We’ve got sinkholes too!

It isn’t just earthquake and rain to worry about. Apparently Pennsylvania is serious sinkhole country to boot. Judith from Easton PA writes:

I am writing to register my strong opposition to the proposed PennEast pipeline. My main concern are the sinkholes that are in the area of
the pipeline,the destruction of the trees,and the run off down the mountain of hexenkopf and into our property and the farm across the street. This will affect Fry’s Run and THE Delaware River…
We have the Columbia Pipeline very close to us and know that you have already approved The LEIDY SOUTHEAST expansion project which will deliver gas from the same start point to the same end point…WHEN WILL THIS STOP???

An interesting thing to note here as well is her mention of the other pipelines already constructed and those in planning. From what I’ve read the FERC process does not consider pipeline projects all together to assess their aggregate impact on the area. Instead they study each one isolation as if none of the others exist.

This is glaring hole in the FERC process that makes the PennEast pipeline looks much better than it actually is in reality. Consider all the proposed pipelines simultaneously and you see that:

a) The supposed need for “more pipelines” goes down as you keep proposing…yet more pipelines.

b) The environmental impact is going to be much greater.

c) The percentage risk of catastrophe goes up with every pipeline built.

You can see Judith’s submission here:

Judith East PA – FERC Generated PDF

Judith East PA – FERC Generated PDF Alternate site

Alternatives not seriously considered

Pamela of West Amwell wrote a tour-to-force submission to the FERC objecting to the pipeline and the procedures being followed in its review.

Pamela of West Amwell – FERC Generated PDF

Pamela of West Amwell – FERC Generated PDF Alternate Site

Pamela points out in particular that PennEast there are many good alternatives to the proposed pipeline route, and they simply are not taking those alternatives seriously. It’s a dense, information packed essay that I urge you to read in full. This one section really caught my eye though:

2) The Transco Alternative as proposed has less potential for impacts in a majority of the CIA categories. It is understood that the Transco Alternative as proposed does not provide the same connectivity benefits as the Preferred Alternative and would need modification prior to impact assessment; however, in the absence of well-developed Transco Alternative(s) that would meet connectivity needs, my comments reference the Transco Alternative as presented.

A comparison of the Critical Issues Analysis (CIA) items in Tables 10-2 and 10-7 shows that the Transco Alternative has less potential impacts within its 400-foot study corridor than the Preferred Alternative. The Transco Alternative:

– Crosses one less municipality;
– Fewer streams;
– Fewer cold water fishes/fewer warm water fishes;
– Fewer naturally producing trout waters;
– Fewer Non-Chapter 93 Designated Streams;
– Fewer Category 1 Streams;
– 26 less acres of NWI wetlands within its corridor;
– Fewer centerline crossings of NWI wetlands;
– Fewer wells;
– 777 less acres of CNHI-designated habitat (Core Habitat/Supporting Landscapes);
– Zero acres of Natural Heritage Priority Sites (compared to 3 acres for the Preferred Alternative);
– 15 less acres of wellhead protection area within its corridor;
– Zero acres within the Delaware and Raritan Canal Commission Review Zone B (compared to
669 with the Preferred Alternative);
– 225 less acres of State Parks (PA) within its corridor (6 acres compared to 231 with the Preferred
Alternative);
– 58 less acres of State Game Lands (PA);
– 203 less acres of NJ Farmland Preserved Parcels;
– 18 less acres of Agricultural Security Areas;
– Zero acres of Karst (PA) (compared to 197 acres within the Preferred Alternative); and,
– Lower percentage of wetland acres within its corridor

Co-location isn’t magic fairy dust

An original criticism of the PennEast project was that it was 0% “co-located” in NJ. That is, it cut a brand new path through virgin territory. The preferred approach is to co-locate a new pipeline along an existing easement to reduce the environmental impact.

That’s all well and good, but co-location isn’t magic. Problems just don’t disappear because you co-located your pipeline. This is especially true when you mix and max utilities. Co-locating two pipelines next to each other may make sense. Putting a pipeline along a high tension power line route….hmm, maybe not so much.

