A Letter to Senators Warren and Markey

Sen. Warren and Sen. Markey:

With regards to your joint letter to FERC Chairman LaFleur in which you stated that the West Roxbury community was not sufficiently included in the WRL review process and asked for more responsiveness from FERC to fears of West Roxbury abutters: your response was qualitatively different from taking a position that the entire plan is dangerous and flawed. You as Senators have oversight as well as legislative responsibility with regards to FERC. Why have you delegated this responsibility to your constituents when you have this leverage?

As residents of West Roxbury, we continue to state our opposition to the planned Spectra/ Algonquin Gas AIM West Roxbury Lateral based upon the following documented issues:

1-The potential devastation that could be caused by intentional Intrusion of the WRL. The West Roxbury Lateral, due to its location within the densely-populated Dedham and West Roxbury communities is considered a Level 3 high-consequence project. TSA/Homeland Security labels such natural gas infrastructure a “high-value terrorist target”. A purposeful intrusion into this infrastructure, specifically the meter and regulating station, with a simple two turns of a wrench, would result in the immediate catastrophic loss of the lives of 1500-2000 residents of West Roxbury.

2-The prospect of a quarry blasting, over time could unsettle the buffer soil and pipeline and set off a catastrophic explosion. As Sen. Markey has noted, in the last 10 years there’ve been many explosions killing hundreds of people from these pipelines. According to the Final EIS, “outside force, excavation, and natural forces are the cause in 34.5 percent of significant pipeline incidents. These result from the encroachment of mechanical equipment such as bulldozers and backhoes; earth movements due to soil settlement, washouts, or geologic hazards; weather effects such as winds, storms, and thermal strains; and willful damage”. As reported in the Final EIS, the focus of the analysis performed by GZA (2014) was on the potential for ground vibrations to impact the pipeline at any given time. No conclusions were drawn by GZA regarding the long term effects on the integrity of the WRL due to repeated blasting by the quarry over a period of time.



Please refer to Title 49: Transportation
PART 192—TRANSPORTATION OF NATURAL AND OTHER GAS BY PIPELINE: MINIMUM FEDERAL SAFETY STANDARDS
Federal Regulation: §192.317 Protection from hazards.

“The operator must take all practicable steps to protect each transmission line or main from… unstable soil, or other hazards that may cause the pipeline to move or to sustain abnormal loads”.

This federal (PHMSA) regulation is absolutely relevant to the plan for the WRL to be subject to regular blasting in close proximity to an active quarry.

“This language was clearly written to protect against transmission lines from being installed in locations where there exist known hazards that will cause the pipeline to move (regularly) known as “slips” (when a transmission pipeline moves creating a hairline crack). There is no question in my mind that this pipeline will “move” each time blasting occurs, as will the soil supporting this heavy and dangerous pipeline if disturbed.” Mark McDonald, NatGas Consulting

3-The Final EIS states in section 5.1.1 Geology and Paleontological Resources:
“In addition, it should be noted that existing pipelines currently operate in Grove Street between the quarry and the proposed AIM Project facilities. We have found no evidence that these existing pipelines have been impacted by quarry activities.”

Point of fact, National Grid’s own list of gas leaks document that this statement is incorrect. Dozens of gas leaks exist within a radius of .30 mi of the West Roxbury Crushed Stone Quarry.

“When science is done right, it is an honest and transparent pursuit of discovery that advances knowledge, not a clandestine effort to achieve the outcome a company desires”.
Senator Edward Markey, March 3, 2015

4-The repair of the existing National Grid gas distribution infrastructure should more than meet National Grid’s needs. The AIM West Roxbury Lateral should not be considered. Instead priority should be given to the repair of the gas leaks in National Grid’s existing natural gas distribution infrastructure.

The Boston Globe reported January 22, 2015:
“The amount of methane leaking from natural gas pipelines, storage facilities, and other sources in the Boston area is as much as three times greater than previously estimated — a loss that contributes to the region’s high energy costs and adds potent greenhouse gases to the atmosphere, according to a new study by scientists at Harvard University. The leaks would be enough to heat as many as 200,000 homes a year and are valued at $90 million a year, the authors said.” National Grid is on record forecasting that the projections for their future gas customers in Boston Is 164,000.

http://www.bostonglobe.com/metro/2015/01/22/natural-gas-leaks-boston-are...
The above conclusions were a confirmation of data compiled from a 2012 study conducted by scientists from Boston and Duke Universities that identified all the existing leaks in National Grid’s gas lines:

http://mobile.nytimes.com/blogs/dotearth/2012/11/20/mapping-gas-leaks-fr...
Refer to the Google Map of Natural Gas Leaks

http://www.edf.org/climate/methanemaps
Sen. Markey’s office itself published an exhaustive report, “America Pays for Gas Leaks” in July 2013, which confirmed the economic loss generated by these gas leaks, but also detailed the health and safety issues the gas leaks precipitate.

http://www.clf.org/wp-content/uploads/2013/08/Markey-Gas-Leaks-Report-2.pdf

We are not driving a NIMBY argument. High-pressure natural gas infrastructure does not belong in any densely-populated area!

Senators Markey and Warren, we need you both to join with Congressman Stephen Lynch and Boston Mayor Marty Walsh and take steps to oppose the West Roxbury Lateral: to protect our community, as well as any densely-populated communities, from this wasteful, very dangerous natural gas project.

Sincerely,

Howard Sorett