Tag: Approval Process

Does FERC follow regulations?

Jeffrey from Bethlehem, PA has been asking a lot of questions about the regulations the FERC is supposed to follow in the pipeline approval process, and if they’re being followed properly.

I am a citizen with no training in interstate natural gas transmission line rules and regulations. My knowledge has come through self-education after PennEast made its announcement to build a pipeline that would go through my town in Pennsylvania. I have done my best to understand the PennEast pipeline proposal and to participate in the process. I have asked many questions to PennEast officials, attended the Open House in my county, attended the Scoping Meeting in the neighboring town, and have read as much as I can from PennEast’s filings, its plans, and about the proliferation of natural gas transmission line proposals in PA. Despite this, I do make errors in trying to understand details and procedures that are unfamiliar to me.

I sent two e-comment yesterdays about third-party contractor for the NEPA review for the PennEast proposal. In reviewing FERC’s _Handbook for Using Third-Party Contracts to Prepare Environmental Documents_ (Rev. Dec. 2014), I did find today that it is possible for applicants in certain circumstances to submit fewer than three contractors (this is stated in Section 1-4). I did not realize this was allowable yesterday in my first e-comment.

My one question on this issue is whether such a justification was presented with the PennEast proposal and if more details could be made available to the public about this issue, in general. I think that _The Handbook_ suggests that fewer than three proposals is not usual because the paragraph where this is mentioned starts with a sentence that begins with the phrase, “In the rare instance…”

Thank you for your consideration of my comments. I know that the NEPA report is very important. For me, if it was at all possible, I would want FERC to have had, at least, three third-party proposals to look at for the selection of the contractor.

This is a great question and it dovetails with other questions I’ve seen people asking about the FERC not doing its job properly. This one in particular really gets to the heart of how and why Tetra Tech was chosen to do the Environmental Impact Statement.

This info might be available somewhere on the FERC site, I’ll do some digging to see if I can find it anywhere.

If not, there’s always the Freedom of Information Act (FOIA Website) as a last resort.

Jeffrey’s submission is available below:

Jeffrey’s submission – FERC Generated PDF

Jeffrey’s submission – FERC Generated PDF Alternate Site

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.

Environmental and conservation regulations ignored by FERC and pipeline companies

I heard Mark Gallagher speak at the Hunterdon County FERC scoping meeting. He’s a VP with a firm called Princeton Hydro that’s dedicated to environmentally-sound engineering projects. His statements focused on reminding the FERC of the rules and regulations in this state, and rather pointedly showed some instances where FERC has been ignoring the rules.

His full submission to the FERC is available here:

Princeton Hydro statement – FERC Genereated PDF

Princeton Hydro statement – FERC Genereated PDF Alternate Site

I think the best part of this submission is near the end, where he states: “Difficulty in the application of the trenchless methods due to constraints such as lack of area or slope should not be used as the basis for an argument to use more invasive measures since these constraints should be viewed as self-induced since Penneast selected the route”.

In other words, Penneast can’t say “Aww, doing it the right way is too hard!”.

My comments are primarily related to the need for the FERC and PennEast to understand the regulatory requirements associated with the proposed pipeline route. From a regulatory perspective, Penneast could not have selected a more onerous pipeline route based on the environmental sensitivity of the area and the number of special protection waters that this pipeline would impact. However, based on other pipeline projects that have been granted findings of no-significant-impact by FERC it is unclear whether either FERC or Penneast has taken any relevant Federal regulations into account when planning this pipeline.

He goes on to talk about past pipelines that FERC approved – and which were found to be sorely lacking.

Previous pipeline applications including Transco’s Leidy Southeast Expansion Project have overlooked various Federal requirements during the scoping and NEPA proecess. After review of Transco’s current application to the NJDEP it is readily apparent that compliance with the Clean Water Act was not take seriously. As indicated above, New Jerseey has assumed jurisdiction of section 440 of the Clean Water Act and as such must implement this regulation as restrictively as the Army Corps of Engineers. However, whether it be a result of ignorance or arrogance the Federal regulations have not been fully applied in previous pipeline applications.

He goes on to illustrate the many issues along the route and what PennEast must do to to conform to regulations:

The route of the Penneast pipeline has shown little to no consideration for either antidegredation streams or the preserved lands along the route. Nonetheless Penneast must show compliance with section 40CFR230.10 of the Clean Water Act.

