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.

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

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.

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

The EPA says they’re not going to rubber-stamp this pipeline

The EPA submitted comments recently about the Environmental Impact Statement (EIS) required by this pipeline. It says in part:

On December 18, 2014 CEQ released revised draft guidance describing how Federal agencies should consider the effects ofgreenhouse gas (GHG) emissions and climate change in NEPA reviews. In light ofthat guidance, agencies should consider both the potential effects ofa proposed action on climate change as indicated by its GHG emission; and the implications of climate change for the environmental effects of a proposed action. The Draft EIS should analyze GHG emissions associated with the construction and operation ofthe project, and from the production, transport and combustion ofthe natural gas. Provided is a link to the revised draft guidance:

http: //www.whitehouse.gov/administration/eop/ceq/initiatives/nepa/ghg-guidance

According to the PennEast Pipeline website, portions of the project may be co-located in the same easement as existing utilities. Co-location may reduce losses ofnatural resources and is encouraged. The Draft EISshould describe the sections and acreages ofthe project that will be co-located, how the pipeline project will be integrated, and how construction and operation ofthe project will affect existing utilities.

Land requirements and environmental information for proposed pipeyards, wareyards and any secondary features of the project should be included in the Draft EIS to ensure the public has a complete picture of the environmental impacts of the project. Cumulative impacts can result from individually minor, but collectively significant, actions taking place over a period of time. EPA recommends a thorough consideration of secondary and cumulative impact in the EIS. Additional suggestions and more detailed comments related to scoping ofthe study are enclosed with this letter.

The letter is in bureacratese, but it saying in no uncertain terms that The EPA knows what’s going on and they’re not going to let these pipelines get rubber-stamped by the FERC without a fight. The reference to the revised guidance to NEPA on green houses gases is pointed and a reminder to FERC that they are not above the law of the land.

It’s even more pointed where the EPA mentions cumulative impacts. I believe when they mention this – “Cumulative impacts can result from individually minor, but collectively significant, actions taking place over a period of time. EPA recommends athorough consideration ofsecondary and cumulative impact in the EI” – they aren’t just talking about PennEast. It’s a shot across FERCs bow that their plan of criss crossing the country with a network of pipelines and sneaking it past the EPA and other conservation organizations by studying them individually in isolation has failed.

The EPA continues in the technical section:

The NEPA document should include a clear and robust justification ofthe underlying purpose and need for the proposed project. In order for the project to move forward, FERC would need to issue a certificate of “public convenience and necessity”. We recommend discussing the proposal in the context of the broader energy market, describing the factors involved in determining whether there is or is not a truly “public” convenience and necessity for this facility.

If you decode that, it’s basically saying: “PennEast’s justification is a load of crap, and we both know it”. And there’s more!

The Endangered Species Act (ESA) provides for the listing of endangered and threatened species of plants and animals as well as the designation ofcritical habitat for listed species. The ESA prohibits the taking of any listed species without (for federal agencies) an “Incidental Take Statement.” The EIS should provide a description of terrestrial, wildlife and aquatic species in the study area. Any threatened or endangered species must be listed. Critical habitat for threatened or endangered species should be property identified. The EIS should describe the potential project impacts to these species. The most recent state and federal threatened and endangered species coordination letters should be included in the EIS. In addition, we recommend that the appropriate state and federal agencies be contacted annually at a minimum regarding these issues.

The EPA is telling the FERC that they better listen to environmental agencies and include their data in the EIS. Having the FERC send a surveyor out for a couple of days isn’t going to cut it.

We move on to farm lands:

Farmland
In New Jersey, the proposed route for the PennEast pipeline appears to cross many farms preserved under the State of New Jersey Department of Agriculture Department preservation program. The Draft Environmental Impact Statement should discuss this program, how the pipeline construction and operation will impact the preserved farms in New Jersey and Pennsylvania, and any necessary mitigation.

They have to detail in their EIS how they’re threatening preserved farms. They have to say how they’re mitigating impact. Which I’m not sure how they can – how do you mitigate loss of usable farm land? It’s not like we can manufacture some more to compensate.

The EPA also knows that pipeline accidents can and do happen. And PennEast has to include that in their EIS as well.

Hazardous sites/Spill concern

The pipeline has the potential to cross several areas that may have RCRA corrective action sites CERCLIS sites or on-going leaking underground storage tank cleanups. The Draft EIS should describe any potential hazardous waste cleanup sites in the vicinity ofthe project and how the project would affect active remediation sites.

