Explain why the gas is needed –EPA to FERC

EPA isn’t buying FPL’s need for new power in Florida,

or that methane is better than many alternatives (including that renewable energy sources should be considered together, not separately), or that a pipeline is the best way to get gas (specifically suggesting Port Dolphin instead), or that any of the proposed routes are appropriate, not to mention catching inconsistent numbers of compressor stations and asking to see any non-FPL customers. And EPA asked for GIS data, as well as further information on water withdrawals and water re-emitted into the environment. My favorite is this one:

EPA recommends FERC provide in the EIS readable and comprehensible maps and figures, and clearly describe all potential impacts with the proposed action upon children’s health. For example, maps of schools, day-care facilities, multifamily housing, and hospitals should have different legend colors and be created at scales providing appropriate information, i.e., proximity of sensitive receptors to the navigation and transportation corridors.

FERC shows EPA’s comments as filed 23 April 2014, although they are dated two days earlier. -jsq

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 4
ATLANTA FEDERAL CENTER
61 FORSYTH STREET
ATLANTA, GEORGIA 30303-8960

21 April 2014

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

SUBJECT: Southeast Market Pipelines Proposed Action, FERC Docket Numbers: PF14-1000 – Sabal Trail Transmission, PF14-2-000- Florida Southeast Connection, and PF14-6-000- Transcontinental Gas Pipeline’s Hillabee Expansion

Dear Ms. Bose:

Thank you for the opportunity to participate in FERC’s seeping process. Consistent with EPA’s Clean Air Act (CAA) § 309 and National Environmental Policy Act (NEPA) § 102(2)(C) responsibilities, EPA has reviewed the available draft resource reports associated with the proposed Southeast Market Pipelines action. Enclosed are our comments based on what we reviewed.

We appreciate the opportunity to be involved with the planning of this pipeline. We also appreciate your staff, John Peconom’s efforts to keep us engaged. If you wish to discuss this matter further, please contact Beth Walls, 404-562-8309 (walls.beth(a)epa.gov) of my staff.

Sincerely,
[signed]
Heinz J. Mueller, Chief
NEPA Program Office
Region 4, US EPA

cc: John Peconom
Enclosure: EPA Region 4 Comments

Internet Address (URL} • http://www.epa.gov
Recycled/Recyclable • Printed Wlth Vegetable 01 Based Inks on Recycled Paper (M1mmum 30% Postconsumer)

Southeast M:ukets Pipeline: U.S. EPA Region 4 Scoping Comments (April 21, 2014)

Region 4, EPA Comments on the Southeast Market Pipelines Proposed Action, FERC Docket Numbers: PF14-l-OOO- Saba} Trail Transmission, PF14-2-000- Florida Southeast Connection, and PF14-6-000 – Transcontinental Gas Pipeline’s Hillabee Expansion.

Background:

As part of the scoping process, EPA has attended some public outreach meetings, met with the Sabal Trail Transmission and Florida Southeast Connection representatives, met with FERC, and reviewed available but incomplete general project description draft resource reports associated with the proposed Southeast Market Pipelines. EPA understands the above three FERC dockets represent three components of a natural-gas infrastructure whose purpose is to import natural-gas to Florida Power and Light’ s Martin County Clean Energy Center.

The proposed Southeast Market Pipelines Action is a new greenfield pipeline consisting of three major components: the Hillabee Expansion, the Sabal Trail Transmission, and the Florida Southeast Connection pipelines. The Hillabee-Expansion pipeline’s purpose is to facilitate Marcellus-shale gas deliveries from Transco’s main pipeline to central/south Florida to fuel electrical power generation by constructing a pipeline north east from its Transco’s existing Compressor Station 85, in Choctaw County, AL, to Sabal Trail Transmission’s proposed new compressor station to be constructed northeast of Station 85 near Alexander City, Tallapoosa County, AL. Sabal Trail Transmission proposes to lease capacity from the proposed Hillabee Expansion from Transco.

The Alexander City Compressor station will be constructed as part of the Sabal-Trail Transmission pipeline component. From the Alexander City Compressor station, Saba)-Trail Transmission proposes to construct 460-miles of 36-inch pipeline trending a direct southeast line through southeast Alabama, southwest Georgia, into north-central Florida, and then south to a proposed new interconnection hub (“the Central Florida Hub”) in Osceola County, Florida. The proposed pipeline route traverses 85 miles through Alabama, 157 miles through Georgia, and the remaining 218 miles through Florida. The proposed pipeline includes the construction of either five or seven (conflicting information was provided) compressor stations to facilitate the flow of natural gas through the line. From this main line, Sabal Trail Transmission also proposes to construct two feeder lines: the Hunters Creek Line—14 miles of new 36-inch pipeline extending from the proposed new Reunion Compressor Station in Osceola County, FL, to Florida Gas Transmission Company’s 30-inch existing mainline in Orange County, FL. The second proposed feeder line is 24 miles of new 24-inch pipeline extending from the proposed Dunnellon Compressor Station in Marion County to a proposed new meter station in Citrus County, FL.

The proposed new Central Florida Hub will be constructed as part of the Florida Southeast Connection component where the proposed Sabal Trail Transmission pipeline will connect. The Southeast Connection component includes a new pipeline to ship natural gas from the Hub to Florida Power & Light’s Martin County Clean Energy Center for purposes of electrical power generation for south Florida.

The proposed action also includes the construction of 6 meter stations, all in Florida with the exception of one in Alabama.

Proposed Action Description. Existing unconfirmed information suggests the description of the proposed action may be incomplete at this time. Consequently, EPA makes the below recommendations for confirming this information.

