Comments to FERC on Cummins Hill (Northeast Extension)

January 13, 2012

The mission of the Delaware Highlands Conservancy is to work with landowners and communities of Pike and Wayne Counties in PA and Sullivan and Delaware Counties in NY to protect the lands, waters, and locally sustainable economies of the Upper Delaware River region.

We are concerned about the Cummins Hill Loop Pipeline project because of its obvious adverse impacts on the lands, waters, and communities of Pike County.

Because the Cummins Hill Loop Pipeline project as it is proposed by the Tennessee Gas Pipeline Northeast Upgrade Project in general and the Loop 323 section specifically would necessarily cut through healthy forests, 80 percent slopes, Exceptional Value streams, important habitats, and most likely disturb nesting eagles, the Delaware Highlands Conservancy strongly recommends FERC conduct a more thorough review of the project than thus far has been conducted.

We recommend that FERC fulfill the requirements of the National Environmental Policy Act which requires that the full extent of environmental impacts, including cumulative impacts, be considered when making the requisite analysis of the adverse impacts weighed against public benefits. FERC should not allow Tennessee Gas Pipeline to avoid accurate environmental review by “segmentation”, or cutting up the pipeline review into small parts as opposed to doing a comprehensive analysis.