(1) proper flood planning, and (2) leakage problems in karst terrain

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 [...]

Water Withdrawal

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.

Impacts of herbicides and how vegetation management in rights-of-way (ROWs) have many risks

This letter is in regard to the use and impacts of herbicides and how vegetation management in rights-of-way (ROWs) have many risks.

Why invasive species are made possible by CP and what it means?

The FEIS mentions the words invasive species (IS) one-hundred eighty-five times. What is an invasive species?

Is the Constitution Pipeline project reasonable and necessary?

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.

Williams fined $388,694 in 2013 — highest fines of any oil and gas company in the PA

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)

Sample letters in one file for easy download

Click this link for a PDF document with all the sample letters in one file for easy download.

Williams consistently & repeatedly violates Permit conditions

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 FEIS fails to adequately document wetland disruption

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.

DEC says it is working to preserve NY’s official State Fish, the brook trout

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 length of 467 football fields clear-cut along trout streams

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 [...]

CP threatens New York’s trout population

The Catskills is famous for its trout fishing. The brook trout is our State Fish. The proposed Constitution Pipeline (CP) would threaten New York’s trout population. According to an article from the DEC magazine Conservationist: [...]

Three 100-year floods in less than a decade!

The hilly regions of the Catskills and Southern Tier have experienced three 100-year floods in less than a decade. Scientists and lawmakers in New York, along with the NYDEC, acknowledge that the frequency of these [...]

CP would clear-cut 1,000 acres of forested land

The Constitution Pipeline (CP) would clear-cut 1,000 acres of forested land along its proposed route through four of New York’s most flood-prone counties. This would equal the loss of between 400,000 and 1.2 million trees, [...]

CP would permanently alter 554 waterbody banks in New York

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. [...]

All of these activities will cause runoff, making streams muddy, or turbid.

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 [...]

Pipeline Would Take 1.2 Million Trees

If the DEC were to approve the permits for the Constitution Pipeline, DEC would be giving a thumbs-up to clear-cutting 1,000 acres of forested land in New York. Assuming ten feet between each tree, this [...]

Disturbingly, no commitment has been made to use HDD in the final EIS for the project

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.

CP’s alteration of New York’s waterways would encourage and exacerbate flooding

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.

DEC protect NY water and safeguard our streams and rivers from flooding

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

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.

Sample DEC Comment | Floods Scour Stream Beds to Expose Pipe

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.

Trout Habitat Will Be Lost

When disturbed, the trout can possibly move to better habitat in cooler streams with less sediment bed load, but if the oxygen sensitive macroinvertebrates such as the mayflies, stoneflies, caddisflies and others are pressured, they [...]

Sample DEC comment on Bird Impacts

The construction and operation of the Constitution Pipeline will pose dangers to many bird species. Careful consideration should be taken before granting a 401 certificate for the project.

Sample DEC comment No need for the project

NYS has nothing to gain from this pipeline. It's pure environmental destruction, with the gas passing through to other places. NYC has all the gas it can distribute.

Sample DEC comment on Trout-Spawning

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.

Sample DEC comment on ecosystem impacts in (your town)

The Constitution Pipeline will cause unreasonable, uncontrolled and unnecessary damage to the natural resources within the town of _________________.

Sample DEC comment on Irreversible impacts from CP

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.

Sample DEC comment on flooding and tree cutting

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.

Sample DEC comment on 100 year floods

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.

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