  • Compressor Station Numbers: EPA recommends FERC clarify in its EIS how many compressor stations will be constructed associated with the proposed action. For example, Sabal Trail Transmission’s Resource Reports indicate 5 compressor stations in its text; however, the copy of the Frequently Asked Questions sheet enclosed with mailed letters sent, indicate 7 will be constructed. The FAQ indicates an additional five stations will be added; in between the proposed station to be constructed in Tallapoosa County, AL, at the start of the pipeline and the proposed station in Osceola County, FL, at the terminus of the Sabal Trail Transmission pipeline. However, the resource report indicates only three stations will be constructed in between the proposed Tallapoosa and Osceola compressor stations.
  • Proposed New Power Plants: EPA recommends FERC discuss in its EIS whether Florida Power & Light’s proposed new Hendry County, FL, natural gas/solar plant will obtain its natural gas from the proposed action and whether any new pipeline will need to be constructed. Additionally, indications exist FPL may be constructing two other new power plants in Florida to run mostly on natural gas.1 EPA recommends all necessary piping to all anticipated new power plants be included in FERC’s environmental analysis if natural gas from the proposed action will be used in their operations.
  • Natural Gas Market Outside FPL: EPA recommends FERC discuss in its EIS existing speculation for non-FPL markets of natural-gas need from the proposed action. For example, the president and CEO of TECO Energy in Tampa was quoted as stating the proposed new pipeline may have to extend to areas beyond what FPL has proposed to make sure the gas can get to markets of need.2 EPA recommends all necessary piping to all non-FPL markets of natural-gas need be included in FERC’s environmental analysis of the proposed action if natural gas from the proposed action will be used to meet this need.

1 Natural gas is Key to Florida’s power supply. But, are Florida’s utilities putting too many eggs in one basket? See: http://www.floridatrend.com/article/15892/natural-gas-is-key-to-floridas-power-supply

2 Natural gas is Key to Florida’s power supply. But, are Florida’s utilities putting too many eggs in one basket? See: http://www.floridatrend.com/article/15892/natural-gas-is-key-to-floridas-power-supply


Purpose and Need. The applicant states the proposed action will allow south Florida natural-gas users to diversify access to growing natural-gas supplies, increase central/south Florida’s natural gas transmission grid, reduce reliance on offshore supply sources and lessen the vulnerability to supply disruptions that can result from severe weather in the Gulf of Mexico.3 EPA recommends FERC provide additional information to support the need for the above purpose per its below recommendations.

  • Diversify Access to Natural Gas Supplies:

    The proposed action’s purpose includes increasing the state of Florida’s natural-gas supply diversity as in access to multiple upstream supply sources from Transco’s Station 85. EPA recommends FERC clarify and discuss how diversity is increased. For example, both the proposed action and the existing Gulfstream pipeline depend directly upon Williamsrrranco’s 10,200-mile pipeline system, extending from South Texas to New York City, which ships natural gas one-way from the Gulf Coast to twelve Southeast and Atlantic Seaboard states, including the major metropolitan areas in New York, New Jersey and Pennsylvania.4 Tranco’s proposed new Atlantic Sunrise pipeline will convert its mainline to allow Marcellus-shale sourced natural gas to be shipped south to Transco Station 85 by mid-2017. In comparison, the existing Florida Gas Transmission pipeline offers an independent alternative access to natural-gas supplies through the Kinder Morgan/ El Paso Pipeline system. Kinder Morgan’s Tennessee Gas Pipeline already ships natural gas south from two northeast natural-gas sources: the Marcellus and Utica shales.

  • Gulf-of-Mexico Supply Disruptions: The proposed action’s purpose includes increasing the state of Florida’s natural-gas supply reliability by hedging against weather-related Gulf-ofMexico supply disruptions. This hedging consists of providing access to onshore natural-gas sources. However, the existing Florida Gas Transmission pipeline receives gas from various onshore natural-gas producing basins’ including the northeast through Kinder Morgan’s Tennessee Gas Pipeline. Additionally, Transco’s Gulfstream pipeline also has access to a diverse supply of onshore natural-gas sources, which will be expanded to include the northeast once the Atlantic Sunrise pipeline is complete. EPA recommends FERC discuss the stated purpose in context of the appearance both existing pipelines (FGT and the Gulfstream) do hedge against Gulf-of-Mexico supply disruptions to south Florida. EPA also recommends data be provided to highlight the significance of Gulf-of-Mexico supply disruptions (both past and future projections) to south Florida. For example, information on past and projected future economic costs, intensity, and duration of these disruptions.

  • Southeast Supply Header System: EPA recommends FERC discuss the proposed action’s need in context of the Southeast Supply Header System project. The System’s purpose, similar to the proposed action, was to be an alternative natural-gas source during hurricane-related disruptions in the Gulf of Mexico.6 EPA recommends FERC explain why Sabal Trail Transmission’s proposed new 36″ line is needed so shortly after the System’s 2011 in-service date.7
  • Natural-gas Capacity Need: EPA recommends FERC provide data and referenced sources to support the implied need for additional natural-gas capacity. The two new existing pipelines serving central/south Florida are indicated to be at or near capacity without providing supporting information and information sources specific to this allegation. For example, information regarding the capacity of the existing two pipelines in context of central/south Florida’s existing use and projected future use with references to the appropriate information sources.

