This information is from our friends in Connecticut and includes sample testimony that you can use to submit your comments.
Comments are due this Friday, September 2. Please email your comments to Douglas.Hoskins@ct.gov. and include the WQC application number, WQC- 201509435, in the subject line.
DEEP will likely approve the water quality certification for Spectra's
fracked gas expansion project, Atlantic Bridge. This project is AIM 2.0.
We must submit hundreds of comments to force DEEP to notice that we
won't tolerate the environment destroying, fracked gas expansion
anymore. DEEP, along with utilities and politicians, are responsible for
Connecticut's terrible energy policy, which is literally forcing fracked
gas projects on other states to satisfy Iberdrola and Eversource. If all
of you send these comments to DEEP, they will get hundreds of letters,
and it will be very hard for them to ignore*.
Testimony and instructions are below and attached to this email. Please include the WQC application number in the subject line: WQC- 201509435. Submit by Sep. 2 to Douglas.Hoskins@ct.gov.*
I am writing regarding Application Number: WQC- 201509435, tentative
determination to approve a water quality certification for the Spectra
Energy/Algonquin Gas project Atlantic Bridge. I respectfully request
that DEEP deny this application.
There are concerns about the impact of fracked methane gas
infrastructure construction, such as enlarged pipeline and new meter
stations, on local watercourses and wetlands. There is evidence
suggesting that impacts to water do occur with methane gas construction
projects, despite DEEP’s requirement that companies use “best management
practices and notification of adverse impact”.
A few concerns are listed below:
-- Runoff during construction - When trees are removed and the ground
is torn up by construction equipment, stormwater carries silt, nutrients
and bacteria along with it into streams and lakes. Subsequently, less of
the rain infiltrates into the ground where it can be used by vegetation
or percolate down to recharge the groundwater.
-- Potential spills from equipment - Petroleum products from fuel
(gasoline and diesel), engine oil and hydraulic systems can be spilled
and pollute the groundwater or be carried by stormwater in lakes and
-- Loss of forest and riparian buffers - The loss of forest is
permanent. These right-of-ways are kept clear so they continue to
negatively impact infiltration because of the compaction do to
construction and maintenance. Removal of vegetation along streams allows
stormwater to directly enter lakes and streams without any biological
treatment that natural vegetation provides.
-- Change in hydrology - The way that water flows across the ground
surface and through the ground after the disturbance of constructing the
pipe can be dramatically changed. It may, for instance, act as a dam
that keeps water from recharging important wetland areas.
There are concerns about the project that extend beyond the impact on
ground water and surface water. Because the majority of Connecticut is
in a Moderate Drought, according to the United States Drought monitor,
and part of the state is in a Severe Drought, it is important to know
where Spectra/Algonquin Gas plans to withdraw water from for this
project. The following link shows which rivers in Connecticut have
historic low flows, which includes part of the Still River.
Issues like these led the New York State Department of Environmental
Conservation to deny a water quality certificate to the Constitution
Pipeline. John Ferguson, the agency’s chief permit administrator said in
an April 22, 2016 letter, “Under the project’s proposal, many of the
streams to be crossed present unique and sensitive ecological conditions
that may be significantly impacted by construction and jeopardize best
usages…. Impacts to these streams are exacerbated as the cumulative
negative effects of multiple crossings are added….”
The above is from
Although this application is for water quality certification, it bears
noting that DEEP is the regulatory agency that procures fracked natural
gas projects, potentially including Spectra’s Access Northeast, the next
stage of expansion on the Algonquin line following Atlantic Bridge. Some
CT residents wonder if it is a conflict of interest for the same agency
to procure the very projects it ultimately gives approvals for. It was
noted by the public that DEEP did not issue a 401 WQC permit to Kinder
Morgan for the CT Expansion project; that permit was automatically
approved when DEEP let the deadline pass without taking action. DEEP
shouldn’t abstain from the choice to protect our waters from unnecessary
Numerous sources have found that New England doesn’t need massively
enlarged gas pipeline, including the 2015 Massachusetts Attorney
General’s report. The following statistics from the U.S. EIA demonstrate
that the need for new pipeline has been hyped by energy companies. “In
2013, the six New England states consumed 889 billion cubic feet of
natural gas. The data also showed…an inflow capacity of 1709 billion
cubic feet….it just means that there was twice as much available as the
demand….” (M. Bellafiore, testimony to FERC, May 13, 2015). The need for
this project is questionable, but the harms that will be caused are
certain. Can DEEP honestly find that the damage to watercourses that
Atlantic Bridge will cause is in the interest of the public?
Connecticut residents, particularly those who live near construction
areas, are scared of Spectra’s poor safety record. Spectra is #7 on the
EPA list of the most highly fined companies.
Of all the New England states, only Connecticut approved channeling
public money from ratepayers to private energy corporations for their
expansion projects. However, it may be impossible for Spectra to build
this multi billion dollar project without more public subsidies than it
will get from Connecticut ratepayers, as happened recently with Kinder
Morgan’s Northeast Energy Direct project. The economics of this massive
construction project may make it unfeasible.
In view of current events in the U.S. related to the climate, the deaths
and destruction from floods and fires, and the Connecticut and New
England wide drought, it would make sense to encourage the growth of
renewable energy, such as wind and solar. Billion dollar fossil fuel
infrastructure projects such as Atlantic Bridge have the unfortunate
effect of locking us into years more of unneeded dirty fuel use. Now is
the time that the need for corporate profit be subordinated to the need
to protect the climate, and that we begin the necessary transition to a
100% renewable energy powered economy.
Your Town and State
The deadline to send comments is *Sep. 2, 2016.* Link to the public
Written comments on the application should be directed to Doug Hoskins,
Bureau of Water Protection & Land Reuse, Inland Water Resources
Division, Department of Energy and Environmental Protection, 79 Elm
Street, Hartford, CT 06106-5127, or may be submitted via electronic mail
to:*Douglas.Hoskins@ct.gov* no later than thirty (30) days from the
publication date of this notice.