Records maintained by the Pennsylvania Department of Environmental Protection show that drilling of wells in the Marcellus Shale increased by nearly 400 percent between 2008 and 2009, from 195 wells to 768 wells.1 The increased development is not limited to the drilling of wells. FERC has reported that 5.6 billion cubic feet per day of pipeline capacity was constructed in the Northeast in 2008 and 2009, and an additional 1.2 billion cubic feet per day will have been constructed in the region by January 2011.2 According to FERC, “[m]uch of the new pipeline capacity in the area is targeted at improving the access of shale gas to markets.”3 Thus, the proposed Project is both a product of the development of the Marcellus Shale and a likely catalyst for further gas development. The impacts of the Project cannot be understood apart from the totality of the past, present, and reasonably foreseeable future actions associated with Marcellus Shale development.
FERC must require a full Environmental Impact Statement that analyzes the extensive and egregious impacts the Project threatens on water resources, forest ecosystems, habitats, air quality, and parks and open space. The NEPA document must assess cumulative and secondary impacts. To do so, the analysis must be thorough and objective.
There is also evidence that pipeline construction and operation could significantly impact habitat for the highly endangered Indiana Bat. Bat populations in our region have plummeted as a result of White Nose Syndrome and the pipeline will pass near and through some of the few remaining areas where this endangered species exists. ....Elsewhere we have seen pipeline rights-of-way impacted and eroded by all-terrain vehicle (ATV) use. Illegal trespass by ATV users is epidemic in our region. Our organization’s wildlife sanctuary has suffered from these high impact machines. The pipeline corridor will invite more illegal ATV use in our area by providing easy access to private land. The impacts from this activity must be considered.
The Delaware-Otsego Audubon Society’s position on the process of high volume, slick water
hydrofracking is to ban this dangerous polluting technology, which does not benefit the greater good,
but promotes corporate profit. The proposed construction of the Constitution Pipeline through local
regions of the Marcellus Shale will provide the infrastructure necessary to support this invasive
technology in the New York counties it would cross.
DOAS further believes that the construction, maintenance and other activities associated with the
Constitution pipeline on the preferred route and the alternative M route will have an irreversible
negative impact upon deciduous and mixed forests, wetlands such as bogs, marshes, swamps,
moving and standing water including rivers, streams, and woodland ponds or vernal pools -
considered the “coral reefs” of the Northeast Forests.
Three state parks will be impacted by the proposed alternative routes of the Constitution Pipeline Project.
Max V. Shaul State park
Mine Kill State Park
Robert V. Riddell State Park
We find that insufficient evidence has been provided to support a determination of public need for this project.
... the proposed pipeline route, and attendant infrastructure, would very likely disturb or negatively impact significant historic, cultural and archaeological resources related to the early settlement of our country and the westward expansion of the American frontier. While Otsego County is arguably one of the most documented counties in New York State with regard to historic and cultural structures, sites and landscapes, it still has only about 20% of its historic resources documented.
...Whether or not the applicant acknowledges it as an objective, hydraulic fracturing is a reasonably foreseeable result of permitting a new pipeline corridor within this region of upstate New York underlain by the Marcellus and Utica shale layers.
Given the proximity of the oroject to known critical rattlesnake habitat, we recommend that a timber rattlesnake habitat assessment be conducted in the project area, in the project segment skirting Taylor Hill (NE of Susquahanna) between Canawacta Creek and Starucca Creek, by a PFBC recognized/qualified timber rattlesnake surveyor.