Tuesday, November 22, 2016

Please Act Now - Kentuckians' Safety Remains At Risk

Please. Help keep us safe.

There’s a large project planned that will impact all of us here in central KY. Please help.

What can you do? Simply write up reasons why this pipeline project is controversial or worries you. Submit them online to the federal agency overseeing the project.

Below, we’ll give you background on the project, where to send your comments and more about why each and every one of us submitting comments is so important.
The current Kinder Morgan natural gas line has a "potential impact radius" of 450 feet to either side of the line (visualized in red). An NGL leak is even more dangerous. An NGL leak can asphyxiate anyone near it. A small spark, even heat, can ignite vapors and cause an explosion. Do you want this in your community? Here’s a map of the pipeline project that shows you exactly where it runs, including through Richmond, Danville and across the Kentucky river upstream of Lexington. 

Kentuckians have stopped a pipeline before.
Let’s do it again!

 
What is this project?
This project is officially entitled “Abandonment and Capacity Restoration Project.” The oil and gas company, Kinder Morgan, owns another company, Tennessee Gas Pipeline, LLC. ­­Kinder Morgan intends to eventually, through subsidiaries, carry natural gas liquids right through Kentucky (and several other states) in a 964 mile long pipeline known as the Tennessee Gas Pipeline.

What are the basics?
There’s a pipeline already running through central Kentucky that’s over 70 years old. It ships natural gas from the Gulf to the north. With all the fracking in the north, Kinder Morgan now wants to send its product in the opposite direction. At first, this may not seem like a big deal.

It is a big deal. What’s coming from the north through the same pipeline will be natural gas liquids (NGLs). These are heavier than natural gas and would put greater pressure on that old pipeline. Worse still, they do not dissipate when they leak and they are highly volatile, so they are much more dangerous than natural gas.

When are comments due?
December 2, 2016

What should I say?
Learn a bit about what this project involves then simply write about your concerns. Write about who could be harmed. Write about impacts to our next generations. Folks who support this project are also free to send in their comments.
 
Important legal terms:
Reference to “foreseeable action” and/or “related action” and the project having “significance” will make a big difference in FERC giving your comments more weight.

Why?

Because FERC will pay closer attention to comments that specifically note the conversion of the pipeline constitutes a foreseeable action, that has significance in terms of its potential devastating impacts to our land, water, and communities. Make clear that the abandonment project is a “related action” to the transportation of NGLs project. They are simply 2 parts of an overall plan.

Where do I send my comments?
You’ll submit them online to the Federal Energy Regulatory Commission (FERC). Write up your thoughts, save them, go to site and add your comments in the form. (Look for the fourth yellow box on the right: eComment). Or, register and submit your comments in the format you want.

You need a docket number!
FERC may not read or process your comments if you don’t label them with the docket # for this project.

>> Include EA Docket # CP15-88-000 right at the top. <<

If you prefer paper and post, you can mail your comments to: Kimberly Bose, Secretary, FERC, 888 First Street NE, Room 1A, Washington DC 20426.

Read on to get all the details and understand this project better….

What are the main concerns?
If FERC doesn’t get enough comments from concerned people, it won’t take any future action and the pipeline project can move forward regardless of the risks.

This is why your comments matter.

That pipeline will begin with shipping 150,000 barrels of NGLs per day and can increase that amount to 450,000 per day. Leaks, spills and potential explosions like the recent one in Birmingham (that was a gas pipeline, not NGL) would be dangerous, if not catastrophic, should they happen in a populated area, or near a water source.

On Nov. 2, FERC issued an Environmental Assessment of the project and decided that assessment was sufficient to review the project’s potential impacts and risks. For a more thorough review, FERC would need to conduct the next step: an Environmental Impact Statement. Your comments can make that happen. Please write FERC.

Why does FERC think an Environmental Assessment alone is enough?
It doesn’t consider the conversion of the pipeline to run Natural Gas Liquids (NGLs) as a “foreseeable action.”

Yet, Kinder Morgan’s company, Tennessee Gas Pipeline, has planned this project for nearly two years. It’s pretty blatant there is a clear intent for use, so declining that it’s “foreseeable” is a problem. Page 10 of the Environmental Assessment even makes the plans clear.

It explains that, upon FERC approval of the pipeline plan, Kinder Morgan will sell the abandoned pipeline to Utica Marcellus Texas Pipeline LLC, which will then construct a project to transport NGLs in that pipeline from processing plants in Ohio down to the Gulf coast of Texas.

