PennEast responds to scoping comments with a fifth grader’s essay

PennEast has responded to the FERC scoping comments made by individuals and organizations:

PennEast’s response – FERC Generated PDF

PennEast’s response – FERC Generated PDF Alternate Site
The response reads like it was written by a fifth grader who forgot their paper was due tomorrow (with all due apologies to fifth graders). It is difficult to enumerate how many things are wrong with this document, but I’ll try:

  • People’s comments are lumped together by category. Instead of responding to each individual scoping document, PennEast has done a massive amount of editing and pushed everybody into buckets. There’s a water quality bucket, protected waters bucket, blasting bucket, etc. If anyone shared any unique information in their specific comments they are completely lost. This is completely outrageous.
  • The comments are boilerplate and vague. For example, on the question of whether this pipeline is needed or not, PennEast says “Section of 1.1 of Resource Report 1 – General Project Description details the purpose and need of the PennEast Pipeline”. That’s it.
  • There’s no detail. When people submit issues for multiple creeks, PennEast lumps it all together and says “We’ll do a study”. That is not acceptable. Before FERC should grant approval they should force PennEast to do all studies up front and prove that they will not endanger streams, will not hurt the ecology, will not damage our wells, and will not generally harm our environment and lifestyles.
  • Responses are missing.  Of the myriad of issues and questions I had in my FERC submission, PennEast responded to…9.
  • PennEast avoids certain questions altogether.  There are two separate questions on blasting – one is about PennEast blasting, another is about the pipeline running near quarries that blast – PennEast lumps the two together.  And then says nothing about the quarry blasting.
  • They are unwilling to move the route.  They’d rather say “we’ll fix any problems we create” than “we’ll move it”.  On the karst geology and sink holes – they say “don’t worry about it, our steel is high grade!”.  On arsenic, they say “Hey arsenic occurs naturally, what’s the big deal?  And if it contaminates anyone’s well, we’ll get them water from somewhere else, somehow”.
  • They keep saying disturbances will be “temporary” in nature.  Once construction is done, all will be well!!
  • They keep saying they will “minimize impacts” to areas.  They don’t say how, they just assert they will.
  • They do bring up compensation.  A lot.  If we screw up your ecology, we’ll pay you.  If we screw up you open spaces, we’ll pay you.  If we ruin your crops we’ll pay you.  If we go through your parks and endanger wild life, we’ll pay you.  Listen up, PennEast.  We don’t want you to pay us.  We want you and your pipeline to go away.
  • It’s all about convenience for PennEast.  On the issue of endangered species, PennEast says “Where practicable, the pipeline route is being adjusted to avoid protected habitats”.  And when it’s not practicable?  Well, then, too bad.
  • On the proximity to schools: “Data shows that while natural gas demand has increased, serious pipeline incidents have decreased by 90 percent over the past three decades alone, primarily as a result of significant efforts by pipeline companies to upgrade and modernize their infrastructure”.  So here PennEast actually admits that accidents do happen.  But it’s rare, so, yeah, we’ll be running that pipeline a few thousand feet from elementary schools anyway.  And if we blow up your kids we’ll compensate you!

Go read the document yourself and be prepared to get annoyed.  Really annoyed.  Keep sharp objects and breakables away from your reading area just to stay safe.  It’s really that bad.

Losing faith in our government

Marcia from Lambertville, NJ writes a heart felt submission to the FERC where she outlines how the public is losing faith in the FERC and their processes:

I humbly and earnestly request that the Commission appoint an impartial firm, instead of Tetra Tech, for the environmental assessment of the PennEast Project. Retaining Tetra Tech for this survey would be a grave mistake for the Commission and for the six partner companies for a number of reason. Tetra Tech, as part of the Marcellus Shale Coalition, has strong ties with companies who will profit from the extraction of gas from Marcellus Shale. Retaining Tetra Tech would be seen by thousands of people as the Federal Energy Regulatory Commission having very serious conflict of interests. FERC should not have asked PennEast for a list of companies that PennEast would like to work with, this was illogical even though PennEast will be financially responsible. The Federal Energy Regulatory Commission has, at the core of its mission a responsibility to regulate. The Commission is seriously endangering their reputation with the public, who are now viewing FERC as a tool of the fossil fuel industry to facilitate construction rather than regulate based on need and infrastructure. The public’s perception related to the selection of Tetra Tech, is that the process has been corrupted and the framework in which the Commission works has been usurped by special interests.