  • Decreasing Electricity Sales: EPA recommends FERC provide data and appropriately referenced sources to demonstrate the proposed-action’s need in context of reported decreasing electricity sales.8,9 U.S. electricity sales appear to have peaked in 2007. For example, 2012 electricity sales continued the decline by 1.9%. Moreover 2013’s first ten months sales were below that of the same ten months in 2012. Suggested causal factors include: the decline in manufacturing, more energy efficient buildings, lighting, and appliances, and increased use of on-site generation. 10 Moreover, energy efficiency is expected to increase with the anticipated senate passage of the Energy Efficiency Improvement Act of 2014, which contains several building energy saving provisions.11

3 Section 10.2, Draft Resource Report 10—Alternatives, p. 10-3.

4 http://co.williams.comlwilliams/operations/gas-pipeline/transco/

5 http://www.energytransfer.com/ops_interstate.aspx

6 Expansion of the U.S. Natural Gas Pipeline Network: Additions in 2008 and Projects through 2011, US DOE/EIA report available at http://www.eia.gov/pub/oil_gas/natural_gas/feature_articles/2009/pipelinenetwork/pipelinenetwork.pdf

7 Southeast Supply Header to Hold Expansion Open Season, http://www.prnewswire.com/news-releases/southeastsupply-header-to-hold-expansion-open-season-65209192.html

8 2013b. Electric Power Sales, Revenue, and Energy Efficiency (Form EIA-861 detailed data files). Washington, DC: U.S. Energy Information Administration. http://www.eia.gov/electricity/data/eia861/.

9 U.S. Electricity Use is Declining and Energy Efficiency May be a Significant Factor, American Council for an Energy-Efficient Economy News Release, see white paper at http://aceee.org/white-paper/low-electricity-growth

10 U.S. Electricity Use is Declining and Energy Efficiency May be a Significant Factor, American Council for an Energy-Efficient Economy News Release, see white paper at http://aceee.org/white-paper/low-electricity-growth

11 H.R.2126- Energy Efficiency Improvement Act of 2014, 113th Congress (2013-2014), http://beta.congress.gov/bill/113th-congress/house-bill/2126. This bill passed the House (3/5/20/14) with bi-partisan sponsorship/support.


Alternatives: The EPA recommends FERC’s EIS should include a review of other practicable alternatives which would increase Florida Power & Light’s ability to reliably serve its customers’ electrical power needs. EPA also recommends FERC discuss whether the purpose as stated is overly narrow for NEPA’s purposes. EPA recommends the alternatives discussion address the following recommendations:

  • Energy Conservation: Because this alternative’s discussion is not specific to the central/south Florida energy users, Florida’s Public Service Commission, and Florida Power and Light, EPA recommends FERC discuss as an alternative the concept of a conservation power plant for the following reasons:

    FPL has reported significant energy savings from its efficiency programs pursuant to federal and state energy efficiency standards: the 2005 National Energy Policy Act, the 2007 Energy Independence and Security Act, and compact fluorescent-bulb use.11 For example, for the 2005-2022 period, FPL projects the cumulative impact of these standards will realize an energy savings on the summer peak demand of 2,898 mega watts (MW), the winter peak demand of 1,650 MW, and on the net energy load of 11,850 GigaWatt hour. In contrast,

    FPL’s four nuclear-power generation units have a 3,333 MW summer-demand capacity.13 It is likely FPL will realize increased energy savings associated with the expected passage of the bipartisan sponsored federal Energy Efficiency Improvement Act of 2014, which contains several building energy-savings provisions.14

    Moreover, the 1980 Florida Energy Efficiency and Conservation Act emphasizes increasing Florida’s electric systems’ efficiency, conserving energy resources, reducing weather-sensitive peak-demand growth, and cost effectively reducing kilowatt-hour consumption growth. Pursuant to this Act, the Florida Public Service Commission establishes electric-peak demand and energy savings goals for Florida’s largest electrical utilities,15 with the 2009 goals being the most recent.16 Florida utilities are required to submit proposed Demand Side Management plans designed to meet these goals. Upon Commission-approval of these plans, companies may recover program costs through the state’s Energy Conservation Cost Recove1y program, which is a pass through of expenses recovered from rate payers on a per kilowatt-hour or per KW basis.17 Neither Progress Energy Florida (Duke Energy) nor FPL’s 2009 DSM plans were approved. While the Commission did not excuse either utility .from meeting Florida’s 2009 goals, it did allow both companies to continue with their existing DSM plans designed to meet the 2004 goals.18

    The Commission’s 2009 goals call for summer, winter, and·net energy load reductions.19 According to FPL, weather is always a key factor affecting its peak demand/energy sales.20 To address weather-related demand, FPL’s DSM plan contains one weatherization program: a Low Income Weatherization program where FPL provides rebates, and weatherization providers leverage these rebates to assist eligible low-income residential customers to reduce home cooling/heating costs.

    FPL may benefit from expanding its weatherization program, which may meet Florida’s 2009 energy efficiency goals in light of the Bonneville Power Administration’s success after the Hood River Demo project. The Hood River Conservation Project was a residential weatherization demonstration project involving direct installation.21 Because of this one demonstration project, Pacific Northwest Utilities saved the energy equivalent of5 billion KW hours, enough to power 50,000 homes. FPL indicates it will begin servicing Vero Beach’s electrical load of 34,000 customers on January 1, 2014.22 In perspective, a Hood River type project could allow FPL to retire the generation units it purchased from Vero Beach.

    Since the Hood River demonstration project implementation, during the 1982-2008 period BPA has realized a savings of 10.4 million MW hours.23,24,25 Bonneville Power Administration reportedly found it was cheaper to retrofit houses than to build new generation capacity.26 Furthermore, BPA has not built nor caused to be built any new power plants since the 1984 construction of the Richland nuclear plant in 1984 while closing one nuclear power plant.27

    In comparison to Bonneville Power Administration, FPL served an average of 4.6 million customer accounts in thirty-five Florida counties during 2012. By 2019, FPL expects the total number of customers exceed five million.28 FPL’s service area has an approximate population of 8.9 million. In contrast, BPA serves the Pacific Northwest population of 12.8 million.29 The Northwest Power and Conservation Council reports over half of the region’s growth in electricity demand, since 1980, has been met with energy efficiency (aka conservation power plant), resulting in saving over 46.4 million MW hours,30 enough to power the state of Oregon (a population of 3,871,859), billions of dollars each year: $3.2 billion in 2012, and lower annual C02 emissions; a reduction of 20.8 million tons in 2012.31 The Northwest Power Act considers energy efficiency to be an energy resource, second behind hydropower— for the nation’s northwest region: a megawatt saved is the equivalent of a megawatt produced.32

    Moreover in light of FPL’s status of meeting Florida’s 2009 energy efficiency goals and the tremendous success that Bonneville Power Administration has achieved with its energy efficiency efforts, EPA recommends FERC address in the EIS the necessity versus the convenience of the proposed preferred alternative in context to the impacts upon Alabama and Georgia communities, property owners, and ecosystems who will bear the risk and impacts but do not appear to benefit from the proposed action’s construction.

