Category: Uncategorized

Chris and Sherri, 4th Generation Farmers

Chris and Sherri own a farm in Milford, NJ. The pipeline is going right through the middle of it.

We are the 4th generation to be living on our farm and hopefully our children will be the 5th. The pipeline is proposed to be going right through the middle of the property, which now makes it impossible for us to farm the land or for any of our children to build their future home. Our surrounding neighbors all have their land in farmland preservation which is supposed to protect the land. There is a natural spring that runs parallel to our property that will be disrupted. We also have a narrow 9 acre wood lot that is in the projected path. It is densely populated with red oak trees. If they go through that, it will kill many trees and make it look like an open field, which will cause serious erosion. Our woodlot sits in the middle of the Gravel Hill Preserve, which was set aside by the state to preserve and keep the natural beauty of the forest. I can’t see how they can destroy all the protected land around us.

We live in the country because of the beautiful surroundings and the feeling of being safe. With all the recent gas explosions, we don’t want to live with the constant fear that we’ll be next.

Read their submission below:

Chris and Sherri submission – FERC Generated PDF

Chris and Sherri submission – FERC Generated PDF Alternate Site

Professor Tullis Onstott provides his formal evaluation to FERC

Prof. Tullis C. Onstott of the Department of Geosciences at Princeton University has been mentioned here and in people’s submissions before. He objects to the pipeline route due to the concentrations of arsenic in Hunterdon county and the amount of it that will be released into our drinking water and waterways if this pipeline is built.

Impact of Pipeline on Drinking Water
Although no specifics have been given as to the depth of the pipeline, the 3‐foot diameter pipeline will require a depth of cover of at least 3 feet below the surface, and, more likely 4 feet below the surface where the pipeline crosses many farmlands in Hunterdon County (as specified by the USDOT regulations at 49CFR192). This means the pipeline trench will need to by 7.5 feet deep and because most of the soil in Hunterdon County is less than 32 to 64 inches10, the bedrock will have to be excavated. This means that the trench construction, which will in some cases require blasting, will fracture, shatter, excavate, deposit at the surface in spoil piles and rebury arsenic‐rich shale exposing it to aerobic conditions. Horizontal Directional Drilling beneath the streams and creeks will crush the bedrock into fine‐grained sand and silt size particles and release arsenic into the drilling mud pits.

The professor goes onto to explain what this means in layman’s terms using an analogy.

To give you a better idea of the consequences of this construction phase imagine you are holding one kilogram piece of Lockatong argillite that has 100 ppm of arsenic. One kilogram is about the size of my fist. If you break it up and leach all of the arsenic from that rock and put it into a 1 liter bottle of Fiji water, the arsenic concentration of the water will be ~250 ppm. The MCL is 5 ppb, so I would have to dilute the water in that bottle with an additional 50,000 liters of Fiji water. In reality the Hunterdon County ground water is not Fiji water and already has elevated arsenic, but I’ll give PennEast a break and say that we would only need to dilute the water in that bottle with ~100,000 liters of Hunterdon County’s best well water. That is only about ~25,000 gallons of well water, which is not that much. If I poured 100,000 liters of water on to the surface of a farm in Hunterdon County, it would fill a 1,000,000 liter volume of the surficial aquifer, reasonably assuming a ~10% porosity. This is equivalent to 1,000 cubic meters. Given that the surficial aquifer is only ~1 meter deep in Hunterdon County, this corresponds to ~30 meter square patch (or ~100 feet by 100 feet) of farmland, which is really not much of an impacted area. The 100‐ foot length is about the width of the temporary ROW for the pipeline, if I understand this correctly. But how many kilograms of Lockatong argillite will be excavated, broken up, exposed to air and reburied into the trench within that ROW? How much of the Lockatong argillite around the trench will be fractured by the blasting? I will give PennEast a break here and just say that the trench is only 2 meters deep by 1 meter wide (it will certainly be larger than this), and I will assume that there is no arsenic in the upper 1 meter. This means that a ~30 meter long pipeline trench will expose ~75,000 kilograms of Lockatong argillite or about 75 metric tons. This is not a lot of rock (about three dump truck loads), but if it contains 100 ppm of arsenic, then it would have to be diluted with 75,000,000,000 liters of Hunterdon County groundwater in order for the arsenic concentration to be reduced below 5 ppb. That is a large volume of water. Another way of thinking about it is to assume that all of the arsenic was released from the 75 metric tons of Lockatong argillite into the 30 by 30 meters of 1‐meter deep surficial aquifer. The arsenic concentration would then be ~180 ppm, but I’ll give PennEast a break and say it is just 100 ppm to make the math easier. So to dilute it down to 5 ppb, you would need a 20,000x dilution factor for 100,000 liters of ground water. To visualize this volume, it would represent a 30‐meter wide strip of land extending perpendicular to the pipeline on both sides for a distance of 300 kilometers (it is just 2×10,000×30 meters), or 216 miles! The average diffusive groundwater velocities in this region are ~1 foot a day, so it would take ~2,500 years give or take a thousand, to dilute the arsenic plume by normal groundwater recharge.

