`I write to encourage FERC to more fully consider the impacts of the proposed
`Transcontinental Gas Pipe Line Company, LLC (Transco) Regional Energy Access
`Expansion (REAE) project (docket number CP2194000) in terms of its significant
`climate impacts, its impacts to environmental justice communities, and the
`irreparable harm it will inflict upon Pennsylvaniaâs pristine streams,
`forests, and other natural resources. The Draft Environmental Impact Statement
`(DEIS) is woefully inadequate and fails to address the scope of negative effects
`that would result from this project.
`First, FERC admits that the climate change impacts of this pipeline will be
`significant but then does no further analysis of these impacts and does not take
`these impacts into account. This is unacceptable given the stakes that we all
`face from a warming climate. FERC should consider the environmental impacts of
`the additional greenhouse gas emissions, including upstream impacts and
`downstream GHG emissions.
`Second, FERC acknowledges that the impacts of certain project components may be
`predominately borne by environmental justice communities, but then concludes
`that the impacts of the project âas a whole â on environmental justice
`communities were not high enough. This minimizes the real and acknowledged
`impact that this pipeline will have on environmental justice communities.
`Burying that impact in conclusions about the project as a whole sacrifices those
`communities to a pipeline.
`Finally, this pipeline will have significant and permanent impacts on some of
`Pennsylvaniaâs highest quality water resources. The project would impact 114
`Exceptional Value (EV) wetlands and 37 High Quality (HQ) streams. Many of the
`streams that would be crossed by the project are cold water trout streams that
`are very sensitive to degradation. Clearing the forest around these streams
`exposes them to direct sunlight, raising the water temperature and jeopardizing
`their suitability as trout waters. Cutting forests and riparian buffers also
`creates habitat fragmentation. This fragmentation should be evaluated in terms
`of not only the impacts caused by these particular pipeline segments but also by
`other cuts in the same region, either by Transco on its other pipeline pieces or
`by other pipeline/linear projects. In addition, when the stream crossing
`includes a cut through a preexisting mature and healthy forest, the degradation
`of the forest on either side of the RightofWay that results from this forest
`fragmentation also needs to be considered in terms of both stream impacts and
`forest impacts. Transco does not have all of its required permits from state
`agencies and has not provided adequate mitigation measures.
`The pipeline is also proposed to be constructed within the habitat of several
`threatened and endangered plant and animal species including whitefringed
`orchid, Indiana bat, northern longeared bat, timber rattlesnake, and bog
`turtle. Potential impacts to wood turtles are completely ignored in the DEIS,
`and this omission should be corrected and impacts to wood turtles should be
`considered.
`For these reasons, I encourage FERC to refuse to approve the Transco REAE
`Project. Thank you.
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