WCAS believes PennEast would inflict far-reaching environmental damage

WCAS INTERVENOR FILING ON PENNEAST PIPELINE
FERC Docket# CP15-558

Washington Crossing Audubon Society believes that the proposed PennEast natural gas pipeline would inflict far-reaching environmental damage along the proposed route through the grasslands of Hunterdon and Mercer Counties, the Sourland Mountain and along the alternate Baldpate Mountain Route.

As part of the federal regulatory review process, an exhaustive environmental impact study should be done, which would assess the impact on regional biodiversity and on regional streams and groundwater, particularly the impact on threatened and endangered bird species, Audubon Watchlist species, American Bird Conservancy Species of Conservation Concern and other threatened species, such as rapidly declining bats, pollinating insects, reptiles, and amphibians. The results of such a study would clearly demonstrate the extensive potential damage to the environment along the proposed route.

The proposed pipeline should not encroach on any land tracts that have been preserved for their high biodiversity, high quality habitat, or rare species. Of special concern are the Sourland Mountain and its outlier Baldpate Mountain, which contain both high biodiversity and rare species.

The Sourland Mountain is of critical importance to migrating and breeding birds, including many species of conservation concern. The Sourland Mountain is the meeting place of Northern and Southern species and contains the largest continuous forest in central New Jersey attracting many interior forest breeding species, including fifteen species of conservation concern. Thirteen of these species are Nearctic-neotropical migrants. These species are either obligate interior forest breeding species or require large forest tracts for breeding success to avoid nest parasitism by the Brown-headed Cowbird. The New Jersey Endangered Breeding Red-shouldered Hawk and Threatened Barred Owl breed in the Sourlands. The Sourland Mountain Regional Ecosystem supports large populations of spring and fall migrants, including sixty-one species of conservation concern. Fifty species of conservation concern use the interior forest reserves, including forty-six species of Neotropical migrants.

The gravest threat to biodiversity today is the loss, degradation, and fragmentation of habitat. Bisecting intact forest with a pipeline right-of-way means more than the loss of a 100 to 200 foot swath of trees. Such a fragmentation of habitat increases the edge effect and allows invasive species to invade the forest interior, threatening and in some cases eliminating interior forest species. The Brown-headed Cowbird, a nest parasite, uses openings through the forest to increase access to the nests of forest-dwelling species, including Nearctic-Neotropical breeding birds. Invasive plant species use the same routes to colonize the forest, displacing native plants that sustain native wildlife. Because the right of way is permanent, these effects cannot be mitigated. The interior forest habitats are permanently degraded.

The proposed pipeline would also cross preserved farmlands, where the potential for environmental damage is just as serious. These farmlands, when properly managed, maintain habitat for rapidly declining grassland birds, which require a significant expanse of grassland to breed successfully, and for pollinating insects, necessary for most fruit and vegetable production. Disturbing this type of habitat would prove harmful to these already threatened species. Of special concern is the New Jersey threatened American Kestrel, a rapidly declining species in the state. The preserved farmlands of Hunterdon County are prime habitat for this species.

Baldpate Mountain has been cited as a preferred route because of the exiting power line right of way. While using existing rights-of-way is generally a less environmentally disruptive option, the geology, environmental sensitivity and ecological uniqueness of Baldpate Mountain makes it a poor choice. The proposed pipeline would run parallel to the existing right-of way with a slight overlap, requiring clearing the forest on the forested up slope of Baldpate for an additional 100’ to 200’.

Because of the extreme ecological sensitivity of Baldpate Mountain, Washington Crossing Audubon Society opposes routing the PennEast pipeline overlapping with and parallel to the JCP&L power line cut that bisects Baldpate Mountain. An outlier of the Sourland Mountains, Baldpate Mountain contains some of the richest biodiversity in New Jersey. Southern and northern species meet at Baldpate, enriching the flora and fauna. Due to the high quality habitat, including areas of intact understory, and the mingling of southern and northern species, Baldpate Mountain has the highest concentration of breeding Neotropical migrants in New Jersey. The thirty-one Neotropical breeding species include thirteen warblers and the Yellow-breasted Chat, two tanagers, three vireos and two Catharus thrushes. Twenty-eight breeding Neotropical migrant species are ranked by the American Bird Conservancy (ABC) as birds of conservation concern. Five of these species, Hooded Warbler, Kentucky Warbler, Worm-eating Warbler, Wood Thrush, and Veery, are New Jersey species of conservation concern. Baldpate is also an important migratory stop for Neotropical birds. Fifty species of Neotropical migrants of conservation concern use Baldpate Mountain as a migratory stop. A total of 165 species have been reported to eBird at Baldpate; sixty-one of these are ABC species of conservation concern that use Baldpate for breeding, a migratory stop or as part of a resident territory. The New Jersey threatened Long-eared Owl has winter roosts at Baldpate Mountain. The New Jersey threatened Barred Owl and endangered breeding Red-shouldered Hawk have also been reported at Baldpate.

