The state representative for Valdosta and parts of Lowndes County cited their two resolutions and enumerated lack of need for a pipeline, threatening letters from Sabal Trail, alternative routes next to a school, ill effects on business including on forestry and agriculture and private property valuations, potential sinkholes due to drilling under the Withlacoochee River, including on the preferred route, or anywhere in the fragile karst limestone containing the Floridan Aquifer, plus Spectra Energy’s own SEC filings say it doesn’t have insurance to cover the kinds of safety problems in Spectra’s own history nor those pointed out by Southern Natural Gas Company. Dexter Sharper noted local evidence that solar power is cheaper and safer, and echoed the Lowndes County Democratic Party in writing:

“…we have a moral obligation to leave our children and grandchildren with an earth as safe, beautiful, and majestic as the one bequeathed to us by our parents and grandparents.”

For all these reasons, on behalf of my constituents and the citizens of Lowndes County and the state of Georgia, I oppose the Sabal Trail pipeline anywhere in the County of Lowndes or the State of Georgia.

I urge that FERC reject any permit for the Sabal Trail pipeline, or at the very least move it entirely out of the State of Georgia.

Filed 7 January 2015 with FERC as Accession Number: 20150107-5100, “Comment of Dexter Sharper, Georgia State Representative, District 177, under CP15-17.”

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

Re: Sabal Trail Transmission, LLC, Docket No. CP15-17

Dear Ms. Bose,

I am writing as the Georgia State House Representative for District 177 on behalf of my constituents to express my concerns regarding Sabal Trail Transmission’s (SST) proposed natural gas pipeline through my district in south Georgia. More specifically I have the following concerns:

1. No need has been demonstrated. The profit for a pipeline company and a utility through piping gas indicated in Sabal Trail’s 21 November 2014 formal FERC filing is not a sufficient need for eminent domain.

   http://elibrary.ferc.gov/idmws/file_list.asp?document_id=14272602

   http://spectrabusters.org/2014/11/21/sabal-trail-formal-ferc-filing-cp15-17/

2. Sabal Trail has for a year now been sending landowners letters threatening Georgia eminent domain even though Georgia law does not authorize eminent domain for a pipeline that does not serve Georgia. Yet Sabal Trail recently told our local newspaper of record, the Valdosta Daily Times (“Sabal Trail: Eminent domain accusation ‘hard to believe’” by Joe Adgie in the Valdosta Times today, 19 November 2014,) that any threats of eminent domain were “hard to believe”. Multiple constituents have shown me example letters from Sabal Trail’s Atlanta law firm threatening eminent domain. Either Sabal Trail does not know what its attorneys are doing, or it thinks I and my constituents do not know. Either way, Sabal Trail’s credibilty is severely damaged.

   http://www.valdostadailytimes.com/news/local_news/sabal-trail-eminent-domain-accusation-hard-to-believe/article_4a9f2c68-6fa9-11e4-acf3-0b963c798765.html

   http://www.l-a-k-e.org/blog/2014/11/sabal-trail-newspaper-assertions-contradicted-by-spectra-corporate-documents-and-ferc-filings-john-s-quarterman-to-fer c.html

3. Three of Sabal Trail’s alternative routes would run down Interstate 75 through my district, next to Lowndes High School, less than half a mile from Valdosta Mall, and less than a mile from Westside Elementary School, all in my district. See Sabal Trail’s 15 September 2014 filing.

   http://elibrary.ferc.gov/idmws/file_list.asp?document_id=14251434

   This is an unacceptable hazard, especially considering the 2009 Florida Gas Transmission pipeline incident in which a much smaller 18-inch pipeline blew up between I-95 and the Florida Turnpike and threw a 104-foot pipe segment across the Turnpike, which could have hit a nearby high school. See National Transportation Safety Board Pipeline Accident Brief for Accident No. DCA09FP007.

   http://www.ntsb.gov/doclib/reports/2013/PAB1301.pdf

   http://spectrabusters.org/2014/02/11/methane-pipeline-blew-up-onto-florida-turnpike-next-to-high-school/

4. Valdosta and Lowndes County pride ourselves on retaining and attracting businesses and industry, and no business wants to be located next to a hazardous pipeline, so Sabal Trail would adversely affect the local economy. Sabal Trail has promised economic benefits from hotel stays and restaurant meals, but these would be slight and temporary as the pipeline was built, leaving the economic damage and hazards.

