SEPTEMBER 2, 2020 DEADLINE!
PennEast filed yet another application with FERC on January 30, 2020 proposing that half the project be built in 2021 up to mile marker 68 (from Luzerne to Northampton Counties in PA), and that Phase 2 be built later in Bucks County and in NJ if they can ever get approvals.
On August 3, 2020, FERC released their Environmental Assessment (“EA”) of the project. We have until September 2, 2020 to comment on this. It is vital that the community weigh in and let FERC know how incredibly bad, inconsistent, and inaccurate this EA is.
FERC Docket: CP20-47-000
How To Comment on the August, 2020 FERC Environmental Assessment
The following link contains instructions on how to physically comment to FERC.
Instructions on how to comment on the FERC docket
Here are some of the many issues that we have found wrong with the EA that you may wish to comment on.
- FERC does not point out flaws in the Purpose and Need Statement. The parrot back that the Purpose and Need is simply that they have subscribers for the project, and fail to mention that PennEast is intentionally hiding the real purpose.
- FERC does not mention that half the pipeline is unsubscribed.
- FERC does not mention that the 4 woeful contracts are with PennEast affiliates. Not a single 3rd party has signed on to the project.
- FERC fails to address why the Hellertown Lateral in PA is not included in the EA.
- FERC fails to address the fact that NJR Energy Services and UGI Energy Services are skipping out on a combined 100,000 dekatherms/day commitment in PA from the original project.
- FERC does not investigate how the NJ affiliates who have contracted for gas volumes will receive gas from Phase 1. This is a problem because Phase 1 never enters NJ.
- The 30 day comment period is insufficient in the time of covid-19. People need more time to assess this given the difficulties of working from home.
- The EA improperly focuses only on the Church Road interconnects. Given that PennEast lacked survey data in the first certificate application, it now has new information where it can more accurately assess environmental impacts beyond desktop surveys.
- The EA assumes Phase 2 is unchanged from the Certificated application. This is false, as PennEast has signaled changes at the Hellertown Lateral due to the Phase 1 changes.
- FERC fails to ask about Phase 2 purpose and need. Given that Phase 1 has some of the same shippers as the original route, FERC must demand shipper details for Phase 2.
- FERC fails to acknowledge the jurisdiction of the DRBC.
- The EA states that it has addressed commenters concerns during the scoping period in the EA. It does not.
- FERC must determine that a new EIS is required. Based on the changes in purpose and need, a new EIS must be prepared so that the Commission can properly assess impacts vs. purpose and need.
Link to 8/3/2020 Environmental Assessment
FERC Environmental Assessment, (8/3/2020
FERC Notice of Comment Period on Environmental Assessment (8/3/2020)