Geology

 Deficiencies in the DEIS:

Missing and Faulty Analysis

  •  ​Prior to construction, PennEast shall file with the Secretary results of the outstanding Phase 2 and 3 portions of the Geohazard Risk Evaluation Report and include the following in its pipeline design geotechnical report:

               a) an evaluation of liquefaction hazards along the pipeline route and at the proposedcompressor station site;

               b) a final landslide hazard inventory;

               c) any specific measures and locations where specialized pipeline design will be implemented to mitigate for potential liquefaction or landslide hazards; and

               d) a post-construction monitoring plan. (Section 4.1.5.2)

  • Prior to construction, PennEast shall file with the Secretary a final Karst Mitigation Plan that incorporates the results of all outstanding geophysical and geotechnical field investigations in karst areas including stream crossings proposed with the HDD method. 
(Section 4.1.5.4)

  • Prior to the end of the draft EIS comment period, PennEast shall file with the Secretary the results of its ongoing evaluation of potential presence of working and abandoned mines near the proposed crossing of the Susquehanna River. The evaluation shall include
documentation of coordination with the Pennsylvania Bureau of Abandoned Mine Reclamation, and shall identify any specific design or mitigation measures. (Section4.1.5.4)

  • Prior to construction, PennEast shall file with the Secretary the results of all outstanding
geotechnical investigations and final planned design of each HDD crossing. (Section 4.1.7)


Sample Letters  

Kimberly D. Bose, Secretary
Federal Energy Regulatory Commission
888 First Street NE, Room 1A
Washington, DC  20426

RE: PennEast Pipeline (CP15-558-000) 

Dear Secretary Bose,

I am (enter your name and state how you are affected - directly impacted landowner?  Intervener?  Business  Owner?) in this proceeding who lives in (enter your address or Twsp).

I am concerned that the DEIS “conclude[s] that the Project would not have significant impacts on geologic resources,” because of the following: 
PennEast has yet to survey 70% of the pipeline route. Therefore, how can it possibly know of and provide mitigation measures for all of the various abandoned mines the pipeline will cross? 

The DEIS says that the “there are no mines or quarries located within 0.25 mile of the Project in New Jersey,” but it also says that FERC is, “recommending that PennEast provide the results of its ongoing evaluation of working and abandoned mines near the proposed crossing of the Susquehanna River.” How can FERC say such definitive statements when they do not have all of the information required to make an informed decision?

Also, the DEIS does not mention the abandoned Uranium mine in Milford Township. How can we know how many other abandoned mines they are missing?

Along with abandoned mine surveys, FERC is still missing information for “site-specific evaluations of landslide risks.” Not only have these areas not been fully surveyed, but also PennEast has yet to file, “final pipeline routing/mitigation measures through geologically hazardous areas, a final landslide inventory, specific landslide mitigation measures with locations, and a post-constructions landslide monitoring plan.”
FERC says, “PennEast conducted a leachability evaluation of rock samples collected along the proposed pipeline route[, and] based on the results of this study we conclude that no mitigation measures related to arsenic mobilization are necessary during Project construction and operation.” However, Tullis C. Onstott, Professor of Geosciences at Princeton University, posted a report to the docket which found that there would be a significant amount of leached arsenic as a result of pipeline construction. PennEast and FERC have yet to respond to this!

With so many information gaps and contested data, I don’t see how FERC can conclude that this pipeline won’t have any geological impacts. 
I respectfully call upon FERC to respond to my comments, and to suspend the review of this fraudulent DEIS.

Sincerely,

 

Sample Letter  

Kimberly D. Bose, Secretary
Federal Energy Regulatory Commission
888 First Street NE, Room 1A
Washington, DC  20426

RE: PennEast Pipeline (CP15-558-000) 

Dear Secretary Bose,

I am (enter your name and state how you are affected - directly impacted landowner?  Intervener?  Business  Owner?) in this proceeding who lives in (enter your address or Twsp)I am commenting on the PennEast Draft Environmental Impact Statement (DEIS).  The PennEast Draft Environmental Impact Statement (DEIS) is deficient and should be withdrawn.  I am concerned about the following geologic issues:

The Draft Environmental Impact Study (“DEIS”) for the proposed PennEast (“PE”) pipeline project states, on page ES-4 of the Executive Summary under the heading GEOLOGY:  "WE CONCLUDE THAT THE PROJECT WOULD NOT HAVE SIGNIFICANT IMPACTS ON GEOLOGIC RESOURCES.”  [emphasis added].

Then it says “In addition, with the implementation of PennEast’s proposed mitigation measures as well as its Blasting Plan, Karst Mitigation Plan, and E&SCP, and our recommendations, the geologic risk to Project facilities would be minimized."

But in another place in the Executive Summary FERC recommends PE file its Karst Mitigation Plan. FERC is not even requiring it to be done, but is just recommending PE file it, without giving a time for that Karst Mitigation Plan to be provided. 

Finally, in their conclusion, FERC appears to rely on the Plans they haven't even seen yet to suggest the project would not have a significant impact on geologic resources. 

How can FERC make that determination without having seen what PE is going to file?  How can the public comment on something it hasn’t seen yet? 

These kinds of omissions from the docket, together with FERC’s pre-determination and the suggestion that whatever PE files wouldn’t change how FERC has already decided are a breach of the NEPA standards and FERC’s own regulations. 

I call on the FERC to withdraw this DEIS until PennEast files all the missing information referenced therein, especially information having to do with the areas that PennEast intends to blast.  Without this information, FERC cannot adequately address the possible implications and cannot make a determination risk to their project or, more importantly, to the public.  Given that people’s safety and constitutional rights to their property are at stake, we must be presented with a complete Draft Environmental Impact Study. 

Sincerely,

 
You will have a FERC ID, if
you filed as an intervener or have filed previously.

  Forgot your FERC ID?
If you have intervened or commented before you should have recieved a FERC ID #.
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You will need to know the Docket # CP15-558 when you file.

Comments to FERC on the Docket

Below are some of the teriffic comments from citizens they have already filed on the docket.

You can use these as a tool to help you build your comments. Some of these comments are from specialist in their field so your comment does not have to be as detailed. You can write about your concerns about GEOLOGY.