made up example, nothing would ever be allowed to run to maximum tolerance with no margin for error).  So even though it’s called a safety factor the actual number indicates how close to the pipeline strength rating you’re allowed to come.

The actual safety factors for pipelines are 72%, 60%, 50%, and 40%.

Note that pipelines operate at a constant pressure across its length, so in reality the safety factors translate into varying pipe widths and/or higher grade pipe.  So if you live on a farm or out in the woods you’ll get a less safe pipe by design then your friends a few miles away who live in a large housing development.

How deeply the pipe is buried

Class location also impacts how deeply the pipe must be buried.  At class 1 locations it can be closer to the surface, at higher locations it must be buried more deeply.  In agricultural areas the pipeline must also be buried more deeply to minimize crop impact, as standard depths are not nearly deep enough.

How often it is inspected

Finally class location defines how often the company is required to inspect the pipeline.  Most pipeline companies trumpet the fact that they have electronic monitoring systems that operate 24/7 so the on-site pipeline walks are unimportant.  This is not actually the case – regular pipeline walks are often neglected but are actually vital as automated equipment can fail, give false positives, give false negatives, or simply be ignored.

Class 1 Location

At this location the pipeline will be allowed to operate up to 72% of the structural stresses allowable, which translates into a thinner pipe and/or lower grade steel.

The pipeline must be buried so it’s top is only 30″ from the surface of the ground – except in areas with hard ground/bedrock.  In those areas it only needs to be 18″ from the surface.

Class 1 locations require the least amount of physical on-the-ground inspections.

Class 2 Location

At this location the pipeline will be allowed to operate at 60% of its structural stresses, so in practice it’s the second thinnest steel.

The pipeline must be buried so its top is 36″ from the surface of the ground, 24″ in areas with hard ground/bedrock.

They require more physical inspections than class 1.

Class 3 Location

At this location the pipeline will be allowed to operate at 50% of its structural stresses, so it’s thicker steel than in class 1 or 2.

Depth requirements are same as for class 2 – 36 ” or 24″ in hard rock/bedrock.

Physical inspection requirements are the same as class 2.

Class 4 Location

At this location the pipeline will be allowed to operate at 40% of its structural stresses, so it’s the thickest steel.

Depth requirements are same as for class 2 – 36 ” or 24″ in hard rock/bedrock.

Physical inspection requirements are the same as class 2.

High Consequence Area

These areas would have increased monitoring and integrity checks over other areas,and include places like schools, beaches, parks, etc where many people will gather/inhabit.

HOW THIS RELATES TO PENNEAST

PennEast has indicated in their federal filings that they will upgrade the to a minimum of class 2 safety factor for the length of the pipeline, even for class 1 areas.  So the pipeline will be operating at 60% of maximum allowable stresses in those areas.  Class 3 areas will still get the thicker pipe and 50% maximum allowable stresses.

The “class 2 upgrade” only applies to the pipe thickness. They will still be burying the pipe more shallowly in class 1 locations.

Incredibly, PennEast has identified ZERO High Consequence Areas, even though there are many that have been identified by myself and others (examples: the strip mall in PA near route 33, the private Christian school in the same area, etc).

PennEast trumpets as loudly as they can to anyone who will listen that this gas is for NJ and PA, period.  They will never, ever, ever, ever (pinky swear, really) EVER let this gas go for export.

Ever.

To help cement our trust on their pinky swear promise, PennEast part-owner New Jersey Resources (NJR) announced this week that they are swapping their interest in the Iroquois Gas Transmission System for an interest in Dominion Midstream Partners instead. NJR stated in their press release that:

“With this agreement, we are exchanging NJR Midstream’s ownership interest in Iroquois for expanded ownership in a variety of midstream assets held by Dominion Midstream Partners,” said Laurence M. Downes, chairman and CEO of New Jersey Resources. “We believe this is an attractive opportunity to diversify our position in the midstream marketplace.”

Formed in 2014, Dominion Midstream Partners, LP owns, operates, develops and acquires natural gas import, storage, regasification, transportation and related assets, including a preferred equity interest in the Cove Point Liquefied Natural Gas (LNG) facility and ownership of Dominion Carolina Gas Transmission, LLC (DGCC). Cove Point provides LNG import, storage and transportation services to the Mid-Atlantic marketplace and DGCC is an interstate natural gas transportation company, delivering natural gas to wholesale and direct industrial customers throughout South Carolina.

The full press release is here:

http://www.njresources.com/news/releases/2015/njr/15-36NJRMidstream.asp

Wait. What? Back that up. To this part:

“including a preferred equity interest in the Cove Point Liquefied Natural Gas (LNG) facility”.

O
M
G

Parse all of the jargon and what we have here is that PennEast part owner NJR is buying a piece of Dominion Cove Point LNG. The very same Dominion Cove Point LNG which is expanding into an LNG export terminal even as I write this.

That’s right. The company who says “this gas is for NJ and PA” just bought a big share in an LNG export company. For those not aware Cove Point LNG export is fully subscribed by heavy industry in Japan and India.

Anyone still have any doubts on where this gas is going?