Because Baldpate Mountain is long and narrow, it is highly sensitive to disruption from activity on the power line cut that bisects the forest lengthwise. Of special concern is noise from blasting and construction that would penetrate deeply into the forest, interfering with vocal communication between birds at a critical time during the breeding season. Construction extending the width of the power line cut would destroy or degrade adjacent breeding habitat along the length of the mountain. Because Baldpate breeding territories are saturated, these birds cannot move further back into the interior forest if disturbed.  There is no place for the displaced birds to go. Blue-winged and Chestnut-sided Warblers, species of conservation concern that breed at the forest-power line ecotone, would be especially affected. Increasing the width of the power line would also extend the edge effect further into the core forest, allowing increased access for brown-headed cowbirds, a nest parasite, and invasive plant species. The ecosystem at Baldpate is intact but stressed, making Baldpate sensitive to new disturbances.

The blasting necessary to penetrate the extremely hard diabase substrate has the potential to affect the springs that feed the creeks that originate on Baldpate, disrupting their flow and the animals that depend on them, including the breeding Louisiana Waterthrush, a species of conservation concern.

The potential damage to the breeding birds of conservation concern cannot be mitigated as there is no other high quality habitat for relocation of these species in central New Jersey. The Sourland Mountain habitat is similarly saturated and the areas adjacent to Baldpate are too degraded to support healthy populations of birds that require closed canopy, healthy understory or interior forest. Healthy forest habitat takes decades to develop, considerably longer than the lifetime of the forest breeding birds, making mitigation impossible. The affected species are of conservation concern because they are declining at an unsustainable rate or their habitat is being destroyed or degraded at an unsustainable rate.

The power line cut predates the requirement for an environmental impact statement. Considering the ecological sensitivity of Baldpate Mountain, the power line cut should have never been placed there. A thorough biological inventory and environmental impact statement would clearly show why. The damage to the fragile but intact Baldpate Mountain ecosystem should not be compounded by allowing PennEast access for their pipeline.

Our preserved lands are not empty spaces on a map. These properties have been preserved for their value in protecting biodiversity, maintaining air and water quality, and sustaining small local farming operations. Furthermore, these lands add immeasurably to the quality of life for the thousands of people who visit them, who live on or near them, or who work on or near them. Often these lands and farmlands were preserved with public money voted expressly for such a purpose. They do not belong to PennEast, and they certainly should not be under consideration for siting a pipeline. These lands provide valuable environmental and agricultural benefits, as well as intangible personal benefits to all of us, benefits that are irreplaceable and that are meant to continue in perpetuity.

WCAS opposes any pipeline that would be sited on preserved lands or farmlands. Because of their importance to birdlife both the Sourland Mountain Region and Baldpate Mountain have been designated as New Jersey Important Bird Areas (IBA’s). Other IBA’s affected by the PennEast pipeline are Hickory Run State Park IBA, the Kittatinny Ridge IBA, and the Green Pond Marsh IBA in Pennsylvania and the Musconetcong Gorge IBA, the Everittstown Grasslands IBA, and the Pole Farm IBA in New Jersey.   To minimize the environmental impact of the proposed pipeline, IBA’s should be especially avoided as the United States Fish and Wildlife Service guidelines clearly state. The findings of a properly executed environmental assessment must be an integral part of the federal regulatory review process, so that no harm will be done to our wild lands and farmlands. We urge FERC to rule “no action” on both the proposed PennEast pipeline.

