Local environmental advocate and Heartwood board member, Matt Peters, has written and delivered this powerful comment piece to the PA Department of Environmental Protection to register his deep concerns about the construction of the Shell Falcon pipeline. Matt also invites everybody to the 20th Annual Heartwood Forest Council, “Edge Effects.” Details here: https://heartwood.org/2018-forest-council/ .
TAKE ACTION: If Matt’s letter inspires you to submit your own comment, please follow our quick guidance here: https://nopetropa.wordpress.com/2018/01/26/take-action-contact-the-pa-dep-asap/.
Public Comments to PA DEP
6 Feb 2018
Re: FALCON Pipeline, PA Bulletin #E02-1773
Dear Protectors of the Environment Department:
I am a resident of Pittsburgh, PA, taxpayer and homeowner. I’m a card-carrying member of the Sierra Club, and I am a member of Heartwood and serve on their board. I live in Hazelwood, that last deep loop of the Mon River Valley between Braddock and The Point, where the air smells just like Clairton. I like to hike in Raccoon Creek State Park among other public forests, and try to get out every so often to one of the county or state parks nearby to hike, where I can watch birds, find peace and connection and renewal among the trees. I have a number of concerns about this proposed pipeline to share with you, wherein I will urge you to deny Royal Dutch Shell the permit application for this pipeline.
I insist on a 30-day extension of the public comment period, during which time public hearings are held where the Public has the opportunity to catch up on the years of planning and collaboration between DEP and Shell. The current 30-day comment period is inadequate, as the first 25% of it was consumed with actually getting the information… although DEP duly noted the beginning of the comment period in the PA Bulletin on January 20, the actual information did not become publicly available until a week later. The date of publication in the PA Bulletin was in fact a Friday, which meant that for the first two days of the public comment period the office was closed. This delay in availability of the information upon which to comment, or even the opportunity to get any questions answered by phone, renders this first 30 day period invalid, and an extension must be given. Public hearings must be held. This is an important decision that merits the most careful consideration.
This pipeline would negatively impact the Ambridge Reservoir, a uniquely pristine and vitally necessary source of drinking water for thousands of people. This will also pollute the Ohio River, source of drinking water for estimated millions of Americans. Every stream, wetland and waterway it crosses pollutes the water for Pennsylvania’s wildlife, some of which ends up in the food supply of American Citizens.
The Falcon pipeline route and its associated subsequent maintenance (yearly mowing and herbicide spraying, runoff, helicopter line inspections, etc.) would have a persistent and accumulating negative impact on the headwater source streams in two of four feeder systems in the Ambridge Reservoir, guaranteeing steady doses of pollution from a number of point-source stream crossings. These headwater source areas are the most sensitive and most fragile part of the watershed, and should be protected to the fullest degree in their entirety at every opportunity.
Of particular concern is the impacts on reptiles and amphibians, already in precipitous decline in our region, insult on top of injury from previous decades (centuries!) of historical industrial activities (Carnegie et al, 1856). Migratory songbirds, returning every spring from central and south America, depend on these zones for nesting, feeding, and breeding habitat. These forests should be carefully examined for populations of rare or unusual plant species, such as the endangered small-whorled Pogonia. Other plant communities of note are those that might include ginseng or goldenseal, which grow best in these forest soils. The pipeline would forever destroy these treasures of the public trust, an irreparable commitment that will prove to be a mistake.
This pipeline would cross the Ohio River, as well as many numerous stream crossings that feed directly into the Ohio. The DEP must consider the impact of this pipeline on populations of the freshwater mussels found in these waters, many of which are endangered and are specially protected under Federal law (or would be, if Trump hadn’t put Scott Pruitt in office!).
The pipeline corridor must be carefully surveyed for maternity-roost trees for Bats, and these trees must be protected! Bats are incredibly faithful to their summer roosting spots, returning to the same shingle of bark or the same church-attic rafter year after year to raise their young. To disturb the forests around these roost-sites contributes to the precipitous decline of bats which are already suffering from White-Nose Syndrome! The endangered species Indiana Bat (Myotis sodalis) is known to occur in the vicinity.
The pipeline corridor must be surveyed for populations of a rare species of firefly: Photinus carolinus, the Synchronous Firefly. While all firefly species appear to be in decline across their regions (there are sixteen species documented in the Allegheny National Forest Faust et al USFS 2011), two in particular are quite rare, of which P.carolinus was once thought to be found only in one location, far south in the alpine mountain habitat of western North Carolina, an area which is now protected as the Great Smoky Mountains International Biodiversity Reserve. The discovery of the Synchronous Firefly in PA in 2010, and confirmation by the biological survey a year later, is a remarkable discovery for science, and it appears that there may be other places where these amazing insects occur in our area. The synchronous firefly does indeed flash synchronously, in deep-forest habitat where complete darkness is essential, in an amazing display that has become celebrated each year by the Pennsylvania Firefly Festival, held in July when their brief display is at its peak. Of all the some three-thousand species of firefly throughout the world, there is only one other that displays synchronously, and that is found in the tropical forests of southeast Asia where it draws thousands of tourists each year.
The disturbance along the miles of pipeline corridor is how invasive plant species get their opportunity to spread. Reliance on the use of toxic herbicides in an effort to control these species merely result in the breeding of an invasive plant that is resistant or adapted to its use.
The Ohio River is listed as one of the most polluted waterways in North America. It is also listed among the most threatened by additional pollution, as results from the expansion of the oil and gas industry in our region. Impacts directly resultant from This Pipeline must be considered in the context of these cumulative impacts.
