FERC Deadline Reminder – August 29th, 2020

DEADLINE TO SUBMIT COMMENTS TO FERC IS WEDNESDAY, SEPTEMBER 2!

As a reminder, we have until Sept. 2nd to make comments on the inadequate Phase I Environmental Assessment (EA) but do it soon and make more than one comment!

Below are 4 comment options and directions on ways to comment.  Do not worry about being original and repeating the comments of others. Every comment to the docket shows that we are watching and are aware of FERC’s actions. If possible, please send the 4 comments separately.  The more comments submitted the better. 

WHAT TO SAY :  Below are the sample comments (free to copy all or parts of and use as your own).  Also, please ask that the comment period be extended to the end of September in every comment.

Comment Option 1

Your Commission has provided inadequate opportunity for public information and public comment concerning this project. No workshops nor public hearings have been held either in person or virtually. Hard copies of the EA have not been mailed to intervenors and all information must be obtained online which is difficult for older impacted individuals and landowners who may not be computer literate. The pandemic has added to the difficulties of obtaining information on this rather confusing project because local organizations cannot fill the void to provide in-person meetings. In light of the foregoing, your Commission must do more to provide information to intervenors and the public and you must extend the comment period to the end of September.

Comment Option 2

The purpose and need portion of this EA simply parrots that used in the original certificated project. Clearly, this is not adequate. This pipeline has a different terminus and cannot serve the same purpose as the original project. Further, this project has subscriptions for only 52% of the pipeline capacity and those subscriptions are self-dealing partners of the PennEast project. The competitive market has shown no interest in this project and these circumstances undercut the purpose and need cited in the original project. It has been six years since the original project was proposed and your Commission should insist on a thorough investigation of the need for this new project in the context of today’s facts. The energy market has changed, and other pipelines have been completed and enlarged to serve the customers of this pipeline. There must be a thorough and honest review of the purpose and need for this Phase I project.

Comment Option 3

The proposed Environmental Assessment (EA) violates the National Environmental Protection Act (NEPA) and the Natural Gas Act because the EA is too narrowly focused on the Church St. Interconnect and fails to consider the full impacts of and alternatives to, building both phases of the project, which FERC defines as the purpose and need. Furthermore, FERC does not have the jurisdiction to amend the original certificate, as that jurisdiction rests with the D.C. Circuit of the US Court of Appeals.

Comment Option 4

This comment is in regard to PennEast (Docket CP-20-47-000) Proposal to segment their pipeline by building it in two stages, claiming that the first stage for which they are requesting approval is a stand-alone project.

If this segment is a stand-alone project, then it is a different project altogether and cannot be approved by FERC under the original Conditional Certificate. It has to be submitted as a new project starting from scratch.

If it is not a stand-alone project it and is dependent on the second phase of the proposed pipeline it cannot be approved by FERC because it is the illegal segmentation of the project.

Either way you look at it, it’s another one of PennEast’s attempts to circumvent the law and the rights of the people.

HOW TO COMMENT:   There are three easy ways to comment on the EA.

  1. The first online option is to go to FercOnline.gov and pick “ecomment” from the blue menu on the left of the screen. Fill in your personal information in the blanks and type in the authorization code (which will be provided) and click “authorize.” FERC will send an email to you with a link to click to permit you to write a comment. You will need to enter a docket number which is CP20-47, click search and the PennEast project will appear on the chart with a blue X beside it. Click the blue X. A screen will appear for your personal information which you fill in. And then (last step) paste your comment into the comment field and click “send comment” at the bottom of the page.
  1. If you have registered as an intervenor, you can go to FERC online and choose “Log In” from the blue menu on the left and then continue as directed above.

Note: It is best to type up your comment before going onto the FERC website. Copy your comment and then paste it into the comment box at FERC online (following the directions above). FERC is notorious for closing out your access in the middle of typing in a comment.

  1. And, you can always send your comment via the postal service but be aware that the mail has slowed by at least a week.

Send your comment to Kimberly D. Bose, Secretary, Federal Energy Regulatory Commission, 888 First St. NE, Room 1A, Washington, D.C. 20426. Be sure and reference the docket number (CP20-4700) in your comment.

“COMING SOON”

The recording of the August 26 Virtual Member Meeting, attended by 20 members by video and phone, will be coming soon to our website. https://haltpenneast.org/

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