3D FLYOVERS OF PENNEAST ROUTE
“Next time someone says “co-location”…
show them this video series”
—Mike Spille

PENNEAST CROSSING DELAWARE RIVER INTO NJ

From Mike Spille’s  THE COST OF THE PIPELINE

“One of PennEast’s favorite ploys when talking about their proposed pipeline route is how painstakingly they worked to “co-locate” the route.   Co-location generally means putting the route along an existing utility corridor, under the theory that the corridor has already damaged the environment, so you might as well stick more utilities there rather than push through an alternative greenfield route. Of course, those of us who have looked at the route in detail know it’s not actually co-located.  And that, in fact,  much of it is in fact green field routes through steep slopes, preserved farmland, and pristine, beautiful properties.  But sometimes it’s hard to convince people of the facts. To help show people the truth behind PennEast’s routing choices, I’m preparing 3D videos of the route through Google Earth.  This shows the reality of the route as proposed to PennEast’s marketing spin.

The large smokey gray area is the 400′ wide survey corridor. The light blue areas are the proposed temporary construction spaces (on top of the existing 100′ clear-cut construction zone, not shown here), and finally the 50′ wide permanent easement. The route here is through some of the most ecologically sensitive in the state of NJ. Here we see routing along the Milford Buffs [Natural Heritage Priority Site] and going right through the Gravel Hill Natural Heritage [Trust] Site… a special designation by the NJDEP for the most critical and unique ecosystems in the state.”

3D FLYOVER OF ROUTE OVER BALDPATE MOUNTAIN & HOPEWELL, NJ

“The video starts at the Goat Hill Natural Heritage Priority Site, and proceeds to show the route going through several farms in the Valley Road area. We follow the HDD under Moore’s creek, and the HDD staging site up on Baldpate Mountain. The route then continues on Baldpate, not co-located at all, but creating a new area of devastation to the West of the power line cut, all in areas of dense old growth forest and steep slopes. And, of course, this whole area is designated an Important Bird Area. It continues through several more farms and through Jacob’s creek, another long HDD under the municipal area around Scotch Road, and then on through more farmland and increasingly residential areas. Then onto the Shoprite shopping center, under Route 31, and on to the terminus in Pennington.”

3D FLYOVER OF APPALACHIAN TRAIL

“This is part of the 3D flyover video series of the PennEast routes. In this installment, we look at the Appalachian Trail crossing of the project in Pennsylvania. As always, the 400′ survey corridor is in smokey gray, the pipeline 50′ permanent easement line is in red, and the light blue areas are temporary construction zones. There is also a 100′ construction right of way not shown here.

In the video, we approach the trail from the South East…  Don’t let the HDD portion fool you.   The AT corridor in this area will be permanently scarred by the 100′ clear cut route of the pipeline on either side of the trail, and the use of HDD means the part closest to the trail will have the greatest impacts (due to HDD entry and exit sites requiring a lot of space).  Trail walkers along the ridge will see the permanent scar running parallel to the mountain to the north and south, thanks to PennEast’s brilliant routing.”
Mike Spille

3D FLYOVER from MILFORD to FRENCHTOWN

“This portion shows the beginning of many impacts to rich farmland in NJ when viewing the route from North to South.  Plus the incredibly steep slopes at the Nishisakawick Creek at 3:05 near the end of the video.”

Mike Spille

3D FLYOVER West Amwell through RockHopper and Swan Creek Reservoir Dam

“At 1:37 the Swan Creek Reservoir starts to slide into view on the left, and you can see the pipeline more than doubling the existing power line cut (in fact going up and down ridges), creating more erosion issues into Swan Creek. Right after that you can see the poor houses on Old Route 518 West who have the construction 10′ from their houses. At the 2:00 mark, it diverges from the power lines and cuts up a steep and heavily wooded slope to the highest point on Goat Hill. This is the area documented with over 80 old hand-dug quarry holes going back to the 17th-18th century which today act as vernal pools. Many endangered salamander species have been documented as laying eggs in these pools, many of which will be destroyed by the pipeline construction and are barely mentioned in the DEIS. After it crosses Hewitt Road you swing by my house (Hi!), it cuts through a bunch more pristine wetlands areas owned by my neighbor, and than at 2:21 it impinges directly upon the Goat Hill Natural Heritage Priority Site for no apparent reason. As with Gravel Hill, this is a special NJDEP designation for an exceptional and rare ecosystem.”

Mike Spille

3D FLYOVER KINGWOOD TWP., NJ

“More agricultural and woodland impacts, plus the first of the incredibly long HDD sites.   If the northernmost Kingwood HDD attempt fails, PennEast will have to either make a major re-route or destroy the major solar panel installation we see at 1:45.”Mike Spille

PennEast would traverse or nip many preserves including Copper Creek, Horseshoe Bend, Muddy Run as well as cross Copper Creek, the Lockatong and other C1 Streams, tributaries, and headwaters.