Greater Fallston Association

2814 Cross Country Ct.

Fallston, MD  21047

                                                                                                                                                                                               


June 12, 2006

 

 

Federal Energy Regulatory Commission

Magalie R. Salas, Secretary

888 First St., N.E. Room 1A

Washington, DC  20426

 

Ref: Docket No. PF06-22-000

Attn: Gas Branch 2, DG2E

 

 

Dear Sir or Madam:

Representatives of the Greater Fallston Association have taken the opportunity to take part in recent meetings held in Harford County regarding the Mid-Atlantic Express Pipeline Project and the Sparrows Point LNG Facility proposed by AES for Harford and Baltimore Counties in Maryland.  The proposed pipeline primary route runs directly through the Fallston Community and in close proximity to both the Fallston Middle School and High School with combined populations of approximately 3,000 faculty and students.  While some portions of the county are served by public water, a large portion of Fallston and the surrounding areas in the path of the pipeline, are served by private wells. Currently, Fallston area residents are suffering from the aftermath of a widespread MTBE contamination of the groundwater.  As we gather data and research the issues surrounding the construction and maintenance of a natural gas pipeline and the associated LNG facility, we find that improper consideration has been given to a number of issues.

Fallston, and the majority of Harford County, sits on top of the Piedmont Plateau.  This plateau is characterized by a layer of fractured and faulted bedrock found at different depths relative to the surface. The bedrock includes a varying network of fractures and aquifers.  The water supplied to the private wells in the area comes from these fractures and aquifers. This geology significantly impairs the ability to contain and remediate any kind of contamination that enters the water supply.  This issue has become significant as it relates to the current MTBE contamination experienced in the area.  In large part, the contamination was caused by a vapor leak at a local filling station.  In addition, per AES consultants, the monitoring of the pipeline will be “state of the art” and constant electronic monitoring devices (“smart pigs”) will be in place.  Should the device detect a disruption or weakness in the pipeline it will eventually result in sections of the pipeline being shut down.  As recently as four months ago we were reminded that even state of the art detection and notification devices are not the answer when there is a weak spot in the system or changes in technology that are not initiated to upgrade a system.  A local gas station had a catastrophic fuel leak due to a simple screw through an underground line.  On multiple occasions, alarms went off locally and in national monitoring stations, pumps were shut down and service contractors were called.  Yet the issue went unresolved while 25,000 gallons of fuel poured into the ground and eventually into the fractures carrying the drinking water for the community. 

The fact that the proposed primary route travels adjacent to at least two large schools is questionable at best. It would seem that it has not been considered that Harford County is serviced by a volunteer Fire and Emergency system.  Both the High school and Middle school share a driveway to one two lane country road that does not have shoulders.  To assume that the schools and local residences could be evacuated and that emergency personnel could gain adequate access to aide in an evacuation and maintain order, while managing an emergency of the magnitude that would be created by a pipeline incident is unthinkable.  Also, this county’s local military installation was chosen to be expanded as a result of the federal governments Base Realignment

 

and Closure plans.  As a result, the local population is due to increase over the next several years by up to an estimated 40,000.  This will significantly increase demand on our emergency services and police.  Their resources should not be additionally challenged by the added risk associated with a new pipeline, given they are already responsible for emergency plans for the two existing pipelines running through the county and the community of Fallston.

According to the Maryland Department of the Environment, there are four pipelines in the state of Maryland currently.  The majority of the state is in fact serviced by these pipelines. Also, liquid natural gas is already delivered to an existing pipeline emanating from Calvert County Maryland. It is our understanding that to date there are no plans set for the Mid-Atlantic Express pipeline to provide natural gas service to either Baltimore or Harford county and that these counties are simply being used as a thoroughfare to transport the product to the North. This state and this county have it’s fair share of LNG facilities and pipelines to transport natural gas. 

In addition to the pipeline itself, the facility in Sparrows Point creates an additional laundry list of issues.   The health of the Chesapeake Bay is certainly a major consideration.  The dredging in Sparrows Point would have a lasting negative irreparable impact on a waterway that has suffered in the past. Millions of dollars have been spent in support of successful programs for the Bays long term recovery.  The boring that would be required to put the pipeline below the Susquehanna River would surely impact the river itself, the Bay that it feeds into and potentially the public water supply in Harford County.  The warming process necessary at the LNG facility to increase the temperature of the LNG to move it into the pipeline as gas would surely impact Bay temperature and therefore life in the Bay that so many in the area rely on for their livelihoods.  The impact to boat traffic during the transport of the LNG up the Bay and the automobile traffic impact on both the Bay Bridge and Key Bridge would be significant.  Lastly,  the terrorist threat level increase created to the areas included in the project is substantial. 

Per a document that was provided by FERC, you are a “federal agency charged with determining whether or not proposed LNG import facilities are in the public interest and interstate pipeline projects are in the public convenience and necessity”.  This project is not in the public interest in either Harford or Baltimore County, nor is the pipeline convenient to Fallston and it is definitely not a necessity.  Based on the significant impact and improper consideration of the obvious and potential threats to the population, groundwater resources, security and other natural resources, the Greater Fallston Association strongly recommends that you oppose and deny AES’s application for the project referenced under Docket No. PF06-22-000.

Respectfully yours,

Steven Scheinin, President

Greater Fallston Association

Beth F. Scheir, Vice President

Greater Fallston Association