People’s voices are being lost by inadequate FERC processes

Below are some additional comments I submitted today to the FERC regarding the scoping process and the poor resources they give individuals to have their voices heard.

I believe the FERC is not providing adequate means for impacted residents to have their voices heard in regards to the PennEast pipeline. While at first glance it may appear that there are sufficient avenues for individuals to comment, including the ferc.gov website and the individual scoping meetings, upon deeper inspection it’s clear that these alternatives are deeply flawed and rob people of their rights.

We have only two scoping meetings in NJ, located an hour apart from each other. As an example, the Trenton location was closest to me but I was unable to attend due to a conflict with my job. As such I was forced to drive to the northern Hunterdon location which is a very long distance away. I know many people have been dissuaded from attending the pipeline meetings because of timing.

In addition the meeting lengths are inadequate. At both meetings time was cut off with people who were on the speaking list dropped. I was lucky enough to speak because I left my job early and made the long drive, arriving at the meeting location 40 minutes in advance. As it was I wasn’t able to speak until 9:40pm, less than twenty minutes before the meeting was terminated. That means people who arrived on time at 6pm were left out.

FERC needs to extend the scoping period by at least 90 days and add two more meetings venues in NJ so that people’s voices will be heard.

The other issue is the ferc.gov web site. This web site has multiple down times every single day. Literally every day – I check the site routinely to search for interesting comments to highlight on my weblog, and every single day I encounter problems. I know there is the backup site for searching, but that does not help people who want to make comments or eFilings. To make matters worse the web site is extremely hard to use requiring a number of arcane steps to get comments submitted or to submit files. I am a software developer with 25 years experience in the field and I, as a software professional, have extreme difficulty in using your site. My initial eFiling took multiple tries to go through.

I can only imagine how the average citizen with a less technical background copes with the site.

This provides a material barrier to people letting you know about issues with the pipeline and its proposed route.

We’re dealing with a billion dollar pipeline, slated to carry a billion cubic feet of natural gas per day in a high pressure 3 foot wide piece of steel, in a trench 8 feet deep that’s over a hundred miles long. And our only tools to comment on this immense project is a creaky stone age web site reminiscent of the worst of the Internet from the 1990’s, and over-crowded, widely spaced apart scoping meetings where people’s scheduled speaking times are dropped.

I’ll update this post with the link when it becomes available on the eLibrary FERC site.

My FERC comments at the scoping meeting

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?

Impact on all-volunteer fire departments an issue

Bernice from Milford brings up many good points, among them a note about the nature of the fire departments in our area. The FERC should take notice:

On a closer to home note, I live in Hunterdon County, a very rural, historic, river town area. We are living on a fault line and had an earthquake a few years ago. We have only volunteer fire departments. I have lived through the Edison and Allentown pipeline explosions. It looks like the end of the world. Last winter, a house that probably would be on the pipeline route, went on fire. Every fire department for miles was there. They got stuck getting up the hill to the house and flagged down my kids in a four wheel drive truck to try to clear a path through the snow. They couldn’t and instead had to help drag hoses toward the fire. Needless to say, the house burned to the ground.

What would happen if a pipeline exploded?

Devastation.

And on an even more personal note, I have wanted to be a farmer all my life. I finally bought a farm with eleven rental units on it, nine years ago. I went through the expense of getting a building lot approved for a farmhouse and paid an architect for drawings. Now there will be a bomb in my front yard when I build. How much value will that house lose? All of it. I am in the process of getting funding from the USDA to start my farm, live in the farmhouse and now the pipeline is putting an end to that. My dream of farming and living on the farm and having a retirement income is all lost for the benefit of PennEast and gas that will never be used by Hunterdon County residents. Not to mention, my eleven tenants are worried about living near a pipeline that they will have to cross everyday.

This is just one persons nightmare from this pipeline. Multiply it by 108 miles of lives. If it gets approved, why can’t we be paid fairly for what we are losing? Please deny them permission so I can get on with my future hopes and dreams to just live safely and farm on MY LAND.