  • Energy Portfolio Alternative: EPA recommends FERC address in the EIS the ability of the various available alternative energy sources to act in the context of a portfolio as an alternative to the proposed action. The existing alternative energy analysis looks at each alternative energy source independent and in isolation of each other to replace natural gas, in lieu of complementing each other and existing natural-gas supplies to supply FPL’s customers’ needs. EPA recommends the discussion be supported by information that appropriately references its sources.

  • Other Energy Alternatives: Because it is indicated that available liquid natural gas and propane air storage/vaporization alternatives meet the proposed action’s objectives,33 EPA recommends FERC provide information in the EIS that appropriately references its sources to support the given determination these alternatives are not viable due to siting constraints, increased environmental impacts, and the time required to develop these alternatives. For example, provide environmental information regarding siting constraints, increased environmental impacts, or social impacts, including the exercise of eminent domain on private property and burdens upon communities not expected to benefit from the proposed action. Lead agencies are not allowed under NEPA to avoid an analysis of reasonable alternatives due to an applicant’s perceived time insufficiencies.

  • Domestic LNG Import:

    EPA recommends FERC discuss in the EIS the alternative for importing liquefied natural gas from a US exporting facility, e.g., Port Pascagoula and Sabine Pass LNGs to the approved Port Dolphin LNG facility offshore Tampa, FL, and constructing associated pipelines from Port Dolphin’s onshore pipeline terminal to FPL’s Martin County Clean Energy Center.

    The operator34 of the newly completed Gulf LNG terminal, at Port Pascagoula, is seeking DOE’s support to export natural gas since the mainland’s natural-gas finds have made importing LNG uneconomical.35 The existing Sabine Pass LNG terminal reportedly is being transformed into a bi-directional facility capable of importing and exporting natural gas and importing and regasifying LNG.36 Sabine Pass is expected to be operational in the 4th Quarter of 2015. Sources indicate US DOT anticipates construction of the Port Dolphin facility to commence later in 2013 and estimates 22 months construction.37 The Port Dolphin terminal is to have the capacity to transport 1.3 billion cubic-feet per day38 to provide additional natural gas supply capacity to the state of Florida. It appears this alternative would give Florida Power & Light access to diverse sources of gas from other countries, if plans for exporting the nation’s natural-gas supplies to other countries realize increased prices for the nation’s consumers.

  • Station 85 to FGT Panhandle Pipeline Route Alternative: The distance from Transco Station 85 to the FGT pipeline in Florida appears to be a much shorter distance than either the preferred Southern Natural Gas pipeline route or the Station 85 route alternatives examined to date. EPA recommends FERC include in its alternatives analysis an alternative where the proposed pipeline commences at Transco’s existing Compressor Station 85 in Choctaw County, AL, and is routed due south to either connect to the existing 5,500-mile Florida Gas Transmission pipeline, or use FGT’s right-of-way for the proposed pipeline. This alternative would minimize impacts to first and second order streams in the highlands of Alabama and Georgia, and identified southwest Georgia regionally important resources as discussed below. Additionally, this alternative would eliminate the need for the Hillabee-Expansion component, its associated costs and environmental impacts. The Hillabee-Expansion’s sole purpose is to connect Transco’s Station 85 to the Sabal-Trail Transmission pipeline component of the proposed action to facilitate Marcellus-shale gas deliveries to central/south Florida. Consequently, the wetlands impacts associated with the Hillabee-Expansion would also be avoided in addition to the impacts associated with the preferred SNG route alternative as described in the Sabal Trail Transmission resource reports.


12 FPL’s Ten Year Power Plant Site Plan for 2013, p. 38.

13 FPL’s Ten Year Power Plant Site Plan for 2013, Table 1.A.1: Capacity Resources by Unit Type.

14 H.R.2126 — Energy Efficiency Improvement Act of 2014, 113th Congress (2013-2014), http://beta.congress.gov/bill/113th-congress/house-bill/2126.

15 Review of Administrative Efficiency of Utility Demand Side Management Programs, (May 2013) By Authority of The Florida Public Service Commission Office of Auditing and Performance Analysis; see: http://www.floridapsc.com/publications/pdflelectricgas/DSMReviewReport.pdf.

16 Commission Order No. PSC-09-0855-FOF-EG.

17 Pursuant to the ECCR clause adopted in Florida Public Service Commission’s rule 25-17.015.

18 Order No. PSC-11-0347-PAA-EG, in Docket No. 100160-EG.

19 FPL’S Ten Year Power Plant Site Plan for 2013, p. 70.

20 FPL’S Ten Year Power Plant Site Plan for 2013, p. 31.

21 Hood River Conservation Project, Profile #12 (1992) http://ecomotion.uslresults/12.htm.

22 FPL’ S Ten Year Power Plant Site Plan for 2013, p. 14. Note: FPL is purchasing Vero Beach’s electrical power system with its generation units which serves the 34,000 population.

23 Reported as 1,190 average MW where one average MW (aMW) is 8,760 megwatt-hours or the annual output of a power plant divided by the 8,760 hours of the year.

