ACTION ALERT! 5 Must Do Actions
#1 Sign this PETITION. It's critical that you let Governor Cuomo know he must pull the plug on the CPV power plant. If we are to end the expansion of fracked gas infrastructure in New York, it starts here.
#2 MOST IMPORTANTLY, PLEASE COME AND TELL NYSDEC THAT THEY MUST DENY THE AIR & WATER PERMIT TO MILLENNIUM PIPELINE FOR THEIR PROPOSED COMPRESSOR IN THE TOWN OF HIGHLAND.
WHEN: JULY 27TH, 6:00 PM
WHERE: MONTICELLO HIGH SCHOOL AUDITORIUM
39 BREAKEY AVENUE, MONTICELLO, NY 12701
Talking points for commenting below.
#3 Sign the Delaware Riverkeeper petition, too. http://bit.ly/NO_ESU
#4 Talking points for commenting to DEC below. Mail or email any or all of the comments by August 4th to:
Karen Gaidasz, Project Manager, Major Projects Management, firstname.lastname@example.org
NYSDEC - Division of Environmental Permits
625 Broadway, 4th Floor
Albany, NY 12233-1750
#5 Comment on Millenniums VLC Project HERE
DEC TALKING POINTS FOR MILLENNIUM ESU
We believe in parts of the application Millennium did not provide clear and deep enough details, and in some cases used inaccurate data about air emissions, which is misleading to the public and the integrity of the permit.
While Millennium has provided an overview of their own modeling and predicted emission levels and concentrations through its FERC Environmental Assessment, the overarching goal of their efforts is to singularly meet aggregated thresholds largely guided by National Ambient Air Quality Standards NAAQS while avoiding any substantive discussion of persistent, known air, health and environmental impacts at local scales. The EA section 8.1 Air Quality presents project-related construction emissions (Table B-16), operational emissions (Table B-17), and dispersion model estimates of various pollutant concentrations (Table B-18). Throughout the EA; RESOURCE REPORT 9 - Air and Noise Quality; and NYSDEC air permit applications for both Highland and Hancock projects, little if any details are provided to address the following:
Localized intermittent as well as persistent local air quality impacts at each compressor project.
Cumulative impacts across the two large compressor projects in close proximity to each other, both within the same Air Quality Region (AQCR 163).
Through Policy DAR-10: Impact Analysis Modeling, NYSDEC provides guidance to applicants in preparation for air permit submissions. Upon review of the policy guidelines in conjunction with the Southwest Pennsylvania Environmental Health Project Minisink Study, 2015, the public is left with significant questions generally, and no specific mechanisms of independent data validation nor ability address to concrete, specific local air and health impacts concerns.
In AERMOD parameters for both Highland and Hancock, meteorological data is utilized from a distance of 72 miles from Highland and 48 miles from Hancock via KBGM: Binghamton Regional Airport. As stated in NYSDEC’s own guidelines:
Meteorological Data - On-site (i.e. site-specific) meteorological data is generally preferred over National Weather Service data. This is especially true for complex terrain settings.
Quick perusal of average wind speed/directions from several regional stations - the majority of which are closer to the Highland and Hancock proposed stations than stations used in the Millennium AERMOD runs (windhistory.com - NOAA archive, METARS 2006-2010) - shows definitive variations from station-to-station in wind speed and direction. By relying on meteorological data from one station decidedly not ‘site-specific’ and not closest, confidence in the AERMOD runs across rough, highly forested, rural terrain is questionable, prompting public concern that the modeling does not represent accurate local conditions. To follow is a listing of stations, proximity distances and near ranks - in the case of Highland, Millennium’s chosen station is the farthest of 4 stations; for Hancock, the second closest:
Proposed Highland CS
Near Rank | Name | Distance Miles
1 KMGJ: Montgomery Orange Co Airport 32
2 KSWF: Newburgh / Stewart 40
3 KAVP: Wilkes-Barre/Scranton International 48
4 KBGM: Binghamton Regional Airport 72
Proposed Hancock CS
Near Rank | Name | Distance Miles
1 KAVP: Wilkes-Barre/Scranton International 48
2 KBGM: Binghamton Regional Airport 48
3 KMGJ: Montgomery Orange Co Airport 52
4 KSWF: Newburgh / Stewart 60
The appropriateness of aggregated, estimated modeling is an ongoing, significant concern of local populations facing real-time localized compressor station emissions. Throughout the EA, any study, modeling or discussion surrounding high-peak emission estimations for blow-down events and maintenance cycles with significant venting is perfunctory at best. At the same time, the public is increasingly aware of the presence and ramifications of local impacts, especially during these extreme venting events. As detailed at length in the Southwest Pennsylvania Environmental Health Project Minisink Study, 2015, PM 2.5 levels averaged 17 to 20 micrograms per cubic meter (ug/M3)—three times the regional average of 6.3, regularly above EPA thresholds. Multiple episodes of peaks into the hundreds, as high as 426, were also recorded by Speck monitors in the study. These spikes further coincided with residents’ adverse health symptoms.
