Jan 292016


Urgent, Rapid Response Needed – A Short Weekend Homework Assignment

Dear Seneca Lake Defenders,

We have just learned that Crestwood’s subsidiary, Arlington Storage, has asked the Federal Energy Regulatory Commission (FERC) for a two-year extension on their methane storage expansion project at Seneca Lake. (The original order expires on May 15th.) This provides us with a golden opportunity—with an extremely short window—to get FERC to deny this request and, hence, stop the project in its tracks, but we need your immediate help.

FERC’s approval of Crestwood/Arlington’s plan to greatly expand methane (natural gas) storage in the Seneca Lake salt caverns was, as you will recall, the trigger for We Are Seneca Lake’s campaign in October 2014. To date, Crestwood/Arlington has not broken ground on that project. But the federal permission that it has to get its project up and running comes with a deadline. Unless the company can secure an extension, the expiration date is May.

Please note that the Arlington project is specific to natural gas (methane). This does not directly affect Crestwood’s other project, which seeks approval for the storage of LPG (propane and butane), for which FERC is not involved.

FERC could approve Arlington’s request as early as this coming Monday, so we need to act quickly. We have a two-pronged approach that requires hundreds of us to act—and act without delay. Thus, your two-part homework assignment:

  1. Call Governor Cuomo. Ask him to tell FERC to NOT issue a 2-year extension to Crestwood’s Subsidiary, Arlington Storage, for their natural gas expansion project on Seneca Lake. Dial 1-518-474-8390. Choose option 3 to talk to a live person. (Expanded talking points below.) Calls are already streaming in to the Governor’s office, and we must keep the pressure up all weekend and on Monday too. After business hours and on the weekend, you can leave phone messages.
  1. Flood FERC with your own comments. Submit comments electronically into the docket Arlington Storage Company, LLC,

Docket No. CP13-83-000. Ask FERC to deny Arlington’s application for a 2-year extension to construct expanded gas storage on Seneca Lake.

 Your comments need to be submitted right into the docket. That takes a few steps, but it’s not difficult. Here’s how to do it:

Step 1: Write your letter using your word processor (MS Word, etc) or a text file. (See talking points below for ideas of what you might say.)

Step 2: Go to FERC’s web site: http://www.ferc.gov/docs-filing/ecomment.asp

Step 3: Click anywhere in the box that says “eComment: Does not require eRegistration” (The “eComment” text has a bright orange background).

Step 4: Fill out the form with your name, address, etc. FERC will send you an email message.

Step 5: Go to your email app. Open the message from FERC (“FERC eComment Request” is the subject line”.)

Step 6: Click on the link in FERC’s message.

Step 7: You’ll see the information you entered earlier (name, address, etc). Paste the text of the letter you wrote into the empty text box at the bottom of the form.

Talking Points for Call and Comment Writing

We know weekend time is precious, so we’ve provided talking points to prime the pump and make your comment writing easier. First, tell FERC clearly what you want it to do; namely,

  • Request that FERC deny Arlington Storage Company LLC an extension for their methane storage expansion project.

Then provide a reason why FERC should do this. Choose any one or two of the reasons below or provide your own. Keep in mind that your comments must be specific to salt cavern storage of methane (natural gas). LPG storage or transportation is not relevant here.

If you have already written a statement as a defender, please feel free to include it! If you have ever written a letter to the editor or explained why you oppose natural gas storage expansion, you can re-use it. Otherwise here are nine possible ideas. Again, choose just one or two and put them in your own words.

  1. Arlington has had plenty of time to ensure that it could meet its construction deadline of May 15, 2016, but instead, sat on its rights. Arlington has not shown good cause why it should be granted another two years to construct a facility that was authorized almost two years ago. Arlington has been on notice since May 15, 2014, that it was required to put its facility into service by May 15, 2016, and yet has taken no meaningful steps to initiate construction. The Commission should hold Arlington to the stated terms of the Certificate Order.
  1. Market conditions have changed. We now have a glut of gas, and natural gas prices have plummeted. The area around the storage project has not experienced the price spikes that allegedly justified expansion of Arlington’s facility. Therefore, the need assessment FERC did in 2014 is no longer valid, and the project is no longer “in the public convenience and necessity.” Arlington is not entitled to keep the project in the pipeline in the hope that market conditions will change. The fact that the market may be more favorable sometime in the next two years is not “good cause” for extending the deadline for Arlington’s project. There is currently no genuine demand for Arlington’s product, which is a clear indication that “public convenience and necessity” do not justify this project.
  1. The community does not want the project. 31 municipalities, representing 1.2 million New York residents, have passed resolutions opposing hydrocarbon storage on the shores of Seneca Lake. Say why you personally don’t want it.
  1. Given both the community’s concerns, and the lack of need for more storage, the project cannot be said to be in the public interest.
  1. If Arlington wants another two years to build this project, FERC should deny the extension, rescind the order authorizing construction, and Arlington should start the application process over again. There’s a reason there’s a time limit on FERC’s orders.
  1. Methane is a powerful greenhouse gas and contributes to the destruction of our climate. Since Arlington received its original approval, all the nations of the world have agreed to move away from fossil fuels as part of the Paris Agreement. More new natural gas infrastructure takes us in the wrong direction.
  1. Underground storage of natural gas is inherently dangerous, as illustrated by the ongoing disaster in Porter Ranch, California at the Aliso Canyon gas storage facility. Storing gas in salt caverns is relatively rare and has a bad track record. There is an unacceptable history of leakage, collapse or explosion, as in, for example, Hutchinson, Kansas and Livingston County, New York.
  1. This project is located in the wrong place. Seneca Lake is a source of drinking water for 100,000 people. Arlington wants to increase gas storage—a seven-fold increase of capacity—on the banks of Seneca Lake, only a few hundred yards from the lake’s shoreline and less than 5 miles north of Watkins Glen, which is visited by over half a million tourists annually, and on the western Seneca Wine Trail. Arlington’s plan would snarl the wine trail with industrial-scale traffic.
  1. This project threatens the Finger Lakes’ sustainable economy based on tourism and recreation that brings over $4.8 billion annual revenue to NY State.