24 BPA Fact Sheet (January 2009) available at http://www.bpa.gov/news/pubs/FactShects/fs200901·Power%20benefits%20of%20the%20lower%20Snake%20River%20dams.pdf.

25 BPA Overview Presentation, see: http://appsl.eere.energy.govltribalenergy/pdfs/0911review_ikakoula.pdf.

26 See BPA’s Energy Efficiency web page http://www.bpa.gov/Energy/N/ where it states “The Northwest Power Act of 1980 called on the Northwest to give energy conservation top priority in meeting its power needs, and the region quickly learned that a megawatt saved is the equivalent of a megawatt produced.”

27 Heberlein, T.A., Navigating Envtronmental Attitudes (2012) Oxford Umversity Press.

28 FPL’s Ten Year Power Plant Site Plan for 2013, p. 32.

29 BPA’s information at http://www.bpa.gov/ncws/pubs/GeneralPublications/gi-BPA-Facts.pdf.

30 Reported as 5,300 average MW where one average MW (aMW) is 8,760 megwatt·hours or the annual output of a power plant divided by the 8,760 hours of the year.

31 The Pacific Northwest is a Leader in acquiring Energy Efficiency, which is our second largest resource after hydropower. The Northwest Power At defines it as an energy resource and makes it the region’s top priority. http://www.nwcouncil.org/energy/energy·efficiency/.

32 See BPA’s Energy Efficiency web page http://www.bpa.gov/Energy/N/

33 Sabal Trail Project Draft Resource Report 10, Alternatives, Initial Pre·filing Draft (Nov. 2013).

34 http://www.kindermorgan.com/business/gas_pipelines/projects/gulf/LNG/

35 http://portofpascagoula.com/pascagoula-lng-term.pdf

36 http://www.cheniere.com/lng_industry/sabine_pass_liquefaction.shtml

37 http://www.marad.dot.gov/ports_landing_page/deepwater_port_licensing/dwp_current_ports/dwp_current_ports.htm

38 http://www.pipelineandgasjoumal.com/port·dolphin-energy-gets-key-florida-permits-deepwater-lng-port


Clean Air Act:

EPA makes the following recommendations to improve upon the existing draft air quality discussion for incorporation by FERC into its EIS to better and more completely address EPA’s Clean Air Act requirements:

  • EPA recommends FERC provide in the EIS the following information for each compressor station along the proposed natural-gas pipeline route:
    • Engine(s) size for the compressor station.
    • A description of the compressor station and its connections to other stations and pipelines.
    • Levels of greenhouse gases and fugitive emissions emitted.
    • Levels of each criteria pollutant that are emitted.
    • Identification of any Hazardous Air Pollutants (HAPs, aka toxics) which may be emitted and emission rates for those identified.
    • A statement as to whether or not the Prevention of Significant Deterioration (PSD) process is triggered for the compressor station through GHGs and/or criteria pollutants.
    • Whether or not a permit for the compressor station is required and how this fits into the development and operation of the pipeline.
    • Discuss any emissions increases from the new pipeline that will occur at existing compressor stations from other ongoing activities, e.g., cumulative effects.
  • EPA recommends FERC provide in the EIS a discussion on the level of pollutants (toxics and criteria) that will be created and emitted into the air for all sources associated with the development and operation of the natural-gas pipeline and any other facilities built in association with the pipeline. (i.e., stationary point, area point (including fugitives), nonroad and onroad mobile). The compilation of a comprehensive emissions inventory is recommended.
  • Section 1.8 discusses environmental training as related to FERC requirements. EPA recommends FERC provide in the EIS a discussion on the environmental status of the area for the compressor stations as related to the Clean Air Act, for air quality for the applicable pollutants subject to the National Ambient Air Quality Standards (NAAQS) and greenhouse gas (GHG) regulations, applicable permitting requirements and demonstrations.
  • EPA recommends FERC provide in the EIS a discussion of the air quality of the area in the vicinity of the compressor stations as related to all NAAQS.
  • EPA recommends the EIS identify any ‘near-pipeline’ sensitive populations, e.g., day-care facilities, hospitals, nursing homes, schools, and Environmental Justice (EJ) communities located approximately within 1,500 feet of any current or reasonably foreseeable future air toxics emission sources. We recommend the analysis consider prevailing meteorological conditions and relevant topography as part of the preliminary air toxics assessment phase.
  • Table 1.13-1 provides information of the status of air quality permits for the compressor stations and the state contacts. EPA recommends FERC provide in the EIS ‘ air quality section, a discussion on the process that will be used in developing those permits. For instance the following is recommended for this discussion but is not an exhaustive list of what could be addressed.
    • If air quality modeling is required, then a summary discussion in the main document of the air-quality process to be developed and later modeling results to show compliance with applicable NAAQS and toxics criteria should be provided.
    • An appendix should be provided to provide details and results consistent with a modeling protocol and recommendations that are consistent with EPA permit modeling, e.g., http://www.epa.gov/ttn/scram/guidance permit.htm.
    • We recommend contact with the EPA Regional Office prior to the development of modeling for a regulatory application, especially since there are many issues that can develop in these projects.
  • Section 1.7.1.3 discusses actions that will be taken for residents’ safety when construction will be performed within 50 feet of residential areas. In addition to the actions listed, EPA recommends that residents be advised of the planned duration of the construction activities so they can take actions to avoid prolonged exposure to air emissions from the construction equipment, which may contain elevated levels of criteria and air toxic pollutants. Actions as simple as staying indoors with the windows closed can significantly reduce exposure levels. Additionally, any sensitive populations (e.g., schools, daycare centers, hospitals, nursing homes) located in close proximity to the proposed construction areas should be identified, and actions should be taken to minimize exposure to construction emissions. We recommended that EPA be contacted to discuss options that may be implemented to minimize exposure to air emissions.
  • EPA recommends that the project implement overall diesel emission reduction activities through various measures such as: switching to cleaner fuels, retrofitting current equipment with emission reduction technologies, repowering older engines with newer cleaner engines, replacing older vehicles, and reducing idling through operator training and/or contracting policies. EPA can assist in the future development or implementation of these options.
Clean Water Act:

