TransCanada, the owner of the pipeline that spilled 17,000 gallons of oil in to South Dakota farmland last year, has filed an application to run a natural gas pipeline from Pennsylvania to West Virginia the shortest (and cheapest) way they can — through Maryland. The pipeline does nothing for Maryland — yet it puts Maryland’s natural resources, and the drinking water of millions downstream, at risk. And TransCanada’s application has no justification or evidence that substantiates a “need” for natural gas in West Virginia’s Eastern Panhandle.
Please take a few minutes to submit comments to the Federal Energy Regulatory Commission (FERC) DUE MAY 25th.
Elements for commenting on FERC docket # CP17-80-000:
FERC is requesting “specific comments or concerns about the project.” They ask writers to “focus on the potential environmental effects, reasonable alternatives, and measures to avoid or lessen environmental impacts.” Input will help “determine what issues they need to evaluate in the Environmental Assessment.”
Original commentary that comes from a person’s own experience and standpoint usually carries more weight in these types of deliberations than obviously duplicated postcards or campaign literature. So we urge you to select from among the arguments below those that resonate most with you personally, or about which you have the most personal perspective, and then if at all possible, rewrite them in your own words. After the introductory paragraph, it would be good to follow with the paragraph that most directly relates to your own situation. Then add other issues selected from the below in their order of their importance or relevance to you. Be sure to read through them carefully and do not just cut and paste.
Here’s how to submit your comment:
Step 1: click on the link below to take you to the FERC e-comment Web page. Once there, fill out the forms with your name, address and email. Once submitted, FERC will send you an email with a link to submit your comments.
Step 2: Click on the link in the email from FERC. Enter the docket number in the space provided. CP17-80-000. Click the search button.
Step 3: Click the “select” button next to the docket file.
Step 4: In a word document, type out your comments.
Step 5: Copy and paste the text in your word document into the comment space on the FERC website that you completed in Step 3. Then press submit.
You will receive a confirmation email that your comment was submitted.
Here are some elements for building your letter:
Dear FERC Commissioners:
I am writing about the proposed Eastern Panhandle Expansion Project, Docket number CP17-80-000. I am a [FILL IN YOUR RELATIONSHIP TO THE PROJECT, e.g. land-owner on or near the path of this pipeline or the related Mountaineer project in WV, resident of one of the affected counties in MD or WV, resident of the District of Columbia who drinks tap water, a lover of the Potomac River or C & O Canal National Park, etc.] In my view, this project would [LEAD WITH YOUR TOP PERSONAL CONCERN]. It would be detrimental to protected national parkland and natural environments, not to mention individual private property rights. No public need put forward by Columbia Gas — or the sponsor of the companion project in West Virginia, Mountaineer Gas — warrants the well-known dangers of such a project. It is my view that there is no “reasonable alternative” or way to “lessen” its environmental impacts. There is no need for this project, and it should not be permitted to go forward at all.
FERC should require a full Environmental Impact Statement (EIS)
It is my understanding that you are only assessing the TransCanada/Columbia Gas portion of what is actually a single project on both sides of the Potomac River. The whole point of the Eastern Panhandle Expansion Project is to connect to its companion project, Mountaineer’s pipeline expansion in West Virginia. I object to the way energy companies around the country have been able to avoid scrutiny of the real environmental impact of their projects by slicing them up into small pieces, which are assessed in isolation. The only way to understand the full impact of the EPEP is to measure all its effects cumulatively, from the starting point in Pennsylvania to the prospective end users in West Virginia. Given the fragile geology, multiple watercourses, and prized national monuments that will be affected, and the potential impact on drinking water for the Washington DC metro area, I think nothing less than a full environmental impact statement, including public hearings, is called for.[INCLUDE ANY OR ALL OF THESE ISSUES – BUT READ THEM CAREFULLY AND DO NOT JUST CUT AND PASTE]
Likely leakage into groundwater
The area this pipeline is supposed to pass through sits on a limestone bedrock called Karst. This rock is full of tiny holes and fissures, meaning pollutants can flow or spread quickly from one place to another. This means that discharges from the pipeline drilling or leakage later can easily get into drinking water wells that might seem to be completely separate from the rivers and streams the pipeline crosses.
Danger of explosions
Among the pollutants that could easily leak and be transmitted this way is methane. Methane as we all know is an inflammable gas. It could flow into drinking water wells. The area’s fragile geology also opens up the possibility of sinkholes that could threaten the integrity of the pipe itself, leading to cracks and then explosions. The Pipeline and Hazardous Materials Safety Administration (PHMSA) collects data on all reported incidents for gas pipelines including gathering, transmission, and distribution. From 1996 to 2015, there were 11,192 incidents costing $6,678,631,880. These incidents killed 371 people and injured another 1,378. In just the first six weeks of 2016, there were 53 incidents costing $10,118,748.
