Florida and the public have a fee interest in these lands –Florida Sierra Club to FERC

Filed with FERC 21 April 2014. -jsq

April 19, 2014

Kimberly D. Bose, Secretary
Federal Energy Regulatory Commission
888 First Street NE, Room 1A
Washington, DC 20426

RE: Sabal Trail Project: Docket No.PF14-1-000
Florida SE Connection Project: Docket No.PF14-2-000
Hillabee Expansion Project: Docket No. PF14-6-000

Executive Committee

Debbie Matthews, Chair
Rudy Scheffer, Vice Chair
Deborah Longman-Marien
Kent Bailey
Bud Long
Tom Larson
Mark Walters

The Florida, Georgia and Alabama Chapters of the Sierra Club oppose the natural gas pipeline that would carry fracked natural gas extracted from Pennsylvania and Texas through Alabama, Georgia, and Florida. Sabal Trail Transmission, LLC is a joint venture between Spectra Energy Partners, LLC and NextEra Energy, Inc. Spectra Energy and its related companies have been fined repeatedly for safety and environmental violations throughout the United States including one fine of $15,000,000.

The proposed pipeline would cut a wide swath through pristine lands with resulting negative impacts on endangered species, critical wildlife habitat, invaluable wetlands, longleaf pine forests, the fragile and irreplaceable Floridian Aquifer, streams, rivers, and springs, and impact private property rights. Furthermore, expanded reliance on fracked natural gas only serves to feed the increasingly destructive effects of drilling for and fracking of shale deposits that have destroyed drinking water resources and entire communities. The Sunshine State, that will be the sole recipient of fracked natural gas from this pipeline, should expand energy efficiency measures and solar power capacity rather than increase its dependence on fracked natural gas which already accounts for more than 60% of Florida’s electricity generation.

Pipeline alignments should minimize environmental impacts and condemnation of land as much as possible.

The proposed Sabal Trail alignment shows that co-location with other linear facilities was not adequately considered. While there are areas the pipeline appears to co-locate with power line easements (Sabal Trail Quad map information), very often the alignment follows section lines or no geographic feature at all. Co-location offers opportunities to reduce or eliminate habitat destruction and fragmentation and more efficiently use existing linear resources while reducing direct impacts to private lands. Sabal Trail Project: Docket No.PF14-1-000 and Florida SE Connection Project: Docket No.PF14-2-000 should show cause when not co-locating.

The Sabal Trail alignment shows that avoidance methodologies were not fully explored. We have seen little evidence that the project alignment professionals attempted to avoid impacts to conservation lands, wildlife habitat and corridors and wetlands.

For example, the state has invested hundreds of millions of dollars protecting the Green Swamp through fee simple acquisitions, purchase of conservation easements and through land protection agreements. See


The state of Florida and the public have a fee interest in these lands and should be treated as such. The proposed Sabal Trail pipeline alignment does not protect these public investments in water and wildlife resources. Maps provided to date on the Sabal Trail website show no avoidance, no co-location with other linear facilities, and no alternative alignments consistent with NEPA requirements. The maps lead one to believe the alignment was chosen without consideration of existing resource analyses that have been performed over the past 20+ years by the Florida Natural Areas Inventory (FNAI). We oppose any routes in the Green Swamp that do not follow existing road, power line, or other existing linear corridors. Cutting a swath through undisturbed wetlands is inappropriate.

The FERC should obtain GIS data from the Florida Natural Areas Inventory (FNAI) and local and regional government jurisdictions that describe the lands that have been acquired for their natural resource values. Local environmental land acquisition programs and land trusts should also be consulted to provide an analysis of direct or proximal impacts to their conservation land investments. The FERC should require these dockets to show cause if impacting these lands and resources.

Available information indicates that there are far better alignments than those proposed that would meet the needs of the pipeline company.



Marian L. Ryan
Conservation Chair

Copy to: Debbie Matthews

Sierra Club Florida, 111 Second Ave. NE, Suite 1001, St. Petersburg, FL 33701

How to comment with FERC.

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