Kentuckians have stopped a pipeline before.
Let’s do it again!
What is this project?
Important legal terms:
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.
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.
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.