Section CFR40 230.75 describes the need to address the minimization of adverse effects on populations of plants and animals. […] Compliance with this section of 404(b) guidelines is extremely important with regard to the Penneast pipeline since the route crosses endangered habitat and antidegredation streams. Penneast must illustrate compliance with this section of the Clean Water Act as part of its need to obtain an Individual Frewshwater Wetland Permit from the DEP.

He goes on to illustrate what methods PennEast must use to stay in compliance with the various sections of the Clean Water Act:

In order to protect the sensitive aquatic resources of New Jersey, Penneast should seek full compliance with section 404 of the Clean Water Act and New Jersey antidegredation standards by by using trenchless crossing methods for, at a minimum, all sensitive waterways that are associated with Category 1 waters and endangered species habitat. The 404(b)(1) Guidelines require an alternatives analysis which addresses how impacts to waters and wetlands (waters of the United States) have been avoided or minimized. The alternatives analysis should address practicable alternatives to the discharge of dredged and fill material for each individual crossing of a wetland and/or waterbody. The proposed method of crossing should not be simply based on convenience but rather focus on the most ecologically sensitive alternatives in order to fully comply with New Jersey and Federal Regulations. Difficulty in the application of the trenchless methods due to constraints such as lack of area or slope should not be used as the basis for an argument to use more invasive measures since these constraints should be viewed as self-induced since Penneast selected the route.

In the end he takes FERC to task again, basically saying that if FERC were not involved this would be a whole other process – one much harder on PennEast, and they would have almost certainly chosen another route (or chosen not to play this game to begin with).

In conclusion if Penneast viewed this project as a typical applicant [to the NJ DEP], not one supported by FERC, and took even a little bit of time to understand the project regulatory constraints they may have more seriously considered the value of an alternative route that would have avoided the numerous antidegradation streams and other environmentally sensitive areas that they are proposing to impact.

Indeed. If this pipeline didn’t cross the Delaware this would be an NJ-only issue, and the proposition would have been dead in the water from day one. It’s only due to the FERC ignoring environmental regulations that we’re in this mess.

Pipelines criss-crossing the landscape

Maria from Wyoming, PA writes to the FERC to remind us that this isn’t about just one pipeline. There are many that have already been built, many more proposed, and some already approved. We may soon all face with what she already lives with in Luzerne County.

I am currently surrounded by the expanding gas industry infrastructure that has invaded my township and has disrupted the enjoyment of my property and the surrounding natural and scenic areas. UGIES already has a large high pressure Auburn II pipeline in close proximity to my home as well as a high pressure pipeline
interconnect, they wish to call a gate station. None of this current infrastructure built by UGI has benefited the residents of the area, and in fact thousands of residents including myself, do not even have natural gas service available. UGI has stated there are no plans for expanding local service from these facilities or any of its proposed future pipeline projects in my area. In addition, the Williams Transco pipeline is a few hundred feet from my home.

I have great concerns over the cumulative effect of all of these pipeline projects on the air quality and the threat of a lethal explosion looms over my home. The area I live in is not a remote desolate area as UGIES would like FERC to believe. I live in an R-1 zone which stands for residential, not remote. I have watched the destruction of wetlands around my home as these pipeline projects have cut through them, as well as increased erosion and water runoff problems on the mountainous terrain where I live. I fear more irreparable damage will be done by yet another pipeline adjacent to the existing ones in my area.

I have seen on my own personal property, the lack of competence when UGI simply needed to provide a new electrical service line underground to my home. They did not evaluate the situation and the environmental issues for this small project by comparison, and caused my home to be flooded and property to be damaged, by not providing proper drainage and releasing an underground water source into my home. In addition, to this present day they never performed any proper restoration to my property. Using this experience as a reference, how can I possibly believe that UGIES will have the ethics and competence to handle such a huge undertaking as the PennEast pipeline? They simply will not.

In considering the scope of this proposed project, I urge FERC to consider the environmental impact and damage in a cumulative way. This is one of several existing and proposed pipelines to invade the area. The track record has been poor so far from what I have seen. I am living with it in my back yard and speak from personal experience. I also fear for the Susquehanna River Levee system as this pipeline project proposes tunneling in close proximity to it and under the river itself. The history of flooding in the Wyoming Valley is widely documented and this levee system is the greatest form of protection.

In conclusion, I sincerely hope that FERC can truly look at this project with objective and impartial eyes, despite the fact that your agency is funded by fees paid to you by the gas Companies themselves, such as UGI. Please protect the citizens of Luzerne County PA as well as all the citizens along this proposed PennEast pipeline route

You can read her submission below:

Maris’ submission – FERC Generated PDF

Maris’ submission – FERC Generated PDF Alternate Site