Sep 162014

Pretty much right on its announced schedule, Kinder Morgan subsidiary Tennessee Gas Pipeline Company (TGP) filed an application with the Federal Energy Regulatory Commission (FERC) on September 15, requesting permission to use FERC’s pre-filing procedure on its proposed Northeast Energy Direct Project. The Northeast Energy Direct natural gas pipeline would run from a pipeline distribution center in Wright, New York through 45 northern Massachusetts towns, including Groton and its neighboring towns, to anther pipeline terminal in Dracut, Massachusetts.

Kinder Morgan announced the application in a series of email to media and officials in affected towns and states this morning. The 14-page letter outlines the pipeline proposal in greater depth than the company has before, and outlines the next steps TGP will take as it moves forward to seek state and US approval of the project. FERC had not posted the application to its website when this story was published, but you can download a copy here. Towns and landowners through which the pipeline may pass received initial notifications about the pipeline early this year, in the form of requests to survey land. Organized resistance started across the state, and has continued to increase over the course of the year, now involving state elected officials and departments.

“The profiling is really the start … It really begins the formal, yearlong process of introduction of the project and the public scoping of the project. Coming soon will be resource reports … which talk about the specific route of the project, they talk about alternative routes, they talk about the purpose and need of the project — that will come next, probably in October,” according to Alan Fore, Kinder Morgan Director of Public Affairs. Kinder Morgan spokesmen expected FERC approval of its application for pre-filing within 10-20 days.

A few of the highlights of the letter of application include:

  • Acknowledgment that some potential end customer of gas transported by the pipeline may be liquefied natural gas exporters, although none have signed contracts for gas transportation services yet.
  • Points out that natural gas from the proposed pipeline “may” contribute to lower electrical rates in the region
  • A statement that increasing natural gas supplies can encourage renewable resource development such as solar and wind, because natural gas provides a backup during periods when renewables are not generating.
  • Presents the option of using a 30″ pipeline, rather than the 36″ that was presented in most public discussions and town meetings
  • Announcement of a series of “Open House” events sponsored by Kinder Morgan in affected towns. Kinder Morgan spokesman Alan Fore said an Open House in or near Groton is planned for November, 2014, but location and date have not been set yet.

TGP tells FERC its reasons for requesting the pre-filing procedure are:

“Tennessee requests that the Commission grant Tennessee’s request to use the pre-filing process for its Project for two primary reasons. First, implementing the pre-filing process will provide early receipt of stakeholder and participating agency input, thus establishing and maintaining constructive stakeholder relations. Second, early identification and consideration of issues will result in the most expedient processing of Tennessee’s certificate application for the Project and the development of a supporting record of decision. Early review of environmental documentation by Commission staff and its consultants as well as its participation in Tennessee’s public outreach effort will facilitate the development of a complete record, including a well-documented environmental document as required by NEPA and the Commission’s regulations in support of a finding by the Commission that the Project is required by the present or future public convenience and necessity and the issuance of a certificate at the earliest practicable time.”

One particular statement by TGP in the application drew some derision from area elected officials involved in monitoring — or trying to stop — the pipeline project:

Consistent open and forthright communications with stakeholders throughout the NED Project area is a priority for Tennessee. Beginning in early 2014, Tennessee has held numerous meetings and distributed information through the Project area to keep stakeholders updated and receive feedback on the proposed Project.

Groton selectmen, particularly Chair Josh Degen and Jack Petropoulos have been critical of Kinder Morgan’s lack of response to enquiries from the Board of Selectmen and the BoS’s Pipeline Working Group, the advisory committee that is charged with monitoring Kinder Morgan’s application process. Degen pointed out recently that the town is still waiting on information that was requested in public information sessions with Kinder Morgan in June — none has been received, he said, although Fore said from the stage that the town and several residents would receive answers to their questions.

FERC EA Pre-Filing Environmental Review Process Flow Chart

FERC’s EA Pre-Filing Environmental Review Procedure

Other residents and officials were also quick to respond to the application. The regional Stop the Pipeline “group of concerned citizens” issued a news release in response to the application for pre-filing just a few hours after Kinder Morgan released it.

“Kinder Morgan’s pre-filing for the Northeast Energy Direct project (Docket # PF14-22) was anticipated as they have been saying for months they would do so in September,” Cathy Kristofferson from Stop the Pipeline said. “This will not deter us from our stated mission to stop this pipeline by proving that increased natural gas infrastructure is unnecessary, as studies have already shown. We continue to believe that we can’t rush into a dependence on more natural gas; we must study all the options before allowing projects that will permanently impact farms, forests, wetlands and countless acres of private property.”

Dennis Eklof, who is on both Groton’s Pipeline Working Group and the inter-town regional group that’s studying the project wrote in an email: “In general it is precisely what I expected. A couple of thing that will be of particular interest to your readers:

  • While KM makes all kinds of statements about relieving gas shortages, etc., when it comes down to the impacts on customers in New England they say the project MAY result in lower gas and power prices and MAY improve NE industrial competitiveness
  • They specifically cite export opportunities to Canada and list LNG exports as one of the potential Canadian customers. In other words, the pipeline is much larger than they think the market is in New England.
  • They make an interesting claim that more gas will promote renewables as it will fuel the necessary backup gas-fired power. I have seen no analysis to support this claim. I expect it to do just the opposite.”

  • If approved by FERC, the pre-filing process would take about a year to complete. It includes numerous opportunities for public feedback and extensive environmental impact investigations and statements. The pre-filing application presents this timeline pictured below, which is more detailed than others released by the company.

    Update: The Massachusetts Executive Office of Energy and Environmental Affairs jumped into the fray quickly too, with a letter to FERC from Secretary Maeve Bartlett, in which she wrote:

    ” … the interests of the Commonwealth include, but are not limited to:

    1. Ensuring a full analysis of the need for the project in Massachusetts and regionally;
    2. Ensuring a full environmental review and consideration of environmental permitting requirements for the proposal; and
    3. Ensuring a full examination of the proposed routing and seeking ways to avoid or minimize the impacts to important natural resources managed by the Commonwealth through its land management and wildlife agencies, as well as other property dedicated to conservation, farming and forestry purposes.

    Northeast Energy Direct Project Timeline, from TGP's September 2014 Pre-Filing Application

    Northeast Energy Direct Project Timeline, from TGP’s September 2014 Pre-Filing Application

    The FERC “Citizen’s Guide” to natural gas projects such as the Northeast Energy Direct proposal is available for download.