The relatively small scope of three planned capacity expansions to Tennessee Gas Pipeline Co.’s (TGP) 300 Line in Northeast Pennsylvania hasn’t stopped green groups from challenging FERC’s environmental review of the projects.
In a motion filed Thursday with the Federal Energy Regulatory Commission, the Allegheny Defense Project, the Appalachian Mountain Advocates and Damascus Citizens for Sustainability argued that TGP’s proposed Susquehanna West (see Daily GPI, April 10, 2015), Triad Expansion (see Daily GPI, June 19, 2015) and Orion (see Daily GPI, Oct. 9, 2015) projects should be considered under one environmental review and had been improperly segmented.
The filing sought to counter TGP’s justification for why FERC should review the projects separately, namely that they serve different customers at different delivery points, would flow in different directions and would involve distinct looping construction at separate segments of the 300 Line.
The groups argued that the projects are connected since they “involve similar construction activities along the same mainline in five adjacent counties.”
Emboldened by a 2014 court ruling that FERC had mishandled its environmental review of TGP’s Northeast Upgrade Project (see Daily GPI, June 6, 2014), green groups have pursued the improper segmentation argument in an effort to force FERC to conduct broader cumulative environmental analyses of proposed natural gas projects. FERC rules call for a full lengthy and expensive environmental impact statement for large projects, while smaller projects require a much abbreviated environmental assessment.
In Thursday’s filing, the groups also wrote that “just because the projects have different shippers and serve different markets does not mean they are not connected actions. FERC made this precise argument in its order denying rehearing on the Northeast Upgrade Project. Again, this was squarely rejected by the court” in the 2014 case.
The temporal overlap of segmented projects has been another component of debates over FERC’s segmentation of its environmental review process. FERC recently pointed to the separate timelines of a series of Transcontinental Pipe Line Co. expansions to defend its decision to opt for separate reviews (see Daily GPI, March 10).
The groups behind Thursday’s filing latched onto this distinction to attack TGP’s proposed expansions. They wrote that “it is noteworthy that Tennessee does not even attempt to argue that the projects do not have ‘common timing.’ In light of the ‘importance’ that” the 2014 improper segmentation ruling placed on the timing of the projects in that case, “the only rationale for considering separately the three projects at issue here is to, once again, avoid a finding of significance.”
For its part, TGP wrote in a May 3 filing that the green groups attempting to challenge a favorable environmental assessment of the Susquehanna West project were “blatant in their attempt to hijack the FERC regulatory process and force their ‘keep it in the ground’ agenda; an agenda that fails to come to grips with the reality that the northeastern United States has a critical need for a lower-cost, cleaner-burning, dependable source of energy.”
TGP filed with FERC for all three projects last year.
Susquehanna West would add 145,000 Dth/d of capacity and involve 8.2 miles of new 36-inch pipeline looping in Tioga County, PA. The Triad Expansion would add 180,000 Dth/d and involve roughly 7 miles of 36-inch looping in Susquehanna County, PA. The Orion Project would involve 13 miles of looping in Pike and Wayne counties, PA, and modifications to a compressor station in Pike County. Orion would add 135,000 Dth/d to TGP’s system.
Environmental groups pushing a “keep it in the ground” energy policy have aggressively challenged new natural gas pipeline infrastructure projects under FERC’s review (see Daily GPI, Dec. 1, 2015), contributing to delays or cancellations of larger and higher-profile greenfield projects in the Northeast, like the Constitution Pipeline (see Daily GPI, May 5) and TGP’s Northeast Energy Direct (see Daily GPI, April 21).