If you live in an impacted county (Morgan, Roane, Fentress, Overton, Putnam, Jackson, Smith and Trousdale), TCWP wants you to have sufficient information about the potential harm of allowing Enbridge to install a gas pipeline in your county and to provide you some guidance in submitting comments or intervening in the FERC process. We are also providing the Sierra Club’s talking points to help when you’re ready to submit your comments or intervention.
- The Company: East Tennessee Natural Gas, LLC., is owned by Enbridge, Inc., a major energy infrastructure. Enbridge is a Canadian company with a history of negligence in installing and maintaining its gas pipelines, causing explosions, leaks, and pollution for instance. We have provided two links to articles about Enbridge and one about another pipeline. One of our TCWP members moved here from Michigan and has firsthand knowledge about a massive leak in Michigan from an Enbridge pipeline. The company had received 15,000 complaints of leaks from corroded pipe but did nothing, resulting in a million gallons of leaked oil.
Here are the Enbridge damage links::
PLD19FR002.aspx (ntsb.gov)
Why Michigan is trying to shut down Canada’s Enbridge Line 5 pipeline (bbc.com)
Another pipeline case that caused farmers to lose access to clean water can be found here:
All Around the Mountain Valley Pipeline, Farmers Are Losing Access to Clean Water | Ambrook Research - What is the Federal Energy Regulatory Commission (FERC)? Simply put, FERC reviews applications for construction and operation of interstate natural gas pipelines pursuant to Section 7 of the Natural Gas Act. Under the Natural Gas Act, FERC may only approve those pipelines that serve “the present or future public convenience and necessity.” Historically, this has meant that the pipeline developer must have a preexisting agreement with a purchaser to supply natural gas. In this case that is the proposed methane plant in Kingston, TN. FERC can consider environmental impacts but has a poor track record of rejecting a pipeline for those reasons. However, under the Infrastructure Investment and Jobs Act as well as the Inflation Reduction Act there is commitment to transitioning to clean energy reliance.
- Directions to submit comments or intervene. BY JULY 15. If you are a landowner in one of these counties then you will want to preserve your legal right to challenge FERC’s decision about the pipeline in the future, so you will need to “intervene” rather than only submit comments. The process for intervening or submitting comments start on the same page of the FERC website at FERC.gov.
For either comments or intervention, once you click on efile/ecomment you will be taken to a page to register, which is fast and free.
You will receive an email with your FERC ID number that you will need to sign in later. Then, you are ready to log in.
TO SUBMIT COMMENTS: Once you are logged in, click on the left of the screen at “ecomment” & fill in the information.
Once you complete this screen you will move to a screen that will ask for the Docket number.
For either an intervention or to submit comments you will need the Docket Number. Start with CP23-516 which will bring up the original docket number (CP23-516-000) and the new sub-docket, CP23-516-001. When you see the blue + sign, select it to choose both dockets.
Then, you will type in your comments. You can pick some of the comments from the Sierra Club, below, but it is very important that you add something personal like this: “I live on the route of the proposed Ridgeline Expansion Project.” (Include a sentence or two about you and about how the project will impact you. i.e. “I have lived in X county for X years and am concerned about the project’s effects on my drinking water.”
TO INTEVENE: You will click on “General” rather than “ecomments.” That will bring you to a box with a list of choices. Select Intervention from the list, then in the box on the right, select (doc-less) Motion to Intervene.
Follow the same directions for docket number above and in the box describe why you wish to be an intervenor. A sample:
“I am a landowner on the route of the proposed Ridgeline Expansion Project. (Include a sentence or two about you and about how the project will impact you. i.e. I have lived in X county for X years and am concerned about the project’s effects on my drinking water. The outcome of this proceeding impacts me directly. Pursuant to Section 214, C.F.R. 385.214, I am filing this Motion to Intervene under Docket # CP23-516-000 and CP23-516-001.”
After you fill in the reason for your intervention, do the following:
- Click next. On the “Specify Filing Parties” page, click “As an Individual.” Then, click next. In the open box you see add your contact email and select “Add as Signer.”
- Click next. A submission description will pop up. We recommend editing it to something like “(doc-less) Motion to Intervene of (your name) under CP23-516-000 and CP23-516-001.
- Click next. Make sure the summary page looks good and then click
But you are NOT DONE because you must serve everyone on the Service list. Here’s how you do that:
- Return to ferc.gov and click “Query Service List.”
- Enter the docket number CP23-516-000 and click “search.” (The second docket number doesn’t include a separate service list, so you only need the primary docket number). Once you click “search,” you will see a blue plus sign under “select.” Type of address should say “email” and format should say “delimited with semicolon.” Click “Download list” and save the txt document to your computer. Cut and paste this list into the address field of an email.
