Following what goes on with oil and gas exploitation in and around Adrian, Michigan since 2013 - and how these events in our little city connect to the global environmental situation... - with the occasional sidetrack to other related environmental issues in Lenawee county, Michigan and how those relate to global issues.
Saturday, December 12, 2015
[Michigan Climate March] Over 800 strong in the #MIClimateMarchduring...
Ethan Wampler, Jayson Toweh and Nicholas Jansen posted in Michigan Climate March.
Ethan Wampler December 12 at 5:53pm
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Thursday, December 10, 2015
Michigan Climate March in Ann Arbor this Saturday at 2pm
As world leaders from 195 countries end their negotiations on how to stop climate change and how to transition to a fossil-free world, here's a chance to urge Michigan to do the same, as well as to celebrate progress made in Paris .
Michigan Climate March, a state-wide event in Ann Arbor
https://act.350.org/event/D12-solidarity_attend/11510
Michigan Climate March, a state-wide event in Ann Arbor
https://act.350.org/event/D12-solidarity_attend/11510
Date: Saturday, December 12 - gather at 2:00 PM
Location: In front of the Federal Building at 200 E. Liberty St.
Details: March through downtown, ending with a Rally on the UM Diag
Saturday, November 28, 2015
Less = More Coalition Documentary - Crisis: Factory Farms and Lake Erie Algae
Pam Taylor
ECCSCM
ECCSCM
I've included a copy of Less = More "Follow the Manure ..." Report, plus the Appendix, in the OneDrive below, in case you'd like to download it directly. The interactive map is available at the link in the press release.
(Note that the manure calculations are average-per-species-per farm, so if a farm has different animal classifications such as nursery pigs, finishing pigs, etc., an average manure production for that species was used. All sources listed in report endnotes.)
One of the things that this data showed us is that, while Michigan has less than 1% of the NPDES-permitted CAFO animals, they provide almost 20% of the manure produced by NPDES-permitted CAFO animals in the WLEW. This manure is applied on a relatively small amount of land acreage.
This report does not include non-permitted farms, i.e., smaller CAFOs or farms that don't confine their animals.
Video documentary here:
https://www.youtube.com/watch?v=R4XD_wtePNI
Pam Taylor
ECCSCM
FOR IMMEDIATE RELEASE
Media Contact: Gail Philbin, Sierra Club Michigan Chapter, 312-493-2384, gail.philbin@sierraclub.org<mailto:gail.philbin@sierraclub.org>
Federal Funding Flows While Lake Erie Contamination Grows
New report offers first-of-its-kind mapping of factory farm pollution & federal subsidies
630 million gallons of waste annually in Lake Erie watershed, $17 million in subsidies to waste generators since 2008
LANSING, MI––NOVEMBER 19, 2015––Today, the Less=More Coalition<http://moreformichigan.org/> released a report that takes an unprecedented look at the relationship between the manure load from factory farms in the Western Lake Erie Watershed (WLEW) and the federal subsidies that have poured into the region to facilities that generate that waste over the last seven years. Between 2008 and 2015, U.S. Department of Agriculture direct payments, cost-shares and other conservation subsidies to owners of Concentrated Animal Feeding Operations (CAFOs) totaled more than $16.8 million in the WLEW, which includes Ohio, southern Michigan and eastern Indiana.
The report, "Follow the Manure: Factory Farms and the Lake Erie Algae Crisis," shows that millions of dollars in taxpayer funds continued to be disbursed, even as phosphorus contamination levels in the WLEW climbed and CAFOs in the watershed were fined for illegal waste discharges. The Less=More report also provides a groundbreaking set of interactive maps at this link<http://www.sierraclub.org/michigan/follow-manure-factory-farms-and-lake-erie-algal-crisis> that locate all CAFOs in the watershed and connect them with novel data about manure production and subsidies in the region.
"While agricultural runoff has been identified as a major contributor to the growth of Lake Erie algae blooms, no one has connected the dots between the problem and federal subsidies before," said Gail Philbin, director of the Michigan Sierra Club, a Less=More member. "This report is a portrait of a watershed inundated by waste and taxpayer money to fix it, but with nothing much to show for it after many years."
Follow the Manure also spotlights the environmental violations and subsidy records of seven CAFOs in two counties in southern Michigan—Lenawee and Hillsdale Counties—that offer a closer look at what is happening throughout the WLEW.
Currently, 146 industrial CAFOs are sited in the WLEW, housing nearly 12 million animals that produce more than 630 million gallons of waste annually. The manure contains dissolved phosphorus, which is considered the key culprit in the growth of blue-green algae, known as Cyanobacteria, and microcystin that caused the 2014 toxic algal poisoning of the City of Toledo's drinking water and this year's record algal bloom in Lake Erie.
"The deterioration of the WLEW is proof that no amount of money can create a healthy, safe and sustainable CAFO," said Lynn Henning, a Lenawee County, Mich., family farmer. Henning is the 2010 Goldman Environmental Prize winner (North America) and a regional associate for Socially Responsible Agricultural Project. "Instead of slowing or reversing the pollution levels, the subsidies seem to only deepen and accelerate the contamination crisis."
The WLEW covers portions of Michigan, Indiana and Ohio, encompassing the Maumee River, the largest tributary to Lake Erie, as well as several other major waterways, including Michigan's River Raisin. Ohio has the largest land area in the WLEW, and its 57 CAFOs generate the most manure. Michigan and Indiana also play a major role in the WLEW, together contributing nearly 38 percent of the waste in the watershed.
"CAFO owners and those who should be regulating them tell you everything is being done to protect our land, water, natural resources and public health," said Henning. "This report says otherwise."
Findings in the report include data showing that Indiana's Adams County has received the most federal subsidies to-date ($10,622,663); Michigan's Lenawee County is home to the most CAFOs with environmental violations (67) and the most illegal discharges (37); and Ohio's Paulding County along with Lenawee are the top manure producers in the WLEW. In addition, CAFOs in the watershed were cited for 112 illegal discharges of waste since 2008, an average of 16 per year, and were fined a total of $1,137,000.
The U.S. Environmental Protection Agency (EPA) requires certain qualifying farms to obtain a National Pollution Discharge Elimination System (NPDES) permit. Follow the Manure demonstrates that, despite this regulation, many CAFOs fail to meet the EPA Clean Water Act regulations as stipulated in their NPDES CAFO permits.
"This is just the tip of the iceberg," said Philbin. "Our report only represents what we were able to track down from Freedom of Information Act requests and our own research online and in person. It's not easily accessible information, and it's highly likely that there are many more federal payments and violations that occurred over the last seven years that aren't reflected in this report."
A set of interactive maps included in the report provides a new and essential information tool for public understanding of CAFOs in the WLEW. Using the maps, individuals, state agencies and watchdog organizations can obtain detailed information on which animals are housed at each CAFO, the amount of manure produced, the violations incurred and the taxpayer subsidies awarded.
"If information is power, this report is a game-changer," said Pam Taylor of Environmentally Concerned Citizens of South Central Michigan, a Less=More coalition member. "Before, there was no single source where people could go to find accurate and current information about the largest factory farms in the WLEW with explanations for how the manure they produce impacts Lake Erie, how it contributes to algae blooms and how federal subsidies are connected. Now there is."
The Less=More coalition presents Follow the Manure for use by policymakers and agricultural producers to aid in understanding of the issues at play in the WLEW and to facilitate efforts to solve Lake Erie's algae problem. To this end, the report contains several recommendations for key first steps to tackle the impacts of CAFO waste in the WLEW. These steps include: declaring Lake Erie an impaired watershed; ending the practice of giving federal taxpayer dollars to polluting CAFOs; changing the phosphorus soil-test requirements; and banning the application of CAFO waste on frozen or snow-covered ground within the WLEW.
A copy of "Follow the Manure: Factory Farms and the Lake Erie Algae Crisis" can be downloaded at http://www.sierraclub.org/michigan/lessmore-reports.
Less=More is a coalition of organizations engaged in diverse aspects of our food system and seeking to level the playing field for sustainable farming in Michigan. Less support for polluting factory farms means a more sustainable Michigan. For more information, please visit MoreforMichigan.org<http://moreformichigan.org/>.
Members of the Less=More Coalition include: Beery Farms of Michigan, LLC, the Center for Food Safety, Crane Dance Farm, LLC, ELFCO food cooperative, Environmentally Concerned Citizens of South Central Michigan, Food & Water Watch, Greater Grand Rapids Food Systems Council, Groundswell Farm, Zeeland, Humane Society of the United States, Michigan Voices for Good Food Policy, Michigan Young Farmers Coalition, Sierra Club Michigan Chapter and Socially Responsible Agricultural
ptaylor001 has files to share with you on OneDrive. To view them, click the links below.
[https://a.gfx.ms/ftype/v4/pdf.png] Follow the Manure (FINAL) 11.19.15.pdf <https://onedrive.live.com/redir.aspx?cid=905e55fad267e6fa&parentid=905E55FAD267E6FA%211341&parId=905E55FAD267E6FA%21165&authkey=%21AMpvyFuLliHd0lo&ithint=folder%2c&resid=905E55FAD267E6FA%211334>
[https://a.gfx.ms/ftype/v4/pdf.png] Follow the Manure Appendix (FINAL) 11.19.15.pdf <https://onedrive.live.com/redir.aspx?cid=905e55fad267e6fa&parentid=905E55FAD267E6FA%211341&parId=905E55FAD267E6FA%21165&authkey=%21AMpvyFuLliHd0lo&ithint=folder%2c&resid=905E55FAD267E6FA%211335>
Pam Taylor
ECCSCM
FOR IMMEDIATE RELEASE
Media Contact: Gail Philbin, Sierra Club Michigan Chapter, 312-493-2384, gail.philbin@sierraclub.org<mailto:gail.philbin@sierraclub.org>
Federal Funding Flows While Lake Erie Contamination Grows
New report offers first-of-its-kind mapping of factory farm pollution & federal subsidies
630 million gallons of waste annually in Lake Erie watershed, $17 million in subsidies to waste generators since 2008
LANSING, MI––NOVEMBER 19, 2015––Today, the Less=More Coalition<http://moreformichigan.org/> released a report that takes an unprecedented look at the relationship between the manure load from factory farms in the Western Lake Erie Watershed (WLEW) and the federal subsidies that have poured into the region to facilities that generate that waste over the last seven years. Between 2008 and 2015, U.S. Department of Agriculture direct payments, cost-shares and other conservation subsidies to owners of Concentrated Animal Feeding Operations (CAFOs) totaled more than $16.8 million in the WLEW, which includes Ohio, southern Michigan and eastern Indiana.
The report, "Follow the Manure: Factory Farms and the Lake Erie Algae Crisis," shows that millions of dollars in taxpayer funds continued to be disbursed, even as phosphorus contamination levels in the WLEW climbed and CAFOs in the watershed were fined for illegal waste discharges. The Less=More report also provides a groundbreaking set of interactive maps at this link<http://www.sierraclub.org/michigan/follow-manure-factory-farms-and-lake-erie-algal-crisis> that locate all CAFOs in the watershed and connect them with novel data about manure production and subsidies in the region.
"While agricultural runoff has been identified as a major contributor to the growth of Lake Erie algae blooms, no one has connected the dots between the problem and federal subsidies before," said Gail Philbin, director of the Michigan Sierra Club, a Less=More member. "This report is a portrait of a watershed inundated by waste and taxpayer money to fix it, but with nothing much to show for it after many years."
Follow the Manure also spotlights the environmental violations and subsidy records of seven CAFOs in two counties in southern Michigan—Lenawee and Hillsdale Counties—that offer a closer look at what is happening throughout the WLEW.
Currently, 146 industrial CAFOs are sited in the WLEW, housing nearly 12 million animals that produce more than 630 million gallons of waste annually. The manure contains dissolved phosphorus, which is considered the key culprit in the growth of blue-green algae, known as Cyanobacteria, and microcystin that caused the 2014 toxic algal poisoning of the City of Toledo's drinking water and this year's record algal bloom in Lake Erie.
"The deterioration of the WLEW is proof that no amount of money can create a healthy, safe and sustainable CAFO," said Lynn Henning, a Lenawee County, Mich., family farmer. Henning is the 2010 Goldman Environmental Prize winner (North America) and a regional associate for Socially Responsible Agricultural Project. "Instead of slowing or reversing the pollution levels, the subsidies seem to only deepen and accelerate the contamination crisis."
The WLEW covers portions of Michigan, Indiana and Ohio, encompassing the Maumee River, the largest tributary to Lake Erie, as well as several other major waterways, including Michigan's River Raisin. Ohio has the largest land area in the WLEW, and its 57 CAFOs generate the most manure. Michigan and Indiana also play a major role in the WLEW, together contributing nearly 38 percent of the waste in the watershed.
"CAFO owners and those who should be regulating them tell you everything is being done to protect our land, water, natural resources and public health," said Henning. "This report says otherwise."
Findings in the report include data showing that Indiana's Adams County has received the most federal subsidies to-date ($10,622,663); Michigan's Lenawee County is home to the most CAFOs with environmental violations (67) and the most illegal discharges (37); and Ohio's Paulding County along with Lenawee are the top manure producers in the WLEW. In addition, CAFOs in the watershed were cited for 112 illegal discharges of waste since 2008, an average of 16 per year, and were fined a total of $1,137,000.
The U.S. Environmental Protection Agency (EPA) requires certain qualifying farms to obtain a National Pollution Discharge Elimination System (NPDES) permit. Follow the Manure demonstrates that, despite this regulation, many CAFOs fail to meet the EPA Clean Water Act regulations as stipulated in their NPDES CAFO permits.
"This is just the tip of the iceberg," said Philbin. "Our report only represents what we were able to track down from Freedom of Information Act requests and our own research online and in person. It's not easily accessible information, and it's highly likely that there are many more federal payments and violations that occurred over the last seven years that aren't reflected in this report."
A set of interactive maps included in the report provides a new and essential information tool for public understanding of CAFOs in the WLEW. Using the maps, individuals, state agencies and watchdog organizations can obtain detailed information on which animals are housed at each CAFO, the amount of manure produced, the violations incurred and the taxpayer subsidies awarded.
"If information is power, this report is a game-changer," said Pam Taylor of Environmentally Concerned Citizens of South Central Michigan, a Less=More coalition member. "Before, there was no single source where people could go to find accurate and current information about the largest factory farms in the WLEW with explanations for how the manure they produce impacts Lake Erie, how it contributes to algae blooms and how federal subsidies are connected. Now there is."
The Less=More coalition presents Follow the Manure for use by policymakers and agricultural producers to aid in understanding of the issues at play in the WLEW and to facilitate efforts to solve Lake Erie's algae problem. To this end, the report contains several recommendations for key first steps to tackle the impacts of CAFO waste in the WLEW. These steps include: declaring Lake Erie an impaired watershed; ending the practice of giving federal taxpayer dollars to polluting CAFOs; changing the phosphorus soil-test requirements; and banning the application of CAFO waste on frozen or snow-covered ground within the WLEW.
A copy of "Follow the Manure: Factory Farms and the Lake Erie Algae Crisis" can be downloaded at http://www.sierraclub.org/michigan/lessmore-reports.
Less=More is a coalition of organizations engaged in diverse aspects of our food system and seeking to level the playing field for sustainable farming in Michigan. Less support for polluting factory farms means a more sustainable Michigan. For more information, please visit MoreforMichigan.org<http://moreformichigan.org/>.
Members of the Less=More Coalition include: Beery Farms of Michigan, LLC, the Center for Food Safety, Crane Dance Farm, LLC, ELFCO food cooperative, Environmentally Concerned Citizens of South Central Michigan, Food & Water Watch, Greater Grand Rapids Food Systems Council, Groundswell Farm, Zeeland, Humane Society of the United States, Michigan Voices for Good Food Policy, Michigan Young Farmers Coalition, Sierra Club Michigan Chapter and Socially Responsible Agricultural
ptaylor001 has files to share with you on OneDrive. To view them, click the links below.
[https://a.gfx.ms/ftype/v4/pdf.png] Follow the Manure (FINAL) 11.19.15.pdf <https://onedrive.live.com/redir.aspx?cid=905e55fad267e6fa&parentid=905E55FAD267E6FA%211341&parId=905E55FAD267E6FA%21165&authkey=%21AMpvyFuLliHd0lo&ithint=folder%2c&resid=905E55FAD267E6FA%211334>
[https://a.gfx.ms/ftype/v4/pdf.png] Follow the Manure Appendix (FINAL) 11.19.15.pdf <https://onedrive.live.com/redir.aspx?cid=905e55fad267e6fa&parentid=905E55FAD267E6FA%211341&parId=905E55FAD267E6FA%21165&authkey=%21AMpvyFuLliHd0lo&ithint=folder%2c&resid=905E55FAD267E6FA%211335>
Thursday, November 26, 2015
Victory! Agent Orange Crops Halted
From: Center for Food Safety <office@centerforfoodsafety.org<mailto:office@centerforfoodsafety.org>>
Date: November 25, 2015 at 17:39:38 EST
Date: November 25, 2015 at 17:39:38 EST
In response to CFS litigation, the Environmental Protection Agency (EPA) has announced it is revoking the registration of "Enlist Duo," a toxic pesticide designed to be used with genetically engineered "Agent Orange" crops!
Responding to a lawsuit brought by Center for Food Safety and Earthjustice, yesterday EPA announced it is revoking the registration of "Enlist Duo," a toxic combination of glyphosate and 2,4-D – the main ingredient in Agent Orange.
Approved by the agency just over a year ago, Dow's Enlist Duo was created for use on the next generation of genetically engineered (GE) crops, what we dubbed "Agent Orange crops", designed to withstand being drenched with this potent herbicide cocktail. In its court filing, EPA stated it is taking this action after realizing that the combination of these chemicals is likely significantly more harmful than it had initially believed.
EPA had approved use of Enlist Duo in Illinois, Indiana, Iowa, Ohio, South Dakota, Wisconsin, Arkansas, Kansas, Louisiana, Minnesota, Missouri, Mississippi, Nebraska, Oklahoma, and North Dakota, and had intended to approve it in additional areas in the near future.
Dow created Enlist crops as a quick fix for the problem created by "Roundup Ready" crops, the previous generation of genetically engineered crops designed to resist the effects of glyphosate, the active ingredient in Monsanto's Roundup herbicide. Just as overuse of antibiotics has left resistant strains of bacteria to thrive, repeated use of Roundup on those crops allowed glyphosate-resistant "superweeds" to proliferate, and those weeds now infest tens of millions of acres of U.S. farmland. Enlist crops allow farmers to spray both glyphosate and 2,4-D without killing their crops, which they hope will kill weeds resistant to glyphosate alone. But some weeds have already developed 2,4-D resistance, and the escalating cycle of more toxic pesticides in the environment will continue unless EPA stops approving these chemicals, and USDA stops rubber-stamping new genetically engineered crops.
The decision by EPA to withdraw the illegally approved Enlist Duo crops is a huge victory for the environment and the future of our food!
Thanks for your support. We are so grateful to be able to share this tremendous victory with you!
- the Center for Food Safety team
Read more about this victory: http://www.centerforfoodsafety.org/press-releases/4144/epa-pulls-registration-for-dows-enlist-duo-herbicide-citing-high-toxicity-levels<http://salsa3.salsalabs.com/dia/track.jsp?v=2&c=I5f99RLJwtHxc150NPeUl%2Fa0q2ImMd9F>
Contact Us
CFS welcomes your questions and comments. Please contact us at office@centerforfoodsafety.org<mailto:office@centerforfoodsafety.org>, or at one of our offices.
Donate<http://salsa3.salsalabs.com/dia/track.jsp?v=2&c=ypDDUj0aFxfTzzvp1ZA8a%2Fa0q2ImMd9F>
National Headquarters
660 Pennsylvania Ave, SE, #302
Washington, DC 20003
phone (202) 547-9359 | fax (202) 547-9429
www.centerforfoodsafety.org<http://salsa3.salsalabs.com/dia/track.jsp?v=2&c=Nhmvgy9BoLx9dwLVGUbxLva0q2ImMd9F>
[empowered by Salsa]<http://www.salsalabs.com/?email>
Responding to a lawsuit brought by Center for Food Safety and Earthjustice, yesterday EPA announced it is revoking the registration of "Enlist Duo," a toxic combination of glyphosate and 2,4-D – the main ingredient in Agent Orange.
Approved by the agency just over a year ago, Dow's Enlist Duo was created for use on the next generation of genetically engineered (GE) crops, what we dubbed "Agent Orange crops", designed to withstand being drenched with this potent herbicide cocktail. In its court filing, EPA stated it is taking this action after realizing that the combination of these chemicals is likely significantly more harmful than it had initially believed.
EPA had approved use of Enlist Duo in Illinois, Indiana, Iowa, Ohio, South Dakota, Wisconsin, Arkansas, Kansas, Louisiana, Minnesota, Missouri, Mississippi, Nebraska, Oklahoma, and North Dakota, and had intended to approve it in additional areas in the near future.
Dow created Enlist crops as a quick fix for the problem created by "Roundup Ready" crops, the previous generation of genetically engineered crops designed to resist the effects of glyphosate, the active ingredient in Monsanto's Roundup herbicide. Just as overuse of antibiotics has left resistant strains of bacteria to thrive, repeated use of Roundup on those crops allowed glyphosate-resistant "superweeds" to proliferate, and those weeds now infest tens of millions of acres of U.S. farmland. Enlist crops allow farmers to spray both glyphosate and 2,4-D without killing their crops, which they hope will kill weeds resistant to glyphosate alone. But some weeds have already developed 2,4-D resistance, and the escalating cycle of more toxic pesticides in the environment will continue unless EPA stops approving these chemicals, and USDA stops rubber-stamping new genetically engineered crops.
The decision by EPA to withdraw the illegally approved Enlist Duo crops is a huge victory for the environment and the future of our food!
Thanks for your support. We are so grateful to be able to share this tremendous victory with you!
- the Center for Food Safety team
Read more about this victory: http://www.centerforfoodsafety.org/press-releases/4144/epa-pulls-registration-for-dows-enlist-duo-herbicide-citing-high-toxicity-levels<http://salsa3.salsalabs.com/dia/track.jsp?v=2&c=I5f99RLJwtHxc150NPeUl%2Fa0q2ImMd9F>
Contact Us
CFS welcomes your questions and comments. Please contact us at office@centerforfoodsafety.org<mailto:office@centerforfoodsafety.org>, or at one of our offices.
Donate<http://salsa3.salsalabs.com/dia/track.jsp?v=2&c=ypDDUj0aFxfTzzvp1ZA8a%2Fa0q2ImMd9F>
National Headquarters
660 Pennsylvania Ave, SE, #302
Washington, DC 20003
phone (202) 547-9359 | fax (202) 547-9429
www.centerforfoodsafety.org<http://salsa3.salsalabs.com/dia/track.jsp?v=2&c=Nhmvgy9BoLx9dwLVGUbxLva0q2ImMd9F>
[empowered by Salsa]<http://www.salsalabs.com/?email>
Rover posting to FERC
From: Frank Zaski
Date: November 25, 2015 at 11:39
Subject: Rover posting to FERC
This was just posted to FERC to counter the demands of Rover and 3 shippers to pull ahead the timing for the final EIS and approval.
Rover assumes FERC will approve their application and that nothing in the EIS will delay or deter them. Rover has even set a DEADLINE FOR FERC TO APPROVE ROVER, "no later than the second quarter of 2016." (Roughly a 5-6 month pull ahead.) http://elibrary.ferc.gov/idmws/file_list.asp?accession_num=20151109-5038
Unlike Rover, many people think FERC approvals are not automatic and depend on a thorough evaluation of all factors.
Rover states that the "numerous pipeline certificate applications" are evidence of lack of pipelines. On the contrary, perhaps they represent the irrational speculation and poor planning that has plagued this industry for years.
However, THIS application is not about "numerous pipelines" but specifically Rover. Energy Transfer has not provided enough specific facts to prove Rover is justified, especially north of Defiance, OH.
If there really was a pipeline shortage, there would be high gas prices and low working gas storage levels. As it is, hub prices are below average, and the US is awash with natural gas with working gas storage at a record 4,000 Bcf level. All parts of the US have gas storage levels above their 5 year averages. http://ir.eia.gov/ngs/ngs.html?src=email
The substantial Marcellus price differential is being caused by Marcellus drilling companies blindly seeking production volumes rather than value. The pipeline companies are complicit. Economics dictates excessive production results in excessively low prices.
Over speculation and production has resulted in many gas drillers having risky debt levels and poor credit ratings. It is probably that some will not be able to fulfill their commitments.
http://www.capitalcube.com/blog/index.php/range-resources-corp-value-analysis-nyserrc-november-18-2015/
Shipper/drillers requests to pull ahead the Rover EIS should be evaluated considering FERC's own policy, "the Commission's traditional factors for establishing the need for a project, such as contracts and precedent agreements, MAY NO LONGER BE A SUFFICIENT INDICATOR that a project is in the public convenience and necessity." https://www.ferc.gov/legal/maj-ord-reg/PL99-3-001.pdf
And regarding the long view…
The DOE reports the US needs only "relatively modest interstate pipeline capacity additions (2.2–2.7 Bcf/d annually between 2015 and 2020). These "are potentially lower-cost alternatives to building new infrastructure and can accommodate a significant increase in natural gas flows."
http://energy.gov/sites/prod/files/2015/02/f19/DOE%20Report%20Natural%20Gas%20Infrastructure%20V_02-02.pdf
Few new pipelines are needed to meet the proposed Clean Power Plan. The EPA expects the proposed "Plan to increase natural gas use for electric generation by 1.2 Tcf in 2020, declining over time." http://www2.epa.gov/sites/production/files/2014-06/documents/20140602ria-clean-power-plan.pdf
A study finds new natural gas pipelines are NOT needed even in New England.
http://www.berkshireeagle.com/local/ci_29134769/new-gas-pipelines-not-needed-region-energy-report
Rover's hopes for LNG EXPORT may be dashed. Many analysts predict few new US and Canadian LNG export facilities will be built. From an SNL analysis of worldwide LNG overbuild, "The new consensus<https://www.snl.com/InteractiveX/article.aspx?ID=33750706> among analysts and other industry observers that the global LNG market will be oversupplied<https://www.snl.com/InteractiveX/article.aspx?ID=33795399> in the near term could mean that expansions of U.S. export projects constitute an overbuild." https://www.snl.com/InteractiveX/article.aspx?CDID=A-34491752-12842&KPLT=4 Longer term, even more foreign LNG capacity is coming. http://www.eia.gov/naturalgas/weekly/?src=email
It is up to FERC to consider ALL factors NO MATTER HOW LONG IT TAKES to conduct a thorough review of Rover.
Based on available information, it appears the economic, social and environmental COSTS OF ROVER FAR OUTWEIGH ANY BENEFITS.
FERC, thank you for your thorough review of Rover and for asking the right questions.