Recently in the news the Federal Energy Regulatory Commission has been labeled a rogue commission. Given that the Federal Energy Regulatory Commission rarely, if ever, votes for no-action, perhaps their very existence should be questioned.

The portion of New Jersey that this pipeline would be crossing is among the most beautiful and unspoiled in the state. I am asking that you don’t just follow procedural protocols, but listen and read the many comments made in the scoping process. Please follow an honest and ethical course of action. I personally have lost all faith in this process and believe that FERC will simply ignore these comments.

We the People may be battered in this process, but are determined to persevere for an ethical and fair process.

I agree with Marcia. Regulation does not equate to a rubber stamp. FERC has an completely lopsided view of its own role in the industry. Jeffrey Wright, Director of the Office of Energy Projects at the FERC has been quoted repeatedly saying that FERC should “follow the markets” and give the market “options” to achieve their goals.

That’s not the way it’s supposed to work. A regulator is supposed to define the rules and ensure the players abide by them. FERC’s actions are akin to the SEC taking Bernie Madoff to the side and saying “So, you want to create a ponzi scheme to defaud tax payers? OK, let’s see how we can work together to achieve your goals!”.

Marcia’s comments are available below:

Marcia’s comments – FERC Generated PDF

Marcia’s comments – FERC Generated PDF Alternate Site

Connecting the export dots

As I’ve mentioned before in this blog the numbers for the PennEast pipeline just don’t add up. They say this pipeline is strictly to benefit PA and NJ consumers and businesses. But for the most part, we seem to have more than enough natural gas. PA is already a net-exporter of natural gas so the idea that PennEast is going to help consumers and businesses in PA fails the laugh-test.

That leaves us with NJ. But as my blog post shows, when you look at eia.gov data the numbers still don’t work. This pipeline represents 200% of our existing residential consumption – yes, twice as much as we already consume. Electrical generation is going to slowly switch from coal to gas, but that only represents a modest increase in natural gas usage in NJ.

I talked about price volatility – yes, there are shortages in a few days a year. But those shortages do not justify building a 3-foot wide high pressure gas pipeline. It makes even less sense when you look at all the other pipeline projects approved or proposed.

So why are they spending billions of dollars to build these pipelines?

Connecting the Export Dots

Here’s why.

The above article details the four Liquid Natural Gas (LNG) export terminals approved by the FERC and that will be ready to go in a few years. Some details:

Cove Point LNG,  Maryland — Dominion Resources Inc

This facility will be able to export 1.8 billion cubic feet of natural gas per day. It’ll be up in 2017. PennEast will be connecting to this facility via Spectra Energy’s pipelines. PennEast will start construction in 2017 if approved.

About 1 billion cubic feet of that is approved for sending too FTA nations (nations we have a fair trade agreement with).  The rest is for nations we don’t have an FTA with.

Sabine Pass Liquefaction, Louisiana/Cheniere Energy
This will export up to 2.8 billion cubic feet of natural gas per day.

Cameron Liquefaction Project, Louisiana — Cameron LNG
This will export up to 1.7 billion cubic feet per day.

Freeport Liquefaction & Export Project, Texas — Freeport LNG Development LP
This will export up to 1.8 billion cubic feet per day.

These just cover the four approved as of today.  There are another 17 proposed that the FERC will be evaluating.  One of these will be the Downeast LNG in Maine.  So far they are conditionally approved by the DOE to export up to .460 billion cubic feet per day to FTA nations.

At the same time Creswood Midstream Partners is proposing the Marc II pipeline to connect to the PennEast pipeline;.  This will help get PennEast gas to New England markets.  And just coincidentally will have connections to DownEast LNG’s export facility.

LNG Export as a strategic direction

One of PennEast’s partners is Spectra Energy.  As a public company they’re required to file regular quarterly and annual reports with the SEC outlining their company’s financial health and their strategic vision for the future.  This is called a 10-K document.  Here’s Spectra Energy’s 10-K for the fiscal year 2014.
In it Spectra Energy outlines their business strategy.

