Pipelines Across the Delaware

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1 Pipelines Across the Delaware Protecting Coldwater Ecosystems from Natural Gas Pipeline Impacts

2 Understanding the Setting: Pipeline Predictions TNC report: PA could see up to 27,000 miles of new gathering lines by 2030 Gathering lines are meeting up with transport lines where Delaware watershed will see impacts 2

3 Pipelines in the East 3

4 Pipelines in the Delaware River Watershed What s missing? TGP-NED Linden Pipelines in the DRW. Map source: Sam Koplinka- Loehr, Clean Air Council 4

5 A little closer to home Linden Energy Services: 12 miles to connect TGP line to Millennium O&W railroad construction ROW; 75 permanent ROW 16 lines - 2 natural gas lines; 1 water line 180 day survey being done; easement negoations not subject to public notification laws APPROVALS NEEDED? 5

6 Pipeline Impacts on Coldwater Ecoystems

7 Potential Impacts on Streams, Water Quality & Aquatic Life Erosion & sedimentation creating turbidity in streams Removing vegetation on steep slopes, draining to waterways Upland development (paralleling stream) ATWS close to stream Removal of riparian buffers Turbidity: NY numerical stds; PA narrative stds 7

8 Potential Impacts on Streams, Water Quality & Aquatic Life CONSTRUCTION: Stream crossings and alteration In-stream construction (short-term impacts, sometimes) type of crossing method construction time period filtration seasonal restrictions for spawning fish bentonite blowout PHOTO: notennesseepipeline.org PHOTO: Washington Co. Observer-Reporter 8

9 Potential Impacts on Streams, Water Quality & Aquatic Life Water Withdrawals for Hydrostatic Testing DRBC approval Volume of water (over what time), seasonal restrictions, ecosystem flows or standard Q710? Discharge of hydrostatic testing water Sediment Water temperature 9

10 Potential Impacts on Streams, Water Quality & Aquatic Life RESTORATION: Stream crossings and alteration Long-term impacts Depth of buried pipe Restoration (long-term impacts resulting in channel migration, scour and downstream flooding) wetlandnotes.com 10

11 Potential Impacts on Streams, Water Quality & Aquatic Life Long-term & Cumulative impacts Multiple stream crossings in one watershed (from same or different pipelines) Loss of forest cover in headwaters Loss of riparian cover Effect on hydrologic regime Water quality death by 1000 cuts 11

12 Who regulates what?

13 Federal agencies & DRBC: interstate pipelines PERMITS/APPROVALS FERC approval: Certificate of Public Convenience & Necessity US Army Corps of Engineers: CWA 404 permit (individual, programmatic general (PA)or nationwide) streams and wetlands DRBC: water withdrawal/hydrostatic testing CONSULTATION USFWS: T&E species 13

14 State agencies: interstate pipelines PENNSYLVANIA approvals/permits CWA 401 WQC CWA 402 NPDES hydrostatic test water discharge Ch. 105 dam and encroachment CWA 402 NPDES /Ch. 102 erosion and sedimentation control/stormwater (CCD review & inspections) Consultation Clearance state T&E species NEW YORK approvals/permits CWA 401 WQC SPDES for stormwater discharge Part 601 Water Resources permit (hydrostatic testing) WWD reporting form Consultation Clearance state T&E species 14

15 Untapped Opportunities to Address Landscape-scale Impacts & Cumulative Impacts

16 Cumulative Impacts: Individual Pipelines Recommendations for limiting individual and cumulative impacts to stream systems and aquatic life during planning, construction and restoration Smaller ROWs Identify type of crossing (specifically, what type of dry crossing) Avoid wet crossings Seasonal restrictions and contingency plans (e.g. pumps with sufficient capacity) Locate streams crossings downstream of confluence Collect critical stream characteristic data during surveys and use to inform stream crossing and restoration methods Scour depth analysis Avoid steep slopes and highly erodible soils Neck down ROW at crossing, replant riparian areas Limit work space and disturbance near stream 16

17 Cumulative Impacts: Individual Pipelines Advocacy in federal and state processes: 404 permit: stream encroachments 401 permit: state certification that the proposed activity and discharge will comply with water quality standards as well as the other identified provisions of the CWA 17

18 Cumulative Impacts: Individual Pipelines Pro-actively seek increased protections through state water quality or fisheries designations PA: Streams with Class A or Wild Trout Stream status receive HQ or EV protections in permitting process ~200 streams assessed; ~45% found to hold naturally reproducing trout populations; more than 295 stream miles added to WTS list this year NY: Urge DEC to update designations based upon monitoring reports Angler monitoring: before, during and after construction 18

19 Cumulative Impacts: Multiple Pipelines/Landscape Scale Increased state engagement/cooperation in FERC processes Urge Programmatic EIS allows consideration of pipelines across multiple states/jurisdictions Ex. MVP/ACP (VA/WV) Constitution/TGP NED 19

20 Cumulative Impacts: Multiple Pipelines/Landscape Scale Landscape conservation planning & analysis: Identify high priority ecological areas where pipeline infrastructure should be avoided 20

21 Thank you for your time! Katy Dunlap, Esq. Eastern Water Project Director Trout Unlimited