- Compose an email to the service list. On the subject line use “CP23-516-000 and CP23-516-001- Motion to Intervene” as the subject line. The email body may say something like “Please be advised that (your name) has filed a Motion to Intervene with FERC on Dockets CP23-516-000 and CP23-516-001” and sign with your name. Also, be sure to include a link or an attachment of your Motion to Intervene. You can access a link to your submission at elibrary.ferc.gov with either docket number.
- Click SEND and you are done.
Sierra Club Talking Points – Public Comments on Ridgeline Expansion Project
FERC needs to look at the big picture: the Ridgeline Pipeline is a rotten deal for Tennessee.
- The Ridgeline Pipeline can’t exist without a planned TVA gas plant near Kingston and vice versa. The pipeline and gas plant are connected actions and FERC needs to consider the pros, cons, and alternatives together.
- Economists and EPA agree that the Kingston Gas Plant will cost over $1 billion more than lower-risk clean energy options. TVA justified its preference for the gas plant by relying on unsupported assumptions and ignoring financial incentives established by the Inflation Reduction Act, leaving money on the table and sticking ordinary Tennesseans with the bill. In fact, TVA messed up so badly that EPA says TVA broke the law.
- If FERC approves the pipeline, the pipeline company will be allowed to seize private property to trench and blast through farms, pristine streams, and steep mountains. How can FERC justify those impacts for a pipeline whose only customer is an unregulated monopoly—TVA—and a gas plant plagued by serious questions?
- To protect consumers and the environment, FERC must seriously consider alternatives to the package deal that don’t involve gas.
The Ridgeline Pipeline is bad for local communities.
- Pipeline construction will threaten dozens of wells and springs that people depend on for their drinking water. If these are contaminated or dewatered during construction, people may be left with no other options. FERC must require the pipeline company to provide pre- and post-construction testing free of charge and hold the company accountable for any change in quality or quantity.
- The Ridgeline Pipeline will not bring jobs to the region. The pipeline company says construction will last less than 18 months and that only half of those temporary jobs, at most, will go to local workers. The pipeline would provide only one permanent, full-time job.
- Ordinary Tennesseans will be forced to pay for the pipeline on their power bills, and local communities will bear the brunt of the environmental harm it will cause.
- Neither FERC nor the pipeline company have offered any guarantees that property owners will be able to get help if construction harms their land, water, or access to their property.
- Pipelines explode. In 1992, a gas pipeline explosion in White Bluff, Tennessee, sent flames 200 feet into the air, destroyed three homes and charred hundreds of acres of farmland, and injured five people. FERC must weigh the safety risks carefully—especially because the gas plant and pipeline aren’t needed.
The Ridgeline Pipeline will threaten or harm East Tennessee’s natural treasures.
- The Ridgeline Pipeline puts a target on streams and species. The pipeline company wants to trench and blast through hundreds of streams that are home to rich populations and fish, mussels, and other wildlife.
- The Ridgeline Pipeline is likely to adversely affect at least four federally endangered or threatened species, and experts are still reviewing whether others will be harmed. Some of the impacts to these rare species could be avoidable if only FERC would require it. For example, the pipeline should go under the Emory River, not straight through it. This special river is home to federally listed endangered and threatened species like the Spotfin chub, a brilliant turquoise fish that can be found in just four rivers in the Southeast today.
- East Tennessee holds unique geology and a one-of-a-kind cave in a meteorite crater that NASA used to train Apollo astronauts. FERC shouldn’t let the pipeline company through this natural time capsule when it could go around.
The pipeline company hasn’t finished its homework, and FERC shouldn’t let an unproven design pick up momentum.
- There are serious unanswered questions about the design of this pipeline. For example, the pipeline company wants to dig a one-mile-long tunnel under the Cumberland River, even though its own geotechnical experts have raised concerns—which still have not been resolved—about whether the plan is feasible.
- FERC cannot give tentative approval to an unproven design. Simply requiring that the company show its work before starting construction doesn’t cure the problem—it just stacks the deck in favor of a plan that may turn out to be impossible.
The Ridgeline Pipeline will cause decades of climate pollution.
- This pipeline will be responsible for over 1.6 million tons of downstream greenhouse gas emissions each year for decades. FERC cannot hide this climate pollution by subtracting it from the historic emissions of the retiring coal-fired Kingston Fossil Plant. The coal plant must retire within a few years regardless of whether the pipeline is built.
- The Ridgeline Pipeline will cause an increase in upstream greenhouse gas emissions from gas production and transportation. The pipeline will connect gas producers to new and previously unreachable demand at the gas plant, so basic economics teaches that either supply will increase to meet this new demand, or prices will rise.
- Recent studies show that upstream greenhouse gas emissions from gas pipelines are higher than previously thought and can swallow up any supposed climate benefit of methane gas replacing coal. FERC cannot leave these foreseeable emissions off the ledger.
- The planet is heating up, and we must stop using fossil fuels. Between 2014 and 2023, the global average temperature was 1.2 C (2.16 F) above the pre-industrial average, making it the warmest 10-year period on record, according to the United Nations.
