20100729-4004 FERC PDF (Unofficial) 07/29/2010

From: Chris Len [mailto:chris@nynjbaykeeper.org]

Sent: Thursday, July 29, 2010 3:02 PM
To: Kara J. Harris
Cc: debbie@nynjbaykeeper.org
Subject: Spectra Natural Gas Pipeline; Docket No. PF10-17-000

July 29, 2010

Kara Harris
Environmental Project Manager
Federal Energy Regulatory Commission
888 First Street, NE, Room 1A
Washington, DC 20426

RE: Scoping Notice for Docket No. PF10-17-000

Dear Ms. Harris,

Thank you for soliciting comments relating to the above referenced natural gas
pipeline expansion project. NY/NJ Baykeeper is a founding member of the Water
Keeper Alliance, and as the foremost environmental advocacy group working to
preserve, protect and defend the Hudson/Raritan Estuary, we and our
membership are naturally very interested in a gas pipeline sure to impact several
local water bodies, communities and shore and near-shore ecosystems.

As you are no doubt aware, the project is extremely complicated and presents
numerous concerns:

The pipeline would impact ecological resources already stressed past any
reasonable limit by centuries of industrial development.

The pipeline would be built through the most densely populated

metropolitan area in the country, home to roughly 20 million residents,
and one of the most densely populated in the world.

The pipeline would add to impacts on numerous poor and minority

communities already burdened by some of the most outrageous affronts
to environmental justice on record.

Approval, if granted, would carry the power of eminent domain, impacting

the property rights of all manner of people, including both some of the
poorest and some of the wealthiest in the country.
20100729-4004 FERC PDF (Unofficial) 07/29/2010

Natural gas – asphyxiant, reactive, flammable and explosive – would be

piped through communities, posing risks to human health both real and
imagined.

Construction is likely to affect traffic, noise levels, and air pollution and cause
other temporary yet troublesome disruptions to millions.

For a project this complicated, raising environmental, social and health concerns
for so many millions of people, it is striking to me that FERC has decided on such
a short timeline between its announcement, its scoping meetings and its
comment deadline. With so many people to alert and so many impacts to
consider, FERC would be far better served to announce and pursue an extended
scoping period – particularly when so many of the affected are difficult to reach
and organize, and many don’t even speak English.

Your notice states “The purpose of the Pre-filing process is to encourage early
involvement of interested stakeholders and to identify and resolve issues before
an application is filed with the FERC.” NY/NJ Baykeeper fails to understand how
FERC can expect helpful input as envisioned by the National Environmental
Policy Act if it has such unrealistic expectations from a startlingly short scoping
period. I fear that the timeline that you’ve laid out for the scoping process is so
short as to not only be a poor policy decision, but to genuinely raise due process
concerns.

I ask that you reconsider your scoping timeline, and extend it sufficiently to
allow interested citizens to understand and process the proposal, learn what it
means to them, and respond to FERC in a considered and helpful fashion.

I hope that FERC will take these comments seriously and adopt a timeline in
better accord with the purpose of your announcement.

Sincerely,

Christopher Len
Staff Attorney
NY/NJ Baykeeper
20100729-4004 FERC PDF (Unofficial) 07/29/2010

July 29, 2010

Kara Harris
Environmental Project Manager
Federal Energy Regulatory Commission
888 First Street, NE, Room 1A
Washington, DC 20426

RE: Scoping Notice for Docket No. PF10-17-000

Dear Ms. Harris,

Thank you for soliciting comments relating to the above referenced natural gas pipeline expansion project.
NY/NJ Baykeeper is a founding member of the Water Keeper Alliance, and as the foremost environmental
advocacy group working to preserve, protect and defend the Hudson/Raritan Estuary, we and our membership
are naturally very interested in a gas pipeline sure to impact several local water bodies, communities and shore
and near-shore ecosystems.

As you are no doubt aware, the project is extremely complicated and presents numerous concerns:

• The pipeline would impact ecological resources already stressed past any reasonable limit by centuries
of industrial development.
• The pipeline would be built through the most densely populated metropolitan area in the country, home
to roughly 20 million residents, and one of the most densely populated in the world.
• The pipeline would add to impacts on numerous poor and minority communities already burdened by
some of the most outrageous affronts to environmental justice on record.
• Approval, if granted, would carry the power of eminent domain, impacting the property rights of all
manner of people, including both some of the poorest and some of the wealthiest in the country.
• Natural gas – asphyxiant, reactive, flammable and explosive – would be piped through communities,
posing risks to human health both real and imagined.
• Construction is likely to affect traffic, noise levels, and air pollution and cause other temporary yet
troublesome disruptions to millions.

For a project this complicated, raising environmental, social and health concerns for so many millions of
people, it is striking to me that FERC has decided on such a short timeline between its announcement, its
scoping meetings and its comment deadline. With so many people to alert and so many impacts to consider,
FERC would be far better served to announce and pursue an extended scoping period – particularly when so
many of the affected are difficult to reach and organize, and many don’t even speak English.

Your notice states “The purpose of the Pre-filing process is to encourage early involvement of interested
stakeholders and to identify and resolve issues before an application is filed with the FERC.” NY/NJ Baykeeper
fails to understand how FERC can expect helpful input as envisioned by the National Environmental Policy Act
20100729-4004 FERC PDF (Unofficial) 07/29/2010

if it has such unrealistic expectations from a startlingly short scoping period. I fear that the timeline that you’ve
laid out for the scoping process is so short as to not only be a poor policy decision, but to genuinely raise due
process concerns.

I ask that you reconsider your scoping timeline, and extend it sufficiently to allow interested citizens to
understand and process the proposal, learn what it means to them, and respond to FERC in a considered and
helpful fashion.

I hope that FERC will take these comments seriously and adopt a timeline in better accord with the purpose of
your announcement.

Sincerely,

Christopher Len
Staff Attorney
NY/NJ Baykeeper

NY/NJ BAYKEEPER Page 2

20100729-4004 FERC PDF (Unofficial) 07/29/2010

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