Comment of Allegheny Defense Project under CP14-497.

UNITED STATES OF AMERICA BEFORE THE FEDERAL ENERGY REGULATORY COMMISSION Dominion Transmission, Inc. Docket No. CP14-497-000 COMMENTS OF ALLEGHENY DEFENSE PROJECT The following comments are provided on behalf of the Allegheny Defense Project regarding the Federal Energy Regulatory Commissions (FERC) environmental assessment (EA) for Dominion Transmissions (Dominion) proposed New Market Project (Project). Dominion proposes to construct and operate two new compressor stations near Pennsylvanias shale gas fields in the southern tier of New York. See EA at 1. Dominion further proposes modifications at three existing compressor stations (including adding compression at one of these stations) and at an existing meter station. I. FERC failed to consider the indirect effects of gas drilling in the Marcellus and Utica shale formations. According to Dominion, the Project is designed to provide natural gas firm transportation services in Pennsylvania (PA) and NY, creating increased access for production in this region to major natural gas markets of the Northeast and Mid-Atlantic regions[.] Application at 1 (emphasis added). Since New York has banned shale gas development, it is highly likely that the majority of shale gas that will be produced for the Project will be sourced from Pennsylvanias shale gas fields, impacting Pennsylvanias land, water and air. FERC, however, failed to even consider the increased production that is likely to result from authorization of this Project as an indirect effect in the EA. Indirect effects are: 1 [C]aused by the action and are later in time or farther removed in distance, but are still reasonably foreseeable. Indirect effects may include growth inducing effects and other effects related to induced changes in the pattern of land use, population density or growth rate, and related effects on air and water and other natural systems, including ecosystems. 40 C.F.R. 1508.8(b). The indirect effects of shale gas development in the Marcellus and Utica shale formations are both causally related to the Project and reasonably foreseeable. As such, this will lead to effects on Pennsylvanias land, water and air. Therefore, FERC has an obligation to take a hard look at the environmental effects of Marcellus and Utica shale extraction as part of its analysis of the Project. a. There is a sufficient causal relationship between the Project and induced shale gas extraction in the Marcellus and Utica Shale formations. Before discussing the causal connection between the Project and induced shale gas drilling, it is first important to point out that ...