Dear Friend, The PennEast pipeline is slated to bulldoze through miles of northeast Pennsylvania’s untouched forests and cross some of the region’s most pristine waterways. Earlier this month, the Federal Energy Regulatory Commission (FERC) issued its Environmental Assessment (EA) which wrongly claims that the project would not significantly affect the environment. Your voice is needed to speak out against the threats that PennEast poses to our environment and to the health and safety of our communities. PennEast was originally planned as a 120-mile fracked gas pipeline from Luzerne County, PA to Mercer County, NJ. After facing legal challenges and permit denials in New Jersey, PennEast’s developers, the PennEast Pipeline Company LLC, proposed to divide the project into two phases, with Phase 1 remaining entirely within Pennsylvania. The developers state that they hope to later complete Phase 2 in New Jersey once it overcomes legal and regulatory hurdles, but argue that Phase 1 could function as a stand-alone project even if Phase 2 is never approved. Although PennEast’s phased proposal differs markedly from its originally proposed plan, PennEast’s developers are attempting to avoid fulfilling regulatory requirements by treating it as a slight modification of their initial proposal, instead of as a new project. PennEast’s Phase 1 includes constructing 68.2 miles of new pipeline through Luzerne, Carbon, and Northampton counties as well as building a new compressor station (a facility which increases the pressure of gas in the pipeline) in Kidder Township (Northampton County, PA). Phase 1 diverges from PennEast’s original plan by terminating in Bethlehem Township, PA and interconnecting with the Columbia Gas Transmission pipeline as well as the Adelphia pipeline, which runs through Bucks, Montgomery, Chester, and Delaware counties. FERC’s EA shows that the purpose and need of the phased PennEast pipeline remains unclear. Even though PennEast’s Phase 1 proposal differs markedly from its original plan and Phase 2 may never be constructed, PennEast’s developers still rely on the original plan’s purpose and need to justify the development of Phase 1. The Phase 1 project has obtained shippers for only half of the pipeline’s capacity, and these shippers are all self-dealing partners of the PennEast project. Please copy the sample comment provided below, or modify/add on to it as you see fit, and submit it to FERC using its eComment webpage. For additional guidance on how to submit your comments using FERC’s eComment system, follow the directions on Clean Air Council’s website. FERC is accepting public comments on its EA until 5pm on Wednesday, September 2nd. -------------------- Sample Comment: Docket Number CP20-47-000 The Federal Energy Regulatory Commission (FERC) must consider the following issues in regard to its Environmental Assessment (EA) of the proposed PennEast 2020 Amendment Project. FERC must require a thorough and honest review of the purpose and need for Phase 1 of PennEast since the proposed purpose and need remain unjustified. Phase 2 may never be developed due to the legal and regulatory challenges PennEast faces in New Jersey. Although PennEast’s developers argue Phase 1 could operate as a standalone project, they fail to provide a clear justification for Phase 1’s purpose and need. Instead, the EA references the purpose and need provided in the Environmental Impact Statement drafted for the original project. Phase 1 cannot have the same purpose and need as the original project since this pipeline ends in Bethlehem Township, far from the terminus of the original project and has interconnections which weren’t part of the original project. PennEast Pipeline Company LLC can’t find enough shippers for its gas, yet it still wants FERC to approve the project. The Phase 1 project has found purchasers for only 52% of the pipeline’s capacity and those companies are self-dealing partners of the PennEast project. This means that the competitive market has shown no interest in this project. If Phase 1 is a stand-alone project, then it is a different project altogether from PennEast’s original proposal and therefore must be submitted as a new project and begin its permitting and review process from scratch. FERC cannot allow PennEast to circumvent the law. If Phase 1 is not viable as a stand-alone project and is dependent on the second phase of the project to fulfill its purpose and need, then FERC cannot approve Phase 1 because it would amount to an illegal segmentation of the project. In its EA, FERC needs to be more thorough in considering the health impacts gas infrastructure inflicts on communities. FERC only looks at air pollution on a yearly basis, but some of the worst harm to lungs comes from spikes in air pollution - large emissions over hours or minutes - which can cause asthma attacks, rashes, bleeding, nausea, and other illnesses. The analysis doesn't consider these harms, which makes it incomplete and wholly unacceptable. Thank you for considering these comments. | 