A pipeline failure during the construction or operation can cause potential toxic environmental damage to water quality, various habitats, communities, flora, and fauna. EPA recommends that the draft EIS address the potential for such a failure, appropriate state- identified and FERC-identified Best Management Practices (BMP’s) for spill prevention. The Draft EIS should describe the capabilities of emergency operators along with necessary emergency plan and mitigation of spills in emergencies for all sections of the pipeline and all construction and use phases ofthe pipeline’s life.

Note that the EPA explicitly mentions the “capabilities of emergency operators along with necessary emergency plan and mitigation of spills in emergencies for all sections”. From my point of view, how are volunteer fire departments along the route that are already stretched thin for resources going to deal with a pipeline accident?

Traffic impacts are also mentioned – I’m glad to see that, not many people have talked about how construction is going to impact roads. Especially in rural communities when there aren’t a lot of options to get from Point A and Point B.

Tragic and Transportation: The EIS should address traffic and transportation as it
relates to the Proposed Action, especially during construction. It may be necessary to provide an evaluation of existing roads specifying existing levels of service at major intersections near the project area as well as accident data.

And then the EPA pulls out it’s heavy guns – and points them at FERC’s head:

Secondarv and Cumulative Impacts

The Council on Environmental Quality in 40 CFR 1508.7 implementing NEPA defines cumulative impacts as “impacts on the environment which result from the incremental impact of the action when added to other past, present, and reasonably foreseeable future actions regardless of what agency (federal or non-federal) or person undertakes such other actions.” The cumulative impacts analysis should consider the environmental impacts of the project as a whole and as one of a number of the other proposed and/or approved actions in the area that would have the potential to impact the same resources, including natural and community resources such as wetlands, air quality and EJ communities. This should include information on proposed and reasonably foreseeable projects in the study area ofLuzerne, Carbon, Northampton and Bucks Counties in Pennsylvania, and Hunterdon and Mercer Counties in New Jersey, documenting location, distance from the proposed project and description ofpotential cumulative impacts. These should include, but not be limited to: FERC jurisdictional projects, intrastate pipelines and compression, gathering pipelines, gas processing facilities, gas wells, and projects such as industrial or commercial facilities and other developments regardless ofwhether these actions are energy related or not, or whether or not FERC has jurisdiction over them.

We recommend focusing on resources or communities of concern, or resources “at risk”
which could be cumulatively impacted by all of the above actions. Please refer to the Council on Environmental Quality (CEQ) guidance on “Considering Cumulative Effects Under the National Environmental Policy Act”, and EPA’s “Consideration ofCumulative Impacts in EPA Review of NEPA Documents” for further assistance in identifying appropriate spatial and temporal
boundaries for this analysis.

The EPA comes out and shoves the reality right back at the FERC: the EPA knows there are many pipelines and other energy projects being planned. Everybody knows it. So the EPA is demanding those projects be considered as part of the EIS and show their cumulative impact.

I have no idea if this will make a difference but if FERC does not follow the EPA’s recommendations it is, at the very least, an excellent basis for a law suit.

The FERC thinks that since they have sole approval authority they can ignore every other law in their quest for approving energy projects as fast as possible. This is in fact wrong. Laws often conflict with each other, and when that happens it’s the courts that decide.

Let’s hope if the FERC does continue to ignore other agencies that either our law makers fix the situation by taking sole approval authority away from the FERC. Or that towns and organizations impacted by their decisions successfully take them to court and prove their numerous violations of federal laws and Presidential directives.

The EPA’s complete submission is available below:

US EPA’s submission – FERC Generated PDF

US EPA’s submission – FERC Generated PDF Alternate Site

The FERC is not here for the people, it’s here for the gas companies

A couple of contributors to the Stop Penneast pipeline Facebook page (https://www.facebook.com/stopthepenneastpipeline) pointed out a presentation given by the FERC Office of Energy Projects last fall at the Maine Natural Gas Conference.

This presentation (available here) shows that FERC is indeed a cheerleader of the natural gas industry, and the purpose of this presentation seemed to be to help companies maximally exploit natural gas reserves all over the country.

There are a few smoking guns in this presentation.

Smoking Gun Number 1 – FERC knows that demand for natural gas in the US is very low. And will remain so for the foreseeable future.

This graphs shows projected consumption by type of consumer out to 2040:

  • Residential use of nat gas – flat.
  • Commercial use – flat.
  • Industrial use – flat.
  • Lease and plant fuel – flat.
  • Transportion – very moderate growth.
  • Electric power – moderate growth.
  • Exporting gas to foreign countries – massive growth.

Basically FERC is acknowledging that there is only one growth opportunity in the US for natural gas – electrical power generation.  This will grow modestly as power plants convert from coal to natural gas.  But this is only a modest gain, and cannot account for the billions of cubic feet coming out of regions like Marcellus every day.

