A Letter to Every Citizen and Family in the Path of the Gas Thug Pipelines: Why This Insanity Must Be Stopped

Photo, Wendy Lynne Lee

Dear Pennsylvania citizen,

Whether or not you live along the right-of-way of  Williams Partners proposed Atlantic Sunrise Pipeline, and regardless whether you’ve been contacted by their aggressive landmen,  you need to be aware of several serious issues regarding this massive natural gas pipeline project. My message is simple: whether or not you live on or adjacent to the pipeline right-of-way, you could be impacted by this project in ways that endanger you property values, your health, and your community. Do you know that

·  the primary goal of the 42 inch, 177 mi. Atlantic Sunrise expansion of the TRANSCO is export to global markets via, for example, Dominion Energy’s planned 3.8 billion dollar Cove Point Liquefaction Project—recently approved by the Federal Energy Regulatory Commission (FERC) over 650 registered comments, virtually all of them opposed?
·      the ecological costs—borne by taxpayers—of Williams’ pipeline project include forest fragmentation, soil compaction, escalated flooding potential, water and air pollution—including possible exposure to carcinogens as well as neurotoxins?
·      the Atlantic Sunrise expansion will require compressor stations attended by their own unique hazards—including the emission of ozone, volatile organic compounds and other toxins, as well as the potential for explosion? Do you know that the explosion radius of any one of these compressors can exceed a half-mile?
·      no Environmental Impact Statement (EIS) was required for issue of the permit at Cove Point?
·      Williams has a very disturbing record of pipeline leaks and explosions, several which have resulted in human casualties?
·      the natural gas industry’s own estimate is that –with this massive pipeline infrastructure in place—as many as 100,000 hydraulically fractured—fracked— wells could be on the horizon for Pennsylvanians?
·      the Department of Environmental Protection has finally released its report of at least 243 instances of drinking well contamination directly due to fracking since 2008? There are currently about 8200 operating unconventional gas wells in the state. Can you imagine the potential for contamination from 100,000?
·      FERC has approved three other LNG export projects, all in the Gulf of Mexico: the Sabine Pass Liquefaction Project, the Freeport LNG Project, and the Cameron LNG Project. Are you aware that fourteen LNG export proposals are pending, but expect approval?
·      the Pipeline and Hazardous Materials Safety Administration (PHMSA) inspects only 7% of the 305,000 miles of the natural gas pipeline currently operating in the U.S.?

The Atlantic Sunrise poses unacceptable risks not only to the environment, but to human health and welfare. In addition,

·      Do you know that if you’re directly on the pipeline right-of-way, it could

Ø  Endanger your property values?

Ø  Endanger you and your children’s health?

Ø  Endanger your ability to secure homeowner’s insurance, second mortgages, and market value for your property?

Ø  Endanger your basic right to determine the use of your property by threatening its appropriation through eminent domain?

Ø  Endanger the clean air and water upon which your community depends?

·      Do you know that even if you’re not directly on the pipeline right-of-way, it could

Ø  Endanger your property values?

Ø  Endanger you and your children’s health?

Ø  Endanger your ability to secure homeowner’s insurance, second mortgages, and market value for your property?

Ø  Endanger the clean air and water upon which your community depends?

Do not let this happen.

For more information, including the EIS and the FERC documents, please see: 

THE WRENCH LIBRARY: STOP THE ATLANTIC SUNRISE PIPELINE

For opportunities to action, please see:

 Lancaster Against Pipelines

Atlantic Sunrise Project: Williams Companies, Inc. | Shale Justice

For a printable copy of this letter, please contact wlee@bloomu.edu

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

Photo Wendy Lynne Lee

INTRODUCTORY NOTE: 

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

CITIZEN DEMANDS –

·       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: 

(http://www.cadc.uscourts.gov/internet/opinions.nsf/30B6F48600A85C1E85257CEF004E34F1/$file/13-1015-1496336.pdf) 

·       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!

HOW TO FILE?

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 (www.ferc.gov) under the link “Documents and Filings.”

WHY TO FILE?

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: wlee@bloomu.edu

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

When Sunrise for the Global Gas Markets is Sunset for Pennsylvania: Williams Partner's "Atlantic Sunrise" Expansion of the TRANSCO

Note: The following is the first of what will be a series of letters to the editor concerning Williams Partner's, MLP (WPZ, formed in 2007) planned expansion of the TRANSCO natural gas pipeline. Each  addition to the series will focus on a specific aspect of the Transcontinental Gas Pipe Line Company, LLC's strategy to maximize natural gas transport from frack pad to compressor station to pipeline to export depot. My aim will be to show that--contrary to Williams' claims to concern for the environment, safety, human health, property rights, job opportunities, or community integrity--the Oklahoma company's singular objective is to maximize the profits of its shareholders and its affiliated industry partners at virtually any cost--so long as that cost can be externalized to the public.