Of course not all of the Lockatong and Passaic formation shale is 100 ppm and not all of the arsenic will be released during the excavation and blasting, but you can easily see that even if a mere fraction of the arsenic is released, that it will have a severe impact on the arsenic concentrations of the privately owned wells down gradient from the pipeline for more than the 30 year operational lifetime of the pipeline. We do know the range of arsenic concentrations in these two formations, but we do not know specifically what the arsenic concentration is of the bedrock along the proposed PennEast Pipeline route. We also do not know what form that arsenic is in within the bedrock along the proposed pipeline route, whether it is soluble arsenic or arsenopyrite or some other arsenic phase. But neither does PennEast know. This needs to be determined for the Environmental Impact Statement.

He goes onto explain the many, many threats there are to the pipeline’s integrity and the many, many ways arsenic can be released not just by the pipeline construction but also by its ongoing operations. I urge you to read his report in full.

The report also has a number of startling pictures to demonstrate what he’s talking about. This image shows the arsenic concentrations and the pipeline route. Sadly the route goes right through the highest arsenic concentrations in the state of NJ.

It shows the route crossing the Ramapo Fault System:

It goes right through water recharge zones – the zones are colored in blue:

The report goes on and on about the risks this pipeline poses to our health and environment, and provides a litany of things PennEast will have to do to even provide a basic measure of safety throughout the pipeline’s lifetime.

Please, go read his report below at one of these two sites:

Professor Onstott’s Statements – FERC Generated PDF

Professor Onstott’s Statements – FERC Generated PDF Alternate Site

Blasting concerns in Baldpate and Belle Mountain areas

It may not be widely known that for large portions of the PennEast route mere “digging” isn’t going to cut it. The route is going through very mountainous terrain with rock formations exposed right at the surface. Drive around West Amwell, Lambertville, and Hopewell township and you’ll see what I mean. Exposed rock everywhere! Driving along route 29, or route 518, or even on 202 near the Delaware river bridge and you’ll see the stone formations. They’re actually quite beautiful in the winter as small water falls freeze in place on the walls. If you’re not from the area think of the NJ palisades, those are made of the same stuff.

What you’re seeing is diabase, which is what makes up the bulk of the Sourland mountains. Goat Hill, Belle Mountain, and Baldpate are all made of diabase.

As I said, digging isn’t going to cut it for installing a pipeline. So they’re going to have to blast out the rock.

William and Dorothy of Hopewell, NJ tell the FERC why it’s a very, very bad idea to do this.

We are writing to voice our concerns regarding the proposed PennEast pipeline. The PennEast pipeline is one of more than ten pipelines being proposed to supply gas to New Jersey, a state already well supplied with natural gas. The two routes proposed by PennEast are particularly detrimental for Hopewell Township and neighboring townships to its north. The original route sought to minimize disturbance of private landowners by traversing public lands where possible. This route disregarded the fact that many of these environmentally sensitive lands had been specifically purchased to protect forests and the wildlife therein. The second route would traverse sensitive lands north of Hopewell Township but within the township. It would co-locate with an existing JCP&L high tension right of way to minimize environmental disturbance. However, that route would necessitate passing near Belle Mountain and then crossing Baldpate Mountain. Both formations are comprised of diabase extending more than 1000 feet below the surface. This particularly hard rock will require significant blasting to excavate an 8-10 foot deep trench that would be required to safely bury a 36 inch pipe.

Our concern is the potential consequences of the blasting. Vibrations are transmitted very efficiently through this diabase over unexpectedly long distances. As an example, at present we feel the vibrations from the blasting at the Trap Rock mine which is more than two miles away on Route 29.

Based on this ongoing experience, we anticipate even stronger vibrations arising from construction of a pipeline trench within 0.25-0.5 miles of the houses along Pleasant Valley Road even if well designed explosive charges are employed. Depending on the structural integrity of the diabase, the vibrations of the blast can be very efficiently transmitted to neighboring houses causing structural damage. Such damage could be manifested by cracking of foundations, tiled surfaces, plaster walls or swimming pools.