5. Those three alternative routes would drill under the Withlacoochee River, risking sinkhole collapse and further contamination of our drinking water, not far from where that River already leaks into the Floridan Aquifer, causing the City of Valdosta to sink its wells 400 feet deep. See “Sustainability of Ground-water Resources”, by William M. Alley, Thomas E. Reilly, and O. Lehn Franke, 1 January 1999, United States Geological Survey, especially Box E on Page 63.

   http://pubs.usgs.gov/circ/circ1186/

6. Sabal Trail’s preferred route would cross the Withlacoochee River just south of US 84 at the Brooks-Lowndes County border, with all the same concerns and risks of contamination, given that water underground does not flow in the same direction as aboveground.

7. Crossing the Withlacoochee River anywhere is an inappropriate risk, given the fragile karst limestone geology containing our Floridan aquifer. See the 21-page “Karst Features and Hydrogeology of the Proposed Sabal Trail Natural Gas Transmission Pipeline Withlacoochee River Crossing ” Hamilton County, Florida”, by professional geologist David Brown, August 2014, already filed with FERC along with Resolution No. 14-10 7 of 19 August 2014 by the Board of County Commissioners of Hamilton County, Florida.

   http://elibrary.ferc.gov/idmws/file_list.asp?document_id=14282868

   http://www.wwals.net/2014/08/27/resolution-14-10-hamilton-county-fl-19-august -2014/

   Hamilton County filed a motion to intervene 18 December 2014.

   http://elibrary.ferc.gov/idmws/file_list.asp?document_id=14282868

   All Hamilton County’s concerns about the Withlacoochee River in Florida apply equally to the same Withlacoochee River in Lowndes County, Georgia. See also the 15 November 2014 FERC filing of opposition from WWALS Watershed Coalition Inc., which includes a copy of the Georgia Water Coalition Dirty Dozen 2014 Item Number 9, opposing the Sabal Trail pipeline anywhere in Georgia, plus corrosion issues in our acidic soil and water, and the WWALS motion to intervene of 16 December 2014, which adds further material.

   http://elibrary.ferc.gov/idmws/file_list.asp?accession_num=20141117-5041

   http://www.wwals.net/2014/11/17/dirty-dozen-sinkhole-aquifer-drinking-water-corrosion-wwals-ferc-sabal-trail/

   http://elibrary.ferc.gov/idmws/file_list.asp?document_id=14280938

   http://www.wwals.net/2014/12/19/wwals-moves-intervene-ferc-sabal-trail-pipeline/

8. Much of the land on Sabal Trail’s preferred route is used for forestry and agriculture, which would be damaged by cutting down all trees on the proposed hundred-foot right of way, and risked by the inadequate three-foot top cover. Agriculture is a major industry in this county.

9. Many landowners in Lowndes County would have to give up easements for Sabal Trail’s pipeline on any of those routes. Such easements would limit their use of their property and reduce their property values, while introducing hazards to their safety and drinking water, yet would leave landowners paying taxes on damaged property.

10. According to the annual SEC Form 10-K filings by Spectra Energy, co-owner of Sabal Trail, Spectra does not have adequate insurance coverage for major incidents such as leaks or explosions, and Sabal Trail itself has no visible assets beyond the pipeline contract. This would leave local and state taxpayers to pay for sending law enforcement, fire department, ambulances, hospitalization, cleanups, and other costs of any such incidents.

