FERC’s ecomment system was malfunctioning, so Beth emailed this on behalf of the board, which unanimously approved it earlier that same day. She also forwarded it to John Peconom of FERC and to her U.S. Rep Ted Yoho (FL-03) and to Rep. Sanford Bishop (GA-02). Here is contact information for your elected officials and candidates. -jsq
From: Beth Gordon
To: efiling <email@example.com>
Date: Sat, Apr 19, 2014 6:05 pm
Subject: PF14-1 Sabal Trail Pipeline
To Whom it may Concern at FERC:
I am the President of a group of citizens and landowners from Alabama, Georgia, and Florida affected by the Sabal Trail Pipeline. Here are some important questions we hope you will answer for us. We have had no answers from FERC representatives at any other time. These are the questions we would like answered:
- Is lack of justification of energy need by Florida sufficient for FERC staff to recommend denying a permit for the Sabal Trail pipeline?
- In 2009 Gulfstream (jointly owned by Spectra Energy and Williams Co.) objected to Port Dolphin‘s application to FERC for an LNG import permit, referring to “the unneeded construction and operation of the proposed Port Dolphin pipeline”. If an additional pipeline was unneeded in 2009, why is it needed in 2014?
- If Sabal Trail is going to promote, and indeed justify, the need for this Project based upon how many consumers’ homes this Project may affect, when will we see a more accurate breakdown of the distribution of supply?
- Will FERC please ask Sabal Trail to identify who the consumers will be for the added gas supplies resulting from the Project. Will it be delivered to homes, businesses, industries, hospitals, schools, and power generation plants? What proportion of the gas will result in use at consumers?
- How will Sabal Trail meet future demand in Florida, including details for future plans and expansion activities, especially including any plans for any additional pipeline on the same right of way?
- Given that Sabal Trail’s Draft Resource Report 10: Alternatives (RR10) estimates a range of 1,991 to 5,974 acres to produce equivalent solar power, yet FERC in Moultrie, GA told the audience the Sabal Trail pipeline would require 13,000 acres, how can the conclusion of that RR10 that solar power would take more acres than the pipeline to produce the same power be valid?
- How can Sabal Trail’s RR10, which assumes solar power would require newly-cleared acres, even though most solar PV panels go on rooftops or on already-cleared land, be taken seriously?
- How can FERC proceed even with a pre-filing process with such an obviously incorrect RR10 from the applicant?
- Will FERC provide, and if so when, a legitimate comparison between the physical footprint of energy provided by the proposed Sabal Trail pipeline and renewable alternatives, including calculations of the total physical footprint associated with the production of natural gas?
- Sabal Trail claimed in its application that natural gas is a “cleaner” fossil fuel. When will we see peer reviewed analysis supporting that claim?
- Is lack of justification by the applicant for why its methane would be better for energy for Florida than demonstrably less expensive solar photovoltaic generation, which also requires much less land by Sabal Trail’s own acreage figures, and is far less environmentally damaging, sufficient for FERC staff to recommend denying a permit for the Sabal Trail pipeline? If not, why not?
- Given that at least two companies have LNG export authorizations from U.S. DoE’s Office of Fossil Energy from Martin County, Florida, exactly at the end of the three-part Transco, Sabal Trail, FSC pipeline, how much of the methane through that pipeline is intended for export, rather than for use within Florida?
- Why, even after repeated questions over many months by many people in many locations as to whether the pipeline was to provide natural gas for export, has neither Spectra nor FERC answered with any information about these LNG export authorizations?
- If the gas through the Sabal Trail pipeline is intended for export by the end users, how can federal eminent domain apply for the pipeline?
- Given that Spectra Energy representatives have repeatedly expressed lack of familiarity with its own safety record (in Moultrie, GA, Valdosta, GA, Clyattville, GA, and Gilchrist County, FL), and that record includes repeated severe problems (corrosion, leaks, explosions, property damage, injuries, and fatalities) over more than thirty years, what assurance can FERC provide to landowners and local governments that Spectra has learned from its errors?
- Specifically, Spectra was fined a record $15 million by EPA in 1989 for spilling PCBs at 89 pipeline sites, plus an even larger fine ($18.6 penalty + $200 million for cleanup) by Pennsylvania. Spectra’s own SEC filings say some of their pipelines are still contaminated by PCBs. In 1985 and 1986 two Spectra pipeline explosions in Kentucky destroyed property and injured and killed people, and again in 1994 in Edison, New Jersey. The National Transportation Safety Board (NTSB) found similar causes for all three incidents, of pipeline damage followed by lack of inspection, corrosion, and explosion. Spectra was fined in December 2012 by the Pipeline & Hazardous Materials Safety Agency (PHMSA) on five points of not following federal regulations or its own corporate guidelines for inspection and prevention of corrosion and leaks. It appears Spectra’s safety has not improved in thirty years, and Williams Transco’s connecting pipeline in Alabama blew up in 2011, destroying more than 60 acres of trees. Where and how, specifically, has FERC taken this Spectra and Williams safety track record into account?
- Why, even after repeated questions about Spectra’s safety record, over many months by many people in many locations, has neither Spectra nor FERC told us about these numerous safety problems? Spectra’s admission in Clyattville, GA and in Gilchrist County, Florida of the twenty or more safety incidents recorded by PHMSA is not sufficient: why has not Spectra or FERC responded with any information about the EPA or Pennsylvania PCB fines, or about the NTSB investigations of multiple explosions that damaged property and injured and even killed people?
- FERC has refused to provide lists of affected landowners to those very affected landowners. How can FERC claim it is protecting landowner privacy that way while FERC does nothing to stop Sabal Trail and the other pipeline companies from repeatedly going onto landowners’ land and having attorneys threaten landowners with eminent domain takings?
- By refusing to provide landowner lists to affected landowners and the general public, is not FERC, a tax-payer-funded agency, using taxpayer dollars to subsidize an unfair advantage for the pipeline companies against the very public which pays for FERC?
- FERC has refused to provide copies of the request for proposals (RFP) or the proposals used for the tax-funded selection of a tax-paid environmental assessment consultant, even though FERC’s own acceptance letter for that consultant says FERC’s employees used those proposals to make the choice of consultant. How can FERC justify this lack of transparency with materials and staff time paid for by the taxpayers, many of whom are the landowners against whom FERC is enabling encroachment and threats of eminent domain by the pipeline companies?
- If the excuse for refusing to provide copies of the RFP for or the proposals from environmental assessment consultants is that they might contain competitive information, how can that be asserted of the RFP itself?
- By refusing the public and affected landowners access to the proposals, is FERC not enabling the consultant and the pipeline companies to compete unfairly with the landowners with whom the pipeline companies threaten eminent domain?
- We do not maintain insurance coverage against all of these risks and losses, and any insurance coverage we might maintain may not fully cover the damages caused by those risks and losses.Given that Sabal Trail appears not to have sufficient insurance to cover a major explosion such as those in Kentucky in 1985 and 1986 or New Jersey in 1994, local and state taxpayers will have to foot the bill if such an explosion occurs, how can FERC justify withholding from the public and local and state governments important information such as landowner lists, RFPs, and proposals?
- What would it take for FERC staff to recommend denying a permit for the Sabal Trail pipeline?
-Beth Gordon, President
(Beth Gordon, 352-528-0111)
Update 12:30 21 April 2014: This list of questions is now in FERC’s ecomment system. How to comment with FERC.
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