Last week FERC posted a letter they sent to PennEast containing their comments on a number of PennEast’s recent filings. The letter, along with other recent ones, is a very encouraging development because FERC is continuing to be critical of PennEast and is starting to listening stake holders along the route.
The full letter is available here:
Some highlights from it include:
- An emphasis on avoidance over mitigation. A comment on archeological finds states “Include site avoidance plans for all archaeological sites that PennEast plans to avoid” and “Describe how PennEast would minimize or avoid impacts to aboveground cultural resources, such as the Delaware Canal, historic covered bridges, and other resources, that may be vulnerable to effects from vibration“.
- Many references to PennEast having to seriously consult with local historical and cultural organizations
- An eye-brow raising request to count temporary workers from other parts of the country from local ones. FERC is asking PennEast to explicitly state how many people they’re bringing in from other states as opposed to using local labor.
- Questions on the veracity of the Drexel University economic impact analysis. “Many commenters expressed concern about the conclusions of the Econsult Solutions Inc. and Drexel University economic impact analysis, which estimates that construction of the Project would support a total of 12,160 jobs. The fact sheet on PennEast’s web site states that “slightly less than half (of these jobs) would be in industries other than construction.” This implies that more than 6,000 jobs would be in the construction sector. This appears to conflict with other estimates presented in draft Resource Report 5 of 2,500 people employed during construction. Explain this apparent discrepancy“.
- Questioning PennEast’s statements about agricultural impact: “Draft Resource Report 5 does not appear to consider the value of agricultural land that would be permanently impacted by the Project. Confirm that no agricultural land would be permanently removed from production or otherwise permanently impacted as a result of the Project, or include a description of any agricultural land that would be permanently removed from production. Confirm that the acres temporarily impacted by county listed in table 5.5-6 match those in draft Resource Report 8 table 8.2-2, and if not, clarify the discrepancy“.
- Questioning the targeting of conserved lands: “Address public concerns that the Project would negatively affect public and private conservation lands and other public lands that have been preserved in their current condition through public and other sources of funding.”
- Requests to widen the analysis to include cumulative impacts: “Assess the potential cumulative effects of the Project in conjunction with past, present, and reasonably foreseeable projects, including the projects identified in table 1.4-1 of draft Resource Report 1.”
- More information on impacted farmlands: “Update tables to include columns for ‘prime farmland’, hydric’ and average slope and compaction. In addition, summarize the percentage of each of these categories for the route.”