In June 2016, PA IPL board member William A. Lochstet submitted the following comments to the Federal Energy Regulatory Commission in regards to the Draft Environmental Impact Statement for the Atlantic Sunrise Project:
The staff of the Federal Energy Regulatory Commission (FERC) has prepared a draft environmental impact statement, FERC/EIS-0269D, for the Atlantic Sunrise Project, Docket No. CP15-138-000, (Ref. 1). This report (Page 4-196) states that:
The EPA found that the current and projected concentrations of the six GHGs in the atmosphere threaten the public health and welfare of current and future generations through climate change.
However, this report concludes (Ref. 1, Page 4-289) that the net change in GreenHouse Gas (GHG) emissions from operation of this project would be less than 0.1 percent of the year 2005 Pennsylvania total of 313 million metric tons of CO2 equivalent. The impacts of Marcellus Shale wells and gathering systems are ignored in this conclusion even though these are specifically highlighted (Ref. 1, Page 4-259). This report (Ref. 1, Page 4-288) also states:
Although climate change is a global concern, for this cumulative analysis, we will focus on the potential cumulative impacts of climate change in the Atlantic Sunrise Project area.
Such a choice ignores most of the earth where many more impacts will occur. How narrow a focus is appropriate for personal responsibility? Consider that person A drives person B to a bank to rob it. Person B is held for bank robbery. But person A only provided transportation to his/her friend who wanted to go to the bank. The law considers person A to be an “accessory,” which is also a crime. This is a broader focus which considers more of the whole.
Many religious traditions address the question of who is my neighbor. Christianity suggests that even persons normally rejected by society are actually neighbors. Native American tradition suggests that neighbors extend seven generations into the future. We are all brothers and sisters together now, in the past and into the future. How narrow a focus would our legal system allow?
Our environmental laws also take a broader view as is required by the National Environmental Policy Act of 1969 (NEPA), as amended. In fact, this position has been upheld by the court in Calvert Cliffs Coordinating Committee v. USAEC, 449 F. 2nd 1109 (D.C. Cir., 1971) which states:
We conclude, then, that Section 102 of NEPA mandates a particular sort of careful and informed decision-making process and creates judicially enforceable duties……But if the decision was reached procedurally without individualized consideration and balancing of environmental factors–conducted fully and in good faith—it is the responsibility of the courts to reverse.
Therefore, we will consider a full Life Cycle Analysis (LCA) for this entire system.
This pipeline does not exist as a whole, without connecting to a source of natural gas and a customer who has an intent to utilize its energy for a useful purpose. The Project would move 1.65 billion cubic feet per day (Ref. 1, Page 1-2) of natural gas. Using the good approximation that this is pure methane, there are 12 million metric tons of methane transported per year. If this methane is burned by the customers, it yields 33 million metric tons of CO2, and some water. Methane escapes into the air at the well site, during storage, processing, and delivery to customers. The total leak rate is estimated to be in the range of 3.6% to 7.9% of production, with a mean value of 5.8% of production (Ref 2). Taking production to be 12 million metric tons of methane, which is an underestimation, the total leaked in a year is 0.71 million metric tons of methane. Methane has an enormous Global Warming Potential (GWP) in the first few decades after release, before it undergoes chemical reactions and is no longer methane. This prompt surge in global temperature rise could trigger any of several tipping points. For instance, a large sudden rise in temperature for a few decades could melt the polar ice cap, so that it absorbs summer sunlight, rather than reflecting it as snow and ice do. Thus, the short term is important to consider here. Using the GWP of methane for the first 20 years of 86 (Ref. 3), the 0.71 million metric tons of methane is equivalent to 61 million metric tons of CO2. The total warming effect due to operation of this entire system for one year is the sum of the methane burned or leaked. This sum is 94 million metric tons CO2e over the first 20 years.
This EIS reports that, in 2005, Pennsylvania emitted 313 million metric tons CO2e of GHG (Ref.1, Page 4-289). There is no indication if this is for a 20 year or 100 year period, or what the separate quantities of the GHGs were in 2005. The report goes on to compare this value with its estimate of CO2e emissions from operation of the project. Nevertheless, 94 million metric tons is about 30% of 313 million metric tons. This pipeline does not operate, or exist without these other emissions.
