Harihokake, Lockatong, Wickecheoke, Alexauken, Nishisakawick, and Little Nishisakawick

25 February 2015

Ms. Kimberly Bose

Federal Energy Regulatory Commission

Office of the Secretary

888 1st Street, NE

Washington, DC 20428

Re: Docket No. PF15-1-000: PennEast Pipeline Project, EIS Scoping

Ms. Bose:

The New Jersey Chapter of the Sierra Club hereby states its opposition to the PennEast Pipeline project, in any configuration.  The Environmental Impact Statement, encompassing proper, wide scope and depth, would demonstrate an overwhelming amount of environmental degradation, loss of preserved open space, and destruction of a rural sense of place, all without demonstrable need, in the name of profiteering from a rush to extract natural gas from the Marcellus Shale.

A thorough Environmental Impact Statement (EIS) is imperative; its scope must be broader than the footprint of the pipeline.

The purpose and need for the PennEast pipeline must be proven beyond the desire for profit.  In its Resource Report submitted to the Federal Energy Regulatory Commission (FERC), PennEast cites the need for inexpensive natural gas as the reason to build a 114-mile pipeline through one of the most rural stretches of the Delaware River watershed. The report also suggests, as if profit were an inalienable right, that the no-build alternative would be detrimental to the owners of the pipeline company.  There is no proof, within the report or elsewhere, that the natural gas shipped through the PennEast pipeline would even serve those whose land the pipe has severed.  It is possible, however, that the transported gas will be compressed and sold offshore, where it would fetch a higher price.  Were this to be the case, the project purpose and need, beyond profit, would be nothing.

When considering the extent of the project area, the EIS must include not only the footprint of the pipeline right of way, but also, at minimum, the farthest boundaries of all contiguous and adjacent properties and water bodies, historic sites, and economic centers. Environmental degradation, fragmentation, siltation, contamination, and historic devaluation would occur far beyond the limits of the pipeline right of way.

Cumulative impacts must also be considered, not only for the length of the pipeline, but also within the context of the Marcellus and Utica shale fracking boom. Multiple pipelines have been proposed and constructed to transport shale gas throughout New Jersey. The PennEast project must be considered within the expanding network of natural gas pipelines.  The National Environmental Policy Act (NEPA), under which the EIS must be written, dictates that cumulative impacts include not only past, but also present and future impacts.  Cumulative impact analysis should include effects on water quality, wildlife, forest fragmentation, invasive species, preserved open space, preserved farmland, property values, recreation, employment, and the rural aspect of the pipeline’s path. The effects from blasting through diabase rock, disturbing arsenic-rich Triassic shale, ancillary construction, pumping stations, and maintenance must also be considered.

The EIS must also take into consideration the unique ecosystems through which it would cross, and the many protections these ecosystems have on them.  For example, the pipeline’s crossing near Riegelsville would be within the Lower Delaware National Scenic and Recreational River. Near its southern terminus, the pipeline would cut through the Sourland Mountain, which contains the last contiguous forested areas in central New Jersey and has been recognized as a unique and fragile ecosystem.  From its origin in Luzerne County, Pennsylvania, to its destination in Mercer County, New Jersey, the pipeline would cross more than 88 waterways, 44 wetlands, 30 parks, and 33 conservation easements [see the Delaware Riverkeeper Network’s FERC submission, 20150218-5212(30172450)] .  In New Jersey, 6 streams carrying the Category 1 designation for their exceptional ecological significance, will be crossed, some more than once.  These streams are the Harihokake, Lockatong, Wickecheoke, Alexauken, Nishisakawick, and Little Nishisakawick Creeks, all of which feed into the Delaware River from rural ridges in Hunterdon County.  The EIS must also consider the possibility that the pipeline would violate Section 404 of the Clean Water Act because of the number of high quality streams, wetlands, and rivers it would cross.

The scope of the EIS must also include thorough analyses of steep slope degradation, runoff, siltation, soil compaction, above- and below-ground hydrological alterations, crop production, native and invasive vegetation, and native and invasive wildlife. Surveys of endangered and threatened species should occur when such species are the most visible; multiple surveys for multiple species should occur.

Changes in air quality must also be evaluated in depth.  As a greenhouse gas, methane is many times more potent than carbon dioxide. From potential methane leaks along the pipeline to construction-related air pollution, cumulative impacts on local, regional, and global air quality must be considered.

Several socioeconomic impacts must also be considered.  Employment opportunities would be, for the most part, transient.  Property values along the pipeline are likely to decrease.  Historic sites and recreational areas would be negatively impacted.  New Jersey’s taxpayers have contributed millions of dollars to preserve the forests, farms, and waterways that the PennEast pipeline would cross.  The effect is that of a taking for private gain.

A properly executed EIS must include not only the preferred route and the no-build option, but alternative routes as well.  All routes must be evaluated with the same criteria.  As proposed, the negative impacts of the PennEast pipeline route are overwhelming.  While PennEast has attempted to align much of Hunterdon County’s route with existing rights of way, the negative impacts have not been reduced.  Because of its intended origin and destination, alternative construction through the built environment carries with it large socioeconomic impacts without reducing many of the environmental ones.  In the end, the only reasonable option is the no-build alternative, which must be considered equally with all proposed routes. With due diligence and thorough analysis, the PennEast EIS should demonstrate that this 114-mile pipeline carries only profit for those who would never bear the negative impacts of the destruction of one of the last remaining stretches of rural New Jersey.