FERC Docket: CP11-515
Orange Environment Comments on the proposed Compression Station in Minisink, NY dated, November, 9, 2012 during the second Scoping Session By President Michael Edelstein and Executive Director, Kathy Baker Skafidas.
Orange Environment, Inc seeks to protect and promote the ecological integrity and sustainability of the communities and environment of the Orange County New York region and beyond by promoting the active involvement of citizens in the affairs of their communities and, networked through Orange Environment, in the direction of the region. Orange Environment is dedicated to continued action in defense of our environment based on citizen activism, civic responsibility, and democratic principles. Orange Environment (OE) was incorporated in 1982.
After reviewing Millennium Pipeline Company’s application, OE would like the following comments to be considered as FERC prepares an Environmental Assessment of the Minisink Compressor Project under CP11-515. We, however are very concerned that an Environmental Assessment which is the chosen route of review at this time, will not adequately review all the significant impacts currently in play at the Minisink location (environment, historical, social-economic, etc), and that a full Environmental Impact Statement be performed instead.
The EA/EIS must thoroughly address:
1. The record of accidents at compressor stations, including release of gas, explosion, fire and all other events, including records of human injury, injury to animals, injury to property and the extent of the damage outward from the station and the circumstances by which injury and damage occurred.
2. The mitigatory measures in place at the time of all such accidents and incidents and why the event occurred despite the mitigation.
3. An analysis of mitigatory measures employed in this instance and how they will work better than measures that failed in other instances.
4. A report on the detection system used to detect line and junction releases, its failure incidence in other instances, and how improved measures are in place for detection and response to any such releases.
5. A risk analysis reflecting the hazards of gas inhalation, its explosiveness, its flammability and any other hazard situations surrounding the gas transmitted, including a record of past events where the hazard was materialized and an analysis of all potentially sensitive receptors who might feasibly be injured at this site and the mechanisms of exposure that might occur. This analysis shall include other chemicals used on site or in transmission lines besides gas. A full analysis of the sour tendencies of the gas shall be offered.
6. An analysis of baseline noise at the site and outward one half mile radius; an analysis of comparable compressor sites from one half mile inward; an analysis of a simulated comparable noise source at the site and its noise impacts outward until a point of non detection measured in every direction and from every point where sensitive reception might occur. These measurements will record decibel A levels, as well as fully characterize noise according to its annoyance value for receptors. Noise will be measured from homes with open and closed window conditions and from utilized portions of property. Significance of detection will be rated professionally and also by residents living within a mile radius of the compressor site. Noise levels will be discussed on their own and in comparison to baseline noise conditions.
7. A similar local and expert analysis will be made for light conditions at the planned site, to account for the annoyance value of lights to be used at the site, taking into account intended patterns and intensity of lighting, its height and direction and hours of operation. These will be discussed on their own and in comparison to baseline light conditions.
8. Similarly, baseline odors will be measured and contrasted to scenarios of odor release associated with gas or other chemicals found in gas lines or used at compressor stations. These will be discussed on their own and in comparison to baseline odor conditions.
9. A similar analysis will be made of visual impacts associated with the compressor station and any adjunct lines and facilities or work vehicles or permanent and temporary structures or conditions. The baseline visual ambience will be contrasted to the post-project visual conditions by experts and by the opinion of residents living within a mile of the site. This analysis will consider detectability, visibility and compatibility in contrast with the existing ambience and community character.
10.A real estate stigma analysis will be conducted to determine the impact of the proposed facility on property values and desirability of property within one mile radius, taking into account the direct impacts noted above (noise, odor, visual, light) as well as hazards issues that might affect property value but not limited to these. The analysis will use comparable properties not proximate to a compressor station and gas pipeline.
11. A quality of life and stress impact study will be made to ascertain impacts to the psycho-social well being and quality of life for residents living within one mile radius of the site. Non-resident impacts will also be considered, for example to those working or recreating in the vicinity. And community scale impacts, as impacts to character of community, shall be studied thoroughly.
12. These analyses will be contrasted between all candidate sites, the no-build alternative and other siting options that are feasible but were not considered in the initial analysis. In particular, the potential for piggybacking the compressor operation onto existing operations of similar character will be considered. For example, the Wagoner Measuring Station in Sparrowbush, NY, owned by Millennium, is approximately 10 miles from the Minisink site. It is nestled in the woods, in some 18 plus acres and in the past has housed temporary compressors; so it is a already disturbed site. It is an interconnect for both Columbia and Millennium and is already FERC approved. Or, for example, with Alternatives: Looping Option and a Mainline Replacement Option, in Section 10.3.0, there is a discussion of a looping option and a mainline replacement option. Both of these options need to be further examined because according to Section 10.3.1, “both options will upgrade the piping making it unnecessary to build a Minisink Facility”. According to Millenniums scoping report, this, upgrades to piping, is something that will need to take place in the upcoming future anyway. Again, cost options need to be examined for upgraded piping versus fiscal and social-economic impacts to a local community. Additionally, according to FERC requirements, Millennium must mitigate impacts to the public and the environment and examine the options listed above and not just move the Minisink station a few hundred feet north on the same property, as was proposed recently. That is not a true Mitigation alternative. In 10.5.2, “Compressor Station Site Evaluations, Common goals for the compressor station location were to avoid residential areas, and to select a location that would be acceptable from an aesthetic perspective”.
13. There will be an examination for presence of threatened and endangered species within a 1 miles radius of the proposed compressor station including the already identified Indiana Bat; examining breeding patterns, protection of nesting areas and ways to protect the found species from demise in said location. The study will also provide a natural resource inventory for the site and surrounding area.
14. A baseline aquifer and riverine system water quality study should be performed for the grounds and within a five mile vicinity to the proposed Minisink station. A list of water contamination from other compressor stations including a record of any past contamination issues and what mitigatory steps were taken and at what cost to the local environs and private households. If the residents are on wells, then their should be sampling of 20 public and private wells, spread out within the surrounding neighborhoods within a five mile radius of the Minisink station, to provide for a baseline of water quality in the event of ground water or riverine contamination.
We thank you for your time and consideration on this matter and hope that a very thorough examination of all sites and scenarios be under taken.
Michael Edelstein, President
Kathy Baker Skafidas, Executive Director
PO Box 25, Goshen, NY 10924