Further concerning in the EA itself are discrepancies between potential emissions ostensibly modeled then presented in Table B-17 and significantly higher independent estimations for the Highland Compressor Station’s Solar Titan 130E gas-fired compressor using the manufacturer's own published information about the system’s energy consumption and using AP-42 emission factors for lean burn natural gas turbines. Adding to the confusion, FERC obfuscates and incorrectly dismisses ongoing public concern by conflating an obviously applicable study with other studies and determines that none of the studies are relevant to the matter at hand:
We received comments claiming that compressor stations release large quantities of toxic pollutants. Some commenters also cited reports from the Pennsylvania Department of Environmental Protection and Southwest Pennsylvania EnvironmentalHealth Project linking compressor station emissions to health impacts. The majority ofthe reports/studies that were referenced by commenters are based on natural gasproduction facilities that transport and process raw field gas, which typically containsmore pollutants than transmission-quality natural gas. Therefore, we do not find thereferenced studies applicable for relating health impacts from operation of the Highlandand Hancock Compressor Stations.
To complicate matters even further, the FERC EA is utterly bereft of any supporting modeling graphics, diagrams or maps beyond table results designed explicitly to show modeled emission levels relative to aggregated NAAQS standards. This lack of modeling detail is a serious deficiency of the EA in preparing the public for induction of nearly 45K HP of compression within a relatively small geography. Specifically, there exists no wind rose diagrams representing input meteorological data; no terrain elevation and grid modeling graphics for AERMOD runs; and no graphical output describing the shape and extent of maximum project impacts across any or all criteria found in the model summary charts. The public is left with the impression that they literally do not exist in proximity to the project, and the only benchmark of consequence for NYSDEC permitting is solely NAQQS regional thresholds.
Beyond perplexing disregard for known air quality impacts at individual compressors, the EA further fails to address or even mention the cumulative impact of 60,700K HP compression and resulting emissions within the same AQR within 25 miles. As far as the EA is concerned, these two projects exist in separate universes and do not require any cumulative impact analysis whatsoever. While FERC may disregard both local and regional air quality concerns as a result of the same project, its incumbent upon NYSDEC to take into consideration all modeling, emissions data and scientific evidence to not only ‘identify and control sources of air pollution’ but proactively protect populations both near and between project components. Until NYSDEC can assure the public that their concerns have been fully addressed, no air permitting should move forward for the Eastern System Upgrade project.
How does NYSDEC determine what is a safe distance for residents?
THE HALF-MILE “SAFETY” RADIUS GUIDELINE LACKS A TRANSPARENT METHODOLOGY AND IS PROVING INSUFFICIENT AND UNSAFE
The EA neglects to address the community’s concerns on the required distance of the proposed Highland Compressor Station to nearby residences, natural resources and wildlife. There is no answer to the fundamental question, “How close is safe?” FERC and NYSDEC need to provide the laws and detailed analyses that justify the distances between the proposed project and the surrounding habitat and its inhabitants are in fact safe.
We understand that a half-mile (0.5 mile) radius is used to determine the distance between a compressor station and the nearest resident. However, there is no clear methodology or rationale to how half-mile distance is determined and how it ensures the safety and health of residents. This distance requirement appears to be arbitrary and does not protect people or property. We urge you to provide transparency in the methodology you are using to determine this distance.
QUESTION. How does this distance requirement take into account the safety and health of residents within the 0.5 mile requirement?
