DEIS Wetlands - Bullet Points

Return to DEIS Page

4.4 Wetlands

  • “Transco identified and delineated wetlands along the proposed pipeline route during field surveys in 2014.” However, “For areas where Transco was unable to complete surveys in the 2014 and 2015 field seasons, remote-sensing resources were used to approximate the locations and boundaries of wetlands within the project area.” <span style="color: red;">So, how is FERC okay with a wetlands analysis based on a research methodology of approximation?</span> (4-69)
  • Transco’s surveys identified a “total of 50.4 acres” that “would either be crossed by the project, affected by temporary extra workspace, or located within the construction right-of- way.” (4-69)
  • Of those 50.4 (approximate) acres, 48.2 acres are in PA. Again, “Transco did not have access to survey all parcels; therefore, the total acreages were determined through a combination of field survey data and remote sensing.” (4-70)
  • ”The proposed temporary access roads would cross 12 wetlands. However, Transco argues that the impacts would be minimal due to their proposed use of “free-span bridges at temporary access road crossings to avoid wetland impacts.” (4-70).
  • The Pennsylvania pipeline facilities (CPL North, CPL South, Chapman Loop, and Unity Loop) would cross 251 wetlands.” Of these, 153 are classified as palustrine emergent; 13 palustrine scrub-shrub; 41 palustrine forested; 44 have more than one wetland classification)
  • “Exceptional value wetlands are given special protection in the state of Pennsylvania by the PADEP under Pennsylvania Code Title 25 (Pennsylvania Code, 1991)” (4-71)\
  • Note: “Fifty-one of the wetlands crossed by the proposed pipelines in Pennsylvania are classified as exceptional value, with 15 of these containing a forest component.” (4-71). This means that fully 1 in 5 (or 20%) of all wetlands being crossed by this proposed line in PA are designated as “exceptional value wetlands.” What does “special protection” of “exceptional value wetlands” mean if they are not, in fact, protected from a project as invasive and permanently destructive as this pipeline project?
  • “The project would cross eight forested wetlands…that are characteristic of the Hemlock/Mixed Hardwood Palustrine Forest  community type, which the PADCNR identified as a natural or special concern community type due to a restricted range, relatively few populations, recent and widespread declines, or other factors making them at risk of extirpation in Pennsylvania” (4-71). The obvious question here: Why, then, aren’t these areas protected altogether against such a project?
  • In wetland areas, “Construction would be conducted in accordance with Transco’s ECP” (4-71). Question: Why is FERC willing to allow Williams, the company responsible for inflicting harm on these wetlands, to determine the guidelines by which construction in wetlands will take place? Why wouldn’t an independent party be contracted to determine construction guidelines for these highly sensitive areas?
  • NOTE: According to Transco’s assessment, 15 of the “exceptional value wetlands” affected by this project in PA are forested. Since the pipeline right-of- way must remain permanently deforested, how does FERC justify the pipeline’s impact as acceptable in these areas?
  • “Following construction, Transco would ensure that all disturbed wetland areas are successfully revegetated” (4-74). Note: Of course, we know that the pipeline right-of- way must remain permanently deforested; this would appear to counter the promise of successful revegetation. Furthermore, what is meant by “Transco would ensure”? Transco “ensuring” this or that is hardly reassuring! So what happens when Transco fails to fulfill these soft promises? Which body will enforce any kind of meaningful consequences when Transco fails to meet this ridiculous, meaningless promise?