I know in my town and the surrounding areas fire departments always have a tough time getting funding. They’re mostly volunteers. They’re always fighting for equipment. It took years for West Amwell to finally get modern radios, which help keep firemen safe when they’re entering burning buildings. Every year we get a note from wafco26 (http://wafco26.com/) asking for money, which we gladly donate to every year. We’re all on wells which means no hydrants. Towns routinely help each other when disasters occur but they can only stretch so much. If a 3′ pipeline ruptured I believe it would be far beyond our local fire department’s ability to handle.

Maybe that $5,000 PennEast is donating to organizations will help? Well let’s see, just the radios I mention above cost more than $5,000 in total cost. So I don’t think it’s going to make all that big of a difference. A single fire truck costs more than $100,000……

Who benefits again exactly?

Michael in Pennington has a very in-depth submission to the ferc.gov.  What he (and everyone else) is wondering about is: who will this benefit again exactly?  Not vague assurances and statistics, but actual quantifiable results?

Ill perceived benefits

As I write, the the Penn East Pipeline Company is seeking approval from FERC to place a pipeline through our community. I have attended meetings and listened to presentations by their representatives who continue to tow the party line that the pipeline will be beneficial to the community because of the savings for the cost of gas and for the creation of new jobs.

Meanwhile, there are neighborhoods in the community through which the proposed pipeline would traverse that does not even have gas service. The gas distribution company in the area- PSE&G- which is also a member of the Penn East Pipeline Company conglomerate admittedly has no plans for service upgrades to serve the residents of those communities. Additionally, there is no specificity and no commitment for a set reduction in or delivery price for gas. The savings are neither quantifiable nor do they appear to be better than the rates that will be offered to communities that will not be impacted by the pipeline. In other types of government subsidized or enabled projects there are incentives to businesses and concessions made by those businesses that provide direct, quantified benefit to the citizens. One such example would be tax credits that are given to real estate developers for providing low or middle income housing. In these models there is a precise quantifiable benefit to private corporations and also a quantifiable benefit or value to citizens. The FERC model of review and grant of eminent domain to private entities does not even come close to quantifying a benefit to citizens. This is extremely problematic and disconcerting considering there is a taking of resources from ordinary citizens and licensing them to private businesses.

I have the same trouble with the PennEast assertions that this is good for our area.  There are assertions that the pipeline will have enough capacity to service “4.7 million homes” in the area.   This is a nonsense statistic.  According to the U.S. census bureau there are only 3,186,418 households in the entire state of NJ and 4,958,427 in all of PA.  Does PennEast really expect us to believe this one pipeline is going to power the equivalent of 57% of all the households in the two states?

Of course not all households are served by natural gas, and households aren’t the only consumers.

So let’s go to the U.S. Energy Information Administration’s page and see what actual energy use in PA and NJ is:

NJ Monthly natural gas usage

PA Monthly natural gas usage

These graphs show the monthly usage breakdown for each in millions of cubic feet. Unfortunately they only do states, not regions, so we can only get the entire state breakdown. For reference the PennEast pipeline will deliver one billion cubic feet a day, so divide the table’s numbers by 30 (avg days in a month) to see how they compare to PennEast’s production.

NJ’s peak usage across all categories was 1.6 billion cubic feet a day.
PA’s peak usage across all categories was 2.9 billion cubic feet a day.

For a total of 4.5 billion cubic feet a day.

This mean’s the PennEast pipeline has enough natural gas flowing through it to supply more than 20% of both states natural gas needs combined.

Now shrink those numbers down to “Eastern PA and central NJ”, as PenNEast claims they’ll be helping, and this number climbs in excess of 100% of the total natural gas usage in the region.

Do you still believe PennEast is going to be using this natural gas in just our region? Or do you suspect – as I and many people do – that PennEast is going to send this to a Liquid conversion plant for shipping overseas (where gas is much more expensive)?

Michael’s full comments are available here

Michael’s full comments – Alternate Site