Category: Uncategorized

A strange way to show support

The FERC posted 9 rather odd submissions today. They were images of postcards people apparently were given by PennEast. They filled out their contact info and a checkbox saying they support PennEast. It’s all rather…well, let me just show you:

.

They’re all post marked the same day so I’m guessing these either were solicited from one of the scoping meetings or else someone gave them to PennEast.

The logo on the top says “I support safe clean affordable locally produced natural gas to energize my community!”.

Oh boy.

You can see the submission from above here:

I supposed PennEast postcard – FERC Generated PDF

I supposed PennEast postcard – FERC Generated PDF Alternate Site

Hunterdon County Board of Freeholders talks of “draconian measures”

I heard John King speak at the Hunterdon County FERC scoping meeting. He sounded extremely reasonable, gave well thought-out arguments. And it was clear he was severely pissed at PennEast and the FERC.

John is the director of the Hunterdon County Board of Freeholders, so his words carry some weight.

He opens:

The subject of the Penn East natural gas pipeline has sparked comment and controversy since the unveiling of the project’s concept last year. This Freeholder Board withheld judgment to afford the pipeline’s proponents and critics a fair hearing and consider additional issues affecting Hunterdon County as a whole. In light of the facts before us, we are compelled to oppose Penn East’s application.

Like many people (myself included), he and the rest of the board was not instantly against the PennEast pipeline. He was willing to listen to what they had to say and see what benefits they might afford us.

From my POV, what he found is that:

1) This pipeline is not meant to benefit the people of New Jersey. Any such benefit would be mere side line of opportunity, not the main point.

2) The choice of route is incredibly bad.

3) They are choosing the easy way instead of the ethical way.

In his words:

Our objections are based upon (1) the disregard of potential alternate paths using existing easements that may result in the abuse of eminent domain to destroy conservation easements and pre-empt County open space policy; (2) the insufficiency of proposed compensation to affected landowners; (3) the threat of construction- generated water contamination in specific neighborhoods serviced by private wells; and (4) the absence of a lasting public benefit outweighing the burdens upon homeowners in
the project’s path.

He goes on to point out how PennEast is almost systematically wiping out Open Space conservation easements in the County, and is not even trying to find alternatives.

Among the properties lying in the proposed pipeline’s path are 23 farms constituting 2,007 acres of County-preserved open space. If approved, the Penn East pipeline would necessarily extinguish the County’s conservation easements of those those farms and trump a County open space policy mandated by three successive voter referenda. This issue alone warrants our opposition.

Moreover, Penn East has raised the specter of eminent domain —presumably to thwart the County’s defense of its interests in the preserved open space. This threat arises despite the existence of alternate routes within established public utility rights-of-way, including similar pipeline easements.. It is our understanding that Penn East has not contacted some utility companies to negotiate co-location of its pipeline within their easements. A judicial taking of property for use by a for-profit corporation should always be a last resort. We will never support a proposal that threatens the condemnation of land where less draconian measures of property acquisition have not first been exhausted.

The above issue is one of the biggest ones I personally have with PennEast. They aren’t even really trying here. Their route choices are predominantly based on playing with Google Earth, and a single aerial reconaissance. If they were serious about minimizing impacts they would do real surveys before even getting the FERC involved.

John goes on to talk about the inadequate compensation involved:

Penn East also proposes inadequate —and therefore unjust —compensation to Hunterdon taxpayers in the project’s path. The utility conglomerate merely proposes to pay owners the one-time loss of value attributed to the new encumbrance on property. Pipelines earn continuous profits potentially to include additional revenue from other public utilities. The benefits Penn East would reap from any targeted property are analogous to those received by wireless providers from cell. towers. Wireless companies place cell towers on another’s property with an agreement to provide the owner with a
stream of income, much like a lease. When the company leases those towers to other wireless providers, the land owner receives additional income due to the third party’, commercial use of the owner’s land. Properly owners in the pipeline’s path should be treated no diiferently. Thus, if Penn East is going to earn continuous profits from the exploitation of the land of another, it should make that owner a partner.

The issue of people’s wells is of course well known. He argues that PennEast must avoid these entirely.