Private Property[INCLUDE YOUR OWN EXPERIENCE OR SPECIFIC EXAMPLES OF ACTS OF INTIMIDATION OR DECEITFUL SUGGESTIONS THAT DECISIONS HAVE ALREADY BEEN MADE OR LAND WILL BE SEIZED BY EMINENT DOMAIN. NOTE SUCH SCARE TACTICS ALSO LEAD PEOPLE TO SELL THEIR LAND FOR LESS THAN IT IS WORTH. ALSO PIPELINE PASSAGE AND ANY LEAKS OR INCIDENTS WILL AFFECT PROPERTY VALUES IN THE VICINITY.] I don’t like [or like the idea of my neighbors] being treated this way. Gas companies even tried to get the West Virginia legislature to approve a measure that would allow them onto people’s private land without their permission. For a project that serves no broad public interest, that is a shocking violation of the principles of protection of property that founded this country.
The Potomac River is one of the most majestic waterways in this country. Not far downstream from the proposed crossing site are the magnificent Great Falls National Park. No objective described by Columbia Gas warrants a threat to that remarkable place and the river that thunders through it — before winding past the Nation’s Capital and emptying into the Chesapeake Bay. But the intent is to drill right under the river, using a hydraulic drilling method. This would happen on a portion of the river that is listed as sensitive on the Nationwide Rivers Inventory, and is notable for its historical as well as its hydrological importance. Pressurized water will be blasted through rock. Even if there is no catastrophic accident, that water will invariably seep into the fragile bedrock, further destabilizing it. The whole idea raises the possibility of poisonous spills into the Potomac River both during and after drilling. A significant accident would have truly catastrophic consequences. The whole city of Washington depends on the Potomac River for its drinking water. Imagine the effect if we had some version of Flint, Michigan right in the Nation’s Capital.
Likely leakage into multiple rivers and streams
All told, this pipeline and its Mountaineer companion are slated to pass under dozens of rivers, streams, and creeks in Maryland and West Virginia. These are some of the cleanest and most pristine creeks in the eastern U.S. They not only supply drinking and irrigation water for agricultural use, they are intrinsic to the natural environment of these regions, are the habitat for fish, waterbirds, otters and other wildlife. These creatures are a treasure that improves the general quality of life for Marylanders and West Virginians and visitors to those states. They are also a means of livelihood for many people who eat the fish they catch or the game they have hunted on the banks of these streams.
TransCanada safety record
There is evidence that, in the recent rush to build so many new pipelines to support the expansion of fracking and investment in natural gas, the pipelines are being built with fewer quality controls. In fact, new transmission lines are failing at the same rate as those constructed in the 1940s. Carl Weimer, of the Pipeline Safety Trust, “The new pipelines are failing even worse than the oldest pipelines.”
Columbia and TransCanada assure you that the utmost care will be taken in executing this project, that the latest safety precautions and state-of-the-art technologies will be put to the task. But TransCanada is notorious for explosions (Bison), leaks (Keystone I), and general shoddy materials and cracks and corrosion, for ignoring its own safety inspections and quality controls, and repeated other instances of cutting corners and malfeasance. We simply cannot trust our precious national resources in the hands of this company. Not to mention that it is a foreign company, which will be extracting profits from our land and water.
C&O Canal National Park
The National Park running alongside the Potomac River, a National Historic Register site, is one of the most prized recreational areas in the region. Thousands of people each day take advantage of the towpath for biking, running, hiking, fishing, and camping. They bring their children on weekends, or participate in one of the many special activities the park hosts. [ADD PERSONAL EXPERIENCE OF PARK.] This project is a threat to the integrity of the park and its ongoing tourism potential. A single spill or incident would be enough to mar its image for years and the clearcut that will accompany the pipeline would mar the visual aspect forever.
Maryland’s Ban on Fracking
I am a resident of the state of Maryland, which recently enacted a foresightful ban on fracking in the state. I don’t want fracking in Maryland, and by the same token, I don’t want Maryland used as a pass-through for fracked gas. I resent that my state’s environments will be threatened for a project that brings no benefit whatsoever to Maryland, and runs counter to our state’s position on fracking and fossil fuels. We’re told that oil and gas represent an economic bonanza. But the fact is that around the world, most regions whose economies have come to rely on fossil fuels have ended up poorer, environmentally devastated, corrupt, and often violent. It’s called the resource curse, and we can see it shades of it here in the United States as well.
TransCanada has not supplied any convincing evidence of public need. The pipeline is supposedly to serve customers in West Virginia’s Eastern Panhandle. But according to the feasibility study commissioned on behalf of that project, current WV residents are very unlikely to convert their residential installations to gas. There is clearly no current demand. The whole pretext for this project is potential future residential and industrial expansion. The claim is that increased availability of natural gas will draw businesses into the region (or perhaps increase the prices developers can charge for new houses). But population is growing plenty without the national gas. And business will inevitably follow the people. That gas would add to the attraction is speculative at best, and does not outweigh the likely dangers.
Because of methane’s effects on climate, EPA has found that it, along with five other well-mixed greenhouse gases, endangers public health and welfare within the meaning of the Clean Air Act. The reliance on as-yet non-existent demand as the rationale for this project is particularly galling at a time when this country needs to speed up the move away from fossil fuels that is already underway. The boom in new residential building in West Virginia’s Eastern Panhandle is a perfect opportunity not for a gas pipeline, but for solar energy. Local solar energy companies are also offering innovative packages to small businesses. This positive development should be encouraged, not competed with. Autonomous or on-grid solar should be the draw for homeowners and small businesses, not durable infrastructure that will lock them into an energy of the past, which is doomed to become obsolete within decades.