Action Alert! Help Stop The Tennessee Gas Pipeline!

Kinder Morgan, an oil and gas company, intends to use a 70 year old pipeline that runs through central Kentucky to eventually carry natural gas liquids (NGLs) through Kentucky.  This 964 mile long pipeline is known as the Tennessee Gas Pipeline.

km-pipeline

This project is officially titled “Abandonment and Capacity Restoration Project”.  Currently, the pipeline ships natural gas from the Gulf to the north.  With all the fracking going on in the north, Kinder Morgan now wants to send its product in the opposite direction (north to south) and the product coming from the north through the same pipeline will be NGLs.

What are Natural Gas Liquids?

NGLs, for short, are a mixture of several different inert gases.  They include ethane, butane, and isobutane, among others.  NGLs are NOT Natural Gas but rather are a byproduct of fracking.  These are heavier than natural gas and would put greater pressure on that old pipeline.  Worse still, they do not dissipate when they leak and they are highly volatile, so they are much more dangerous than natural gas.

When NGLs leak, about 85% will turn into an odorless, colorless and highly flammable vapor once exposed to air, settling in valleys, creeks, rivers and other low points.   Vapors can be ignited by heat, spark or flame, with the potential to explode from a small spark.   The other 15% of an NGL leak remains a liquid and may contaminate the soil and water with chemicals like benzene, known to be a human carcinogen.  Kinder Morgan has not disclosed information that will allow the public, county government, or first responders to understand the risks of carrying NGLs beneath our homes and to plan accordingly.km-pipeline-2

Your comments matter!

This pipeline will begin with shipping 150,000 barrels of NGLs per day and can increase that amount to 450,000 per day.  Leaks, spills and potential explosions like the recent one in Birmingham Alabama (that was a gas pipeline, not NGL) would be dangerous, if not catastrophic, should they happen in a populated area, or near a water source.

On Nov. 2, the Federal Energy Regulatory Commission (“FERC”) issued an Environmental Assessment (“EA”) of the project and decided that assessment was sufficient to review the project’s potential impacts and risks.

FERC has decided that the EA alone is enough because it does not consider the conversion of the pipeline to run NGLs as a “foreseeable action” even though the Tennessee Gas Pipeline has planned this project for nearly two years.  If there is intent to use the pipeline to transport NGLs, the conversion of the pipeline to run NGLs is a “foreseeable action”. 

The conversion of the pipeline to run NGLs is more than just “foreseeable”.  For a more thorough review, FERC needs to conduct the next step: an Environmental Impact Statement (“EIS”).  Your comments can make that happen.

If FERC doesn’t get enough comments from concerned people, it won’t take any future action and the pipeline project can move forward regardless of the risks.  Please write to FERC. 

Deadline for comments: December 2, 2016. 

Where do I send my comments? 

You’ll submit them online to the Federal Energy Regulatory Commission.  You can use the summary below as a guide or submit your own comments in the form, or register and submit your comments in the format you want.

Don’t forget the docket number!

Include EA Docket # CP15-88-000 right at the top.  FERC may not read or process your comments if you don’t label them with the docket # for this project.

If you prefer paper and post, you can mail your comments to:

Kimberly Bose, Secretary, FERC, 888 First Street NE, Room 1A, Washington DC 20426

Comment guideline

These comments are regarding Docket Number CP15-88-000, the Kinder Morgan “Abandonment and Capacity Restoration Project”.

I, (your name), live in (name of city or community) and I am writing to urge the Federal Energy Regulatory Commission (“FERC”) to develop a full Environmental Impact Statement (“EIS”) that includes thorough review of both the environmental effects of the abandonment and the subsequent use of the pipeline for transporting NGLs.

If you live near the pipeline or your kids attend school near the pipeline, please make this fact known.  Personalize the comment and tell your story! 

I wholeheartedly disagree with FERC’s findings in the Environmental Assessment (“EA”) that abandoning the pipeline “would not constitute a major federal action significantly affecting the quality of the human environment.”  The intent of Kinder Morgan to “abandon” this pipeline in place so that it can be converted is clear.  Therefore the conversion and repurposing of the pipeline to transport natural gas liquids (NGLs) is foreseeable.  The dangers of converting this 70 year old pipeline to carry a much more dangerous and heavy substance is also clear.

FERC must follow the law and should develop a full EIS that includes a thorough review of the environmental effects of the pipeline abandonment and its conversion to transport NGLs.  The EIS should evaluate the risks posed to land and water resources from NGL spills and leaks; groundwater in particular because of Kentucky’s unique KARST system.  Alternatives to approving abandonment of the pipeline in place, including mandating removal of the abandoned line, must be evaluated.

When Natural Gas Liquids leak, about 85% will turn into an odorless, colorless and highly flammable vapor once they hit the air, settling in valleys, creeks, rivers and other low points.  Vapors can be ignited by heat, spark or flame, with an explosion potential from a small spark.  The other 15% of an NGL leak remains a liquid and may contaminate the soil and water with

chemicals like benzene, known to be a human carcinogen.  Therefore, the EIS should also evaluate impacts on public safety and public health associated with both catastrophic and small leaks and spills.

As a concerned citizen of Kentucky, I urge FERC to develop a full EIS.  Thank you for the opportunity to submit this comment.