FERC's Environmental Assessment of "Residences in the Vicinity" of the Dominion New Market Pipeline Borger Facility Missed 133 Homes

To: Members of the Dryden Town Board
From: Walter Hang
Re: Proposed Dominion New Market Pipeline Expansion of the Borger Compressor Station

Greetings:

I write to bring to your attention critical shortcomings in the Dominion New Market Pipeline Environmental Assessment conducted by the Federal Energy Regulatory Commission (FERC).

I believe that this improper Environmental Assessment warrants your urgent action. The inadequacies I will document for your review support my request that the Town of Dryden immediately write Governor Cuomo to require him to stop the proposed New Market Pipeline Project from proceeding at this time due to New York's inadequate regulatory oversight of this massive project.

FERC's Analysis of "Residences in the Vicinity" of the Borger Compressor Station Missed 133 Homes

As part of FERC's Environmental Assessment, a total of 12 residences were identified "in the vicinity" of the Borger Compressor Station. See PDF page 62: FERC Environmental Assessment

Toxics Targeting mapped a total of 133 additional residences in the area covered by FERC's analysis. These homes would be obvious to anyone who is familiar with that area of the Town of Dryden.

See: FERC's 10/15 Environmental Assessment Residences Survey Failed to Identify 133 Residences "in the vicinity" of the Borger Compressor Station

An Environmental Assessment that fails to identify more than 100 nearby homes which could be harmed by the proposed expansion of the Borger facility is unacceptable. This basic analysis is absolutely paramount to safeguarding local residents from catastrophic natural gas accidents and toxic pollution releases.

FERC's Environmental Assessment Failed to Address Existing Toxic Problems at the Borger Facility

FERC's Environmental Assessment did not include any baseline analysis of the Borger Compressor Station's existing contamination hazards which I later brought to public attention. As a result, FERC failed to assess how the proposed expansion of the Borger facility might exacerbate existing toxic problems which already exceed state clean up standards. This fundamental inadequacy warrants action by the Town of Dryden.

FERC's Environmental Assessment Included the Area South of Ellis Hollow Creek Road Just Granted Wetland and Waterbody Protection Variances

The "Limits of Study" area for the Borger Compressor Station clearly included a portion of the facility south of Ellis Hollow Creek Road. This area was also included in the "Approved Limits of Disturbance" for the New Market's Stormwater Pollution Prevention Plan. FERC just granted Dominion's request for wetland and waterbody protection variances for that area.

See PDF page 23: FERC Environmental Assessment

This same area south of Ellis Hollow Creek Road was also included in the Wetland Delineation and Waterbody Identification Study conducted for the proposed New Market Pipeline Project.

See page 21: Resource Report 2 - Water Use and Quality

The Town of Dryden's consultant stated that the New Market Pipeline Stormwater Pollution Prevention Plan was properly conducted even though this area south of Ellis Hollow Creek Road was not originally included in the proposed SPPP.

I believe, however, that the SPPP is fatally flawed and must be revoked because it failed to address that area of the proposed New Market Pipeline Project. If the consultant did not review the two other studies, he might not have known about this area's inexplicable exclusion from the SPPP.

This key area adjoins a protected wetland that drains into Cascadilla Creek, a major tributary to Cayuga Lake. The Town of Dryden wisely opposed the granting of wetland and waterbody protection variances for this area.

For all the reasons that I have documented, I reiterate my request that the Town of Dryden withdraw its approval of the SPPP.

Conclusion

I believe that FERC's shockingly inadequate Environmental Assessment and a factually incorrect SPPP for the proposed Dominion New Market Pipeline underscore why the Town of Dryden must immediately require Governor Cuomo to take all appropriate action to halt the proposed project at this time.

Until their fundamental shortcomings have been resolved, the inadequate Dominion New Market Pipeline Environmental Assessment and New Market SPPP must not be used for regulatory compliance purposes because they cannot protect the Town of Dryden and its residents.

For all these reasons, I respectfully implore the Town of Dryden to exercise its home rule authority to address these inadequate regulatory proceedings.

I trust that you will find my request to be self-explanatory, but please do not hesitate to contact me if you have any questions that I might be able to answer. Thank you for your consideration.

Very best regards,

Walter Hang

cc: Honorable Kimberly D. Bose
Honorable Barbara S. Lifton
Honorable Andrew M. Cuomo
Honorable Basil Seggos
Honorable Howard Zucker
Honorable Walter Mugdan