Stop the hazardous liquids pipeline

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KFTC Sign-On Letter Re: Kinder Morgan Hazardous Liquids Pipeline

Federal Energy Regulatory Commission
Office of the Secretary
888 First Street, N.E.
Washington, DC 20426

Re: Docket Number CP15-88-000; Tennessee Gas Pipeline Company’s Proposed Abandonment and Capacity Restoration Project. 

Dear Members of the Commission,

We understand that Kinder Morgan’s request to FERC is in regard to the abandonment of natural gas service in the designated pipeline, and that the Commission considers its authority to be limited to the question of abandonment. We disagree and believe strongly that FERC should not wash its hands of the announced future use of the pipeline for the transport of hazardous liquids in making decisions, particularly in light of one of your primary purposes to “Promote the development of safe, reliable and efficient energy infrastructure that serves the public interest.”

The Kinder Morgan pipeline is not safe for its intended re-purposed use. The age of the pipe in the ground; its route through some significant karst areas in Kentucky; the manufacturing methods, welding practices and exterior protective coatings used decades ago that are now considered obsolete; the flow reversal; the product change from gas to a liquid; the volume and pressure proposed; and the company’s own safety record all point to this proposal being neither safe nor in the public interest.

Natural gas seeps or leaks, even small ones, that currently go undetected because of the dissipatory nature of methane may become major problems when the product escaping is natural gas liquids. NGLs will not dissipate into the atmosphere, and a portion will get into the soil and likely the groundwater. Experience with even small leaks (Ivel, Kentucky 2004; Parachute Creek, Colorado 2013) informs us that the risks are significant, cleanup extensive and expensive, with ongoing health consequences likely.

Although the company claims some testing of the pipeline will be done for integrity and suitability, such testing provides only a view at a given point in time, which is insufficient for a pipeline that is decades old and soon to be subject to pressure and performance for which it was not built. The public needs and deserves better protection.

We also oppose the company’s request for an expedited process:

• some landowners whose property hosts the TGP are only just hearing about proposal;
• many other affected landowners and residents have not yet received notification, either through the company or some other local process;
• decisions should be community decisions and many communities are only beginning to learn about the proposal; few details have been provided to local officials, and though considerable information has been filed with FERC, the availability of this information is not necessarily known or easily accessible by all parties who have an interest in the outcome;
• this is a significant project in its nature and scope, even on a national level, and needs a deliberate and thoughtful process. 

For these reasons and others, please deny the request for an expedited process and extend the public comment period for a minimum of 60 days. We also ask that the Commission hold several public hearings about this application at convenient locations in Kentucky along the route of the pipeline.

In fact, the reasons are numerous for denying Kinder Morgan’s request for abandonment based on its intended re-purposed use, which is neither safe nor in the public interest.

Given the possibility that the Commission may approve Kinder Morgan’s request, we ask that a blanket abandonment in place not be granted. The existing pipeline – even with the product it is currently carrying – is dangerously close to some residences, popular business districts, major transportation routes, schools and urban areas. Public safety concerns dictate that switching to a product that is more dangerous by an exponential factor also should require re-routing the pipeline to safer distances.

We ask that any home or business owner, school board or local governmental unit with a public facility within 1000 feet of the re-purposed pipeline (or a greater distance determined by the Commissions) be allowed to request and be granted a re-routing of the pipeline to a safe distance (given studies by PHMSA, a distance of 2000 to 5000 feet would not be unreasonable). The Commission could deny abandonment in place in these areas and require removal of the pipeline.

Finally, the company is indicating that it plans significant disturbance of land and water resources for the purposes building compressor stations, installing new pipeline for the shifting of natural gas service to other lines, and for “re-tooling” along various lengths of the pipeline. This activity is of such magnitude that a comprehensive Environmental Impact Study is called for that examines direct and indirect impacts as well as threats to the three places where the pipeline crosses special use designated waters, threats to waters used as a public drinking water source, and threats to the Green River, one of the most biologically diverse in the nation.

Thank you for your careful consideration of these concerns, and the many others expressed by Kentuckians.

Dana Beasley Brown, KFTC Chairperson

Carl Shoupe; Elizabeth Sanders, Tanya Torp and Suzanne Tallichet
KFTC Executive Committee members

NOTE: We are no longer submitting new signatures to FERC for the above letter. However, if you still want to complete the form below we'll add you to the list for receving occasional updates. Thanks.