Construction disturbance near a local drinking water supply raises contamination concerns. The proposed project slices through 53 acres of Tier 1 well protection areas —neighborhoods with residents overwhelmingly dependent on the consumption of well water. Prior local experience with drinking water contamination caused by poorly supervised construction near an existing transfer station proves that a potential threat to the well protection area is a well-founded misgiving. In fact, we would prefer that any pipeline be routed around this area entirely.

On the question of who benefits, PennEast again fails to give us any useful information.

The usual benefit of a pipeline passing near a neighborhood is access to the natural gas running through it. In the public hearings, however, Penn East could not guarantee that this pipeline would connect a single additional residence to natural gas in any time frame beneficial to current homeowners. In fact, our County is poorly served by natural gas due to the nature of its dispersed rural population. As a result, our homeowners are unlikely to reap much of any corresponding reduction in the cost of natural gas because so few County residents have access to it.

He closes with the point that the main issue is not the source of the gas. It’s an issue for some but not all. But that the route is nearly wrecklessly determined and will not benefit us.

To be clear, this Board has not swallowed whole every argument brandished by critics of Penn East’s application. We do not oppose the principle of constructing underground pipelines to transport natural gas. This method of delivering energy to consumers has proven far less dangerous than alternate means of transport: ship, truck and rail. Natural gas ibrelf is known to be a much cleaner burning fuel than this region’s other major sources of electricity, such as oil and coal. Secondly, several natural gas pipelines already cross Hunterdon County and have existed for decades. We do not subscribe to the notion that the mere presence of an additional pipeline within our County’s borders is a sufficient basis to oppose this project.

As proposed, however, the Penn East project unnecessarily threatens property rights at the Constitutional sword point of eminent domain, and offers no prospect of just compensation for the land it targets for lease or condemnation. The pipeline’s construction endangers an identifiable drinking water supply and fails to deliver the only lasting benefit that such a project can offer atfected neighborhoods: connection to natural gas. Thus, the Hunterdon County Board of Chosen Freeholders shall resolve to oppose the proposed configuration of the Penn East pipeline.

The Hunterdon County Board of Freeholder’s submission is available below:

Hunterdon County Freeholders Submissio – FERC Generated PDF

Hunterdon County Freeholders Submissio – FERC Generated PDF Alternate Site

Winifred tells it like it is

Winifred from Holland Township, NJ has a whole lot to say about to the FERC about this pipeline, the scoping process, and a whole lot more. It’s so well-written I’m going to include the entire text here, but I want to highlight one piece in particular because it strikes so close to how myself and many others feel:

“I object to the construction of the Penn East Pipeline for many reasons. The biggest reason is that I love my land and the birds, plants and animals I share it with. Removing the trees and tainting the water that runs through it and below it will damage it forever. It will never be the same.” (emphasis mine).

The complete text of her submission:

My name is Winifred Waldron. I am a landowner in Holland Township New jersey and would be directly impacted by the Penn East Project. My property lies between mile posts 82 and 83 and is within 2 tenths of a mile from mile post 83- and I was denied the opportunity to speak at last evening’s FERC scoping meeting. After the meeting I was told that there were 20 people still on the list waiting to speak including me. Later, I learned that there were about the same number of people denied the opportunity to speak at the Trenton meeting as well- totaling at a minimum 40 people. If we were all given the mere 3 minutes allotted to speak, it would amount to another 120 minutes – essentially the length of a scoping meeting. It goes to show that the number of FERC scoping meetings held in New Jersey were insufficient. There were 3 meetings in Pennsylvania and only 2 in New Jersey. Another meeting should be held in New Jersey, about halfway between the two ends of the pipeline that might traverse the region, so that the people who wanted to talk will be provided that opportunity. Furthermore, the recently announced route changes, there should be additional meetings for these people affected. As a landowner denied the opportunity to speak my piece, I know how those landowners must feel at not having the opportunity to prepare and speak out- on the record.

I was anxious to speak and having the public hear my concerns – on the record. I have been waiting more than 2 months to speak. I wrote and revised my concerns until I was able to put them into a succinct speech that would fit into the 3 minute time slot. I have lost all of that time and energy spent preparing, similar to the land that I could lose if this pipeline is approved. I have been monitoring the FERC submissions since the fall, I see how many come in and how thorough and lengthy some of the submissions are. I know that only a few people see those submissions. Given a chance to speak, I might have been heard by more. My husband and I attended Penn East informational meetings in good faith and expecting that our concerns would be heard and questions answered. It did not happen. Instead the Penn East Representatives would send us from table to table and eventually explain that the person that I needed to speak to was not at that meeting but should be at the next.

