From a hydrologist with 40 years of professional experience: I have two concerns about the Constitution Pipeline: (1) proper flood planning, and (2) leakage problems in karst terrain. Click here to download the pdf of [...]
The withdrawal of millions of gallons of clean water from any stream, let alone two protected trout and trout-spawning streams, would be a violation of DEC §703.2 Narrative water quality standards for flow. The replacement of this formerly clean water after hydrostatic testing with water now contaminated with oil, drill cuttings, biocides and other unknown substances would be a violation of DEC §703.2 Narrative water quality standards for Taste-, color-, and odor-producing, toxic and other deleterious substances; for suspended, colloidal and settleable solids; and for oil and floating substances.
This letter is in regard to the use and impacts of herbicides and how vegetation management in rights-of-way (ROWs) have many risks.
The FEIS mentions the words invasive species (IS) one-hundred eighty-five times. What is an invasive species?
This letter is in regard whether or not the Constitution Pipeline project is reasonable and necessary, whether or not it will endanger the health, safety or welfare of the people of the State of New York, and whether or not it will cause unreasonable, uncontrolled or unnecessary damage to the natural resources of the state, including soil, forests, water, fish, shellfish, crustaceans, and aquatic and land related environment.
In Pennsylvania, Williams builds gathering and transport pipelines via three subsidiaries: Williams Field Services, Laurel Mountain Midstream, and Laser Northeast Gathering. Through these subsidiaries, The Pennsylvania Department of Environmental Protection (PADEP), fined Williams $388,694 in 2013 -- the highest fines of any oil and gas company in the state.(1)
According to a 2013 Compliance Report issued by the Pennsylvania Department of Environmental Protection (DEP), Williams, through three pipeline subsidiaries, was charged the most fines of any oil and gas company in the state. The [...]
The removal of wetlands, or their relocation to other areas, will increase the impact of future storm events. According to the DEC, a project must not cause unreasonable, uncontrolled or unnecessary damage to the natural resources of the state, including soil, forests, water, fish, shellfish, crustaceans, and aquatic and land-related environment.
According to the DEC website, “DEC is working to preserve” New York’s official State Fish, the brook trout.1 The proposed Constitution Pipeline (CP) would interfere with these efforts, not only by tearing across 45 trout [...]
The proposed Constitution Pipeline (CP) would threaten New York’s brook trout by clear-cutting 1,000 acres of forested land surrounding prime brook trout habitat. This deforestation would include permanent removal of vegetation and tree canopies on [...]
The proposed Constitution Pipeline (CP) would permanently alter 554 waterbody banks in New York—most of them creek-, stream- and riverbanks—by clear-cutting 100-foot-wide swaths of trees and vegetation leading up to and away from 277 waterbodies. [...]
The Constitution Pipeline (CP) would require the clear-cutting of 1,000 acres of forested land, including 100-foot-wide swaths leading up to and away from delicate streamside riparian zones. Riparian zones are extremely vulnerable to erosion if [...]
CP is proposed to cross 91 wetlands and 277 streams, no commitment whatsoever has been made to use HDD in the final EIS for the project. In fact, plans by CP became worse between the draft EIS and final EIS because the few crossings where HDD had been planned have now been changed to Direct Pipe. Direct Pipe is a cheaper, inferior trenchless technique involving shallow burial and more surface disturbance.
It is the DEC’s mandate to halt “alterations that will impair waters for their best usage.”3 CP’s alteration of New York’s waterways and surrounding trees and vegetation would encourage and exacerbate flooding, putting at risk the lives of everyone along the pipeline route and downstream.
An article in the December 2014 issue of the DEC’s own magazine, Conservationist, discusses the importance of stream equilibrium, or a stream’s ability to “pass water and sediment during small and large flood events, and then regain its natural shape.” The article, which addresses learning from past floods in New York how to better handle future ones, states: “stream sections can become unstable when human activity upsets that equilibrium and alters the stream’s ability to move its water and sediment effectively. When this happens, the stream can become a source of flooding for communities located along its banks.”
CP is using a 5-year storm event as the basis for its 401 Water Quality certificate despite the fact that the Southern Tier and Catskills have experienced three 100-year floods and many other extreme rainfall events in the past eight years.
The Southern Tier and Catskills have experienced several 100-year floods in the past decade. It’s widely acknowledged that extreme rain events are expected to continue in the area with increasing frequency.1 Future flooding is not a matter of if, but when.
Fish, especially baby trout, need a lot of dissolved oxygen (>7.0 mg/L) in their spawning streams. They also need clear cold water, and will not survive if the water is too turbid (muddy), or too warm. However, construction in clay soils on steep slopes will cause a turbid runoff lowering the amount of oxygen in the water and smothering trout eggs in silt.
The Constitution Pipeline will cause unreasonable, uncontrolled and unnecessary damage to the natural resources within the town of _________________.
Construction of the Constitution Pipeline clear-cut of hundreds of thousands of trees, the use of herbicides to maintain the clear-cut areas, the restrictions to our land, the noise and structural damage from blasting and jackhammers, the contamination of our village and town water and personal wells and water bodies from the blasting, the degradation of our water quality, and the additional paths this project will create for storm runoff.
Construction of the Constitution Pipeline violate Section 401 of the Clean Water Act and in particular, Tree Cutting Along Hillsides, Flooding and Sediment Deposition in relation to the Disturbance of the Bed or Banks of a Protected Stream or Other Watercourse.
In the joint application, the best management practices (BMPs), size of pipe flumes for stream crossings, and design of the required silt fences are based on engineering calculations of a 5-year storm event.1 CP considered 2-year, 5-year, and 10-year storm events, but is assuming a 5-year storm event as the basis for their 401 water quality certificate, and 4 related permits. There is no rational basis for this assumption.