Furthermore, FERC is required by law – the National Environmental Policy Act – to consider significant impacts of this pipeline project. Here’s what the Act states:
“significance exists if it is reasonable to anticipate a cumulatively significant impact on the environment. Significance cannot be avoided by terming an action temporary or by breaking it down into small component parts.”

How can I do my own research?
For starters, here’s the Environmental Assessment document released by FERC on Nov. 2. (Click the top pdf link.)
Here’s text of the National Environmental Protection Act.
This is a story from WPFL that includes a nice explanation of the project, and the harms of natural gas liquids.
Here’s a map of the pipeline project that shows you exactly where it runs (including right through Richmond).

What should FERC do?
The next step, a full Environmental Impact Statement, must happen. The project is more than just “foreseeable.” It’s obvious. So, examination of all that could happen by shipping the heavy, dangerous NGLs needs considered.
The Tennessee Gas Pipeline runs through residential areas, across prime farmland, through water sources and sensitive karst (cave) terrain. Please submit your comments today, and please share this message. Our neighbors, friends and family members deserve to know what the government and this corporation are trying to do to us. 
What could I include in my comments?
 
  • Personalize your comments. Tell your story. Show FERC you really care. For example, if you live near the pipeline or your kids go to a school near the pipeline, say so. Heartfelt worries, if not fears, can sway FERC.
 
  • Point out the obvious: that the intent of Kinder Morgan to convert the pipeline to transport NGLs is quite clear. For over 70 years, the pipeline has delivered natural gas and Kinder Morgan intends to run a much more dangerous and heavy substance, Natural Gas Liquids, through the aging pipes.
 
  • State clearly that FERC has to follow the law. Note the project has significance, and is thus worthy of more detailed scrutiny. Explain how FERC must follow the mandates of the National Environmental Policy Act and consider the significant impacts of the pipeline project.
 
  • FERC should develop a full Environmental Impact Statement that includes thorough review of 1)  the environmental effects of the pipeline abandonment and 2) its subsequent use to transport NGLs.
 
  • The flow reversal, the change to NGLs and the conversion to service of this 70+ year-old pipeline are controversial actions that warrant thorough analysis. FERC approval of the project, an “abandonment in place” so it can then be sold and repurposed, is a prelude to any leaks, spills, or other damage, and is a “major federal action.”
 
  • The EIS should evaluate the risks posed to land and water resources (groundwater in particular) from NGL leaks and spills.
 
  • The EIS should evaluate impacts on public safety and public health associated with both catastrophic and smaller leaks and spills.
 
  • FERC should evaluate alternatives to approving abandonment of the pipeline in place, including mandating removal of the abandoned line.
 
  • FERC must analyze the reuse of the pipeline because its abandonment is a foreseeable and related action to transporting NGLs. (This one is a bit more complex, but important to include in your comments.)
  •  
    •  FERC claims that the pipeline’s use is not within its oversight because it doesn’t regulate what happens after the pipeline is abandoned. However, abandonment is a necessary step before repurposing it to transport NGLs. It directly relates to transport of NGLs.
    •  
    • The National Environmental Protection Act requires FERC to regulate effects of the project that are “direct, indirect, and cumulative.”  The effect of abandonment is to run NGLs and the effects of NGLs are of significant impact on safety, health and the environment, all of which can be either direct or indirectly related to the abandonment, and any harmful effects, taken together are cumulative damage.
  
  • The reuse of the pipeline is a “related action”, meaning the potential reuse of the pipeline for NGLs is directly related to if the abandonment of the pipeline is approved, and FERC must analyze it even if that use is not within FERC’s “jurisdiction” (FERC is currently claiming that it's jurisdiction ends with the abandonment of the pipeline). The reuse of the pipeline for NGL transport has effects that are “direct, indirect, and cumulative” and which NEPA requires be analyzed.

What happens with an NGL leak?
When Natural Gas Liquids leak, about 85% will turn into an odorless, colorless and highly flammable vapor once they hit the air, settling in valleys, creeks, rivers and other low points. Vapors can be ignited by heat, spark or flame, with an explosion potential from a small spark. The other 15% of an NGL leak remains a liquid and may contaminate the soil and water with chemicals like benzene, known to be a human carcinogen. Kinder Morgan has not disclosed information that will allow the public, county government, or first responders to understand the risks of carrying NGLs beneath our homes and to plan accordingly. A complete analysis in the form of an Environmental Impact Statement (EIS) would provide this needed information. Your comments are needed to make this happen. 

 
 
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