My husband and I both took time off from work to attend 3 of those meetings. We never had our concerns addressed. Finally, at the last meeting we attended, I explained to Medha Kochlar from FERC that I felt that my concerns were not being addressed and my questions were not being answered. She kindly introduced me to, Alisa Harris from Penn East. Ms Kochlar also recommended that I submit my concerns to FERC. She cautioned that I would not hear back from them as they gather the information for review, but do not answer questions. She also told me that there would be the scoping meetings sponsored by FERC where I would be able to express my concerns publicly. She pointed at the flow sheet and said that they would most likely be held after the holidays. She was right about being after the holidays, but she misspoke bout having the opportunity to express my concerns.

Well, I submitted my concerns on paper, but now I have more to say. I am a landowner directly impacted by the proposed Penn East pipeline. The 400 foot survey area bisects my property. It starts approximately 30 feet from my house and runs through the middle of my backyard. It could take out my fence on 3 sides, many trees as the fence line and one end of the yard are wooded, some fruit trees, my gardens – I grow my own vegetables, my strawberry patch, my onions, garlic and shallots, my blackberry patch, my raspberries, my coneflowers, the garden for my sunflowers, my fire pit and my barn! It could be within 50 feet of my well. I already have some arsenic in my well water. The level bumped up a bit after the earthquakes. The excavation and construction for the pipeline could easily raise the arsenic level up to the toxic range. Death by arsenic- not my first choice. But then, given the proximity to my house, if there were an accident, such as an explosion, BOOM! I would be incinerated. Hmm… I don’t think I like option two any better. I could lose a lot to this pipeline.
I work from home and one of my favorite things about working from home is watching the wildlife. In the morning a young hawk comes to visit about the same time as I sit down to my desk. It perches in the trees – trees that will be displaced by the pipeline – with its keen eyes scanning the yard. I might make a noise or get up to take a closer look through the window and it will turn and look right at me with those keen eyes that appear to miss nothing.

Later in the day, the older hawks start soaring in the sky above my house. The black birds who normally sit at the tops of the pine trees guarding the yard from intruders will become frantic and start calling out in alarm. A group of them will gather and try to chase the predators away. Unfettered, the hawks just fly higher up into sky.

When I cast my eyes towards the ground, I see Wild Turkeys jogging through the yard or the deer sleeping lazily under the trees. A fawn was born and lived in my flower garden for a summer. Now grown, it is not bothered by our presence in the yard and will keep munching away –helping itself to the plants and fruit we grow here.

I love to sit at my desk and listen to the birds chirping during the day and hear the sound of the stream, babbling down the hill to the Harihokake Creek. When my day has ended, I love to relax on the deck at night and listen to the frogs chirping and watching the bats flitter about diving and catching bugs or looking out into the back yard to see the fireflies light up the woods and sky. I object to the construction of the Penn East Pipeline for many reasons. The biggest reason is that I love my land and the birds, plants and animals I share it with. Removing the trees and tainting the water that runs through it and below it will damage it forever. It will never be the same.

I know that Penn East promises to return my land to the way it was before the pipeline construction took place. I am told that after construction, it will be hard to tell that the line is even exists. There is no way they can keep that promise. It is an empty promise. A lie. I do not trust Penn East. All of my interactions with them have been negative. From the land agent Mr. Gilbert and his threats of eminent domain to the Penn East representatives at the company sponsored meetings who took our information and questions and promised that we would hear from someone from the company who would supply the answers. The last of whom was Ms. Harris who at the request of Ms. Kochlar from FERC took my name, phone number and Email address and promised that I would get a call back in 48 hours. I did not get an Email until February, it was not from her and it was to ask me if I still had questions!? Of course I do, no one took the time to answer them yet! At this point, I am not sure that I would believe what they have to say anyway. Their stories have changed so much. From the size of the pipe, to the width of the corridor and the location of the pipe on my property- which was moved closer to my house and now bisects the land! They made no effort to follow boundaries or edges. Not to mention the lack of documentation of the wetland, category 1 stream and the extent of the slope of the hill to the stream. They have been evasive and dishonest. I do not trust Penn East.

