Comment NOW on Dominion's plan to bring more FRACKED GAS into NEW YORK!
Thank you to everyone who attended FERC's terribly-conducted scoping hearing last week on Dominion's "New Market Project."
Threatening to bring a billion more cubic feet of fracked gas into
New York every day, Dominion Transmission Inc. wants to squeeze more gas
into its aging pipeline network by building two massive compressor
stations and dramatically expanding a third. These three compressor
stations alone would dump 200,000 additional tons of greenhouse gas
emissions and cancer-causing air pollutants into the atmosphere every
year.
Those who were at the hearing saw
first-hand how FERC was totally unprepared for the opposition it
received, even admitting that it made a big mistake by scheduling just
one hearing in an illegally overcrowded room. But now we need to drive home the message that apologies are not good enough.
We must demand that FERC schedule MORE SCOPING HEARINGS in each of the affected areas, especially where the THREE massive compressor stations are proposed: HORSEHEADS, GEORGETOWN, and BROOKMAN CORNERS. And we must demand that FERC extend the OFFICIAL time period for
submitting scoping comments so that communities, organizations, and
individuals have fair and adequate opportunity to weigh in on how FERC
reviews Dominion's proposed project.
But until we hear otherwise, the official deadline for scoping comments is still October 20th, which means that your help is needed right now! Here's how to comment:
TO COMMENT ONLINE:
Submitting comments electronically is actually the best way, but it's a bit tricky.
It involves using the "eComment" feature on FERC's website
http://www.ferc.gov/docs-filing/ecomment.asp , begin the process by clicking the orange and white "eComment" tab in the middle of the page. (To send attachments, you have to use the "eFiling" feature and first create an account using the "eRegister" feature.)
You'll receive
another email after this one with detailed instruction for how to
submit comments to FERC using "eComment". But if you still have trouble
commenting online, don't let that stop you! You can still send your
comments in by paper mail.
TO COMMENT BY PAPER MAIL:
Send written comments to:
Kimberly D. Bose. Secretary
Federal Energy Regulatory Commission
888 First Street NE, Room 1A
Washington, DC 20426
All scoping comments must be received by October 20th. So for paper mailing, please post-mark by October 18th.
And be sure to identify the docket number for the Dominion "New Market" Project, which is CP14-497-000.
HERE ARE SOME POINTS TO MAKE IN YOUR COMMENTS:
In addition to objecting to the project, please insist that the following be part of FERC's scope of review.
---
It is outrageous that FERC scheduled only one scoping hearing for a
major project that impacts much of New York and 200 miles of pipeline.
FERC must schedule additional scoping hearings in affected areas, especially where compressor stations would be built or significant expanded in Horseheads (Chemung County), Georgetown (Madison County), and Brookman Corners (Montgomery County near Otsego County). FERC must also extend the OFFICIAL deadline
for scoping comments by at least 90 days so that communities,
organizations, and individuals have adequate opportunity to weigh in on
how FERC will review Dominion's proposed project.
--- FERC should require a full Environmental Impacts Statement (EIS)
instead of letting Dominion pursue an expedited Environmental
Assessment (EA). The EIS process would require a much more comprehensive
analysis of technical and safety issues relating to carrying an
additional 112,000 Dekatherms of gas per day in Dominion's aging
pipeline network, as well as a more thorough analysis of all direct,
indirect, and cumulative induced impacts. A full EIS should be performed.
--- The increased risk of pipeline failure and catastrophic fire or explosion due
to higher pressure and flow rate must be fully analyzed--especially
since parts of Dominion's network are up to 50 years old, corrosion,
degradation, or other stresses have likely occurred over time, and the
original pipe may have been constructed using inferior welding methods.
Maximum allowable operating pressure must be disclosed and verified.
This danger impacts not only people living near compressor stations, but
along the ENTIRE Dominion pipeline corridor.
---
Dominion has named this its "New Market Project" because it wants to
create new markets for fracked gas. Therefore, a comprehensive build-out analysis of the negative cumulative impacts
resulting from increased use of gas should be performed (including the
likelihood of future power plants, CNG/LNG facilities, and other types
of gas-infrastructure). A build-out analysis should also be performed of
negative environmental, health, and societal impacts of more drilling and fracking enabled by additional pipeline capacity.
---
The Dominion pipeline connects to the Iroquois pipeline, which is
planned for reversal so that it will carry gas from the U.S. to
Canada. Dominion will therefore be a conduit, in part, for exporting gas out of the United States. FERC must analyze this conflict in determining domestic public need. It is also improper segmentation
to consider this project without regard to all of the economic and
environmental impacts of exporting natural gas, which the project
facilitates.
---
A comprehensive health impact assessment should be performed to
evaluate the negative effects, short and long-term, to people living
near and at various distances from the proposed compressor stations.
Exposure to volatile organic compounds (VOC's), nitrogen oxides,
ground-level ozone, and other hazardous air pollutants from compressor
stations can cause cardiovascular,
respiratory, and neurological damage; birth defects, cancer; leukemia;
infertility; burning of lungs, eyes, and throat; muscle pain; mental
impairment, headaches, and a host of other acute and chronic illnesses.
In particular, VOC's from the Brookman Corners compressor station would
be 16 times higher than levels at the other two stations, Nitrogen
Oxides would be three times higher, and Carbon Monoxide would be 5 times
higher. Dominion MUST propose design alternatives to protect the public
from this level of exposure.
--- With
the construction and expansion of two compressor stations in Horseheads
and Georgetown, and the massive expansion of another one at Brookman
Corners, Dominion would pump over 200,000 TONS of greenhouse gas
and hazardous chemicals into the air every year, create noise
pollution, impact wildlife, and industrialize pristine rural areas.
These environmental, health, and community impacts must
be comprehensively studied. Dominion claims that greenhouse gas
emissions from the Brookman Corners compressor station alone would be
just under the 100,000 TON threshold for a major emitter. This level is
suspect and would certainly be exceeded if routine blowdowns and other
activities are considered.
---
The public must be granted full access to information, including
critical energy infrastructure information (CEII) necessary to assess
emissions and safety factors. Local fire-fighters and emergency
responders are often volunteers and may not be equipped or trained to
respond to catastrophic events such as uncontrolled gas fires,
explosion, and widespread exposure of the public to gas and airborn
toxic chemicals that could be released during an incident. Response
capability and the need for additional training or full-time responders
must be thoroughly evaluated.
--- Safety and compliance records of Dominion must be disclosed in the record and considered by FERC.
THANK YOU FOR COMMENTING!