It might be argued that 94 million metric tons CO2e is too small to be considered. Taken alone, it might not do much harm, but consider raindrops. One raindrop is not a problem, but put enough of them together and there is a flood. Every little bit counts! We are like the alcoholic who says that one little drink will not matter. Every ton of fossil carbon that is added to the atmosphere is a threat to our present and future, as was quoted in the EIS and repeated at the beginning of these comments.
Normal Methane Releases
In the normal routine of operation of this pipeline, there are activities which will release natural gas to the atmosphere. Some of these are ordinary operating and maintenance activities at compressor stations, meter stations, regulator stations and mainline valve sites. It would be helpful, and produce a more complete picture if the final EIS would present numerical values for these expected releases. It is unsatisfactory to merely state that they are not significant. Let the public see the numbers, and then let them decide.
Section 4.9.8 discusses environmental justice issues (Ref. 1, Page 4-177). It presents population data by county, only. In order to conclude that no population group is disproportionately burdened by the project, it would be necessary to survey the pipeline path, rather than the whole counties. The data presented does not support the conclusion presented of no disproportionate burden.
Section 126.96.36.199 has a portion headed “Greenhouse Gases” ( Ref. 1, Page 4-196). This states that methane has a GWP of 25 over a 100-year time period which is from the IPCC 4th Assessment Report of 2007. The correct value as of the IPCC 5th Assessment Report of 2013 (Ref. 3) is 34 over 100 years, and 86 over 20 years. It would be helpful to compare GHG impacts over both the 100 year time period and the 20year time period, Please use up to date information.
Sections 188.8.131.52 and 184.108.40.206 describe the operation of compressor stations 605 and 610 which are to be powered by electric motors, with a natural gas-fired emergency generator (Ref. 1, Pages 4-208, 4-210, 4-289). The text seems to assume that the electricity has no GHG emissions. Since Pennsylvania is an electric choice state, the GHG burden for this electricity would depend on which supplier is chosen, and is not presently indicated. The GHG burden of the source of the electricity should be included.
Section 220.127.116.11 also states: “Methane (CH4), which is a product of natural-gas fuel combustion…” (Ref. 1, Page 4-289). Combustion of natural gas results in CO2 and water. Please correct this simple typo.
Section 18.104.22.168 also states : “Natural gas is a lower CO2 emitting fuel when compared to other fuel sources (e.g., fuel oil or coal),” and “This would result in a potential reduction is regional GHG emissions” (Ref. 1, Page 4-289). It is true that burning natural gas in a boiler produces less CO2, at the boiler, than burning coal. However, as described at the beginning of these comments, there are many places where methane escapes into the air, and so much escapes that the result is the GHG effect of burning natural gas exceeds the GHG effect of using either coal or oil (Ref. 2). Using natural gas is worse than coal for climate change. This is the life cycle analysis.
It is not only necessary to evaluate the environmental impact of this project to the region within 10 or 20 miles of the pipeline, but also to consider the impact to the entire country, and perhaps even also the rest of the world. Many faith traditions tell us that we are all brothers and sisters together on this planet. Operation of this pipeline for one year will be accompanied by the release of 94 million metric tons CO2e when evaluated over the first 20 years. This impact is greater than would be realized from using coal, which is far too polluting. And, this impact is also about 30% of the emissions for the entire state of Pennsylvania in 2005. The EPA recognizes that the current and projected concentrations of GHGs in the atmosphere threaten public health and welfare of current and future generations. This pipeline is thus a threat to public health and welfare, now and in the future. As a threat, this pipeline cannot be a public convenience or necessity.
- U.S. Federal Energy Regulatory Commission, 2016, Draft Environmental Impact Statement, Atlantic Sunrise Project, Transcontinental Gas Pipeline Company, LLC, FERC/EIS-0269D, Docket No. CP15-138-000, Accessed May 2016.
- Howarth, R.W., 2014, A bridge to nowhere: Methane emissions and the greenhouse gas footprint of natural gas, Energy Science and Engineering ; 2(2): 47-60 DOI: 10.1002/ese3.35
- IPCC. 2013. Climate change 2013: the physical science basis. Intergovernmental Panel on Climate Change. Available at: https://www.ipcc.ch/report/ar5/wg1, Accessed July 2014
Pennsylvania Interfaith Power & Light is a community of congregations, faith-based organizations, and individuals of faith responding to climate change as a moral issue, through advocacy, energy conservation, energy efficiency, and the use of clean, renewable energy.