The FERC.gov site has been down for quite awhile today so I haven’t been able to file our submission yet. I’ve linked to it here:
Apologies for the length, I’m a pretty wordy individual.
Update:
The FERC website stayed up long enough for our submission to take 🙂 Our official comments (same as the document above are available below):
The pipeline will carry 1 billion cubic feet of natural gas through it per day. PennEast says that’s “enough gas to serve more than 4.7 million homes”. In their FERC filing under “Purpose and Need” they state that “…the Project is designed to bring lower cost natural gas to homes and businesses in Pennsylvania and New Jersey”. They repeatedly state that this pipeline is for the benefit of New Jersey and Pennsylvania.
Here’s some facts taken from the U.S. Energy Information Adminstration (http://www.eia.gov/).
The entire state of NJ has approximately 2.6 million natural gas residential consumers. All of Pennsylvania also has about 2.6 million natural gas residential consumers. Combined that’s 5.2 million residential consumers.
PennEast is delivering enough gas for “4.7 million homes”. Wait, what? This pipeline carries enough gas to supply 90% of all consumers in both states? Why do we need this pipeline? We already have sufficient supplies for both states. In fact this is a smokescreen, this pipeline is vast over kill for NJ/PA residential use. Unless PennEast thinks NJ and PA will double the number of natural gas consuming homes, which seems a bit ridiculous on its face.
Maybe we should factor in all uses of natural gas in both states, both residential and commercial. eia.gov has those numbers too. In total NJ averages 1.8 billion cubic feet of natural gas consumption per day across all consumers, and 3.0 billion in PA. So that’s 4.8 billion cubic feet used by both states per day. These numbers still don’t add up – this one pipeline represents 20% of our total commercial and residential consumption in the two states combined.
Worse – since 2011 PA has been a net-exporter of natural gas, thanks to the Marcellus Shale fracking operations going on there. This means they already have an EXCESS of natural gas and certainly do not need more locally.
In fact the backdoor PennEast is trying to sneak in through is price volatility. In January 2014 there was a sharp price spike in natural gas prices for a couple of days, peaking out near $120 when it is normally $4-$8. From January 2009 to October 2013 there were 8 other short spikes of much smaller magnitude.
This is PennEast’s true justification. Because natural gas spikes a few days a year, we should get this 108 mile long, 3′ wide, high pressure natural gas pipeline. This will indeed reduce or eliminate those spikes.
Do you really think PennEast is spending a billion dollars to eliminate 10 days worth of price spikes over a 5 year period?
Of course not. Their justification is those 10 days in a 5 year span. Their real motivation is that they’ve already sunk a ton of money into Marcellus Shale production, and they want to ship that gas somewhere. We sure as heck don’t need it in NJ and PA, and they know that. Look at the eia.gov web site graph for total consumption in NJ and it’s been effectively flat since 1998. FLAT.
Their FERC submission highlights NJ and PA companies that will be using the gas provided. There are indeed some. But it doesn’t mention the non-NJ/PA companies.
You see companies like Spectra Energy, a part-owner in PennEast. Spectra has a grid of pipelines across the entire eastern sea board of the U.S. They show in their presentations that PennEast gas could go anywhere they want in that grid – including to LNG (Liquid Natural Gas) sites. Once in LNG form it’s shippable over seas.
It’s for companies like Crestwood. It’s proposing a new pipeline to connect to PennEast called the MARC II Pipeline Project. Pipelines begetting yet more pipelines.
It’s for companies like New Jersey Natural Gas and their Southern Reliability Link project. The Southern Reliability Link is yet another pipeline they’re connecting to PennEast. More pipelines!
Take a look at what energy analysts in the market place think. Here’s an article from research firm Sterne Agee. It states:
Things are already ugly in U.S. natural gas markets, and its only going to get worse, according to research firm Sterne Agee. SA analysts Tim Rezvan and Truman Hobbs argue that the double whammy of continued supply growth amid weak demand mean that natural gas prices are still not done dropping, and slash 2015/2016 estimates across the board for the natural gas firms in their coverage universe.
Rezvan and Hobbs lower their 2015/2016 Henry Hub natural gas forecast “to $2.70/$3.20 per mcf from $3.40/$3.70. We also trim our 2015/2016 WTI forecast to $58/$65 from $63/$70. The glut of oil and gas in the U.S. will require a lengthy, at times painful, healing process for coverage companies and E&P investors. Investors should remain bottoms-up focused, commodity agnostic, and prepared to look beyond 2015 gas price woes.”Natural gas prices likely to stay depressed well into 2016
Why do we need this pipeline again?
Julian in Pennington, NJ is another resident along the pipeline route who’s had unsatisfactory discussions with PennEast representatives. He tells the FERC:
As a landowner in Hopewell Township (NJ), Block 92, Lot 8, on Scotch Road, I object to the current proposed pipeline route along the existing power easement. That route would require clear cutting a large swath of old growth forest – hundreds of years old – on my and adjacent parcels. This is a forest my family, neighbors, community and I explored and enjoyed for many years, in my case, the past 50 years since moving there in 1965.
I mentioned this objection to several pipeline representatives, and was told by all that clear cutting old growth forest is not a consideration for them in routing or re-routing their pipeline, period. I hope that your agency would think otherwise – that forest will take hundreds of years to regenerate and provides much needed habitat for a wide range of plant and animal life.
In addition, I object generally to the need for this pipeline. The fact that interested parties will purchase natural gas to resell abroad does not, in my view, establish the kind of need warranting a certificate of convenience and necessity. The current slow-down in drilling Marcellus Shale in PA arises not from a lack of pipeline infrastructure, but from low prices resulting from arguably an over-supply, a condition which the
proposed pipeline would only exacerbate.Thank you for your consideration.
I supposed PennEast caring about clear cutting old growth forest shouldn’t be a surprise to anyone anymore.
Take note of the other section of Julian’s submission. As he indicated exploitation of Marcellus Shale is slowing down significantly because prices of oil and gas are so low. We have a glut of energy and this pipeline makes no sense.
Compare this pipeline to the Leidy Southeast expansion. Leidy is carrying only half as much natural gas, but it’s being spread from NY down the coast to the Carolinas. With this already approved, why do we need a PennEast pipeline carrying twice as much natural gas – but supposedly only targeted to central NJ and eastern PA? This makes no sense – the PennEast pipeline will effectively double the amount of natural gas being pumped into the region. There’s no way we could use all this gas here. In fact it’s pretty obvious that the gas will not benefit our region at all but will be shipped elsewhere. Possibly ashore – the news is awash with stories of U.S. becoming an exporter of natural gas for the first time and companies aggressively pursuing permits from the government to ship natural gas abroad.
Julian’s submission is available below:
The scoping meeting is in Trenton tonight at 6pm, please go!
West Trenton Ballroom
40 W. Upper Ferry Road
West Trenton, New Jersey 08628
If you live in Southern Hunterdon county or Mercer county this is the closest scoping meeting to you by far.
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
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
The Cost of the Pipeline 