We observed that the 0.5 mile “guideline” is being applied inconsistently. QUESTION. With the varying horsepower levels of shale gas compressor stations, how can this distance be applied universally? By way of example, how can there be no difference in distance/radius for a 12,200 horsepower compressor station such as the one in the Town of Minisink vs. the proposed 22,400 horsepower compressor station for the Town of Highland? We have had great difficulty locating information on the half-mile requirement.
QUESTIONS. What is the outer-marker used for measurement (e.g. center of the structure, end of the structure, end of property line, etc.)? And, what authority do you rely upon for the basis of this measurement and propriety of this measurement? If there is no half-mile requirement, who and what determines the distance between a compressor station and a home? How is this distance requirement being used for the Town of Highland and what is being taken into account to “safely” site the location of the proposed compressor station? Why aren’t there requirements to monitor near to long term effects on public health and the environment?
Comment 4 - ESU is covering up segmentation
Millennium is covering up the true size and scope of the project. NYDEC needs to say no and to urge the NY Attorney General to investigate the misleading information being provided by Millennium to the state.
Expert analysis and data on the record confirms that Millennium has improperly split the ESU from the overall planned expansion of its natural gas pipeline system in an attempt to avoid a more rigorous comprehensive environmental review of the impacts of pipeline construction, operation and maintenance.
→ The pipe being inserted at the Neversink crossing of the pipeline is out of keeping with the rest of the pipeline.
→ There is a high level of compression being proposed over a relatively short distance as compared to other pipeline projects.
Together, this supports expert and objective assertions that Millennium is anticipating future expansions of the Millennium pipeline, including significant looping to create additional future capacity, that it is failing to disclose.
As the Accufacts expert report released by the Delaware Riverkeeper Network states: "further expansion projects are likely or already planned in the future operation of Millennium Pipeline."
In addition, the Millennium ESU is clearly connected with the Millennium Valley Lateral project and the associated CPV powerplant. In addition to the Accufacts Report, the US Environmental Project Agency (EPA) are both on record stating their concerns over the interdependency of the Valley Lateral Project and the ESU
The State Facility Permit for the Hancock Compressor Station was issued in March 2013 for a ten-year period, after local residents were informed by Millennium Pipeline that no further expansion was contemplated. Not three years later, Millennium Pipeline proposed a second, larger compressor unit at that same site, which requires a Title V Permit from DEC due to the projected bump-up in emissions. Certainly, the current permit application to DEC for an additional 22,400 HP compressor exposes Millennium’s original intent. What happened in Hancock suggests that Millennium will return to the DEC a few years from now and request even more compression on the 80-acre site it now owns in Highland. And, undoubtedly, it will then state, as it now has said of Hancock, that it would be an expansion of an “existing industrial site,” since that is exactly what the proposed compressor station will make of this forested land — in contravention of current zoning law.
I believe that Millennium continues to misrepresent its plans so as to mislead the DEC into approving the requisite State permits. But if the DEC determines, despite Millennium’s history of deceptive segment by segment expansion, to grant Millennium’s air permits, I urge the DEC to deny the requested State permits for the ESU unless and until these segmented projects are considered and evaluated as a whole and their aggregate impacts on our community and region are taken into account.
The DEC should reject Millennium Pipeline’s applications for the Highland Air State Facility Permit and the Hancock Title V Air Permit given Millennium’s substantial misrepresentation of the scope of the proposed Eastern System Upgrade project (“ESU”). There are indications that Millennium has in the past, and continues to, unlawfully segment pipeline expansion and associated infrastructure. In so doing, Millennium may be misleading the DEC into inappropriately approving permits on a piecemeal basis that the DEC would not approve if the agency were aware of the full scope of Millennium’s project plans.
This concern is premised on an expert report by Accufacts Inc. posted on the Federal Energy Regulatory Commission (FERC) docket for ESU that analyzes ESU’s Critical Energy Infrastructure Information, which is not available to the public. Based on its review, Accufacts concludes (1) that the oversized 36” segment of pipe at the Neversink Crossing, independently and combined with the proposed additional compression in Highland and Hancock, signals that “further expansions are being anticipated or planned as a result of this project”; and (2) “this unusual proposal suggests further expansions are in Millennium’s plans and such ‘segmented’ expansion(s) should be included with this Project’s proposal.”
