As we at PRKN prepare to submit our comments to the Federal Energy Regulatory Commission’s Environmental Assessment (EA) of the Potomac Pipeline, we want to make sure our fellow pipeline opponents know about the serious problems we’ve identified in the EA. Remember that the comments are due Monday, February 26, so join in and help us out by submitting your own! Be sure to refer to docket number CP17-80-00. All of you have been so helpful – attending rallies, writing letters and comments, and we think it’s making a difference. Keep it up!
Here are some ideas we’d like to share.
FERC Failed to Properly Evaluate the serious risk and potential impacts on public health and safety posed by HDD drilling under the Potomac River and C & O Canal
The proposed route of the Project would have it crossing the river where it’s nearly 500 feet wide. This makes it a “major” waterbody crossing under FERC’s classification system. The Potomac is also an American Heritage River. The designation sets three goals: (1) continued improvement of water quality and environmental restoration along with development of effective flood control plans; (2) promotion of the region’s rich historical heritage and recreational opportunities; and (3) involvement of citizens at local levels. The Potomac River provides drinking water for people in the areas of Hagerstown, Sharpsburg, Funkstown, Smithsburg, and Williamsport. The Project would also cross the Canal which is designated as a National Historic Register Site.
Columbia proposes to use the horizontal directional drilling (HDD) method to construct the pipeline under the Potomac and Canal and has developed an HDD Contingency Plan to minimize the impacts of an inadvertent release into the Potomac River or adjacent habitats. The EA states that staff reviewed Columbia’s assessment of risks and its mitigation plan and found both acceptable. But the analysis takes at face value Columbia’s assertion of the minimal risk of “an inadvertent release.” FERC should have independently assessed the risks and Columbia’s proposed response to a spill in light of recent HDD drilling accidents that show the risk of major environmental harm. Contrary to the EA’s reliance on Columbia’s assurances, an inadvertent release of drilling fluids during HDD construction poses a grave threat to the Potomac, as the clean drinking water supply for six million people downstream. Given the rash of recent spills that occurred during HDD construction of a natural gas pipelines in Ohio and elsewhere, FERC must not take Columbia’s assurances at face value: protecting the Potomac requires the strictest possible safety measures to minimize the risk of an accident and respond quickly if one would occur.
The EA, by using methodologies which are outdated or based on inaccurate facts, fails adequately to consider impacts on climate change
FERC is required to ensure the scientific integrity of its analyses; it violates this where its analysis is based on factual inaccuracy. And, the EA’s analysis of the operational emissions of the pipeline underestimates the climate impact of methane emissions. FERC must use the most current methane standards, which it has failed to do. Its outdated estimate of methane’s global warming potential (GWP) is all the more important because methane is a much more potent greenhouse gas than carbon dioxide.
In addition, the EA doesn’t address the potential downstream greenhouse gas (GHG) emissions that would result from transporting natural gas through the Project and Mountaineer pipelines to serve gas-fired power plants in West Virginia. It assumes that burning all the transported gas would displace the equivalent existing coal or oil use, potentially offsetting some regional GHG emissions. But courts have already ruled that FERC is not excused from making emissions estimates just because those emissions might be partially offset by reductions elsewhere. The EA errs in trying to minimize the impacts by reasoning, without evidentiary support, that replacing coal with gas will reduce CO2 emissions.
And finally, the EA ignores legal requirements to discuss the significance of indirect GHG emissions – it simply provides estimates of them, without any discussion of their significance or explanation of why FERC concludes they are insignificant.
The EA Fails to Consider the Mountaineer Project as a Connected Action
The Potomac Pipeline has no use or purpose at all, except to transport fracked natural gas from Pennsylvania gas fields to the proposed Mountaineer Pipeline in West Virginia. It’s pretty plain that the two are connected, but FERC ignored this obvious fact and analyzed only the Potomac Pipeline in its EA. Taken together, these connected actions will result in more than minimal adverse environmental impacts in Pennsylvania, Maryland and West Virginia, including crossing of dozens of freshwater streams, many of which are impaired and some of which are direct tributaries to the Potomac. The proposed route of this Project also crosses sensitive karst geology, which presents unique risks during construction and operation that must be fully assessed and avoided in order to protect nearby drinking water wells and the Potomac River.
The EA Does Not Adequately Discuss All Reasonable Alternatives.
Analyzing alternatives to the Columbia pipeline is critically important in the environmental review process, because if done right it ensures that all options were considered, and the least environmentally harmful is chosen. In this case FERC failed miserably to meet this standard. FERC did not take a hard look at other route options that would avoid crossing the Potomac, and they accepted at face value Columbia’s pitch that the pipeline is critically needed, allowing FERC to reject the “no action” alternative.
The EA applied three criteria to decide which alternatives to discuss, including the No Action alternative:
- Ability to meet the Project’s stated objective;
- Technical and economic feasibility and practicality; and
- Significant environmental advantage over the proposed action
The EA does not adequately discuss all of the route alternatives. In particular, it addresses one above ground route that would cross the Potomac by utilizing the existing Route 522 Bridge, thereby avoiding the need to employ HDD to construct the pipeline under the Potomac and Canal. Conceding that this “above ground crossing attached to a bridge would also avoid impacts on the Potomac River,” the EA inconsistently and in-comprehensively concludes that it “would not decrease the impact on the river in comparison to the proposed HDD crossing.”
Common sense means to me that using the bridge, rather than drilling, is the way to go, and we should tell FERC exactly that.
We’ll have our comments posted on Monday, so look for them on the PRKN website. In the meantime, I hope that you might be able to use these thoughts to write a comment, but by all means, please include your personal or local perspective. Our comments have a wide scope, but you might be more interested in the Project’s impact on drinking water or some other community issue. Your voice is important!