New Jersey Environmental AttorneyI am a resident of Delaware Township, Hunterdon County, New Jersey, and I oppose the PennEast Pipeline.  I oppose the application and additional submissions submitted by PennEast.

The impacts of this pipeline, both short and long term, vastly outweigh any benefits.  The pipeline is mapped through preserved and conserved farmland, woodlands, and natural lands, funded with local, state, and federal dollars.  In addition to such agricultural preservation and conservation, local zoning initiatives and New Jersey state law have sought to preserve the rural character of our lands, our natural resources, and our communities.

photodune-4205541-farm-sThese lands serve as migration corridors for wildlife, habitats for listed species, open space promoting numerous values including aesthetic, historic landscapes to preserve our heritage and culture, working farms to support local agricultural and local sustainability, soil conservation plans which do not allow the impacts a pipeline will cause, organic farming designations, stream and wetlands which serve as habitat and promote water quality and reduce flood impacts, water bodies with high resource value, and numerous unmapped tributaries which are not indicated on FERC mapping.  The pipeline will impact each and every resource for which a report must be written in the EIS process, as is evidenced by the work of many people and organizations which have submitted knowledgeable and expert testimony.  The individual and cumulative impacts cannot be adequately mitigated.

New Jersey Farmland AssessmentYet another perspective is that the pipeline will impact our planning.  We have planned our community.  We have planned open space, agriculturally preserved farms, environmental conservation, residential development, preservation of historic districts, and similar.  We have fought for it, funded it with tax dollars, supported and funded conservation organizations that hold easements, endorsed programs that support these initiatives with our votes and our dollars.  Now a pipeline supporting private corporate profit, exports, and an archaic procedure for advancing natural gas threatens preemption in a manner that is unconstitutional, unjust, and an insult to our self determination.  The formulas for “just compensation” make a mockery of what the value of such a “government taking” actually is.

The segmentations of FERC’s review is extremely problematic.  This segmentation occurs not only geographically – with the overall plan to lay pipelines broken into separate segments, under new LLC partnerships made up of the usual suspects.  But the segmentation also occurs over time.  What are the long term plans of the parent companies, and why aren’t we forcing disclosure and review of that?  The segmentation also occurs within government, with one agency promoting natural gas for the purpose of making energy affordable, at the expense of any holistic vision (i.e. FERC).  Another agency reviews sustainable energy policies, and another oversees pipeline safety.  A handful oversee national security, yet with what coordination?   And in the end, the pipelines are entrusted to private, profit driven corporations who don’t live and work, here.

Transco Pipeline, Lebanon

Transco Pipeline, Lebanon

National security, long term energy, and agricultural sustainability must preempt FERC’s outdated mandate and corporate greed.

Regarding national security, pipelines are explosive.  Numerous reports have identified natural gas pipelines as targets for physical and cyber terrorism.  Insider threats, which occur when personnel are recruited or planted within the pipeline companies or their contractors, combined with coordinated attacks, to cause “un-natural disaster,” energy disruptions, or death, are known threats.  It is easy to find reports on this.  Review “Keeping America’s Pipelines Safe and Secure: Key Issues for Congress,” by Paul W. Parfomak, March 13, 2012.  Look at the TSA “Pipeline Threat Assessment,” which notes Islamic extremist terrorist groups identifying pipeline attacks to damage our economy, national security, public health, and psychology.  These reports identify both cyberattacks to pipeline control systems as well as use of explosives to carry out terrorism on US soil.  Review the “Human Factor in Critical infrastructure Security: The Insider Threat,” by the Hazar Institute,

And these national security risks are in addition to the issue of our local emergency personnel, equipment, roads, and training being inadequate to address physical threats and accidents occurring locally.

These significant and alarming threats to our safety and environment must be considered in the evaluation of Necessity and Public Convenience.  The segmentation of FERCs review lacks any intellectual integrity when considering the bigger pictures.  It is a joke, protective of corporations at the expense of the due process, self determination, and protection of American landowner’s and communities.

Symbol of environmental protectionWe need safe, sustainable energy sources.  We need a complete overhaul of our programs for evaluating and permitting energy infrastructure.  We do not need hydraulic fracturing and natural gas exports and thousands of miles of explosive pipelines.  More progressive alternatives exist for energy, our economy, our safety, and our right to plan our own communities.

This Pipeline must be denied.  Not in our back yard. Not in anyone’s.