FERC knows the only place for the majority of this excess gas to go is to exports.  This will be massively profitable as natural gas is extremely expensive in places like Asia.

If you live in NJ and PA – this gas will not materially benefit you.  FERC knows this. And I have bad news for all the people cheering the pipeline companies because you think your gas prices are going to plummet: they’re not. In fact, research and common sense says that your gas prices are likely going to climb modestly.

This is basic economics. Consumption is flagging in the U.S. Demand is surging in natural-gas poor areas like India and Asia. Natural gas is very expensive there. So the natural gas companies will maximize their profits by getting as much gas to expensive areas as possible.

A side effect of this is that your residential rates will go up slightly, because no one will want to ship gas to cheap residential customers when the LNG export stations are begging for suppliers.
Smoking gun number 2 – FERC knows there are a ton of pipelines in pre-filing stage

They know it and they trumpet it loudly. They purposefully evaluate them in isolation but they know these pipelines are all connected and are part of a master plan of the FERC and energy industry to maximize profits, but if they evaluated them together the ecological impact would be obvious and overwhelming.  Only by evaluating them individually can they hope to slip this past residents and state DEP officials.

Smoking gun number 3 – FERC knows about all the proposed pipelines

Look at that slide – it’s absolutely outrageous. Pipelines are criss crossing the country in this picture, and FERC is extremely satisfied with this result. Firms like Spectra Energy, a Penn East partner, crows about running pipelines all over the country to get gas “where the lights are”. What they mean is “where they can make the most money” – over seas.

Smoking gun number 4 – FERC knows and champions the proposed LNG export facilities

FERC knows there’s nowhere for all this gas to go in the U.S. They know the purpose of all this pipelines is to get the gas to facilities to turn the product into liquid natural gas (LNG) and ship it overseas. LNG is 600 times denser than nat gas in its natural state, so it’s highly efficient to ship it by LNG cargo ships this way. The ones in this slide are on top of the 4 LNG export stations already approved by the FERC.

And there’s another slide showing 13 more!

Those are bad enough. But the real smoking gun is yet to come. FERC says you – the residents, the home owners, the environmentally conscious, the teachers, the emergency responders, the individuals worried their drinking water will be contaminated forever, the non-profit organizations dedicated preserving our land and our heritage – YOU ARE IN THEIR WAY

If you are worried about this pipeline, FERC sees you as the enemy. You are a negative issue they must work around. You are an impediment to them helping gas companies reap billions of dollars from Marcellus shale. You an annoyance that irritates them and they really wish you would just go away so they get on with their jobs.

The final insult – there is not a word in this document about the ecology, conservation, or safety.

It is abundantly clear that FERC is a cheerleading organization who sees its mandate to facilitate big energy companies in any way they can. This isn’t about infrastructure for America. This is about money and profits for large industries.

Things you can do

There are things we can do collectively to help stop this pipeline and the many others like it.

Talk to your government representatives.

I think it’s clear that the laws have to change. The FERC should not be the sole agency in charge of approving pipeline and LNG projects. They are clearly not willing or capable to do the environmental surveys that they are required to. Write your Congressmen and Senators and demand that other agencies such as the EPA have the right to shut pipeline approvals down if they do not meet their standards. Demand that the Clean Water Act be upheld. Hold the government and the pipeline companies accountable.

Demand funding for government oversight.

Demand a tax on pipeline companies to fund more government regulation in the approval phases and oversight phases. Make them pay for the cost of these pipelines in full so we can ensure they are safe and ecologically sound. This will not bankrupt them. The whole FERC budget is a mere $175 million. This is a trillion dollar industry we’re talking about – a mere 1% tax would barely dent their budgets but would fund oversight quite easily.

Sue them.

If the FERC approves this pipeline, urge your town, county, and state to sue the FERC for violating their mandates. It’s been done before and people have won.

Force eminent domain.

Don’t give into the FERC and PennEast. Fight for your rights. Deny them access to your property, do not let them buy an easement. Force them to sue you. If enough people force PennEast to court it is likely they will just walk away, or at the very least choose a more sensible route that does not impact so many farmsteads, preserved areas, and ecologically delicate locations.

Write your state’s DEP.

Talk to your DEP representatives. They are our last line of defense. Even if FERC approves this pipeline Penn East must get approval from them before they can begin construction. Urge the DEP to hold PennEast to the letter of the law and protect our category 1 streams, our watersheds, our grand rivers like the Delaware.

Keep up the pressure.

Keep submitting to the FERC. Keep demanding to be heard. Keep up the protests. The FERC has noticed – and it’s worried. It’s worried congress will act and strip them of their regulatory approval capabilities. And they are right to be worried.  Help make their fears a reality.