My message is simple and clear: this pipeline cannot be built, and if we allow it we will be to blame for the disaster that will follow. For there's one truth that's as unmistakable as it is undeniable: more pipeline, more frack pads, more compressors, more tractor-trailor, sand can, chem-truck, and waste hauler traffic, more explosions, more abuses of eminent domain, more forced integration, more property condemnations, more water and air pollution, more forest fragmentation, more invasive species, more community division, more cancer, more endocrine disruption, more lung disease, more rashes, more livestock illness, more suffering--more climate change. What this pipeline represents in the continuing liquidation of Pennsylvania's assets, and its systematic  conversion into an industrialized natural gas extraction colony for multinational corporations--just like Williams. 

I will show you.
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Letter 1: Williams' plans are to pipeline frack-gas from the Marcellus Shale to whatever market--foreign or domestic--that will pay the most for it. Because this market is likely to be foreign, we can expect to see a steep rise in the domestic price of natural gas along with an accelerated expansion of drilling and compressor operations to accommodate so significant an expansion of the TRANSCO. This will be accompanied by the ecological liquidation and community division that are the hallmarks of the fracking industry.
It is genuinely difficult to know where to begin an objective evaluation of Williams Partners plan to construct a $2.1 billion dollar, 42 inch, high pressure, expansion of the TRANSCO natural gas pipeline. From their FERC (Federal Energy Regulatory Commission) request for pre-filing review, 3.31.14 (Docket PF14-):

As a result of significant interest expressed by shippers, the Project will be designed to provide 1,700,000 dekatherms per day (“dt/day”) of incremental firm transportation capacity along two project paths: 850,000 dt/day of firm transportation capacity from various points along Transco’s Leidy Line in north central Pennsylvania to Station 85 in Choctaw County, Alabama; and 850,000 dt/day of firm transportation capacity from a proposed interconnection in Susquehanna County, Pennsylvania (the “Zick Interconnection”) to as far south as Transco’s existing point of interconnection between Transco’s mainline and Dominion Transmission’s Pipeline located in Fairfax County, Virginia.

But even as early as page two of the FERC filing, Williams has already told what will no doubt the first of many half-truths and falsehoods with respect to its real objectives:

There are no LNG [Liquified Natural Gas] terminal facilities related to or proposed as part of the Project.

Half-truth at best: the reference to Fairfax County, Virginia is at least indirectly connected to Dominion's plan to convert an LNG import facility into an LNG export at Cove Point, Maryland. Indeed, Dominion's project slogan is "Support Maryland Sending Clean Energy to the World," and Williams certainly comprehends the opportunity to export to Chinese and Indian buyers. Consider the Gulf Trace Project, for example:

HOUSTON – Williams Partners is planning a $300 million pipeline expansion to carry natural gas to Cheniere Energy’s planned liquefied natural gas export facilities at the Sabine Pass in Louisiana, the company said Friday.
It’s a move to connect abundant supplies of domestic shale gas in the northeastern U.S. with international markets through the nation’s first LNG export facilities, the Oklahoma-based pipeline operator said. Booming U.S. shale-gas production has in recent years prompted companies like Cheniere and Exxon Mobil to plan facilities to send Gulf Coast supplies abroad to eager buyers in China, India and elsewhere.
The development project for Williams Partners’ massive Transco pipeline could carry 1.2 billion cubic feet of natural gas to Cheniere’s natural gas cooling stations on the Gulf Coast, where Cheniere plans to launch LNG tankers to

foreign buyers after its facilities are fully constructed late next year. 

(Fuel Fix » Williams Partners plans $300M pipeline expansion for gas export facility)

In other words, Williams knows where the big money is--and it ain't the U.S. domestic markets. "Once complete, the Sabine Pass LNG terminal will be the first large-scale LNG export facility in operation, in the United States," and if you think for a minute that frack-gas from under your land isn't headed to the global markets, think again. Williams to Expand Transco Pipeline to Deliver Gas to Sabine Pass LNG>> LNG World News.

Just imagine what will happen when Dominion's Cove Point facility goes on-line.

Anyone who believes the patriotic hype about "Cheap! American! Abundant!" just isn't paying attention. Fact is, whether the Atlantic Sunrise expansion is intended for foreign or domestic markets is irrelevant since we can expect to pay whatever the Chinese are willing to pay. Why should Williams sell it to us for any less? 