Furthermore, Accufacts’ analysis suggests that the ESU, Millennium’s Valley Lateral Project, and the CPV power plant in Waywanda appear to be part of an integrated whole that should have been presented to the DEC and reviewed as a single project for purposes of evaluating the requisite water and air permit applications. Indeed, the U.S. Environmental Protection Agency is also on record questioning the interdependency of the Valley Lateral Project and the ESU, inquiring of FERC “whether the ESU would be constructed and meet the purpose and need with or without the Valley Lateral being completed.”
I urge the DEC to deny the requested State permits for the ESU unless and until these segmented projects are considered and evaluated as a whole and their aggregate impacts on our community and region are taken into account.
Comment 5 - HEALTH
Millennium, NYSDEC & NYSDOH have all known about health problems around Minisink compressor (as detailed in the SWPEH report) and have done no further investigation. Relying on Millennium modeling does not give an accurate picture of emissions. SWPEH recorded emission spikes that surpassed an acceptable level of particulates for human health. Approving additional compressors is criminally negligent until the real emission data is known. Laughably, Millennium claims that their compressors are safer than scented candles or skin moisturizer, and blames respiratory issues around Minisink on woodstoves.
NYSDEC, along with NYSDOH and Governor Cuomo have all received the Minisink study, and yet, close to two years later, nothing has been done to investigate the alarming impacts in the report. Approving additional compressors without a full understanding of their impacts would be criminally negligent.
In Massachusetts, Governor Baker has asked for a review of air quality impacts for a proposed compressor station in Weymouth along with public safety and climate resiliency reviews. New York should follow this example, as no less than the safety and well-being of the public is at stake.
It should be noted that Sullivan County is ranked 61st out of 62 counties for health in New York. A compressor station similar to Minisink and Hancock that has caused health issues will further exacerbate that problem.
Given the ongoing proliferation of natural gas infrastructure throughout New York, despite New York’s own State-wide moratorium on high volume hydraulic fracturing (“fracking”), it is long past the time that the NYS Department of Health should undertake a Health Impact Assessment (“HIA”) of compressor stations and other gas infrastructure. The State-wide moratorium on fracking imposed by the DEC was largely founded on the conclusions of the NYSDOH that fracking would have an adverse impact on the health of NYS’s citizens. The DOH needs to initiate a similar critical health inquiry with respect to gas infrastructure and its conclusions must be taken into account by the DEC before any further air and water permits are granted. Towns and counties, particularly rural counties like Sullivan, lack the funds and personnel to launch an HIA and therefore are unable to fulfill government’s central responsibility — protecting the health and welfare of its citizenry.
Sullivan County tried and failed to commence an independent HIA with the wholly inadequate amount of $50,000 promised by Millennium Pipeline. While the County is now attempting instead to secure a baseline air quality assessment through a new RFP, residents in proximity to the proposed Highland compressor station do not want to be the “guinea pigs” for future planned compressor stations. The fact that Millennium has bought out homeowners who lived in proximity to other Millennium compressor stations (Minisink and Hancock), and that at least one homeowner abandoned his home due to health concerns attributed to a compressor station, should be more than sufficient evidence that a DOH-led state-wide HIA of gas infrastructure is warranted and that DEC must delay permitting pending the DOH’s conclusions.
Residents in proximity to the proposed Highland compressor station are concerned about the potential adverse impacts to their health and urge the DEC to reject the requested Air State Facility permit unless and until the NYS Department of Health undertakes a Health Impact Assessment that concludes that compressor stations do not pose a significant health risk.
We are aware of the health evaluations undertaken by Southwest Pennsylvania Environmental Health Project (SWPA), which collected information from 35 individuals (including 12 children) living within a mile of Millennium’s far smaller (12,000 HP) Minisink compressor station. Their symptoms included respiratory problems, neurological problems, and dermatological problems. Periodically high levels of particulate matter 2.5 (PM 2.5) found outside multiple homes at similar time frames — as compared to regional levels of PM 2.5 reported from Newburg Airport--were recorded by Speck monitors. This led SWPA to conclude that the episodic nature of health symptoms reported by residents is likely associated with the episodic high emissions that come from the Minisink compressor station.
The Minisink compressor station compresses the same “transmission-quality” gas as would the proposed Highland compressor station. As such, FERC’s statement in the Environmental Assessment that adverse health impacts have only been noted at natural gas production facilities transporting “raw field gas” fails to address the health complaints of Minisink’s residents.
