How to Submit a Public Comment (using eComment) on the Federal Energy Regulatory Commission’s (FERC) Review of PennEast’s Environmental Assessment :
Click here for a full introduction to this issue.
- Go to FERC’s eComment webpage.
- Type your personal information in the spaces provided.
- Type the characters (the combination of letters and numbers) you see in the picture provided and click “Authorize.”
- FERC will then send you an email from the address eFiling@ferc.gov which will contain a unique link to access your eComment page.
- When you open the email from eFiling@ferc.gov, click the link to continue with the eComment process.
- Once you are directed to FERC’s eComment webpage, find the box that says “Enter Docket Number” and type the docket number “CP20-47-000” in the space provided, and then click “Search.” When the docket CP20-47-000 appears as an option, click the blue plus symbol to select it.
- In the comment box, you can either copy and paste Clean Air Council’s sample comment and modify it as you see fit, or write your own comment.
- Once you have finished typing your comment, hit the “Send Comment” button at the bottom of the page to submit your comment.
Sample Comment:
The Federal Energy Regulatory Commission (FERC) must consider the following issues in regard to its Environmental Assessment (EA) of the proposed PennEast 2020 Amendment Project.
FERC must require a thorough and honest review of the purpose and need for Phase 1 of PennEast since the proposed purpose and need remain unjustified. Phase 2 may never be developed due to the legal and regulatory challenges PennEast faces in New Jersey. Although PennEast’s developers argue Phase 1 could operate as a standalone project, they fail to provide a clear justification for Phase 1’s purpose and need. Instead, the EA references the purpose and need provided in the Environmental Impact Statement drafted for the original project. Phase 1 cannot have the same purpose and need as the original project since this pipeline ends in Bethlehem Township, far from the terminus of the original project and has interconnections which weren’t part of the original project.
PennEast Pipeline Company LLC can’t find enough shippers for its gas, yet it still wants FERC to approve the project. The Phase 1 project has found purchasers for only 52% of the pipeline’s capacity and those companies are self-dealing partners of the PennEast project. This means that the competitive market has shown no interest in this project.
If Phase 1 is a stand-alone project, then it is a different project altogether from PennEast’s original proposal and therefore must be submitted as a new project and begin its permitting and review process from scratch. FERC cannot allow PennEast to circumvent the law. If Phase 1 is not viable as a stand-alone project and is dependent on the second phase of the project to fulfill its purpose and need, then FERC cannot approve Phase 1 because it would amount to an illegal segmentation of the project.
In its EA, FERC needs to be more thorough in considering the health impacts gas infrastructure inflicts on communities. FERC only looks at air pollution on a yearly basis, but some of the worst harm to lungs comes from spikes in air pollution – large emissions over hours or minutes – which can cause asthma attacks, rashes, bleeding, nausea, and other illnesses. The analysis doesn’t consider these harms, which makes it incomplete and wholly unacceptable.
Thank you for considering these comments.