Nor do I trust Tetra Tech. I know it is a member of the Marcellus Shale Coalition and represents Marcellus shale to the government. It is also involved in the natural gas and pipeline industry. I question the ability of the consultants to be unbiased. With the recent news of Tetra Tech’s biased decisions and questionable business practices- destroying evidence? I am thinking that this concern is valid. Even without the illegal activities recently brought to light, just its membership to the Marcellus Shale Coalition should prevent them from being environmental consultants for a natural gas line transporting product from the Marcellus shale region. It is a conflict of interest. Although I am not surprised that FERC would allow it – it has a reputation of being pro-pipeline and pro-infrastructure. I am even less surprised after I read that FERC regards landowners as “problems” for pipeline infrastructure in the power point presentation by FERC “A View from the Beltway”. I am NOT sorry to be such a problem. I have told my children and patients that it is important to self-advocate. I, as do many of the other landowners affected, have a multitude of concerns about this pipeline and not only about its effect on Me but on Our World and the futures of Our Children. I will speak out and I will be heard.

Take the “No Action” alternative and do not approve the Penn East Pipeline Project.

Thank You for Listening

Winifred’s submission is available below. Please visit it to see the lovely pictures she’s included:

Winifred’s submission – FERC Generated PDF

Winifred’s submission – FERC Generated PDF Alternate Site

PennEast says: Well, no, this pipeline isn’t really for PA and NJ….

Recently PennEast revamped their “Proposed Route” link to involve multiple pages showing all of the various alternate routes and the reasoning behind each of them. This was done to help minimize confusion over the routes – which makes sense, as there were tons of alternatives and residents and organizations were predictably confused as to exactly where the pipeline’s supposed to go.

So kudos to PennEast on trying to do something right.

However, whoever wrote the copy for the pages probably didn’t pass it by the right PennEast censors public relations people for release. Specifically the page for “Prior Alternative 4” pretty much says the only reason PennEast exists is to get gas out of PA and out to much, much wider markets. PA and NJ are just the states they have to pass through to achieve that goal. The page says:

PennEast considered a loop of Transco’s Leidy Line pipeline system as an alternative to the proposed Project. A loop of Transco’s Leidy Line could access the same production region that the PennEast Project accesses; however, the Transco Leidy Line does not offer the same access to specific delivery point locations provided by the PennEast Project.

PennEast will offer direct delivery to both UGI Utilities in Pennsylvania and Elizabethtown Gas in New Jersey that cannot be made by utilizing the Transco system. PennEast’s proposed route is also uniquely capable of providing an interconnection with Algonquin Gas Transmission, LLC (Algonquin) and Texas Eastern Transmission, LP (Texas Eastern) at one location, which will provide supply for growing markets served by each transmission system in the capacity constrained northeast and New England. Because the Transco Leidy Line cannot make these direct deliveries to UGI Utilities and Elizabethtown, and Transco does not access Algonquin and Texas Eastern at one location, any Transco system alternative does not satisfy the purpose and need of the PennEast Project. In addition, if Transco were to loop its Leidy Line pipeline system as an alternative to the Project, there would not be an additional new pipeline system to deliver production from this region to the markets to be served by the Project, providing a further reason why this system alternative does not satisfy the purpose and need of the Project. PennEast is also considering requests for interconnections with existing power generation located within a short distance of PennEast’s proposed route that cannot be served from Transco’s ROW.

Let’s look at the key point: “PennEast’s proposed route is also uniquely capable of providing an interconnection with Algonquin Gas Transmission, LLC (Algonquin) and Texas Eastern Transmission, LP (Texas Eastern) at one location, which will provide supply for growing markets served by each transmission system in the capacity constrained northeast and New England. Because the Transco Leidy Line cannot make these direct deliveries to UGI Utilities and Elizabethtown, and Transco does not access Algonquin and Texas Eastern at one location, any Transco system alternative does not satisfy the purpose and need of the PennEast Project“.

It’s funny that none of this is mentioned in PennEast’s submission to the FERC in justifying the project. They are required by law to prove why this project is required and in the best interests of the United States (and to allow them to use emminent domain). They said this pipeline was required to serve the commercial and residential consumers in PA and NJ. Well, guess what? They lied. It’s PennEast blatantly comes out and tells us that their pipeline is uniquely setup to get gas into Algonquin and Texas Eastern, and their by make the gas available to the entire eastern seaboard.