The Federal Agency for Toxic Substances and Disease Control (ATSDR) released a study last year of air quality near one gas compressor station in Susquehanna County, PA, which found PM 2.5 at levels that the agency said could damage the health of people with long-term exposure, indicating that it could cause increases in mortality, respiratory problems, hospitalizations, and pre-term and low-birth weight births.
While the SWPA and ATSDR are very small studies, they suggest the need for a comprehensive appraisal by the NYS Department of Health and for the DEC to postpone air permit approvals for compressor stations pending the conclusion of such a study. This is also important because Millennium and FERC point to Millennium’s compliance with pollutant levels established by the EPA as protective of human health. But as former Congressman Chris Gibson wrote in a letter to FERC last year, these air toxin exposure standards were established decades ago and therefore may be obsolete. He noted that the standards should reflect current information regarding risks to human health from inhalation of these chemicals and also do not address higher exposure rates at peak release times.
Comment 6 FERC has been shown to hide full information (see Orion case) from the public.
Until a full examination of FERC information on Millennium’s plans is available, deliberation on the project should be put on hold.
Comment 7 Highland is designated an Important Bird Area by NYSDEC
Millennium vastly underreported the number of bird species in their own review. Again, Millennium uses inaccurate and incomplete data to make their determination of environmental conditions. Further study is required in order to obtain accurate information
Comment 7.1 As a local resident and bird enthusiast, I strongly urge the DEC to undertake its own evaluation of the potential impacts that the Eastern System Upgrade may have on birds and other wildlife. The planned 22,400 HP Highland compressor station is proposed to be sited within an Audubon designated critical bird habitat, the Mongaup Valley Important Bird Area (IBA). In addition, New York State has enacted a Bird Conservation Area program, modeled after the IBA program, to identify and manage publicly owned lands important to birds and part of the Mongaup Valley IBA is included.
Our IBA provides significant breeding and wintering habitat for Bald Eagles with some of the highest concentrations of that special bird within the State. This state-listed bird species is frequently seen flying, feeding and nesting by residents both in Highland and the bordering towns and some nearby properties in the bordering Town of Bethel even have construction restrictions due to proximity of nesting sites. Further, the intact forest tract currently supports a diversity of priority forest birds like the Rose-breasted Grosbeak, Wood Thrush, and various species of warblers, and fragmentation of this forest by Millennium will have a disproportionate negative impact on these birds.
Last summer, volunteer expert birders from the Cornell Lab of Ornithology conducted their own bird surveys in forested parcels abutting the proposed Highland compressor station site and they found discrepancies with Millennium Pipeline’s Resource Report #3. In contrast to their own on-site surveying, Millennium’s conclusions were based on the 2000-2005 NYS Breeding Bird Atlas without any actual, verified survey work. As such, it is possible that they were nowhere near the actual site of the proposed compressor station.
I therefore urge the DEC, as the State agency responsible for protecting significant species and environmental habitats, to have staff conduct its own surveys and assessment of potential impacts to at-risk bird species and habitats. Anything less places our eagles and high priority forest birds at risk-- subject to forest segmentation, blasting, noise and other construction impacts, and the vibration, noise, and air pollutants/emissions that will impact the area for the decades-long duration of this industrial and unwanted invasion of the property known locally (and, it now sadly seems, ironically) as the “Eldred Preserve”.
Comment 8 - Timber Rattle Snake conditions
Again, Millennium submitted inaccurate data that put suspected rattlesnake dens outside of their property. This is consistent with Millennium’s pattern of obfuscation and misrepresentation. Further study is required in order to obtain an accurate picture of endangered species populations.
Comment 9 - Cumulative Impacts
There will be three compressor stations in 52 miles (Hancock with 2 compressors, Highland and Minisink) along with a fracked gas power plant (CPV). Based on the data supplied to FERC alone, the cumulative emissions impacts must be looked at as a whole as the projects are interconnected.
Comment 10 - NYS’ Commitment to a Sustainable Future:
This project does not put us onto a path of sustainability but, in fact, lashes us to dependency on fracked gas for the next forty years. If NY is to be a bulwark against climate change, as Governor Cuomo claims, how does a project that relies on fracked gas accomplish this? Methane is 80X more potent a greenhouse gas than CO2. Millennium, by their own admission, says that 1% of their gas is LAUF (Lost And Unaccounted For).
