Letter to Norman C. Bay, Chairman of the Federal Energy Regulatory Commission - Investigating Alternative Routes for and Questions Concerning the Northeast Energy Direct Project

Letter

Date: Aug. 14, 2015
Location: Concord, NH

Dear Chairman Bay:

I write to request that the Federal Energy Regulatory Commission (FERC) require Tennessee Gas Pipeline Company (the Company) to respond to the questions and concerns of New Hampshire residents related to the proposed Northeast Energy Direct (NED) Project, as well as to ask the commission staff to closely review these concerns and consider potential alternative routes as they begin the Draft Environmental Impact Statement (DEIS) process.

Over the past few months, I have heard from many communities and individuals along the proposed route with a number of safety, environmental, economic, and health questions and concerns. To address these issues, I request that FERC, or the Company, as part of the DEIS process, provide detailed responses to the concerns and questions of New Hampshire residents, including the following:

The protection of drinking water is critically important to our state and our people. Many residents and municipalities have concerns about potential impacts on the region's water supplies, water quality, and water supply infrastructure from the development of natural gas transmission infrastructure. Has Tennessee Gas Pipeline Company compiled a complete inventory of potential impacts to water supplies and water quality from the proposed NED Project? If not, we request that FERC require such an inventory. What efforts will be undertaken to avoid or mitigate any potential impacts to water supplies and water quality? What, if any, short-term and long-term water quality monitoring will the Company conduct?

Many residents and municipalities, particularly those in New Ipswich and the surrounding towns, have concerns with potential air quality and emissions impacts from the proposed compressor station, as well as concerns about noise and the size of the proposed compressor station. What efforts will be undertaken to avoid or mitigate air quality impacts from the compressor station? How will Tennessee Gas Pipeline Company measure and control methane and other emissions from the compressor station? How will the Company measure any downwind air quality impacts? Are there alternatives to a 40,000 horsepower compressor station? To address noise concerns, we ask that the Company provide detailed information about noise impacts and mitigation related to the proposed compressor station.

Some of the towns along the proposed route are rural in nature and may have only limited emergency response resources. Will Tennessee Gas Pipeline Company work with communities to enhance emergency response capabilities? How will the Company monitor for potential safety issues?

There are many concerns that the project is not needed in our state, and that any regional benefits will not outweigh the impact on the communities along the proposed route. Does FERC's public need review consider where any unsubscribed capacity on the proposed line will be used? Does FERC's review consider any benefits that the project would have on system reliability and energy prices for all states in the region, including New Hampshire? It would be useful for stakeholders to understand the methodology that will be used to calculate these types of cost/benefit calculations in FERC's review of the project.

Many concerns have been raised that this natural gas will be exported to other nations. We ask that the Company provide a detailed response to these concerns, and to commit to using these supplies in New England.

The current proposal traverses primarily through communities where residents and businesses do not have access to natural gas. While we recognize the potential positive impact that increased natural gas supplies could have on energy prices across the region, we urge FERC to give serious consideration to alternatives that would place the pipeline closer to communities that will be directly served. In addition, we ask the Company to develop proposals that ensure that any impacted community will see energy benefits from a pipeline.

State agencies are currently reviewing the Company's Resource Reports and other filings and may have additional questions.It is my hope that you will require the Company to respond individually to state agency questions and concerns, as well as to questions and concerns from municipalities.

In addition to requiring the Company to address the questions above, I ask that FERC staff looks closely at the proposed route and consider all potential viable alternatives. The siting of energy transmission projects must strike a balance between potential benefits in reduced energy costs and potential negative impacts. We must work to ensure that the potential negative impacts of the proposed NED Project do not disproportionately outweigh the benefits, particularly for the residents and communities that would bear the burden of hosting the project.

Thank you for your consideration.

With every good wish,

Margaret Wood Hassan
Governor


Source
arrow_upward