Urgent Actions Needed Re: FERC’s Draft Environmental Impact Statement (DEIS) for the PennEast Pipeline (FERC Docket # CP15-558-000)
This is the MOST IMPORTANT PUBLIC COMMENT PERIOD!
On Friday, July 22 the Federal Energy Regulatory Commission (FERC) released a Draft Environmental Impact Statement (DEIS) for the proposed PennEast pipeline.
It is critical that you act during the next 48 days!
This DEIS is riddled with data gaps and incomplete information. It should be withdrawn until PennEast has submitted all of the required data.
Between now and September 12, there are a number of actions we must each take to show FERC our profound opposition to this dangerous, unneeded pipeline. We must make our voices heard during this important comment period.
Submit letters to the PennEast Docket (#CP15-558-000) to:
A. demand that FERC withdraw the DEIS;
B. demand that FERC extend the public comment period until a complete DEIS is available for review; and
C. point out specific problems in the DEIS, including assumptions, missing information, and issues that are either ignored or insufficiently addressed.
Comments submitted to FERC during this period become part of the legal record in FERC’s mandatory environmental review. Our goal is to submit as many substantial, fact-based comments as possible. Intervenors’ comments and landowners’ comments carry more weight, and FERC must respond to each relevant comment.
Directions on posting to the Docket and sample letters can be found at:
In your comments to FERC, it is important that you raise as many different points as possible. You should include detailed notes, specific data and unique stories about how you, your family, your community, and your property or business would be impacted by PennEast.
If you need help drafting or submitting your letter,
-New Jersey Conservation Foundation,
-the Stony Brook-Millstone Watershed Association,
-Rethink Energy NJ,
-HALT PennEast (Homeowners Against Land Taking),
-the Citizens Against PennEast groups (CAPS),
and several townships are holding 3 workshops, slated for the following dates and locations:
Tuesday, August 2, 7-9 pm*
33 Risler St, Stockton, NJ
Thursday, August 4, 6:30-9 pm*
The Holland Township Municipal Building
61 Church Rd., Milford, NJ
Monday, August 15, 7-9 pm*
Stony Brook-Millstone Watershed Association
31 Titus Mill Rd., Hopewell, NJ
Concerned Citizens & Impacted Landowners are sponsoring the following workshop in Pennsylvania:
Tuesday, August 2nd, 6:30 PM-8:30PM
Towamensing Fire Dept.,
State Rte. 209 (near the Intersection of Trachsville Hill Rd.)
Towamensing Twp, PA
The workshops will have writing coaches and experts on hand to help you craft your letter. If you have a laptop, please bring it. If you are unable to attend one of these workshops, you can contact Charles Slonsky email@example.com, Mike Spille firstname.lastname@example.org or Alix Bacon email@example.com.
*For the latest event details, including possible time/location changes, visit www.rethinkenergynj.org/stoppenneast
Attend a public hearing.
FERC will hold six public hearings at which the public can comment on the DEIS.
It is critical that as many people as possible attend these hearings.
Monday, August 15, 6-10pm
Penn’s Peak, 325 Maury Road, Jim Thorpe, PA, 18229
Best Western Lehigh Valley & Conference Center, 300 Gateway Drive, Bethlehem, PA 18017
Tuesday, August 16, 6-10pm
Grand Colonial, 86 Route 173 West, Hampton, NJ 08827
Peddler’s Village (Lahaska and Neshaminy Rooms), Routes 202 & 263, Lahaska, PA 19831
Wednesday, August 17, 6-10pm
Best Western Genetti Hotel & Conference Center, 77 E Market Street, Wilkes-Barre, PA 18701
Clifford B. Memorial Hall, 1666 Pennington Road, Ewing, NJ 08618
For more information about the fight against PennEast, visit:
Please check this site frequently for the latest details about how you can stop PennEast.
The PennEast pipeline is not needed, not wanted, and would have unacceptable impacts on our land, water and communities. Thank you for joining with us and the many organizations working together to send a strong message to FERC.
Together, let’s STOP PENNEAST!
The agenda for all these workshops are identical and simple. The overarching purpose is to help people exercise their rights and learn how to physically comment on the docket, to teach people how to comment effectively, and to provide some sample topics to speak to.
To that end, this will be a hands on workshop. Bring your Laptop/Tablet with you! We will be showing people how to comment on the docket electronically, live and in color. We will walk individuals through the commenting process, now to login to FERC, post eComments and how to post larger documents.