11. Representatives of Sabal Trail have repeatedly told us they are a safe company, yet their safety record as recorded by the Pipeline & Hazardous Materials Safety Agency, the Environmental Protection Agency, and the National Transportation Safety Board, among others, shows a pattern of lack of inspection of pipelines for corrosion or leaks, leading to repeated leaks and explosions with major property damage, injuries, and even loss of life.

    http://spectrabusters.org/hazards/spectra-safety-violations/

12. Even another natural gas pipeline company, Southern Natural Gas, filed with FERC 13 November 2014 noting multiple points on which Sabal Trail’s pipeline plan is unsafe.

    http://elibrary.ferc.gov/idmws/file_list.asp?document_id=14254847

    http://spectrabusters.org/2014/11/14/needless-risk-through-unnecessary-crossings-sonat-to-ferc-about-sabal-trail/

    Southern Natural Gas has filed a motion to intervene 16 December 2014, including similar comments.

    http://elibrary.ferc.gov/idmws/file_list.asp?document_id=14281386

13. The price of solar photovoltaic panels continues to drop and has already made solar energy more cost-effective than natural gas, without environmentally damaging rights of way or hazardous pipelines, witness the 1.25 megawatts of solar power at Valdosta’s Mud Creek Wastewater Treatment Plant. Valdosta recently was named “Smart Energy Municipality of the Year” for that solar installation among other reasons.

    http://www.valdostacity.com/Index.aspx?page=270&recordid=3101&returnURL=%2Findex.aspx

14. The Lowndes County Board of Commissioners passed a resolution 9 December 2014 opposing the Sabal Trail pipeline anywhere in Lowndes County, and recommending it not be routed anywhere in the state of Georgia. That Commission had already filed the text of the resolution with FERC 18 November 2014.

    http://elibrary.ferc.gov/idmws/file_list.asp?document_id=14273088

    http://spectrabusters.org/2014/11/24/opposes-sabal-trail-pipeline-in-any-portion-of-lowndes-county-lowndes-county-commission/

15. The Valdosta City Council passed a resolution 11 December 2014 opposing the Sabal Trail pipeline anywhere in its city, county, or state, and filed it with FERC 17 December 2014, supporting the Lowndes County Commission’s resolution and adding a clause of concern about the Floridan Aquifer, which is the source of almost all our drinking water:

    “WHEREAS, the City of Valdosta has concerns regarding any potential effect the proposed pipeline or its construction might have on the Floridan aquifer, the primary source of the drinking water supply for our City, County and the south Georgia area; and”

    http://elibrary.ferc.gov/idmws/file_list.asp?document_id=14281846

    http://www.l-a-k-e.org/blog/2014/12/valdosta-passes-resolution-against-sabal-trail-pipeline-not-in-this-city-this-county-or-this-state-vcc-2014-12-11.html

16. As the Lowndes County Democratic Party (LCDP) said in its policy statement filed with FERC 4 March 2014, and also filed in its motion to intervene of 12 December 2014:

    “Georgia Democrats believe we have a moral obligation to leave our children and grandchildren with an earth as safe, beautiful, and majestic as the one bequeathed to us by our parents and grandparents.”

    http://elibrary.ferc.gov/idmws/file_list.asp?document_id=14191155

    http://elibrary.ferc.gov/idmws/file_list.asp?document_id=14280133

For all these reasons, on behalf of my constituents and the citizens of Lowndes County and the state of Georgia, I oppose the Sabal Trail pipeline anywhere in the County of Lowndes or the State of Georgia.

I urge that FERC reject any permit for the Sabal Trail pipeline, or at the very least move it entirely out of the State of Georgia.

I would like to thank you for your consideration and would appreciate receiving a written response to the concerns I have raised.

Sincerely,

Dexter Sharper

State House Representative
District 177
411-B Coverdell Legislative Office Bldg.
Atlanta, GA 30334
404-656-0126

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