No Build Option

Key Writing Points For Comments

 
Alternatives

  • The alternatives analysis provided in the DEIS is based on satisfying the requirements of National Environmental Policy Act (NEPA) and does not fulfill the requirements of an alternatives analysis under Section 404 of the federal Clean Water Act.

  • NEPA requires a cumulative environmental and market review of the effects if a project is not brought to fruition. The DEIS does not give any real consideration to the ‘no build’ alternative.

  • The DEIS states: “If PennEast’s proposed facilities are not constructed, the Project shippers may need to obtain an equivalent supply of natural gas from new or existing pipeline systems." The alternatives analysis does examine whether the stated needs could be met through existing pipelines.  Several of the shippers have stated in the application that they intend to displace existing supplies, suggesting that existing capacity is currently meeting their needs. 

  • FERC has also not evaluated how construction of PennEast might negatively impact captive customers on the existing pipelines that PennEast shippers are currently relying on. 

  • Alternatives such as LNG and dual-fuel generation plants are not evaluated as an alternative to meet possible peak demand needs.

Sample Letter  


Kimberley Bose, Secretary
Federal Energy Regulatory Commission
888 First Street, NE
Washington, DC  20426

Re:  Docket CP15-558-000 – Proposed PennEast Pipeline Project

Dear Ms. Bose:

I am  (name here)
in this proceeding who lives in (address or Township) .  I am commenting on the PennEast Draft Environmental Impact Statement (DEIS).

I urge FERC to reconsider your issuance of this DEIS at this time and withdraw the DEIS.  
Under NEPA, a DEIS is required to seriously consider the "No Action Alternative."

The "No Action Alternative" considers the baseline state of what would happen if the project were not constructed.  This alternative is supposed to be considered seriously and comprehensively.  However, in the PennEast DEIS issued by FERC, the "No Action Alternative" is a bare four paragraphs in length. Within those four paragraphs, there is only a single citation made.  That citation is to a list of shippers on the project.  There is no mention that the majority of shippers are affiliates of the owners, and that FERC has ruled in past proceedings that affiliate shippers carry less weight than contracts with unrelated entities that serve as arms-length transactions. 

There is no mention that they are lacking survey permission in over 70% of the route within NJ, and that there are strong indications that a certificate would in fact require eminent domain condemnation proceedings to be brought against 70% of the landowners in NJ or more. 

And that extensive use of eminent domain is yet another factor in the NEPA weighing that FERC performs, and should have heavy weight in considering a "No Action Alternative."

There are numerous assertions throughout the "No Action Alternative" that are backed up with no data or citations.  The sections on regional pricing impacts, reliability, and renewables are all based on assertions with no actual citations made at all.

Currently, the DEIS is not compliant with the requirements of NEPA and therefore, the DEIS must be withdrawn.

I respectfully and vehemently ask that FERC withdraw its Draft EIS and demand that a serious evaluation and comprehensive consideration of the "No Action Alternative" be conducted.

Sincerely,
 

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 #.
If you do not have it you can enter your email address you used to file.
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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 NO BUILD OPTION.