If you don’t have a computer, don’t panic! We have plenty, and you can use ours to get your comments in.
We will have wi-fi. So don’t worry about that either.
So the agenda will be simple:
• Description and live demo of how to comment
• Brief discussion of major categories to consider commenting on
• Go write your comments!
You say you already know how to comment to FERC?
Have you been doing this PennEast thing for well-nigh two years now? Can you navigate the FERC site in your sleep (and have nightmares of doing exactly that?). Have you memorized “CP15-558?” Then feel free to dive right in and comment.
You can get the DEIS files at http://pipeinfo.org if you haven’t done so already. It’s 20x faster than FERC and it has yet to go down, ever.
Some tips on commenting:
• Identify yourself and your interest to FERC right at the top. The format I use is:
My name is XXXX, I am a [Intervenor][and Impacted Landowner][Concerned resident] regarding docket CP15-558-000 for the PennEast Pipeline. I live in the town of [Town, State]. I am commenting on the PennEast Draft Environmental Impact Statement (DEIS).
In other words – if you an intervenor or impacted landowner, say so. It raises your status up. And also be CRYSTAL CLEAR that you’re commenting on the DEIS.
Here are some samples – but TRY TO WRITE YOUR OWN if you can!
See DEIS Sample Letters
- Try to keep one major overarching topic per submission. In the past FERC and PennEast have taken people’s lengthy submissions covering many topics, and ignored half of them. Don’t let that happen to you! Pick a topic (safety, water, what have you) and stick to just that topic for your submission. Then make another one. And another one.
- If you get stuck in writing, don’t sweat it. We all get writers block. But the good news is that we’re not writing a best selling novel. We’re writing stuff for bureaucrats to read. So they won’t mind if you’re not the next Steven King.
One tip if you’re stuck: bullet points. Just put out bullets of the major points you want to make. If you can’t get past the bullets, then just submit those. But you’ll be surprised – many times the act of putting bullets down in writing gets the juices flowing and you’ll find that stress melting away and a natural way forward.
Possible Comment topics
If it helps, here are the major sticking points for us in regards to the DEIS and the PennEast proposal as a whole. These aren’t definitive by a long shot – these are just the things we see as obvious candidates for comments.
- The DEIS is incomplete and it is unfair to put it before citizens in such a state
- The comment period is too short, especially during summer vacation seasons
- FERC outages exacerbate the short comment period!
- There is no demonstrated public need for this project. Numerous studies show this project is being undertaken for the private gain of 6 companies and not for the good of the people of NJ and Eastern PA.
- The DEIS indicates a 2017-inservice date when PennEast themselves have admitted they cannot be inservice before 2018.
- 70% of impacted landowners in NJ have refused all attempts at surveying their land. This implies 70% of the land or more in NJ will have to be seized via eminent domain. 70% eminent domain is an atrocious figure that should be appalling to any agency, and doubly so given the demonstrated lack of public need
- Direct economic tourism impact on Lambertville/Frenctown/Millford and other towns not being considered adequately
- Indirect tourism impacts (hikers, bikers, equestrians, etc) also not considered adequately, including major areas such as Appalachian Trail, Baldpate, Lehigh River, Delaware River, etc. not considered adequately
- Impact on conservation programs (who will preserve land if companies like PennEast can take it?) not addressed by DEIS
- Traffic considerations during construction (school bus routes, small roads and bridges, few alternative road choices) not addressed properly in DEIS
- Personal impacts! Their house, their farm, their business, their families, their lives
- Impacts to local features near them (Baldpate, Goat Hill, Gravel Hill, Alexuaken Creek Preserve, Copper Creek Preserve, Delaware River, Swan Creek Reservoir, on and on…)
- Drinking water, wells, septic. Drinking water, wells, septic. Drinking water, wells, septic. Drinking water, wells, septic. Drinking water, wells, septic. (you get the idea)
- Concerns about Arsenic and Radon not addressed in DEIS
- Trenching through people’s driveways, farm access roads not addressed in DEIS
- Deliberate nearness of proposed route to homes, route no adequately defended in DEIS
- Deliberately ignoring NJ safety rules in favor of inadequate Federal standards – we get a pipe that has a 50% smaller safety margin then we would otherwise have
- Major studies controverting PennEast studies are not mentioned in the DEIS (Delaware Riverkeeper Network, NJCF/Stony Brook Millstone WaterShed Association, West Amwell Citizens Against the Pipeline, Skipping Stone, Labyrinth Consulting and others).