Even more troubling is the potential for the blasting vibrations to adversely impact the wells of the homes along Pleasant Valley Road and Valley Road. In this area all homes and farms depend on well water. Unlike wells which draw from alluvial aquifers, these wells are low yielding because they depend on ground water recharge which is delivered through existing sporadic fractures in the diabase. Depending on how the fractures respond to the blast vibrations, the water output of these wells could be increased, decreased or stopped entirely. Failure of a well would be devastating for a homeowner.

Drilling a replacement would be expensive since these wells typically are several hundred feet deep. In addition the new bore may not be successful since the source is not an aquifer but rather a chance pocket of water.

The potential economic benefits for construction of a new single-sited pipeline do not compensate for the impact on the New Jersey communities through which it passes. Here we alert FERC to the issue of blasting vibrations and well viability that is directly related to the underlying geology of the area through which the pipeline passes. After consideration of these environmental and geological concerns, we hope that you will reject the PennEast pipe line proposal.

Their submission is below:

William and Dorthy’s submission – FERC Generated PDF

William and Dorthy’s submission – FERC Generated PDF Alternate Site

The New Jersey Natural Heritage Program means nothing to PennEast

Cathy Urbanksi, the chair of the West Amwell Township Environmental Commission, has made another submission to the FERC site.

The New Jersey Natural Heritage Program
“As New Jersey continues to experience industrial and economic growth, it is imperative that we take steps to ensure that remaining areas of natural significance be preserved for their resource potential, their educational and research use, and their aesthetic and cultural values for present and future generations. As we become more aware of our dependence on our natural environment for our well-being and ultimate survival, we must answer one question: how can we best preserve our irreplaceable natural heritage.

The New Jersey Natural Heritage Program identifies the state’s most significant natural areas through a comprehensive inventory of rare plant and animal species and representative ecological communities. From the inventory, the Natural Heritage Database compiles information on the distribution, biology, status, and preservation needs of these species and communities”. (NJDEP)

The Natural Heritage Priority Sites Coverage was created to identify critically important areas to conserve New Jersey’s biological diversity, with particular emphasis on rare plant species and ecological communities.

“Using the Natural Heritage Database, the Office of Natural Lands Management (ONLM) has identified 343 Natural Heritage Priority Sites, representing some of the best remaining habitat for rare species and rare ecological communities in the state. These areas should be considered to be top priorities for the preservation of biological diversity in New Jersey. If these sites become degraded or destroyed, we may lose some of the unique components of our natural heritage.” (NJDEP).

Goat Hill has been designated as a Natural Heritage Priority Site. Goat Hill is the westernmost boundary of the Sourland Mountain. It is a steep, woody diabase hillside and the site contains three state endangered plant species (NJDEP). Any disturbance to the natural environment of this area should be absolutely prohibited. See map, below.

The PennEast preferred alternate route comes dangerously close and actually crosses this Natural Heritage Priority site. Any altercation to this site, whether from pipeline construction, the noxious gasses emanating continuously from the pipeline, possible explosions, or herbicide use, would pose a serious problem to the endangered plants. This area is a priority site for a very good reason.

We request that FERC choose the pipeline option of “no build” in order to preserve our critical ecological and rare communities and our fragile natural environment.

George Fisher, Mayor, West Amwell Township
Cathy Urbanski, Environmental Commission Chair, West Amwell Township

The map described is this one below:

The fat black line is (appropriately) the pipeline route.

This is the important part from their submission:

Goat Hill has been designated as a Natural Heritage Priority Site. Goat Hill is the westernmost boundary of the Sourland Mountain. It is a steep, woody diabase hillside and the site contains three state endangered plant species (NJDEP). Any disturbance to the natural environment of this area should be absolutely prohibited.

 

West Amwell has an extensive history of preserving land, both for ecological reasons and so we can continue to be a rural township in perpetuity. People like Cathy have been ceaseless in their efforts at preservation. And it isn’t just talk – we spend time and money ensuring the safety of our land.

Take a look at the West Amwell Natural Resource Inventory. The last entry in the document talks about Goat Hill:

The database has identified Natural Heritage Priority Sites that represent some of the best remaining habitat for rare species and exemplary natural communities in the state. These areas should be considered to be top priorities for the preservation of biological diversity in New Jersey. If these sites become degraded or destroyed, we may lose some of the unique components of our natural heritage.

Goat Hill has been designated as a Natural Heritage Priority Site (Figure 19). Goat Hill is the westernmost boundary of the Sourlands. It is a steep, woody diabase hillside and the site contains three state endangered plant species. This site was preserved in its entirety by the New Jersey Department of Environmental Protection, Green Acres in 2008. It is now known as Goat Hill Overlook.