The Clean Water Act Section 404 established a program to regulate the discharge of dredged and fill material into waters of the United States, including wetlands. Both the U.S. Army Corps of Engineers and EPA share responsibility to administer and enforce this program. The Corps of Engineers administers individual permit decisions and jurisdictional determinations; develops policy and guidance; and enforces Section 404 provisions. EPA develops and interprets environmental criteria used in evaluating permit applications, reviews individual permit applications, enforces Section 404 provisions, and has authority to veto USACE permit decisions. In light of EPA’s Section 404 responsibilities, EPA recommends FERC address the following in the EIS:

  • Compensatory Mitigation: EPA requests FERC provide preliminary information on compensatory mitigation for Clean Water Act Section 404 impacts, such as availability of mitigation banks for stream and wetland credits in each watershed, and whether any permittee-responsible compensatory mitigation is under consideration.
  • Cumulative Impacts: EPA recommends FERC’s EIS provide a cumulative impacts discussion of whether and how the planned work could contribute to or cause hydrologic isolation, fragment stream networks, fragment habitat.
  • High Quality Forested Uplands: EPA requests FERC limit the proposed action’s impacts within high quality forested upland areas to a maximum of 75 feet, consistent with the proposed right-of-way in wetlands areas, in lieu of the proposed 100 foot right-of-way. High quality, forested uplands provide fish and wildlife habitat support to adjacent wetland systems and should be protected.
  • Invasive Species: EPA requests FERC review in its EIS the control of exotic and nuisance species within the proposed right-of-ways within wetlands. The present standard is that no herbicide or pesticide shall be used in or within 100 feet of a wetland.
  • Least Environmentally Damaging Project Alternative: EPA requests FERC review in its EIS other Least Environmentally Damaging Project Alternatives for impacts anticipated to occur within project’s right-of-way.
  • Pipeline Co-location: EPA requests FERC discuss in its EIS the co-location ofthe proposed 36-inch pipeline within the right-of-way of Kimber Morgan’s existing Southern Natural Gas pipeline (vintage 1950’s), which was installed pre-CWA ( 1970). The discussion should address whether co-location with this 10-inch pipeline is consistent with the Clean Water Act’s 404(b) guidelines.
  • Stream Impacts: EPA requests planned work be performed during dry conditions (seasonally or sufficiently post-rainfall) for those intermittent and ephemeral channels to avoid impacts as much as possible.
  • Stream Impacts: EPA requests crossing locations for where the proposed action proposes to cross surface water bodies be identified in an electronic-mapping format (ArcGIS or Google Earth file), and the provision of updated lists and maps to EPA whenever changes to crossing locations are proposed.
  • Water Quality Impacts: EPA requests FERC’s EIS provide additional information on pipeline hydrostatic testing. EPA understands large volumes of water will be potentially withdrawn from nearby surface-water bodies along the pipeline route, to be trucked to the testing site. EPA requests additional information on the water volumes required, sources, timing, and how the withdrawals will be evaluated to ensure that they are consistent with EPA-approved State Water Quality Standards (WQS), including protection and maintenance of designated uses, and compliance with narrative and numeric criteria and antidegradation requirements. In particular, EPA requests information on the types of data and modeling to be used to evaluate potential impacts from hydrologic alteration on recreation, aquatic life, and other designated uses. In addition, EPA requests the EIS address whether any downstream users (e.g., National Pollution Discharge Elimination System (NPDES) permitees, any authorities withdrawing for water supply, etc.) will be notified of the temporary withdrawal amounts and timing.
  • Water Quality Impacts: EPA requests FERC address in its EIS whether hydrostatic testing water discharged into stonnwater management systems will be discharged into the same watershed as the withdrawal. Also, please identify whether the stonnwater systems will be existing municipal stonnwater infrastructure or project-specific.
  • Water Quality Impacts: Even though the environmental requirements of FERC will be presented in the yet to be developed Erosion and Sediment Control Plan, EPA recommends FERC provide in the EIS a summary to complement what is provided in section 1.8 of this information and guidance.
  • Water Quality Impacts: EPA requests FERC address in its EIS whether any part of the proposed action (e.g., the Hillabee Expansion component and the Alabama portion of the Sabal Trail Transmission component) will be constructed in the piedmont region, which in Alabama is associated 3,500 square miles over 9 counties including Chilton, Tallapoosa, and Chambers counties. This discussion should indicate whether acid-producing rock will be disturbed/exposed realizing acid runoff/drainage. Additionally, FERC should discuss any water quality impacts associated with existing available treatment methodologies. For example, while passive alkaline treatment (lime) may neutralize acidity it can lead to other water quality problems, e.g., conductivity within the receiving water body. EPA notes any potential for acid producing rock exposure can be avoided by the Station 85 to FGT Panhandle Pipeline Route Alternative discussed above.
  • Wetlands Impacts: EPA requests FERC provide additional detail in its EIS to that provided in the tables, e.g., within Sabal Trail Transmission’s Draft Resource Report No. 10. While these tables provide a general sense of the magnitude of wetland impacts associated with the preferred route and the various alternatives and diversions, wetlands specific information should be provided in the EIS, including: wetlands quantification by state and watershed, mapping of the affected resources and the proposed pipeline route layer (ArcGIS or Google Earth file), quality/condition, and whether impacts are permanent or temporary and whether the disturbance is on new ground (“green”) or existing right of way.
  • Wetlands Impacts: The preferred route, paralleling the Southern Natural Gas Company’s (El Paso39) pipeline right-of-way was determined to decrease the length of the alignment by approximately 10 miles, and per a desktop evaluation, reduce the extent of wetland crossings by over 8 miles with significantly fewer roadway and waterbody crossings when compared to the Station 85 route alternative.40 The Station 85 route alternative commences at Station 85 extends southeast through eight Alabama counties bordering Florida before crossing into Florida. This route, unlike the preferred alternative, appears to avoid the state of Georgia from the map provided.41

39 Reportedly Southern Natural Gas Company is currently a division of El Paso after its merger with SONAT. See: http://en.wikipedia.org/wiki/Southem Natural Gas.

