By: Nicole C. Sasaki
On July 17, 2013, Riverkeeper, in conjunction with a coalition of environmental groups represented by Earthjustice – Catskill Mountainkeeper, Clean Air Council, Delaware-Otsego Audubon Society, Delaware Riverkeeper Network, and Sierra Club – submitted comments to the Federal Energy Regulatory Commission (FERC) on Constitution Pipeline’s application to construct a interstate pipeline to transport natural gas from Pennsylvania to the New York City and Boston metropolitan areas. Riverkeeper also submitted a motion to intervene in the project proceedings, and will be an active participant in FERC’s ongoing environmental review process. Constitution Pipeline Company, LLC, filed its application with FERC on June 13, 2013 for a Certificate of Public Convenience and Necessity for the 122-mile, 30-inch diameter underground pipeline proposed to run through four counties in New York and one in Pennsylvania. FERC has the authority to deny approval for the project if the environmental costs, among other factors, outweigh the project’s benefits. If approved, the proposed pipeline route would begin in Susquehanna County, Pennsylvania, and connect with the Iroquois and Tennessee Pipelines, both located in Schoharie County, New York.
If constructed, the proposed pipeline threatens to cause severe environmental impacts, including significant alteration of the rural landscape and potential harm to wildlife and human health. Of immediate concern to Riverkeeper are the negative impacts that the proposed pipeline would have on water quality, including the quality of drinking water supplies in the project area. We are also concerned that the preferred pipeline route proposes to go through the Hudson River watershed, crossing the Schoharie Creek, a tributary of the Mohawk River, and that an alternative pipeline route (Alternative Route K) would cut through the New York City drinking water supply watershed. We are seeking to ensure that Alternative Route K is officially declared an unavailable alternative and that the likely impacts to the Schoharie Creek and other water resources are fully identified and considered by FERC before any decision is made on this project. By submitting these comments and moving to intervene, Riverkeeper is in a better position to fully participate in the environmental review of the proposed pipeline to ensure that these resources are protected.
Riverkeeper’s comments urge FERC to thoroughly review the project’s expected adverse impacts, including cumulative impacts, to drinking water resources, as well as to surface waters and wetlands due to waterbody/wetland crossings, water withdrawals for hydrostatic testing (which requires the use of large volumes of pressurized water to test the structural integrity of the pipeline post-construction), and stormwater discharges. As proposed, the pipeline would cross multiple sources of public drinking water, 6 watersheds, at least 286 wetlands, and 263 waterbodies, including designated high quality streams, trout streams, and at least 80 protected streams. Riverkeeper is also deeply concerned that, if constructed, the proposed pipeline would encourage future high-volume horizontal hydraulic fracturing (fracking) of the Marcellus and Utica shale formations in New York and an increase in the fracking already underway in Pennsylvania, areas which the pipeline proposes to cross in both states.
Riverkeeper submitted comments to FERC at this stage to urge FERC to address our concerns in its draft environmental impact statement, the next step in the environmental review process for the project. We intend to continue to fully participate in that process and to urge FERC to deny Constitution’s application, as the environmental costs of the pipeline greatly outweigh its purported benefits.