Monday, July 21, 2014

The Atlantic Sunrise Pipeline EIS: Demand FERC Do it Right!

Photo Wendy Lynne Lee


The following is a letter composed by Restoration Ecologist, Kevin Heatley and Philosophy of Ecology Professor/Writer, Wendy Lynne Lee. It's aim is to provide citizens potentially impacted by Williams Partners' (WPX) proposed construction of a 177 mi. 30-42 inch high pressure natural gas pipeline--the TRANSCO expansion, "Atlantic Sunrise"--with clearly drafted, precise information about the ecological hazards of this project. While this letter's focus is ecological, there are a number of other categories of serious hazard--property rights, the abuse of eminent domain, health hazards, and community division--just to name a few. This set is thus intended neither to be comprehensive nor definitive--but what we know is that if FERC took seriously any one of these DEMANDS, let alone the whole set, fulfilling it would become so expensive, onerous, and time-consuming that WPX would be compelled to abandon the pipeline expansion. Indeed, WPX (or any pipeline company) cannot fulfill these adequately because the harms just are beyond what they can assess, much less repair. We know that, and we know our readers know that. Hence, we invite you to copy this set of citizen DEMANDS for yourselves, your neighbors, include it in part or whole in your own comments to FERC, tack it up on doorways or trees, leave it at diners, bring it to read at the scoping hearings listed below. Send it to your legislators, your county commissioners--to whomever you think relevant to this project.

Our aim is clear: STOP THE PIPELINE.


Dear Citizen,

The Federal Energy Regulatory Commission (FERC) has issued a Notice of Intent that it will be preparing an Environmental Impact Statement (EIS) for the proposed Atlantic Sunrise Expansion Project. This pipeline will entail approximately 177 miles of new 30 to 42 inch, high-pressure natural gas transmission line and will bisect at least 8 counties in Pennsylvania. As you are aware, the environmental and socio-economic impacts associated with this project pose a grave threat to the integrity and security of our region.

You can find the notice in full here: ELibrary File List

This FERC Notice of Intent provides us with an early opportunity to register opposition to this ill-conceived and unnecessary expansion of natural gas infrastructure. As a citizen, you have a right to demand FERC develop a thorough and complete EIS. Unfortunately, our experience reviewing FERC EIS and (Environmental Assessment) EA documents associated with the last three interstate pipeline projects in our region (the Constitution, the MARC I, and the Tennessee Expansion) indicates that FERC has a history of producing inadequate and substandard analyses of impacts.

We thus encourage you to utilize the following observations to inform your comments to FERC. Now is the time to insist that FERC fully account for all the social-economic and environmental consequences of yet another massive natural gas transmission line.

This list is intended to demonstrate some of the inconsistencies in past FERC documents. Utilize it freely but we also encourage you to include issues of concern based upon your own personal insights and experience.

Williams Open House,
Columbia County
Photo Wendy Lynne Lee

·       FERC has constantly refused to address the full cumulative consequences of expanding interstate transmission pipelines. A recent court decision has found this to be inadequate and unlawful. DEMAND that FERC fully account for the increased upstream drilling activity, and ultimate climate instability, that will result from expanding the natural gas transmission capacity!

For the Circuit Court Decision, please see: 

·       FERC is required to develop an “alternatives analysis” that considers other options besides the construction of the proposed pipeline. DEMAND an alternatives analysis that includes decentralized power generation (a model based upon private homeowner and community solar panels and wind turbines).

·       FERC has a history of ignoring the full impacts associated with fragmenting interior forest and creating new forest edge environments. DEMAND that FERC include 300 feet on each side of the pipeline as acreage impacted WHEREVER the pipeline crosses interior forest!

·       FERC has repeatedly allowed the pipeline companies to avoid paying for replanting of removed forest vegetation when “temporary workspaces” (often another 60 feet of right-of-way width) are cleared. DEMAND that FERC require a full restoration and replanting plan for EACH forest area “temporarily” denuded!

Forest fragmentation
Photo Wendy Lynne Lee

·       FERC often requires that agricultural soils be separated, stockpiled, and replaced during pipeline construction. However, they devalue and destroy forest soils, despite the inherent fragility of these resources. DEMAND that FERC require the pipeline company fully protect ALL soil systems.

·       FERC consistently fails to provide for adequate and comprehensive invasive species control. DEMAND that FERC require the same level of invasive suppression in both wetland and upland systems for the ENTIRE service life of the pipeline AND for newly created forest edge habitat adjacent to the maintained right-of-way!

·       FERC repeatedly allows open trenching of small and medium size streams during pipeline construction. Yet they require directional drilling under LARGE streams. This preferential treatment of watercourses is arbitrary and ultimately damaging to watershed health. The cumulative linear footage of water crossings involving smaller streams is potentially orders of magnitude greater than that associated with one or two larger water bodies. DEMAND that FERC require directional drilling during all stream crossings!
Impacted stream at pipeline cut,
Photo Wendy Lynne Lee

·       FERC allows pipeline companies to permanently maintain and mow a right-of-way width of 50 feet in upland systems. Yet they restrict the width to 10 foot in wetlands. There is no ecological rationale behind this arbitrary difference in right-of-way width. If a smaller right-of-way is possible for wetlands, it is possible for uplands. DEMAND that FERC respect the private property rights of upland land owners!

Citizen comments are due on or before August 18, 2014. We encourage you to submit your comments electronically using the “eComment” feature located on the FERC website ( under the link “Documents and Filings.”

FERC has a long history of advancing virtually every project seeking approval. Hence, it is unrealistic to expect FERC to deny the Atlantic Sunrise Expansion solely based upon community concerns or the comments of private citizens. If, however, citizens DEMAND that FERC develop a thorough and comprehensive EIS that addresses the full spectrum of socio-economic and environmental impacts associated with this pipeline, it will become apparent to both FERC and Williams Partners that this project is cost-prohibitive. 

In other words, if FERC took seriously its responsibility to assess the actual impacts of the proposed Atlantic Sunrise expansion,  it would become clear that Williams' Partners' intent is to externalize the risks and the cost onto the taxpayers and communities who will bear the environmental, health, property value and divisive community impacts of this project--but enjoy few if any of the benefits.

The only sound conclusion to draw is not that the pipeline can be moved, relocated, made more efficient. but that the pipeline should not and must not be built.

Kevin Heatley, Restoration Ecologist
Wendy Lynne Lee, Professor of Philosophy

For further information please contact Wendy Lynne Lee:

FERC's Public Scoping Meetings: 7-10PM; Williams Partner's Open House, 6-7PM

8.4.14: Millersville University, Student Memorial Center, 21 South George Street
Millersville, PA 17551.

8.5.14: Lebanon Valley College, Arnold Sports Center, 101 North College Ave.
Anneville, PA 17003.

8.6.14: Bloomsburg University, Haas Center for the Arts, 400 East Second Street
Bloomsburg, PA 17815.

8.7.14: Lake Lehmon High School, 1128 Old Route 115, Dallas, PA 18612

No comments: