Why the ET Rover Pipeline should not be permitted

The ET Rover pipeline is currently planned as a 42 inch pipeline for the transmission of natural gas from the production site in Ohio and Pennsylvania to the final marketing site in Sarnia, Ontario (Fig. 1).

Fig. 1: The proposed course, dimensions, and market segments of the ET Rover pipeline. Source: energytransfer.com

My comment is in regards to the scoping process within the Environmental Impact Statement (EIS) to be prepared by the Federal Energy Regulatory Commission (FERC). There are better energy provisioning alternatives to the proposed pipeline available and the environmental impacts of the proposed pipeline outweigh its potential benefits by far.

My comment has 4 parts:

1. The natural gas to be transmitted is produced by hydraulic fracturing (“fracking”), which is a highly insecure, inefficient, and polluting technology that should not be further promoted, which it would, if this transmission and distribution line is build.
2. The transmission of natural gas in pipelines leads to substantial leakage of the potent greenhouse gas methane, which has a climate altering potential that is estimated to be 28-84 times higher than that of carbon dioxide.
3. Serious incidents in the transmission of natural gas in pipelines are less common but if they occur they are often more serious (explosions) and often cause fatalities.
4. Fossil fuels caused and continue to cause global climate change, which already leads to hundreds of human fatalities every year and will substantially impair the survival and well-being of human and non-human life forms for many decades to come. Renewable energy sources are the only energy sources able to cut greenhouse gases and are available right now providing enough energy for all current and future energy needs. The sooner we switch to renewable energy sources the sooner planet Earth will recover from the inevitable consequences of fossil energies. Every new investment into fossil fuels is unnecessary and unethical and should therefore be avoided.

Below, I will provide arguments and evidence for each of my four statements.

1. Fracking is insecure, inefficient, and causes environmental impacts that outweigh its benefits by far. Workers on fracking sites are at risk of silicosis caused by the exposure to high levels of silica, found in dust particles from hydraulic fracturing sand (OSHA 2014). In addition, many oilfield workers involved in “fracking” lost their lives or endured serious injuries (Earthjustice 2014; Meyer and Stepans 2014; Mountainkeeper Catskill 2014).

Hydraulic fracturing is a high input technology and is therefore in many cases highly inefficient. A lot of energy and water is needed to frack a well and many wells do not pay back the investment. The only reason why the business stays profitable are tax incentives and subsidies, the 2005 exemption of hydraulic fracturing from the Safe Drinking Water Act – known as the “Halliburton Loophole”, the exemption of “smaller” oil and gas production sites from the National Emission Standards for Hazardous Air Pollutants (NEHAPS) within the Clean Air Act, the exemption from stormwater runoff permits within the Clean Water Act, the exemption of oil and gas production sites from the Resource Conservation and Recovery Act (RCAA) governing the disposal of solid and hazardous wastes, exemptions from the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), known as the “Superfund Law”, and the Toxic Release Inventory (TRI), which requires most industries to report toxic substances to the EPA (Earthworks 2014) – and the occasional high-output well. Most of the up to 5 Million gallons of water pushed underground in each well (Mielke and others 2014) is lost or cannot be used for anything else due to chemical contamination (Fontenot and others 2013).

The environmental impacts of the production end of fracking include ground- and surface water pollution (Fontenot and others 2013; Jackson and others 2013; Mall 2014; Vidic and others 2013), methane emissions (Field and others 2014; Howarth 2014; Schneising and others 2014), emissions of volatile chemicals, e.g. BTEX, formaldehyde, hydrogen sulfide and methylene chloride (Argo 2001; Colborn and others 2014; Macey and others 2014), and other concerns (Adgate and others 2014; Bamberger and Oswald 2012; Brittingham and others 2014; Colborn and others 2011). Most current comprehensive analyses of the environmental and social cost-benefit ratio of fracking come to the conclusion that the technology should be put on hold until its flaws are solved, or should not be continued because the production of shale oil and gas allows consumers to continue the wasteful use of fossil fuels and thus causing more severe global climate change (Newell and Raimi 2014; Sovacool 2014; Vengosh and others 2014).

2. According to estimates by the EPA, most methane leakage occurs during the transmission of natural gas (0.7%).

Fig. 2: Picture credit: John Bellamy/Stanford University

While most independent studies consider the EPA’s estimates of the total amount of methane leakage from natural gas operations to be substantially below the real values (Brandt and others 2014; Field and others 2014; Howarth 2014), the allocation of leakage to be highest in transmission and distribution is undisputed (Alvarez and others 2012). Fugitive methane emissions from natural gas systems represent a significant source of global warming pollution in the U.S. (Bradbury and others 2014). In fact, compared to carbon dioxide, methane is considered to be 28x to 84x more potent as a greenhouse gas (Fig. 3) (Howarth 2014).

Fig. 3: Global Warming potential of methane compared to carbon dioxide. Picture credit: Allen (2014)

3. Serious incidents in the transmission of natural gas in pipelines are less common but if they occur they are often more serious (explosions) and often cause fatalities. From 1994 until 2013, the PHMSA (Pipeline & Hazardous Materials Safety Administration) recorded 1236 significant incidences in gas transmission, causing 41 fatalities, 195 injuries and $1,717,072,424 of property damages (PHMSA 2013).
4. Fossil fuels caused and continue to cause global climate change, which already leads to hundreds of human fatalities every year and will substantially impair the survival and well-being of human and non-human life forms for many decades to come (IPCC 2014). Renewable energy sources are available now and are capable to provide enough energy for all current and future energy needs (Becker and others 2014; Delucchi and Jacobson 2011; 2013; Jacobson 2009; Jacobson and Delucchi 2011). The sooner we switch to renewable energy sources the sooner planet earth will recover from the inevitable consequences of fossil energies (Jacobson and Streets 2009). Every new investment into fossil fuels should therefore be avoided.

Fig. 4: Technologically and financially feasible transition to a 100% renewable energy supply for Michigan. Picture credit: thesolutionsproject.org

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