Governor Cuomo has made numerous laudatory commitments to a “Renewable New York,” most recently in light of the President’s withdrawal from the Paris Climate Agreement. Last month, he announced his goal to create 40,000 clean energy jobs in the State by 2020, as well as an investment of $1.5 Billion in renewable energy projects — all aimed at taking aggressive action to address climate change.
On the local level, the Town of Highland, the surrounding towns of Bethel, Lumberland, and Tusten, and Sullivan County have all pledged to be “Climate Smart Communities” under the DEC’s own program. All these entities have committed to reducing their greenhouse gas emissions, decreasing their energy usage and otherwise doing their part to achieve an environmentally sustainable New York State. Sullivan County and the Town of Bethel are on their way to achieving certification. The Town of Tusten has installed a municipal solar installation. It is therefore both confounding and ironic that, on the one hand, our communities partner with DEC to reduce dependence on fossil fuels and climate-destroying greenhouse gases while on the other hand, DEC may approve permits to construct a methane–emitting compressor station against our will and in our midst. Because methane is over 80 times more potent than carbon dioxide over a 20-year span, the planned and accidental blow-downs and venting, along with fugitive emissions, from the proposed Highland compressor station will torpedo local efforts to reduce greenhouse gas emissions.
Thus, despite commendable climate change leadership by the Governor, the DEC’s continued approval of natural gas infrastructure projects, including the enormous CPV power plant in Waywanda, undermines forward-thinking initiatives and anchors New York to fossil fuels for decades to come. The expanding spider web of pipelines and pipeline infrastructure across New York State in recent years has been dramatic. Despite claims of federal preemption for interstate projects, the DEC must take steps — strengthening the State’s air quality standards, evaluating health impacts — to stop it.
Governor Cuomo has pledged to cut greenhouse gas emissions in NYS but DEC, so far, has been too busy approving pipelines and their compressor stations to get started on that. Governor Cuomo has a methane plan which will seek to determine where all the methane is coming from. Governor Cuomo intends, at some future date, to begin moving the state to renewable energy sources. Governor Cuomo has a website usclimatealliance.org where you can stay up-to-date on NY’s efforts to honor the Paris Agreement. On that site Cuomo states: “Alliance members are growing our clean energy economies and creating new jobs, while reducing air pollution, improving public health, and building more resilient communities.” Except Cuomo doesn’t mention Eastern System Upgrade, which the DEC is currently reviewing on this website. His site doesn’t mention the Competitive Power Ventures fracked gas power plant, constructed under a cloud of corruption. He doesn’t mention the recently approved Spectra or Dominion New Market pipelines either.
I am writing to tell Governor Cuomo where the methane is coming from: It is hemorrhaging at rates of up to 12%, from well head to delivery, from pipelines across the state. It leaks from pipelines just like ESU, which DEC is now considering. As Cornell climate scientist Dr. Robert Howarth testified in a recent court case involving the power plant, CPV moves in the opposite direction from the Paris Accord, and from empowering renewables in NYS, and from reducing GHG emissions. CPV, MVL, and ESU represent giant steps backwards.
Further, mile for mile and stream for stream, ESU will impact as many streams and wetlands as the recently rejected Northern Access – nearly two streams per mile. Half of these streams are protected trout waters, and half of them will be trench crossed. So, there is reason enough to reject ESU’s water quality certificate.
There seems to be a widening gap between what Governor Cuomo has pledged to do, and what he is actually doing. DEC must decide now whether it will move forward on Paris, as the governor claims he wishes to do, or backwards on Paris, as the president insists on doing. Is Governor Cuomo going to pledge to protect the environment, but in fact follow Trump as he lurches away from Paris?
In 2015, Governor Cuomo promoted his environmental commitment by signing, with Al Gore, an “Under 2 MOU” which reaffirmed his pledge to reduce Greenhouse Gas (GHG) emissions 40% by 2030 and 80% by 2050. Recently, the Governor announced a plan to reduce statewide methane leakage. What was missing from the governor’s press releases was any indication of how we would get THERE from HERE. Every year, since the state banned fracking, we have imported more fracked gas than the year before. Every year, the state has approved gigantic gas infrastructure projects to carry or burn that gas. Natural gas make up over half of state proposals for new electricity capacity, and far more when megawatts- hours of total generation are considered.
The Eastern System Upgrade (ESU) moves us even further in the wrong direction. Citizens are beginning to wonder if these GHG reduction plans are a hoax. Perhaps state goals, with all their fanfare and hoopla, are actually meant to distract us while DEC continues business as usual: More gas, more pipelines, more compressor stations, more fossil-fuel power plants, more greenhouse gas emissions each year.
Assuming the DEC and the governor wish to lower GHG emissions, let’s see how badly ESU will hurt that effort. ESU proposes to move 223,000 DTh/day of gas. Consider the climate impact of burning all that gas. Over one year this is equal to 223 Billion BTU x 365 = 81.4 trillion BTU/year. This is equivalent to 9.5 billion pounds of CO2 or 4.32 MILLION metric tonnes of CO2 due to combustion.
The governor will certainly want to know what ESU will do to his methane plan. Using the conservative leakage rate of 2.6% from lifecycle emissions, this corresponds to 40,941 metric tonnes of methane leaked into the atmosphere annually. Because methane has a Global Warming Potential (GWP) of 86, this corresponds to 86 x 40,941 metric tonnes of methane = 3.52 MILLION metric tonnes of CO2e annually from leakage. Using more realistic leakage rates, between 5% and 12%, we find the methane leakage is probably between 8 and 16 million metric tonnes of CO2e per year. Wow! I think the governor is going to want to know about this right away.
I wish that were all the unwelcome news the ESU means for state environmental targets. But the Titan 130 turbines planned for ESU compressor stations in Sullivan and Delaware counties will generate almost 100,000 tons of additional CO2 each year as well. Based on how sick the smaller Minisink and existing Hancock compressors already make people, that’s bad news for citizen health, too.
The DEC must reject ESU air permits. ESU means that instead of fighting climate change, the state intends to increase GHG emissions and signal the rest of the country that NY is helping to wreck any hope of the US meeting Paris Accord goals.
Comment 11 - Type 2 is an abdication of duty
Besides threatening nearly two streams per mile, and adding millions of tons of CO2E per year to the state’s GHG inventory, Eastern System Upgrade (ESU) will increase the risk of cancers in NY from radioactive exposure.
In researching the impacts of infrastructure to transport Marcellus and Utica shale natural gas, we find that the levels of radon are 20 to 30 times higher than the historic levels of radon in gas from shallower deposits. Radon breaks down into polonium-210 and radioactive lead-210 which have half-life periods of 138 days and 22 years, respectively. These deadly forms of radioactive Nano-particulates will remain radioactive alpha- and beta-emitters for a hundred years.
Radioactive particles infuse natural gas hydrates (scale) as a coating on the proposed pipe and on all valves, compressors, and associated infrastructure. The filters and pigging sludges become extremely radioactive, posing risks to the public as well as to worker health. The handling of these wastes and consideration of the ultimate disposition of the radioactive pipe has been ignored in pipeline approvals at FERC and DEC. Cutting, purging, and leaving the abandoned pipe in the ground, which is the historic practice, can result in a pollution of groundwater. Consequently, through both immediate stream impacts and long-term radioactive contamination, ESU poses a risk to state water quality.
Current DEC practice of classifying projects like ESU as Type II, and neglecting SEQRA guidelines, is flawed and dangerous. ESU requires a full environmental review. NYS rights under the Clean Air and Clean Water Acts are not superseded by federal permits. To preserve our environment and protect citizen health it is critical that the DEC begin robust review of these projects which jeopardize water quality, state GHG reduction goals, and our health.
Has Millennium been in full compliance with DEC air monitoring standards with regard to its other NYS- sited compressor stations currently in operation, including Hancock and Minisink?
Under Item 9.2 of the draft Highland Compressor Station permit, it specifies that “If the facility owner or operator elects to install a continuous emissions monitoring system (CEMS)….” (emphasis added). Why doesn’t the DEC require a CEMS to be installed? Wouldn’t that provide more information if health issues develop among community members?
Has the DEC assessed any penalties against Millennium/Columbia facilities in NYS and/or has the so-called “Emergency Defense” been utilized by Millennium/Columbia in any actions brought by the DEC?
Does the DEC know how many full or partial blow-downs and venting operations there have been in each year of operation for Minisink and Hancock? How many written reports due to “malfunctions” have been submitted to the DEC from each of these currently operating compressor stations?