- The Tetra Tech employees researching the DEIS are under qualified and the DEIS is obviously not done competently
- Cumulative impacts are not properly considered (Southern Reliability Link, Garden State Expansion, BL England conversion, Blue Mountain resort Expansion, Marc II Pipeline, future Spectra plans
- The “No Action” Alternative is incomplete, has no citations or facts, and does not conform to NEPA.
- The other Systemic Alternatives are incomplete, have no citations of fact, and do not conform to NEPA
- No market studies were included in the DEIS, only the existence of shippers (the infamous Concentric “you could have saved $890 million if we had a time machine” report is not mentioned anywhere in the DEIS).
CRITICAL ACTION ALERT FOR NEW JERSEY – FLOOD HAZARD RULE CHANGES!!!
State Senate President Sweeney did NOT post SCR66 for a vote in time for the legislative deadline of January 18, 2016. The next deadline for a vote on the Flood Hazard rule changes is August 1. The danger now is that projects can be permitted under the new rules during July, and that a compromise on the resolution can be made by August 1 that weakens the resolution. DON’T LET THIS HAPPEN!! Continue to push Representative Sweeney by calling and emailing. Tell him to give us a commitment that new projects will not be approved until after Aug 1, and tell him to post SCR66 for a vote by August 1. Thank you for your continuing efforts on this. If these rule changes go into effect, it will be easier for PennEast to get permitted.
In possible victory for pipeline foes, EPA calls for rethinking of Atlantic Sunrise
The U.S. Environmental Protection Agency (EPA) is urging another federal regulator to consider alternatives for a hotly contested natural gas pipeline project in central Pennsylvania, in what seems like a win for pipeline foes but could also prove a hollow victory in the end. More
Pipeline News from around NJ: Feds tell Transco not to proceed on pipeline – for now
on July 06, 2016 at 6:15 PM, updated July 06, 2016 at 6:22 PM
on June 29, 2016 at 6:59 PM
Hopewell Township — Dozens gathered atop Baldpate Mountain preserve in Hopewell Township on Wednesday to endorse U.S. Rep. Bonnie Watson Coleman’s plan to propose a bill in Congress to revamp pipeline approvals.
Watson Coleman said she will introduce the Safe and Accountable Federal Energy Review for Pipelines Act of 2016, or SAFER Pipelines Act.
Dozens of affected residents also attended the announcement at the scenic backdrop of Baldpate, near sites where the proposed PennEast pipeline will carve through their land.
TAKE IMMEDIATE ACTION: Send a letter to the US Army Corps of Engineers
This is an URGENT Request form the HALT PennEast lead attorney, Steve Richardson of Wiley Rein. The time is short to respond to the two US Army Corps of Engineer (USACE) section 408 permit requests that PennEast has pending. We are asking that all homeowners impacted or potentially impacted in both PA and NJ and supporters of HALT send a letter to the US Army Corp of Enginners regarding a pending PennEast application in response to the Corps’ request for comments. The more letters that are sent, the more pressure is placed on the Corps to do the right thing. Impacted Homeowners and Concerned Citizens can download their respective for emailing to USACE from Delaware Township’s DTCAP site.
A group opposing the pipeline has filed a complaint with FERC arguing New Jersey doesn’t need the natural gas that PennEast would deliver
A group opposing the PennEast pipeline in New Jersey urged a federal agency to hold a formal hearing into whether there is a need for the project, arguing the applicant has failed to demonstrate the state needs the natural gas. More
STOCKTON, N.J., June 9, 2016 /PRNewswire/ — According to ReThink Energy NJ, PennEast’s proposed pipeline project in NJ and PA is considerably delayed in gaining necessary approvals from the Federal Energy Regulatory Commission (FERC) and state agencies, affected by the trend of beleaguered gas pipeline projects throughout the U.S., and widespread, growing opposition by legislators, regulatory agencies and the public. More
Letter from PA republican Congressman Fitzpatrick (newly on board) to FERC that was recently sent requesting an evidentiary hearing
Protesters kayak in opposition of PennEast pipeline at NJ Sierra Club-organized rally
on June 10, 2016 at 2:15 PM, updated June 11, 2016 at 8:00 AM
BORDENTOWN TOWNSHIP — In a move that’s being called a “first win” by environmentalists, the Federal Energy Regulatory Commission (FERC) has granted a rehearing for further consideration of the Transco pipeline project. More