Dear Commissioners of the Federal Energy Regulatory Commission,
Green America, with outreach to 200,000 individual members and 3,000 business members, is writing to comment on the proposed Eastern Panhandle Expansion Project, Docket number CP17-80-000. Based on our review of the proposed project, and the risks that it poses to drinking water for people throughout the National Capital Region as well as threats to the natural environment, air quality, and local landowners and businesses, Green America strongly urges FERC to reject this project.
Green America is concerned that FERC is only assessing the TransCanada/ Columbia Gas portion of a much larger project that is on both sides of the Potomac River. The pipeline needs to be assessed in full across all the affected states. FERC should assess the diverse impacts of the entire pipeline, including a full environmental impact statement, with public hearings.
The potential harms of this project are alarming:
1. Leakage to Groundwater Supply
The geology of the pipeline’s path is such that any leaks from construction or use of the pipeline could be devastating to the water sources of the local population. The pipeline would sit on top of a type of bedrock called Karst, which is highly porous and would allow discharges to enter groundwater supplies. Additionally, the area is prone to sinkholes, which is a further risk to integrity of the pipeline. This would clearly create environmental harm, and would also harm residents and local economies.
2. Risk of Explosions
The main component of natural gas is methane, which is highly combustible, leading to dangerous explosions. The Pipeline and Hazardous Materials Safety Administration (PHMSA) collects data on all reported incidents for gas pipelines. Between 1996 and 2015, there were 11,192 incidents costing $6,678,631,880. These incidents killed 371 people and injured another 1,378. We are opposed to the construction of this dangerous and expensive energy source.
3. Violation of Private Property Rights
Green America is opposed to the way that energy companies have coerced or intimidated individuals into selling their property. We strongly oppose energy companies’ right to invoke eminent domain as this project serves no public interest.
4. Threat to the Potomac River
The Potomac River is the fourth largest river along the Atlantic coast and the 21st largest in the United States. It drains 14,670 square miles of land area from four states and Washington DC. The proposed pipeline will go under the Potomac River in an area listed as sensitive on the Nationwide Rivers Inventory. The method used to drill under the river could destabilize the bedrock. Even without a catastrophic accident during construction or operation of the pipeline, this increases the risk of serious spills. A spill would have devastating effects on the health and livelihoods of the more than 6 million people who live within the Potomac watershed.
The creation of the Rover Pipeline in the Midwest, approved by FERC a few months ago, already resulted in the spill of 2.5 million gallons of drilling fluids into pristine wetlands in Ohio. Those wetlands will never be the same. That’s why FERC needs to do more rigorous environmental impact statements, based on real risk analyses.
5. TransCanada’s Poor Safety Record
Natural gas production in the United States has greatly increased over the last decade. Pipelines are being rushed and built with fewer quality controls. The failure rate of new pipelines is on par with those constructed as far back as the 1940s.
TransCanada is known for explosions, leaks, poor materials, and for ignoring its own safety inspections and quality controls. We cannot allow our natural resources, health and safety, and personal livelihoods to be in the hands of such a company.
6. Methane Emissions and Climate Change
Methane is a greenhouse gas many times more potent than carbon dioxide over the short term in terms of trapping heat. New evidence is showing that methane leaks from natural gas infrastructure like pipelines is a much more severe problem than we thought in terms of climate change. The climate and polluting effects of methane endangers public health and welfare.
In addition to the above, Maryland recently enacted a ban on fracking, which received strong support from the public. Residents of Maryland oppose fracking and do not want additional fossil fuel infrastructure construction in their state.
In closing, our nation needs to move away from fossil fuels and to invest with all due speed in the further development of our clean energy-based economy. Investment in renewable energy creates jobs and provides clean, climate-smart energy and energy security. Rejecting the Eastern Panhandle Expansion Project is a wise decision for the Potomac region and our nation.
Sincerely yours,
Todd Larsen
Executive Co-Director, Green America