Of course, this coincidentally includes the Cove Point LNG export terminal which will be delivering LNG to customers exclusively in Asia and India.

It also (coincidentally, I’m sure) includes the proposed Downeast LNG export terminal in Maine.

You may say “well, wait, UGI and Elizabethtown gas are mentioned too! And they’ll deliver gas to PA and NJ!”. This is true – as far as it goes. But deliveries to those points are going to be relatively small and used mostly to smooth out volatility during peak usage times. They certainly aren’t going to be using a billion cubic feet of natural gas per day! This pipeline is not sized to serve those companies.

No, as PennEast admits, they sized their pipeline to service the entire North East. And Asia. And India. And Europe.

This pipeline is not for us.

For more background into how this is playing out, read this article from Reuters. As the article states, the cover story of energy companies is that they’re here to provide natural gas to cover the winter months where usage spikes and shortages occur.

The reality is that the energy companies are looking at the 9 months of the year where there is no shortage to pump it all to the LNG export facilities and make a killing with it in Europe.

Does FERC follow regulations?

Jeffrey from Bethlehem, PA has been asking a lot of questions about the regulations the FERC is supposed to follow in the pipeline approval process, and if they’re being followed properly.

I am a citizen with no training in interstate natural gas transmission line rules and regulations. My knowledge has come through self-education after PennEast made its announcement to build a pipeline that would go through my town in Pennsylvania. I have done my best to understand the PennEast pipeline proposal and to participate in the process. I have asked many questions to PennEast officials, attended the Open House in my county, attended the Scoping Meeting in the neighboring town, and have read as much as I can from PennEast’s filings, its plans, and about the proliferation of natural gas transmission line proposals in PA. Despite this, I do make errors in trying to understand details and procedures that are unfamiliar to me.

I sent two e-comment yesterdays about third-party contractor for the NEPA review for the PennEast proposal. In reviewing FERC’s _Handbook for Using Third-Party Contracts to Prepare Environmental Documents_ (Rev. Dec. 2014), I did find today that it is possible for applicants in certain circumstances to submit fewer than three contractors (this is stated in Section 1-4). I did not realize this was allowable yesterday in my first e-comment.

My one question on this issue is whether such a justification was presented with the PennEast proposal and if more details could be made available to the public about this issue, in general. I think that _The Handbook_ suggests that fewer than three proposals is not usual because the paragraph where this is mentioned starts with a sentence that begins with the phrase, “In the rare instance…”

Thank you for your consideration of my comments. I know that the NEPA report is very important. For me, if it was at all possible, I would want FERC to have had, at least, three third-party proposals to look at for the selection of the contractor.

This is a great question and it dovetails with other questions I’ve seen people asking about the FERC not doing its job properly. This one in particular really gets to the heart of how and why Tetra Tech was chosen to do the Environmental Impact Statement.

This info might be available somewhere on the FERC site, I’ll do some digging to see if I can find it anywhere.

If not, there’s always the Freedom of Information Act (FOIA Website) as a last resort.

Jeffrey’s submission is available below:

Jeffrey’s submission – FERC Generated PDF

Jeffrey’s submission – FERC Generated PDF Alternate Site

Put yourself in someone else’s shoes

Opposition to the PennEast pipeline is not universal. Approximately 1% of the submissions I see on ferc.gov support the pipeline. They are nearly all identical – they pretty much parrot back PennEast’s justification in their filings with FERC and that’s about it. The story is about jobs and cheaper natural gas for people in NJ and PA. John from Hatfield PA writes:

I am a hardworking member ofthe National Electrical Contractors Association, who’s local Penn-Del-Jersey contractors alone employ over 10,000 workers performing over $ 1 billion of work in the area each year. I support the PennEast Pipeline Project and I urge you to join me. The PennEast Project is an approximately 110-mile, 36-inch pipeline that will bring affordable natural gas to customers in New Jersey and Pennsylvania. With an investment of nearly $1 billion, this new pipeline is designed to deliver approximately 1 billion cubic feet of natural gas per day- that is enough gas to serve more than 4.7 million homes.