Brian from West Amwell explains why:

1. PennEast’s proposed route has been chosen to follow alongside existing right away electric utility easements with little regard to homeowners along those existing easements. There are quite of few houses with smaller yards (1 to 3 acres) in our neighborhood which run along the electric utility easements. Just so PennEast can say that they are following along current easements, they will attempt to squeeze the pipeline through our neighborhood regardless how close our homes are and how much more land we will end up losing for another right away. Just because it is running alongside a current easement doesn’t mean it is the best path. This proposed plan has not taken into account proximity to homes, woodlands, wetlands, and historic sites, etc. that are in its path. This plan does not appear to be well planned or thought out. Basically, they are just blindly following alongside an electric utility easement without regard.

2. I also believe PennEast is not dealing with property owners in good faith. PennEast hosted a dinner where homeowners could look at map models of the 400 foot study corridor. I was invited to the meeting as a homeowner who was supposedly in the 400 foot study corridor. At the dinner, they showed me on the map that my property is no longer in the 400 foot study corridor, yet I was still pressured at the dinner to consent to have my property surveyed. I was even called after the event by the same person asking for a survey. First I’m in the study corridor and then I’m not in the 400 foot study corridor, but they still need me to consent to a survey.

His submission is here:

Brian from West Amwell – FERC Generated PDF

Brian from West Amwell – FERC Generated PDF Alternate site

Baldpate mountain’s unique ecology threatened

Baldpate mountain is right near our house. In fact you can see it from my backyard, it’s right across the valley from us. We’ve taken our Foxhound hiking there on the nature trails and absolutely love it.

The Washington Crossing Audubon Society posted a 20 page comment to the FERC site about the impact the pipeline will have to Baldpate and the surrounding Sourland mountains:

Washington Crossing Audubon comments – original image

Washington Crossing Audubon comments – Original image Alternate Site

Baldpate Mountain has been cited as a preferred alternate route because of the existing power line right of way. While using existing rights of way is generally a less environmentally disruptive option, the geology, environmental sensitivity and ecological uniqueness of Baldpate Mountain makes it a poor choice.

Because of the extreme ecological sensitivity of Baldpate Mountain, Washing Crossing Audubon society opposes routing the PennEast pipeline through the JCP&L power line cut that bisects Baldpate Mountain. An outlier of the Sourland Mountains, Baldpate Mountain contains some of the richest biodiversity in New Jersey. Southern and northern species meet at Baldpate, enriching the flora and fauna. Due to the high quality habitat, including areas of intact understory, and the mingling of southern and northern species, Baldpate Mountain has the highest concentration of breeding Neotropical migrants in New Jersey. The thirty-one Neotropical breeding species including thirteen warblers and the Yellow-breasted Chat, two tanagers, three vireos, and two Catharus thrushes. Twenty-eight breeding Neotropical migrant species are ranked by the American Bird Conservancy (ABC) as birds of conservation concern. Baldpate is also an important migratory stop for Neotropical birds. Fifty species of Neotropical migrants of conservation concern use Baldpate Mountain as a migratory stop. A total of 165 species have been report to erbium at Baldpate; sixty-one of these are ABC species of conservation concern that use Baldpate for breeding, a migratory stop or as part of a resident territory. The New Jersey threatened Long-eared Owl was winter roosts at Baldpate Mountain.

Because Baldpate Mountain is long and narrow, it is highly sensitive to disruption from activity on the power line cut that bisects the forest lengthwise. Of special concern is noise from blasting and construction that would penetrate deeply into the forest, interfering with vocal communication between birds at a critical time during the breeding season. Construction along the power line cut and especially extending the width of the power line cut would destroy or degrade adjacent breeding habitat along the length of the mountain. Because Baldpate breeding territories are saturated, these birds cannot move further back into the interior forest if disturbed. There is no place for the displaced birds to go. Blue-winged and Chestnut-sided Warblers, species of conservation concern that breed at the forest-power line ecotone, would be especially affected. Increasing the width of the power line cut would also extend the edge effect further into the core forest, allowing increased access for brown-headed cowbirds, a nest parasite, and invasive species. The ecosystem at Baldpate is intact but stressed, making Baldpate sensitive to new disturbances.

