Monday, November 23, 2015

New FERC Comments Needed by March 2016: Preliminary Information

Thank you, Coyne Gibson, for an extremely informative presentation this evening!


On or around Jan 4, 2015 FERC will publish the results of their EA, specifically addressing the 615 individual public comments and 4 motions to intervene.
We can expect one of the following three outcomes:

1. Worst case scenario: a finding of "no significant impact" (FONSI), meaning the Big Bend is in fact a wasteland that requires no further study in order for the pipeline project to proceed.
2. Medium case scenario: the EA will refer only to the "jurisdictional" facility (the 1093' of pipe as it crosses the border).
3. Best case scenario: An EIS (full-blown Environmental Impact Study) could be required for only the jurisdictional facility OR – super best case – for the entire 143 mile route.

Between now and March, as many of us as possible will need to file comments with the FERC specifically addressing the notion of IMPERMISSIBLE SEGMENTATION.* We will be posting a template/tutorial with more info soon. Meanwhile, a few points to ponder:

1. In the case of the proposed Trans-Pecos Pipeline we will need to impress upon the FERC that the 1093-foot border crossing (the claimed jurisdictional facility) does not function in isolation, and in fact has ZERO value without the connected "intrastate" (this classification is wholly inaccurate...more on this in a moment...) pipelines on the Texas side of the border/connections to Mexico's new and existing pipeline infrastructure south of the border. The consortium that proposed these pipelines – and our government, via the FERC – would like for us to believe that the 1093-foot segment of pipe has "full utility in isolation", and that the remaining connected pipelines are of no significance.

2. RE: the "intrastate" classification: the gas that comes into the Waha Hub near Coyanosa arrives from OTHER STATES such as Oklahoma and Louisiana where it commingles with gas derived in Texas. There is no way to distinguish a molecule of gas from one state vs. that of another. See also a diagram contained in CFE's (Mexico's power company's) original request for proposals page 13 (image extracted from this document is attached as a jpg...those "10 initial interconnects" are pipes connecting with the line, presumably bringing in gas from other states).

3. This system of new pipelines of which the Trans Pecos is one would export 34 billion standard cubic feet of gas per day to Mexico. If all of the new power plants associated with this project were up and running (see map) and in operation 24 hours a day, 7 days a week (not typically the way power plants work), they would only be able to burn about 1/10 of this volume of gas.

4. We need to request that FERC comply with the National Environmental Policy Act. As part of this, they MUST consider alternatives. Among the alternatives we need to strongly urge them to consider: a "NO ACTION DECISION" other words, this pipeline should not be built at all. Among points indicating that this is the best course of action: that the US is bearing the brunt of the environmental costs of extracting the gas through hydraulic fracturing (including depletion and contamination of groundwater supplies, air pollution, etc), that we currently flare off about 12% of all gas extracted, that Mexico has it's own resources, that the US is currently a net importer of gas, and that gas exports would drive up the domestic price of energy.

Another alternative: TAKE A DIFFERENT ROUTE. See Coyne's gorgeously presented case to the FERC in its entirety here. Map extracted from this document is attached.

More soon!

* "The pipeline boom has many in the environmental community on alert against a perennial bugbear NEPA veterans know well. In any infrastructural “system” built and maintained piecemeal, doubts and questions will necessarily arise over the measurable or practical units under “consideration” or construction at any one time."