New pipeline infrastructure is being driven by an increased demand for gas-fred electric generation, as well as from the residential, commercial and industrial sectors. This new infrastructure will aid consumers in seeing lower utility rates and lesser price volatility during times of high demand —such as frigid temperatures —and better reliability as it pertains to gas and electric power generation.
The PennEast Pipeline will not only benefit energy consumers, but will also have a positive effect on local communities. The Project will create local jobs -specifically during its seven months of construction, contribute to state and local tax revenues and increase business for local stores and other retailers.

Lastly, the Project supports America’s push toward energy independence and a cleaner energy future by maximizing locally produced clean-burning natural gas. The PennEast Pipeline will help decrease our energy reliance on other countries while also reducing carbon emissions.
A cleaner and more independent energy future will be possible because of new infrastructure like the PennEast Pipeline Project, I urge you to support the development of this pipeline.

I understand where John’s coming from. Wouldn’t it be great if this pipeline were bringing “affordable natural gas to customers in New Jersey and Pennsylavania?

He says “New pipeline infrastructure is being driven by an increased demand for gas-fired electric generation, as well as from the residential, commercial and industrial sectors”. Hey, that sounds awesome. There’s increased demand so we’d better find a supply to match, right?

He continues: “This new infrastructure will aid consumers in seeing lower utility rates and lesser price volatility during times of high demand —such as frigid temperatures —and better reliability as it pertains to gas and electric power generation.” Well, yeah. Price volatility is bad, so we should do something about it.

He concludes: “Lastly, the Project supports America’s push toward energy independence and a cleaner energy future by maximizing locally produced clean-burning natural gas. The PennEast Pipeline will help decrease our energy reliance on other countries while also reducing carbon emissions”.

Hell yeah. Right?

Wrong. If PennEast’s justifications were in fact truthful, I would agree with John 100%. The problem is, they aren’t. I don’t blame John for this. I blame PennEast, and the FERC. Let’s look at these items one by one.

Bringing affordable natural gas to customers in NJ and PA? Uh, no. Data from EIA.gov shows that this is a bald face lie. PA is a net exporter of natural gas already, and it’s only getting started. It’s going to be a massive net-exporter once pipelines like PennEast and the half-dozen others in the queue are approved. PA doesn’t need this gas.

NJ doesn’t either. The eia.gov data is clear. Demand for natural gas is flat in NJ, and is expected to continue to be so out to 2014 with the exception of electrical generation. You could argue we need more gas for that generation, but we don’t need 1 billion cubic feet a day. In fact this pipeline is not sized for NJ and PA. It’s sized for the world.

He talks about “increased demand” for gas-fired generation, residential, commercial, and industrial sectors. As I mentioned above – gas-fired generation demand increases are going to be modest. And the rest are absolutely flat.

He goes on to talk about price volatility. Yeah, I agree that’s bad. However, again it pays to look at the data. In FERC’s submission they show the data – there were 10 days of extreme price volatility in the 5 year period from 2009 to 2014. Two of them – the polar vortex days shortly after Super storm Sandy – were really bad.

But you don’t need a billion cubic feet of gas running through our state per day because of volatility experienced on one half of one percent of the year. It’s absurd. Again – this pipeline is way too big for that justification.

He concludes talking about energy independence and reducing carbon emissions. I’m sorry, but this is my “WTF?” moment. I’m sorry, John, but this gas is not destined for use by you and me. The U.S. already has a glut of natural gas and production is far out pacing use. No. This gas is for exporting to foreign countries, to India and countries in Asia. PennEast knows this. Heck, the FERC not only knows it but it’s created presentations showing the U.S. becoming a net-exporter of Nat Gas to the tune of over 4 trillion cubic feet per year. This is not about energy-indepence, John. It’s about profit for a select few companies.

The “reducing carbon emissions” part? I’m curious where John gets this idea. Yes, natural gas is better than coal. But that’s about it. Compared to just about everything else natural gas is a carbon nightmare. It’s made up predominantly of methane, one of the worst green house gases in existence. Compressor stations vent natural gas naturally as part of their function to the tune of tons of emissions per year.

If you know some union people who are pro-pipelines, don’t yell at them. Don’t get mad. Take them aside and point out the facts to them. Don’t let them be blind sided by a few thousand jobs for a year’s time of construction. Show them the bigger issues – the lies and deceit and blind profit-motive behind PennEast and their cheerleader the FERC.

John’s submission is available below:

John’s submission – FERC Generated PDF

John’s submission – FERC Generated PDF Alternate Site