The need for clean water and clean air far outweighs the need for Royal Dutch Shell to meet their profit goals (Spock, 1982). The DEP must place the need for clean air and clean water as its highest priority for consideration, right along with the health of the human population. DEP should consult with county health departments in all affected counties in SW PA, and consult with state agencies in OH and WV. The toxins associated with the petrochemical industry at every stage: extraction, refinement, distribution, and disposal, to say nothing of its actual combustion in its intended engine, are having measurable and demonstrably negative effects on human health, as shown in increased incidences of cancer, respiratory diseases and immune disorders, all linked to industrial pollution. Fish, already under various “eating advisements” from this Agency, limiting the amount that it is safe to eat, are starting to develop hormonal abnormalities, and radiation has been detected in river sediments where frack water is “treated” and disposed. DEP must include these contextual, cumulative facts in their consideration of this permit. There can be no conclusion but to deny the application to build this pipeline.
Global warming is real (Gore, 1990). It is a thing that is happening now, it is an accepted fact beyond reasonable dispute. The main uncertainty in the most up-to-date science on the subject, seems to be the severity of consequences resultant from climate change. This pipeline will directly and immediately contribute to these problems, with inevitable fugitive leaks of pressurized ethane possible if not likely (and with time, inevitably) at every weld and junction, every leaky valve and accidental release of the gas at points of transfer, plus all the incidental uses of fossil fuels associated with its construction and maintenance, all contribute in measurable and significant amounts to the already beyond unacceptable problem of global climate change. This permit must be denied.
The DEP is urged to consider a “reasonable range of alternatives” as presented in the federal NEPA regulations; even though no such requirement exists neither does legislative proscription prevent the agency from doing so at the state level. Moral responsibility and good governance would support an act of doing so. And when it comes to making disposable plastic from fossil fuels there are a plethora of viable alternatives to be considered. In the Commonwealth of Pennsylvania, our biggest economic sector by far, is agriculture. This pipeline is a direct assault on our food supply, turning valuable farmland into an ecologically sterile explosion threat zone. In the past two years, our Governor Tom Wolf has signed legislation that allows for a valuable and versatile crop that has been unavailable to farmers for the better part of a century, Industrial Hemp. The opportunities to produce plastic from the oil-rich hemp seeds is well documented and well known (Ford 1939-41), and although Royal Dutch Shell has recently rejected the opportunity to continue to explore algae as a possible source of biofuels and bioplastics, their competitors are continuing to do so and they would be just as willing to set up shop here in our bioregion and provide greener jobs, safer jobs. The DEP must recognize that to deny this permit is an essential step, your moral imperative to help move our society towards this choice for green, sustainable jobs.
The second largest sector of the economy in PA is outdoor tourism and recreation (Muir, 1838-1914)(US Bureau of Labor Stats 2017). This pipeline will impact the immensely popular Raccoon Creek State Park, directly and indirectly, by degrading the approach for the park visitor with unsightly infrastructure and increased truck traffic. The landscape-scale transformation of the region into an industrial throwback to our polluted fossil-fuel past is inconsistent with supporting the two largest economic sectors in our state. This Pipeline would impact That Park and pass through the numerous state game lands clustered in that vicinity. What if a hunter accidentally shoots the pipeline! I would say “God Forbid!” but you are not God. However, it is in your power to forbid, and it is good judgement to do so in this case. I urge you to deny this permit.
These companies have not proven to be responsible, well-behaved, “good corporate neighbors.” Shell will always be known to me for their role in the execution of Ken Saro-Wiwa, a Nigerian activist who was executed in November 1995 (https://en.wikipedia.org/wiki/Ken_Saro-Wiwa) and their record of pollution and callous destruction is well-documented. Shell is relentless as Exxon in their attempts to open the Arctic for drilling, and both those companies named are among the five now being sued by the City of New York for their role in causing climate change, much like how tobacco companies were sued 20 years ago for obfuscating the science on the dangers of cigarettes. The smaller companies and subcontractors are no better behaved than their corporate overlord. Recently the DEP was obliged to shut down operations of the Mariner 2 Pipeline, because of the reprehensible safety record of the operating company. Renegade dumping of radioactive frackwater goes unreported at far too many remote and isolated stream crossings. The only thing more alarming than the explosive expansion of the petrochemical industry in our region, is the actual explosions! Pipelines exploding, well heads exploding, fires burning uncontrolled for days, planes rerouted, workers vaporized and killed in an instant, these are real consequences that stem from the tiny action of your agency’s approval of these permits. I know folks are commenting with exact figures on the number of schools and day care centers are within so many yards of the pipeline corridor, the “blast zone” as it were. This cannot be reasonably permitted to continue, in any way. This permit must be denied.
The landscape-scale transformation of our region, as threatened by this invasion of the petrochemical industry, will have a tremendous overall negative effect on the quality of life for residents all through the region. The pollution associated with this one Shell facility’s buildout, once completed, will equal or exceed the amount of pollution generated by an estimated 36,000 imaginary cars added to our roads. The city of Pittsburgh is investing taxpayer dollars and years of public planning to develop a Climate Action Plan, seeking to reduce carbon emissions and pollution; this permit for this pipeline is directly undermining that investment. Shell, with all their billions of dollars in tax breaks, should be denied this permit.
Thank you for considering my comments.
[email excluded for privacy]
Pittsburgh, PA 15207