The blasting necessary to penetrate eh extremely hard diabase substrate has the potential to affect the springs that feed creeks that originate on Baldpate, disrupting their flow and the animals that depend on them, including the breeding Louisiana Waterthrush, a species of conservation concern.

….

The power line cut predicates the requirement for an environmental impact statement. Considering the ecological sensitivity of Baldpate Mountain, the power line cut should have never been placed there. A thorough biological inventory and environmental impact statement would clearly show wy. The damage to the fragile by intact Baldpate Mountain ecosystem should not be compounded by allowing PennEast access for their pipeline.

A Google Earth snapshot of Baldpate is shown below with the pipeline route highlighted in purple through it.

The Mayor of Kingwood NJ is hard core

Richard Dodds, the mayor of Kingwood NJ, knows how to fight for his town.

Richard Dodds, Baptistown, NJ.

Hello, my name is Richard Dodds and I am the mayor of Kingwood Township.

Kingwood Township is 36 square miles in area and has approximately 3,800 residents. All of the households in Kingwood Township are dependent on well water and onsite septic systems. The proposed pipeline will cut through seven miles of the township from north to south with potential impacts on every single well. I urge the commission to read the report and testimony of the Kingwood Township Environmental Commission which clearly spells out Kingwoods underlying geology and the source of our drinking water.

If this Commission does approve this project, I am requesting that FERC requires that all the wells in the Township be monitored – not just those on the properties where the proposed pipeline is sited. This is a critical issue in Kingwood because of the geological features of our bedrock, as described in the aforementioned report. The monitoring, conducted for a minimum of 10 years, should consist of pre and post construction depth to water, well capacity, and recharge reports. This work must be done by qualified independent hydrogeologists paid for, but not employees of, PennEast.

If any wells are negatively affected by the construction of the pipeline, Kingwood Township expects that the Commission will require PennEast to make whole those property owners that are affected, by methods including but not limited to drilling new wells, providing potable water in perpetuity, or fee simple purchase of the property at rates based on the past 10 year high. The same monitoring and making whole should be done for all septic systems within the township.

Kingwood is known for its perched water table and numerous streams. Any and all streams, stream buffers, wetlands, and wetland buffers must be fully delineated and avoided along the route. The wetlands and streams carry water that is used in the recharge of our groundwater and provides drinking water throughout the region. Furthermore, a number of the stream crossings in the proposed pipeline route are high-quality systems that are protected by Federal laws. Delineations must be done by qualified environmental scientists paid for, but not employees of, PennEast.

In addition to our precious water, Kingwood Township is home to a host of threatened and endangered species. Again, I urge you to read the read the report and testimony of the Kingwood Township Environmental Commission. If FERC does approve this project, I am requesting that FERC require a complete multi-season study of threatened and endangered species be conducted within 2000 feet either side of the pipeline footprint. That study should meet the standards set by the New Jersey Department of Environmental Protection (NJDEP) for development in the New Jersey Pinelands or the New Jersey Highlands. This study must be done by qualified environmental scientists paid for, but not employees of, PennEast.

The full text is in his submission below:
Kingwood Mayor Comments – FERC Generated PDF

Kingwood Mayor Comments – FERC Generated PDF Alternate Site

Robbing a farm of its organic certification

Carina in Delaware township NJ submitted USDA documents to the FERC that certify her farm as organic. In her submission comments she states:

I have attached CRP contracts with the Hunterdon County USDA that certified my farmland as organic over a period of 10 years. The PennEast Pipeline would destroy them and negate the time and taxpayer $ spent under PF15-1.

Her submission is here:
Carina Delaware Township – FERC Generated PDF