——————————————–
Our Strategy. Our strategy is to create superior and sustainable value for our investors, customers, employees and communities by delivering natural gas, liquids and crude oil infrastructure to premium markets. We will grow our business through organic growth, greenfield expansions and strategic acquisitions, with a focus on safety, reliability, customer responsiveness and profitability. We intend to accomplish this by:

• Building off the strength of our asset base.
• Maximizing that base through sector leading operations and service.
• Effectively executing the projects we have secured.
Securing new growth opportunities that add value for our investors within each of our business segments.
• Expanding our value chain participation into complementary infrastructure assets.

Natural gas supply dynamics continue to rapidly change, and there is general recognition that natural gas can be an effective solution for meeting the energy needs of North America and beyond. This causes us to be optimistic about future growth opportunities. Identified opportunities include growth in natural gas-fired generation, growth in industrial markets, incremental gathering and processing requirements in western Canada, LNG exports in North America, growth related to moving new sources of gas supplies to markets and significant new liquids pipeline infrastructure.
——————————————–

Spectra energy comes right and out and says it – part of their growth strategy is via LNG exports.  PennEast, and the other pipelines approved or proposed, are a big part of it.

The PennEast, Transco Leidy Southeast Expansion, etc are all sized way too big for our local markets in NJ and PA.  Way, way, too big.  But they’re sized just right if you want to export gas to Europe and Asia and India.  Dove point is already 100% allocated out to companies in India and Asia.

Look at the Downeast and Dove point export rates – combined they’re capable of sending out 2.2 billion cubic feet of gas per day to countries over seas.  PennEast – as huge as it is – is only capable of doing 1 billion cubic feet of gas per day.  This is why so many pipelines are being proposed – to get shale gas to LNG export facilities.

Don’t believe the smoke screens

There will be minor benefits from the PennEast pipeline.  It’ll smooth out volatility and peak demand, so we’ll be in better shape a few days of the year.  As coal plants convert to natural gas this will help to supply them as well.

But this is a side show.  PennEast all by itself is way too big for these justifications.  These are all smoke screens and side-benefits.  The real purpose of PennEast and the other pipelines is to get the gas to the export stations.

An emphasis on Speed

One David Bojczak posted a submission to the FERC today. It appears to be another postcard dump, this time it’s copies of 126 post cards submitted by union members in support of the pipeline.

Googling David leads you to The Conti Group, a construction company that focuses on energy projects. So his support of the pipeline makes sense.

But go on there site and you read some troubling stories. For example, they worked on a recent Transco pipeline project:

The Challenge:

Transporting natural gas around the country requires amazing efficiency and effectiveness. With thousands of miles of gas pipelines intricately networked underneath America’s soils, quality gas compressor stations, which pressurize natural gas so it is capable of moving through pipelines at high speeds, are essential to gas transportation. The Transcontinental Gas Pipeline Corporation (Transco) asked Conti to build such a station.

The Solution:

The Conti Group worked on an aggressive, fast-track schedule to provide Transco with a quality, fully-operational gas compressor station. Our workforces performed a minimum of ten hours per day, six days per week to complete construction on schedule. During this time, the team performed all civil work, including 1,900 LF of storm drainage piping, grading, excavation, paving, landscaping, over 2,000 CY of reinforced concrete foundations, and structural work on several buildings. We also installed a 69,000 KV electrical substation generator, transformers and switchgear, grounding grids, two 7,500 horsepower Centrifugal Compressor Motors, and welded process and gas lines of all diameters and wall thickness. The work resulted in a capable compressor station constructed in quickly and cost effectively.

Conti was responsible for this turnkey project and performed construction activities, scheduling, Health and Safety, QA/QC documentation, facility testing, finished painting, cleaning, commissioning, and equipment and systems training.

Does this sound like a good idea to you? They’re building a massive natural gas compressor station. Under pressure from Transco to get it done fast, they create “an aggressive, fast-track schedule” where “our workforces performed a minimum of ten hours per day, six days per week to complete construction on schedule”.