Unrelated to Gulf Trace, Transco is pursuing several other large-volume projects to serve growing domestic demand for natural gas. By year-end 2017, Williams Partners expects to add approximately 3.4 million dekatherms of natural gas transportation capacity from northeast supplies to high-value growth markets with mainline expansions that include the Dalton Expansion Project, Atlantic Sunrise, Leidy Southeast, Virginia Southside and others.

News

But for those still holding out on the hope that Williams flies the American flag for any other purpose than advertising, here's just one of the commitments to which Williams appeals to justify building the Atlantic Sunrise:

The new commitment is to ship from an interconnection in Susquehanna County, Pennsylvania, to Transco's existing Zone 5 Pleasant Valley point in northern North Carolina. That point is situated between Transco's mainline and Dominion Transmission's Cove Point Pipeline located in Fairfax County, Virginia, the notice said. The additional commitment will require Transco to extend the Central Penn Line northward from the Leidy Line to the Susquehanna County interconnection. (Transco looks to expand Atlantic Sunrise project - Natural Gas | Platts News Article & Story).

The Cove Point Pipeline may be in Fairfax County, VA, but "Dominion Cove Point’s natural gas

pipeline is connected to Dominion Transmission’s interstate pipeline, as well as to other interstate pipelines that have access to the growing natural gas supplies in the region. Using Dominion Cove Point as an export facility would provide producers with new international markets" (Dominion Cove Point), specifically India and Japan: "Richmond, Va.-based Dominion Resources now wants to turn its entire Cove Point operation around, reversing the flow so it can liquefy the natural gas now pouring out of Pennsylvania wells and load it onto tankers bound for India and Japan" Fuel Fix » Stakes are high for LNG export plan.

And there you have it, the first lie Williams' landmen will tell  to bamboozle and effectively extort property owners all along the route of the Atlantic Sunrise. Appealing to your patriotism, your concern for national and energy security, your sense of duty as a citizen, they'll try to convince you that letting them on your land to add to their 13,900 miles of already extant pipeline is the right thing to do for your country.

But nothing could be further from the truth. In fact, by selling to foreign buyers, Williams actually strengthens the fuel economies of countries whose interests may or may not align with our national security objectives. Is that really worth the despoiling of our forests, the contamination of our water, division in our communities, and the forfeiture of our property rights?

 But just in case you're still not convinced that Williams doesn't have American interests at heart, consider this: Williams partnered with Dominion--the global markets their explicit objective--at least as far back as 2009:

TULSA, Okla., Aug. 10 /PRNewswire-FirstCall/ -- Williams (NYSE: WMB) and Dominion (NYSE: D) today announced their intention to form a joint venture to market and develop a new pipeline to transport up to 1 billion cubic feet per day of natural gas produced in the Rockies and Appalachian basins (including the southern Marcellus Shale) to growing markets in the Eastern and Mid-Atlantic regions. The proposal, to be known as the Keystone Connector, would extend from the terminus of the Rockies Express pipeline in eastern Ohio to Williams' Transco Station 195 in southeastern Pennsylvania. Williams and Dominion will be working with potential shippers to determine the level of interest in the proposal. Dominion News

The connector for the Atlantic Sunrise? TRANSCO Station 195.

Here's the upshot: since at least 2006, the big energy companies--like Williams--have been working as hard as they can to extract the last drop of fossil fuel before the wells run dry--or the expense, already mammoth, is just too immense. What we can clearly show in 2014 is that this industry spends millions to avoid litigation for contaminating wells, despoiling forests, and polluting air--and they're more than happy to buy out your property once they've destroyed it and made impossible for you to sell, if you'll just sign a nondisclosure and gets your kids to agree to it too (Pennsylvania Judge Orders Records Opened in Fracking Case - Bloomberg). Williams is no exception. Just ask the folks of Appomatox, Virginia, or Marengo County, Alabama (Owner of PA Natural Gas Facility that Exploded Has Lengthy Record of Pipeline Safety Violations - Natural Gas Watch.org).

But more of this in a coming letter.

For photographs of pipeline similar to the one Williams intend to construct, please see:

More pipeline, more fracking, more destruction - a set on Flickr

For articles relevant to this one, please see:

http://thewrenchphilosleft.blogspot.com/2014/03/anadarko-liquidates-public-lands-for.html
http://thewrenchphilosleft.blogspot.com/2014/03/the-hilcorp-frack-gas-stampede-to-utica.html
http://thewrenchphilosleft.blogspot.com/2012/09/the-corporatization-of-american.html

WHEN "REGULATION" MEANS "NEGOTIATING THE TERMS OF SURRENDER": COMMENTS ON PROPOSED CHANGES TO CHAPTER. 78, PENNSYLVANIA OIL AND GAS CODE

Hearing: 1.13.14, 6-9PM, Pennsylvania College of Technology, Klump Academic Center, One College Avenue, Williamsport, PA, 17701.