My town has been at this for quite some time. Here’s a NJDEP release from 2003 talking about West Amwell’s preservation efforts at that time. It mentions:

Standing with local, state government and community leaders at Fiddler’s Creek Farm, Campbell announced the acquisition of the 197-acre turkey farm located in West Amwell. The preservation of Fiddler’s Creek Farm creates a continuous expanse of preserved land connecting the Delaware River Greenway and the Sourland Mountain Greenway. Fiddler’s Creek Farm consists of forested stream corridor, hayfields and pasture and commands a 360-degree view of the surrounding countryside, the Delaware River and Bowman’s Tower in Pennsylvania. A branch of Moores Creek, which supports 18 species of fish, flows through the property, connecting it to other preserved properties including the Howell Living History Farm and Baldpate Mountain. Delaware & Raritan Greenway, the Green Acres Program Hunterdon County and West Amwell Township were partners in the preservation of Fiddler’s Creek Farm.

Of course it goes without saying that the PennEast pipeline will be going through both Moore’s Creek and Fiddler’s creek.

West Amwell is also hardly alone in these efforts. Every town in Hunterdon has significant conservation programs in place and you see Green Acres, Open Spaces, Preserved Farmland, and D&R Land Trust signs all over the place. We think preserving the land is important. Too bad PennEast doesn’t.

The West Amwell submission is below:

West Amwell NJ – FERC Generated PDF

West Amwell NJ – FERC Generated PDF Alternate Site

The Nishisakawick Creek

Eric from Frenchtown, NJ writes about the threat the pipeline is to the environment around his home on the Nishisakawick Creek. The story quickly goes from talking about bald eagle citings to mention of a horrific 36″ gas pipeline explosion in the 90s in Edison, NJ:

I have read just about every comment submitted to date, regarding the proposed PennEast pipeline – I’m sure FERC has, as well. Aside from a handful of comments from individuals, ALL of the remarks favoring this project (perhaps a dozen) are from those that will directly profit from it. Utility companies & union representatives are all raving about the public benefit. This is in stark contrast to the hundreds of comments from the land owners, local governments, scientists, environmental groups, and individuals who view this project as a potential disaster. Why?

For the record, I live in Frenchtown, NJ and my home is adjacent to the Nishisakawick Creek. This stream has a C1 classification and for good reason. It is home to many species of animals that are endangered and/or threatened through loss of habitat. Three weeks ago, my wife and I had the pleasure of watching this bald eagle hunting next to our house:

As of 2012, there were only 119 breeding pairs of eagles in the state of NJ. Over the years I have also had the joy of viewing goshawk, bobcat, and corn snakes in our backyard, which are all classified as endangered by the NJDEP. Not to mention, the black bear, owls, heron, fox, coyote, deer, and dozens of other species that make regular appearances during the year. The stream is pristine and FERC should reject the PennEast proposal, out-of-hand, on this basis alone.

However, aside from the huge environmental impact this project will have, I am equally concerned about my family’s safety. Our home is located well within the thermal radius of the pipeline should it rupture. And in spite of all of the assurances from PennEast, NO ONE can erase the memory I have of the Durham Woods pipeline explosion in 1994. The flames were so high, I thought that my neighbor’s house was on fire, yet we were over 25 miles away. If this were to happen in Hunterdon, putting out the ensuing fires would be next to impossible, as our rural community relies on water tanker shuttles. Just how will PennEast handle a massive forest fire fueled by thousands of cubic feet per second of natural gas? Put simply, they can’t.

I took the time to carefully read PennEast’s “Draft Resource Report 1 and Summary of Alternatives.” In my humble opinion, the sections outlining project necessity and project alternatives were inadequate to say the least. According to PennEast’s report, the binding reservations during their “open season” demonstrated the need for this project. This is fallacious, as it only proves that members of the PennEast consortium (Spectra, UGI et al) want access to cheaper natural gas. According to the US Energy Information Administration, the existing pipeline infrastructure in NJ/NY can meet current firm demand without any problem. And recently, FERC has approved many major pipeline improvement projects to address future demand. Expansion projects with expected in-service dates between 2013 and 2015 have or will “add at least 3.5 billion cubic feet per day (Bcf/d) of additional capacity to New York/New Jersey and Mid-Atlantic markets.” These include the Transcontinental Gas Pipe Line Co.’s Leidy Southeast Expansion & Virginia Southside Expansion Projects, Tennessee Gas Pipeline Company’s Line 300 Expansion, Transcontinental Gas Pipe Line Co.’s Bayonne Delivery Lateral Project, Algonquin Gas Transmission’s Hubline/East to West Project, and Texas Eastern’s Transmission pipeline expansion project from Linden, New Jersey to Manhattan, New York.

