Wednesday, October 15, 2014

Dont be silenced by FERC! Comment NOW on Dominion's plan to bring more FRACKED GAS into NY


Photo: BH

This just in from an ad hoc team of folks looking over the Dominion New Market Project. 
This has been produced and vetted by some of the top frack-fighters in the state.

So you may want to consider this ... "important" :)

PS: Remember: Sharing is caring :)

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:


Submitting comments electronically is actually the best way, but it's a bit tricky.
It involves using the "eComment" feature on FERC's website , 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.

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.

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.


INSTRUCTIONS for filing eCOMMENTS with FERC on Dominion's "New Market Project"

 (Thank you to Suzy Winkler for preparing these great instructions.)
Again, if you have trouble with any of this, send your comments in by paper mail as explained above.

The following instructions will help you file comments about Dominion's proposed project electronically using the "eComment” feature on FERC's website. First you fill out a brief form on FERC's website. Then FERC will then send you an email with a link allowing you to cut and paste your comment online.

Follow these instructions:

1)  Write a comment on your computer and save it. When it's time to enter your comment on the FERC website (#9 below), you will then be able to copy and paste your comment into the allotted space.

2)  Go to:

3) Click on the orange and white "eComment" button. An authorization page will open.
Fill in your name, address, email address and phone number.

4)  Type in the letters and numbers that you see in the gray box and choose the "Authorize" button.

5)  FERC will send you an email with a link. 
Select the link, which takes you to FERC's website. A form with your name and email will appear.

6) In the box marked "Enter Docket Number," fill in CP14-497 (with no spaces)

7) Click on the "Search" button and wait a moment for a response.
Choose the blue plus sign in the far right column under the “Select" heading and wait a moment for a response.

8)  Ignore the new blue box with additional information that appears on the screen.
Find the box for entering your comment slightly below. The system will allow you to enter up to 6000 characters.

9)  Cut and paste your previously prepared comment (from #1) into the box.

10)  Click on the "Send Comment" button in the lower left corner of the screen.

11)  FERC will send you an email saying that your comment has been received. This is your confirmation.
Please save the email.

12)  In the email there will be a link to view your comment in the "eLibrary"

** If you use the "Safari" browser on your computer, this process may give you trouble. For some computers it does and for others it works fine. If the system isn't responding as described above sImply download the "Firefox" browser from the internet and you will be in good shape to move forward.

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