Talking Points from The Delaware Riverkeepers: http://www.delawareriverkeeper.org/resources/Factsheets/Final%20Talking%20Points%201.6.pdf

Comments on proposed changes to Pennsylvania’s oil and gas regulations. Ch. 78, PA Code:

My name is Wendy Lynne Lee, Shale Justice Coalition. I’d like to begin by reiterating that the public comment period must be expanded to 120 days minimum with more hearings in frack-affected counties. This expansion is crucial not only to insuring that affected people and communities get to be heard, but because being heard is a bulwark of a democracy, however much this state and its agencies routinely ignore it just as they ignore the science relevant to the hazards posed by fracking and its associated infrastructure.

As opposed to commenting on each of the stipulated changes proposed for Ch. 78, I’d like to address the very idea that hydraulic fracturing from well-head to compressor, to pipeline, to export depot, to LNG transport tanker, can be regulated sufficiently to guarantee the ecological integrity, species diversity, human health, property value, or the constitutional right to clean air and water. While perhaps no regulation can offer guarantee against accident, the now well-documented hazards posed by fracking have clearly been shown to be substantial whether or not accidents occur. Hence it is equally clear that no regulation can be adequate to make this process of industrialized extraction safe.

We know that the intent of the industry is not to make fracking safe, but to make it as inexpensive, expeditious, and profitable as possible. Today’s hearing on Senate Bill 411, legislation that would render immune to liability the use of acid mine drainage as frack water, SB 1047 that would gut and politicize the process by which species are listed as endangered, or SB 259 that would allow old leases to be treated as newly negotiated, even if the leaseholder declines to permit fracking on her property or didn’t know there was an old lease, make plain that regulation in Pennsylvania is written by and crafted for oil and gas. Because fracking is inherently unsafe, the proposed changes to Ch. 78 are inconsistent with Article 1, section 27 of the Pennsylvania Constitution. Given, moreover, the clear legislative pattern we must assume that the intent of the changes is consistent with SB 411, SB 1047, and SB 259—to act to facilitate the interests of the oil and gas industries.

What the “proposed changes” really encapsulate, therefore, are the negotiated terms of our surrender to these industries. We at Shale Justice have no interest in acceding to this forfeiture of our autonomy as citizens or our recently reaffirmed right to clean air and water. We’d like to thank Chief Justice Castille for his role in the over-turning of Act 13. To accede to any of these “proposed changes” runs directly contrary to that 4-2 Supreme Court decision.

Here’s why:

To wrestle over the details of changes to Ch. 78 presumes that fracking will continue. Many are resigned to this grim possibility. Otherwise, we’d not be haggling over who’s responsible for pre-drill water testing, the use of open pits for frack waste water, the definition of fresh water, the disposal of brine, or the status of orphaned wells. Make no mistake: the industry will cry foul that such regulatory changes will cost them too much money, that they are somehow the injured party. But the facts are that these proposed changes are nothing but crumbs offered to appease us, to convince us that the agencies charged with protecting our air and water actually act to do so. The language here follows the pattern of SB 411 that aims to convert acid mine drainage into “beneficial use” even though its primary effect is to relieve the industry from liability for contaminated water. It follows SB 1047’s absurd argument that “endangered” is best determined via economic matrices. It follows SB 259 that empowers the industry to access more land for drilling under the guise of making royalties more transparent. We cannot afford to accede one more inch to oil and gas drilling. Can you imagine what our country-sides, forests, rivers and trout runs will look like if the proposed Dominion export depot at Cove Point Maryland is completed? 7000 wells will become 100,000, and with it we will become a fossil fuel extraction colony owned and operated by multinational corporations.

I urge you say no to more “regulation.” Why on earth should we surrender our autonomy, our communities, and our health to a rate of harm? Just as there’s no such thing as a little pregnant, there’s no such thing as a little cancer, a little asthma, a little bran damage. Many things are negotiable. Some are not. Just as there could be no compromise on apartheid or slavery, there can be none when the stakes are climate change. Whether we like it or not, our responsibilities are global. Hence there’s also no such thing as a “special place” unless what we mean is the planet.

My yard’s a special place.

So is yours.