Dear Friend,

The Federal Energy Regulatory Commission (FERC) is gathering public input as part of a  “scoping process,” to hear the public’s concerns on the potential environmental impacts of the Regional Energy Access Expansion Pipeline Project, which would be built and operated by Transcontinental Gas Pipe Line Company, LLC (Transco). Similar to the case of the proposed PennEast pipeline, which would run parallel to this project, the public does not need yet another unnecessary pipeline project to fulfill the region’s demand for natural gas. Your voice is needed to speak out against the threats this project poses to our region’s water and air quality and public safety! 

This project will transport fracked natural gas from the Marcellus and Utica shales in northern and eastern Pennsylvania to delivery points in Maryland, New Jersey and Pennsylvania. Transco’s Regional Energy Access Expansion Pipeline Project includes building the following facilities:

  • Approximately 35.8 miles of natural gas pipeline in Luzerne and Monroe Counties in PA.
  • One new compressor station (a facility which increases the pressure of gas in the pipeline) in Gloucester County, NJ. 
  • Modifications to existing compressor stations and other pipeline-related facilities and equipment in PA, NJ and MD. 

The concerns raised in public comments during this scoping process will help determine the issues FERC needs to address in its environmental assessment (EA) for this project. FERC is required by law to prepare an EA, which is an environmental analysis that determines whether the project will significantly affect the environment, whether any damage can be offset, and if a more detailed analysis needs to be conducted. Unfortunately, FERC already started this limited, 30-day public scoping process despite the fact that Transco has yet to submit all thirteen required Resource Reports which detail the projected impacts of this project.  

You can copy and submit the sample comment, provided below, or modify/add on to it as you see fit, urging FERC to restart a new, more transparent scoping process and to require Transco to fully identify the threats to air and water quality that this project poses.  

You can submit your comments on FERC’s eComment webpage. For additional guidance on how to submit your comments using FERC’s eComment system, follow the directions provided on Clean Air Council’s website. 

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Sample Comment:

I strongly urge the Federal Energy Regulatory Commission (FERC) to consider the following issues in its Environmental Assessment (EA) for Transcontinental Gas Pipe Line Company, LLC’s (Transco) Regional Energy Access Expansion Pipeline Project.

This scoping process began prematurely before the public had access to necessary information. To allow a more transparent process, the scoping period should restart once Transco has submitted all 13 of the required Resource Reports, which detail the projected impacts of the project. The public cannot fully and meaningfully participate in identifying the environmental concerns of this project while critical information is unavailable. Additionally, during the virtual scoping sessions held by telephone, members of the public were unable to hear each other testify. To improve transparency during future scoping sessions, FERC should use conference call software that allows all participants to be able to hear each other testify, rather than expect the public to remain on hold for an undefined amount of time and testify in a one-on-one setting.

The Regional Energy Access Expansion Pipeline Project is only the latest in a series of similar projects by Transco. All of these related projects and their cumulative impacts from concurrent construction and operation must be considered together, not separately, as part of this review process. Considering these projects separately would make the damage that they would inflict upon the region appear smaller than it would be in reality. 

With more pipelines comes additional upstream and downstream impacts. FERC needs to consider the environmental impacts spurred by this project as a result of increased demand for more fracking. FERC must also consider the additional air pollution and climate change impacts that burning the gas downstream for electricity, or other uses, would cause. 

Transco needs to identify and analyze all of the risks that this project poses to water resources through the region. This analysis should not only include impacts to streams and wetlands throughout the region but also account for impacts to the numerous drinking water supplies in the project area. This analysis must be based on thorough and up-to-date field research. 

Finally, it’s essential to note that this project would parallel the proposed PennEast pipeline. Transco has not provided any public documentation to prove the existence of a purported demand for the extra natural gas which would be transported by the proposed project. FERC must ensure that Transco provides adequate documentation and analysis to justify the need for the project. There may not even be sufficient demand for natural gas to justify either the proposed expansion of the Transco pipeline or the construction of the PennEast pipeline.

Thank you for considering these comments.

 

Sincerely,

Joseph Otis Minott, Esq.
Executive Director and Chief Counsel
 

 
 

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