40 Section 10.5.1, Major Underground Route Alternative – Station 85 route, p. 10-10.

41 Figure 10.5-1 in Appendix lOA ofthe Draft Resource Report 10 Alternatives.


EPA recommends FERC discuss in its EIS the difference in wetlands type/ sensitivity between the two alternatives. This discussion can be informed by the following studies and other similar studies:

  • The Southwest Georgia Regionally Important Resources Report42 prepared by the SW Georgia Regional Commission identifies nine Wildlife Management Areas, three state parks, large tracts of privately held lands, and significant water resources. Roughly one-half of the Southwest Georgia region found to the west of the Pelham Escarpment is considered a significant recharge area and includes the Dougherty Plain and Fall Line Hills districts. Karst topography is prevalent hi the Dougherty Plain district, and many sinkholes, some still actively forming, are the sites of numerous ponds and marshes. A number of exceptional caves and karst features are found in the Southwest Georgia region. Caves are recognized as a High Priority Habitat in the Comprehensive Wildlife Conservation Strategy and are found primarily along the Pelham Escarpment in the southwestern portion of the region. The lower part of the Flint River Basin, together with the upper part of the Apalachicola basin, has the highest species density of amphibians and reptiles on the continent, north of Mexico. The Ochlocknee River Basin has many parts where native aquatic life is threatened by sediment loading and the loss of riparian tree cover. There are approximately 18 rivers and streams listed on the 303(d) list as waters not meeting their designated use of fishing, which include roughly 150 miles of rivers and streams within the Ochlocknee Basin. Radium Springs is located several miles southeast of Albany is considered one ofthe “Seven Natural Wonders of Georgia” and the largest natural spring in the state. The Chickasawhatchee Swamp is Georgia’s largest wetland in the southwest, second largest deep-water swamp, one of the southeastern United States’ largest remaining freshwater swamps, and is second in size only to the Okefenokee Swamp. This swamp contains thousands of acres of mature bottomland hardwoods and a wide variety of rare plants and animals. The 650-acre Doerun Pitcher plant Bog Natural Area in Colquitt County contains a healthy longleafpine/wiregrass community and about 30 pitcher plant bogs. The 140-acre WolfCreek Preserve in southern Grady County bordering the Florida state line has significant botanical value because it contains the largest and densest known span ofTrout lilies in the world. The 2,437-acre River Creek tract, several miles west ofThomasville in Thomas County, contains some of the best long-leaf pine habitat in the world. Adjacent to the River Creek tract to the east is the 5, 700-acre Greenwood Plantation which contains some of the best examples of old long-leaf pines in the world. Greenwood Plantation was a cotton plantation built around 1835-40. It contains a 1,000-acre tract known as Big Woods with trees ranging in age from 200 to 500 years old. The Greenwood plantation also contains a distinct longleaf pine sand hill community known as the Plateau, a slope forest along the Ochlocknee River, and Heard’s Pond, a 700-acre wetland area critical for the endangered wood stork. Just west of Albany in Dougherty County is the Albany Nursery wildlife management area having a mixture of fields and mature lowland hardwood forest habitat to a wide variety of wildlife species and provides drainage for nearby upland areas. The 4,681-acre Mayhaw WMA near Colquitt in Miller County contains three tracts of hardwood bottoms, cypress-gum wetlands, and young and mature pines where ibis and wood storks habit during the summer.
  • The Georgia River Valley Regionally Important Resources Report43 prepared by the River Valley Regional Commission identifies Eufaula National Wildlife Refuge in Stewart and Quitman Counties, Hannahatchee Creek Wildlife Management Area in Stewart County, Jurisdictional Wetlands- approximately 328,000 Acres and important resources. The River Valley Region has among the higher concentrations of the state’s wetland acreage. Also identified are river Corridors, particularly Harris, Muscogee, Chattahoochee, Stewart, Quitman, Clay, Talbot, Taylor, Macon, Dooly and Sumter Counties along the Chattahoochee and Flint Rivers and portions of Kinchafoonee and Upatoi Creeks. The wetlands and river corridors have been designated a Vital Area of the state.

42 Available at https:/lwww.dca.ga.gov/development/PlanningOualityGrowth/Regional%20Plans/Adopted%20Regional%20Plans/Southwest%20GA%20RC/SWGRC%20RIR%20PLAN FlNAL.pdf

43 Available at http://www.dca.ga.gov/development/PlanningQualityGrowth/Regional%20Plans/Adopted%20Regional%20Plans/River%20Vally%20RC/RV_RegionalResourcePlan_FINAL.pdf.