Imagine living near a compressor station which was created by tired union workers who were pushed to work 10 hours a day six days a week.

This is the type of firm that will likely be bidding on the PennEast pipeline work should it be approved.

David’s submission is below:

David’s submission – FERC Generated PDF

David’s submission – FERC Generated PDF Alternate Site

Travelling the countryside

I hopped into my pickup with my dslr in hand this afternoon to photodocument the pipeline route. Or at least what I can get to before dark. The pictures are breathtaking…until I stop to reflect that a pipeline might be blasted through here. Pics to follow.

Pipeline supporters have no problem lying to persuade the public

A mini-drama has been unfolding on the comments section of nj.com for weeks now. Mysterious people have been showing up in the comments in support of PennEast with a variety of claims. The most egregious is from a user called “HunterdonTreeFarm”.

He has a heart breaking story to tell:

You can call me a NIMBY, but my family’s second generation tree farm is right along the proposed path; so for personal reasons, my family doesn’t wants to see this pipeline built here.

I don’t want to see this pipeline go through some of our scenic areas, like Balpate mountain. I think most of can agree we would not want to see a scar through such scenic areas. Hopefully Penneast can get some more landowners to allow surveys so they find a alternate route around some of more beautiful areas of the county.

At first I told Penneast they couldn’t survey my land and I planned to fight this. All of my neighbors told me that they were fighting this all the way and that I should fight it too. Penneast hosted a luncheon and a dinner for landowners to show us maps of the proposed plan. While I was there, I saw my next door neighbor looking at the map and talking to a representative. She had her back to me; so she didn’t know that I was there. I could hear her telling the Penneat representative that her land had wetlands on it and they should go through my tract instead. The very same neighbor telling me not to survey or to talk to Penneast was trying to convince them to run it through my property instead of her property. My neighbor was trying to cut a deal and leaving me holding the short end of the stick. At that point I decided to do what was best for my business and my family and gave Penneast approval to survey my property. Believe me, I don’t want this pipeline anywhere near my property and I want to fight this all the way. However, I have to be realistic that this pipeline will most definitely be approved. If I work with them that maybe they can minimize the impact on my land/business. I depend on my tree farm. My family lives pay check to pay check. I don’t see many alternatives. I don’t have the resources to pay the legal expenses to fight in condemnation court. All you get in condemnation court is money for the land value. If I work with Penneast they can give me money for loss of profits, land value, etc. I would never get that much through condemnation. I can’t afford walking away from that offer. I respect some landowners fighting this all the way. I just don’t see a plausible alternative for my family.

This is the type of story I like to try to highlight on the blog here – a real human interest story of a real person being confronted with this pipeline.

The only problem is that HunterdonTreeFarm has been blasting this message all across NJ.com. And others such as “Tony C”, “MonmouthCountyResident”, and the creatively named “WeLuvPennEast” are also joining the chorus and saying odd things like they know Tony Cox (the PennEast project manager) and can put in a good word for people who want leniency from the pipeline company. In fact they all write in the same way and vaguely assert they live around here without giving any plausible evidence of it.

In reality these all appear to be people lying on the forums to push public opinion towards the pipeline. The posts from HunterdonTreeFarm seem to be the lowest in that they’re actually trying to pretend they’re a person being hurt by the pipeline. There’s no evidence that this person is on the pipeline route or even a tree farmer. And of course “HunterdonTreeFarm”‘s dialogue rapidly falls apart as they shift from telling a sad story to being a cheerleader for PennEast:

@WestAmwellResident If Tony Cox says it’s not going overseas then it’s not going over seas. You can take that to the bank!

Has anyone ever stood on the texas eastern pipeline trail on the top of the mountain in the Sourlands between Hunterdon and Somerset County? One of the prettiest vistas in NJ. Spectacular view! You couldn’t get a view like that with all the trees in the way. Once I saw that view, I was sold on the PennEastern project.

So who are these people? Random trolls? Shills for PennEast? Union people trying to influence people through deception? A single lonely soul pretending to be a cast of dozens for kicks?

You can see HunterdonTreeFarm’s comments for yourself here:

HunterdonTreeFarm comments