New Jersey is already awash in gas transmission pipelines meeting current & future demand, and yet the gas industry insists that we need more. This is complete and utter nonsense and we certainly don’t need to cut across every Category One stream in our state to have another.

The explosion he mentions was written up in the New York times. According to the wikipedia article on the explosion:

http://en.wikipedia.org/wiki/Edison,_New_Jersey_natural_gas_explosion

…was caused by a rupture in a 36″ natural gas pipeline.  Not too coincidentally, PennEast is a 36″ natural gas pipeline.

Eric’s submission is available below:

Eric’s submission – FERC Generated PDF

Eric’s submission – FERC Generated PDF Alternate Site

Trashing the New Jersey Green Acre Program for Profit

Alex and Laura of Pennington go into details of of how their farm was preserved through the New Jersey Green Acres program several years ago:

Let me say categorically and emphatically that we are strongly against this idea. We worked extremely hard over many years with a consortium of nonprofit land preservation organizations to place a conservation easement over our property, which formed a cornerstone of preserved lands that include significant and vital stream corridor and woodland habitats for wildlife. It seems outrageous that the government, acting through New Jersey’s Green-Acre Program, would work so hard and expend so much of the public’s treasure and effort to preserve land, only to allow you to smash a substantial right-of-way, which would involve cutting down large amounts of preserved forests and carving through wetlands, through pristine lands that provide important ecological resources. It perhaps goes without saying that the stream corridors and wetlands and surrounding woodlands provide vital habitat for wildlife, important buffer zones for aquifer recharge and storm water sequestration, and passive recreation opportunities for residents. Our property, which we worked so hard to preserve, provides roughly 4000 feet of such stream corridor preservation, which you propose to undo completely.

Let me review a few of the facts we discussed. We granted a conservation easement over our property in December 2003 to a group of nonprofit land trust oriented organizations, including the Delaware and Raritan Greenway Land Trust, the Borough of Pennington, a local municipality, and the Stony Brook-Millstone Watershed Association. Each of these organizations used an allocation of available funds from the New Jersey Green-Acres program. The transaction was a so-called bargain sale, in which the nonprofit organizations and municipality contributed a portion of the funds for the bargain sale, and we donated a substantial portion of the value. We have lived quietly on the property since this time and worked to continue to preserve and maintain the conservation values of the ecologically sensitive lands and open spaces. The easement in question involves a combination of conservation easement areas(>95%), with and without public access, and a small portion dedicated to our private residential use, that comprises less than 5% of the property.

Left unchecked, this project would powerfully dissuade people granting conservation easements over the lands in the future. In light of the diminished state financial resources that are available for land preservation now and in future, it will dramatically undermine the willingness of individual private landowners to grant conservation  easements over their lands, and set back the cause of preserving land in our region to a measurable degree. These easements provide a vital tool to prevent real estate development from encroaching on the semi-agrarian nature of our region and our quality of life, and create the conditions under which we avoid flooding, create aquifer recharge, and maintain wildlife population and recreational opportunities.

The public access areas dedicated to the public access-conservation use are used by dozens of people a day for passive recreation such as running, hiking, walking and cross-country skiing. The trails are well used. The trails on the property that pivotally connect to interlocking lands owned by the state of New Jersey Department of  Environmental Protection in the so-called Lake Baldwin Wildlife Management Area, and other lands protected from development and under conservation easement that are owned and managed by the D&R Greenway Land Trust together comprise a mosaic of hundreds of acres of preserved property, trails and natural beauty that provide an important buffer to development and a vital ecological function.

Your project would unavoidably cut through these important trail networksand wetlands, cutting across a swath of woods and agricultural lands, and reducing their conservation value. Protecting preserved lands is a critical stewardship function of the local land trusts we worked with and who continue to have responsibility for this vital role. I served astrustee of the D&R Greenway Land Trust for eight years after we granted the conservation easement, because I felt it was important to work hard in this critical stewardship process of defending the easements once they are granted and finding new properties to preserve. My wife Laura, has recently joined the board of the Stony Brook Millstone Watershed Association in part driven by a similar concern.

We pledge to you that together with as many willing nonprofit land preservation organizations as will support us, and by organizing individual owners of property affected by your plan, we will work hard to defeat your project at every stage. As a society we cannot abide by the wanton destruction of preserved lands.

They bring up a very good point I hadn’t considered before: by breaking conservation easements, PennEast will be providing a powerful disincentive for people to protect lands in the future.

Their entire submission is available below:

Alex and Laura’s submission – FERC Generated PDF

Alex and Laura’s submission – FERC Generated PDF Alternate Site