  • Wetlands Impacts: EPA requests wetland and stream quality be determined for potential impact sites using appropriate functional assessment methods (for example, the state of Florida requires the use of the Uniform Mitigation Assessment Method, which establishes a uniform mitigation assessment method to determine mitigation amount needed to offset adverse impacts to wetlands and surface-water.44
  • Wetlands Impacts: EPA requests the proposed action avoid high functioning, high quality, and rare systems. The EIS should identify any wetlands identified as being of particular sensitivity (e.g., identified by the state as of particular value, presence of ESA species}. For example, Limesink wetlands are a common aquatic habitat in southwest Georgia.45 They occupy shallow depressions formed from dissolution of limestone bedrock and collapse of surface sands. They are seasonally inundated from late February to early July. These wetlands have been recognized as sites of moderate productivity, high biological diversity, and important wildlife habitat. Limesink wetlands range from steep sided, small sinks to shallow flat large expanses of several acres with depths ranging from less than three and up to 24 feet. Vegetation varies from open grassy meadows to forests composed of flood tolerant cypress hardwoods. Many of the depressions have a confining layer of silt and clay that enables them to hold water following heavy rainfall. Consequently, EPA recommends these wetlands be identified and avoided. Mitigation is required if the proposed action impact their ability to exist, i.e., disturb the confining layer of silt and clay that enables them to retain water and thereby exist.
  • Wetlands Impacts: EPA requests grading not be performed in wetlands, and FERC reflect this in the Environmental Impact Statement.
  • Wetlands Impacts: The Draft Sabal Trail Transmission Resource Report No. 1 describes wetland construction methods that include use of wooden swamp mats for inundated or saturated conditions, with stockpiling of topsoil and assembly work staged in uplands when possible. For wetlands with firm, unsaturated and not frozen substrates, fabrication in the wetland is indicated. EPA recommends fabrication on uplands and minimal equipment traffic whenever feasible, even in dry conditions, to avoid compaction of wetland soils.

44 Florida Department of Environmental Protection’s UMAM information web site can be found at http://www.dep.state.fl.us/water/wetlandslmitigation/umamlindex.htm

45 Colladay, S.W., Taylor, B.W., & Palik, B.J., Invertebrate Communities of Forested Limesink Wetlands in Southwest Georgia, USA: Habitat Use and Influence of Extended Inundation, Wetlands, Volume 17, No.3, September 1997, pp. 383-393; available at http://www.nrs.fs.fed.us/pubs/jml/1997/nc_1997_golladay_001.pdf.


Public Health and Safety

  • Co-location with the Southern Natural Gas Line – This 10-inch line is reportedly 50 plus years in age, and concerns exist with the safety of an old line buried in the soils of southwest Georgia. Consequently, concerns exist with the safety of adding a 36-inch natural-gas line in its ROW, particularly in dense population centers. Moreover, should these dense population centers have more than one natural-gas line in their neighborhoods, safety concerns are heightened. This includes Environmental Justice (EJ) communities who may be impacted by the existing natural-gas pipeline infrastructure. For example, the investigation into the March 12, 2014, explosion in East Harlem, NY, discovered a leak in the gas main, an 8-inch line installed in 1987. EPA recommends FERC discuss in the EIS the SNG’s 10-inch line, its maintenance/testing schedule, the pipeline’s integrity, and the cumulative impact associated with a leak in the 10-inch pipeline co-located with the proposed 36-inch natural-gas pipeline. The discussion should identify communities, residents, schools, other population centers in the vicinity, and include measures to ensure the safety of the community, individuals, and property.
  • The route shown at Spectra’s landowner meeting in Lowndes County goes through the closed Lowndes County landfill. EPA recommends this landfill be avoided.

Environmental Justice and Children’s Health

  • Environmental Justice:
    • EPA recommends FERC identify in the EIS specific communities that may be located near and potentially affected by the proposed action and associated construction.
    • The EIS should provide data and maps for unconsolidated tracts and/or block groups in an effort to identify areas with high minority and low-income populations. It should also identify the existence of any pockets along the proposed action’s corridor. Areas within the proposed action having high minority and low-income populations should be readily identifiable in the data provided, and targeted for meaningful public involvement and outreach.
    • EPA recommends the EIS include a discussion of methodology used to conduct EJ assessment and the potential direct, indirect and cumulative impacts (i.e., air, noise, water quality, aesthetics, social, economic, health, and subsistence activities) to EJ populations. Public comments on EJ issues and FERC’s corresponding responses should be summarized, including efforts made to avoid, minimize, and mitigate impacts.
  • Children ‘s Health:
    • EPA recommends FERC provide in the EIS appropriate unconsolidated tract or block group data for children under the age of 17 that resided along/within the proposed corridor. For example, receptors within industry-accepted blast radius of a 36-inch natural gas pipeline and associated compressor stations should be clearly identified, and then additional buffer distances can be added to the appropriate scale maps of the project area to identify any potential risk of impacts to children.
    • EPA recommends the children’s health section discuss the potential direct, indirect and cumulative impacts (i.e., air, noise, water quality, aesthetics, and health) to children in the vicinity of the project area be discussed. Additionally, efforts to avoid, minimize and mitigate impacts, including should also be identified.
    • EPA recommends FERC provide in the EIS readable and comprehensible maps and figures, and clearly describe all potential impacts with the proposed action upon children’s health. For example, maps of schools, day-care facilities, multifamily housing, and hospitals should have different legend colors and be created at scales providing appropriate information, i.e., proximity of sensitive receptors to the navigation and transportation corridors.
Below for your use is a list of EPA Region 4 staff involved with the review of this proposed action.
NEPA Program Staff Beth Walls -lead 404-562-8309
Walls.Beth@epa.gov
Chris Militscher – back up 404-562-9512
Militscher.Chris@epa.gov
Air Program Brenda Johnson 404-562-
Johnson.Brenda@epa.gov
Rick Gillam 404-562-9049 Gillam.Rick@epa.gov
Wetlands Program AL – Rosemary Hall 404-562-9846
Hall.Rosemarv@epa.gov
GA – Eric Somerville 706-355-8514
Somerville.Eric@epa.gov
FL – NW- Elizabeth McGuire 404-562-8721
McGuire.Eiizabeth@epa.gov
FL – NC – Eric Hughes 904-232-2464
Hughes.Eric@epa.gov
FL – S – Ron Miedema 561-616-8741
Miedema.Ron@epa.gov

How to comment with FERC.

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