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On multiple occasions, we have provided written comments to Docket No. CP16-486-000 regarding
our concerns and questions about the potential impact of the Eastern System Upgrade (ESU - "Project")
in particular, the proposed 22,400 horsepower natural gas-fired Highland Compressor Station on our
health, environment, and property value. After review of the FERC's Environmental Assessment (EA) of the
ESU released on March 31, 2017, we are not convinced and we do not feel there is sufficient proof that the
ESU and the proposed Highland Compressor Station are safe to people and the environment
Based on our review, we have drawn the following two conclusions and request that FERC and
Millennium Pipeline carefully and thoroughly respond with sufficient information and explanation of their
use of methodologies, calculations, mitigation plans, and independent analysis that support the EA's
assumptions and conclusions that the project is safe and meets Federal and State regulations.
20170509-0007 FERC PDF (Unofficial) 05/08/2017
Conclusions:
~ No attemptto address widespread community concerns on the required distance for safety of the
proposed Highland Compressor Station to nearby residences, natural resources, and wildlife.
The EA has failed to provide clear proof that this project meets required federal and state
environmental regulations. The EA section 8.1 Air Quality presents project related construction emissions
gable B-16), operational emissions (Table 8-17), and dispersion model estimates of various pollutant
concentrations gable B-18). The EA fails to provide any of the assumptions used related to activity, load
factors, emission factors, models used for mobile sources, sample calculations, and the setup parameters
used in AERMOD, etc. Therefore, there is no possible way to independently validate, quality assure, provide
comments on assumptions that directly impact emissions, assumptions related to fugitive emissions, or
recreate the methods used for the values in the tables. In addition, this section does not estimate emissions
from blow-down events nor maintenance cycles when venting will be required.
Significantly higher potential emissions than those presented in Table B-17 have been
independently estimated for the Highland Compressor Station's Solar Titan 130E gas-fired compressor,
using manufacturer's published information about the system's energy consumption and using AP-42
emission factors for lean burn natural gas turbines. The EA is opaque related to the estimates
presented in the tables; therefore, proper review and comment cannot be conducted by reviewers.
Without this information there is no way for reviewers to confidently respond to the findings in Section
10.5, as the reader is left assuming the authors did everything correctly. If this is acceptable, then why
have the EA process at all?
The EA must provide the assumptions, methods, emission factors, and model setup parameters used
to support its conclusions, or by definition, be considered incomplete. If the section on Air Quality is
anything reflective of the assumptions made in other sections of the EA, then the process that was used to
justify the safety of this project is negligent and improper.
The EA neglects to address our and 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 needs 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.
20170509-0007 FERC PDF (Unofficial) 05/08/2017
As previously stated in prior submissions to FERC and Millennium Pipeline, our home is 0.59 miles
(enter 25 Kieferle Rd) from the proposed Highland Compressor Station. Although we have requested on
multiple occasions justification on the distance requirement from the Compressor Station and a residence
to determine what is a safe distance, no answer or follow-up has been provided. Further, the EA lacks any
information, methodology, or complete analysis describing the assumptions used to determine a safe
distance between a residence, wildlife, or natural resources.
The EA also neglects to acknowledge all of the findings submitted on the FERC docket detailing the
negative impact on homeowner values including consumer testimonials. Instead, the EA states that the
Highland Compressor Station would not, "result in other impacts that would significantly impact adjacent
property values." Our letter addressed to FERC and submitted to the docket (Docket No. CP16-486-000,
letter dated January 4, 2017) addressed this falsehood and provided proof of damage already incurred.
Furthermore, the EA inappropriately bases projected homeowner impacts solely on a gas industry-
funded study (i.e. Real Property Service, LLC) which only looks at broad real estate trends over time and
fails to account for buyers who were turned off by these projects, as we have personally have witnessed. It
does not consider the evidence we provided to the docket regarding homeowner loss estimates ranging
from 25 - 100 percent.
The EA's response to potential impact on homeowner value which states, "Current landowners who
believe that their property values have been negatively impacted could appeal to the local tax agency for
reappraisal and potential reduction of taxes" is an admission of impact and damage. Even so, this does not
allow us begin recouping the damages we are already experiencing. Homeowner taxes in Sullivan County
and specifically in the Highland township are low and the marginal savings on annual tax bills cannot come
close to the loss in sale value or even the ability to sell. FERC's suggestion for nearby property owners to
seek relief from taxation will have the additional effect of increasing taxes on the rest of the township to
cover that loss.
Further evidence can be found in section 6.2 of the EA, where it states that electric units are
absolutely possible, but Millennium Pipeline will not consider this option.
"Although technically feasible, Millennium stated the use of electric units would fail to meet the
Project's purpose and need due to the following: 1) the amount of time required to install required
electrical supply to the area; 2) the increasein acres of impact to install 7 miles of high voltage line, a
substation and transformer, and 3) the greater Project costs required for installation of these electric
facilities."
This clearly indicates a preference for corporate profit as the key objective of this project, ahead of
the financial safety and well-being of key stakeholders, landowners, and the public at large.
20170509-0007 FERC PDF (Unofficial) 05/08/2017
~ Provide full transparency into the assumptions, methods, emission factors, and model setup
parameters used to support conclusions that the Highland Compressor Station will not impact our
air quality and health.
~ Provide the methodology, calculation and complete justitication for what constitutes a "safe
distance" from the Highland Compressor Station to our home, vegetation, wildlife and water sources
(noted in prior requests and understanding we are directly downhill of the proposed Compressor
Station) including full transparency into your approach and its assumptions.
~ Provide full proof beyond the industry-funded study carried out by Real Property Service LLC that
the Highland Compressor Station will not impact the economic value of our property. We request
that FERC consider the research carried out by Key Log Economics and the evidence provided in
our letter to FERC dated January 4, 2017.
~ Provide an amenable and complete financial solution as an alternative to your suggestion of tax
relief for damages we are already incurring.
Our previous written requests have gone unanswered. We kindly ask that you respond to this request-
now made for the fourth time.
Respectfully,
CC:
Mr. Basil Seggos
Commissioner
New York State Department of Conservation
625 Broadway
Albany, NY 12233-1011
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