Date: November 25, 2015 at 11:39
Subject: Rover posting to FERC
This was just posted to FERC to counter the demands of Rover and 3 shippers to pull ahead the timing for the final EIS and approval.
Rover assumes FERC will approve their application and that nothing in the EIS will delay or deter them. Rover has even set a DEADLINE FOR FERC TO APPROVE ROVER, "no later than the second quarter of 2016." (Roughly a 5-6 month pull ahead.) http://elibrary.ferc.gov/idmws/file_list.asp?accession_num=20151109-5038
Unlike Rover, many people think FERC approvals are not automatic and depend on a thorough evaluation of all factors.
Rover states that the "numerous pipeline certificate applications" are evidence of lack of pipelines. On the contrary, perhaps they represent the irrational speculation and poor planning that has plagued this industry for years.
However, THIS application is not about "numerous pipelines" but specifically Rover. Energy Transfer has not provided enough specific facts to prove Rover is justified, especially north of Defiance, OH.
If there really was a pipeline shortage, there would be high gas prices and low working gas storage levels. As it is, hub prices are below average, and the US is awash with natural gas with working gas storage at a record 4,000 Bcf level. All parts of the US have gas storage levels above their 5 year averages. http://ir.eia.gov/ngs/ngs.html?src=email
The substantial Marcellus price differential is being caused by Marcellus drilling companies blindly seeking production volumes rather than value. The pipeline companies are complicit. Economics dictates excessive production results in excessively low prices.
Over speculation and production has resulted in many gas drillers having risky debt levels and poor credit ratings. It is probably that some will not be able to fulfill their commitments.
http://www.capitalcube.com/blog/index.php/range-resources-corp-value-analysis-nyserrc-november-18-2015/
Shipper/drillers requests to pull ahead the Rover EIS should be evaluated considering FERC's own policy, "the Commission's traditional factors for establishing the need for a project, such as contracts and precedent agreements, MAY NO LONGER BE A SUFFICIENT INDICATOR that a project is in the public convenience and necessity." https://www.ferc.gov/legal/maj-ord-reg/PL99-3-001.pdf
And regarding the long view…
The DOE reports the US needs only "relatively modest interstate pipeline capacity additions (2.2–2.7 Bcf/d annually between 2015 and 2020). These "are potentially lower-cost alternatives to building new infrastructure and can accommodate a significant increase in natural gas flows."
http://energy.gov/sites/prod/files/2015/02/f19/DOE%20Report%20Natural%20Gas%20Infrastructure%20V_02-02.pdf
Few new pipelines are needed to meet the proposed Clean Power Plan. The EPA expects the proposed "Plan to increase natural gas use for electric generation by 1.2 Tcf in 2020, declining over time." http://www2.epa.gov/sites/production/files/2014-06/documents/20140602ria-clean-power-plan.pdf
A study finds new natural gas pipelines are NOT needed even in New England.
http://www.berkshireeagle.com/local/ci_29134769/new-gas-pipelines-not-needed-region-energy-report
Rover's hopes for LNG EXPORT may be dashed. Many analysts predict few new US and Canadian LNG export facilities will be built. From an SNL analysis of worldwide LNG overbuild, "The new consensus<https://www.snl.com/InteractiveX/article.aspx?ID=33750706> among analysts and other industry observers that the global LNG market will be oversupplied<https://www.snl.com/InteractiveX/article.aspx?ID=33795399> in the near term could mean that expansions of U.S. export projects constitute an overbuild." https://www.snl.com/InteractiveX/article.aspx?CDID=A-34491752-12842&KPLT=4 Longer term, even more foreign LNG capacity is coming. http://www.eia.gov/naturalgas/weekly/?src=email
It is up to FERC to consider ALL factors NO MATTER HOW LONG IT TAKES to conduct a thorough review of Rover.
Based on available information, it appears the economic, social and environmental COSTS OF ROVER FAR OUTWEIGH ANY BENEFITS.
FERC, thank you for your thorough review of Rover and for asking the right questions.
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