Day #22

Super gorgeous day today—great for visiting the State House. I had a visitor from Somerville who works in Boston, Jenn S. She was able to check out Gov. Baker’s expression as he walked by and I blurted out another friendly “Hey, what’s up?”. My greeting was definitely received in the spirit it was intended judging by the look on his face 🙂

I spoke with John T. the Gov. Baker’s Director of Constituent Services again today about that status of permitting and the project overall. I wanted to know if anyone else could talk to me. I asked if there was anyone else that had a job description between him and Gov. Baker. Short story: no. John’s got a tough job, he was very polite, and he probably deserves twice what they are paying him. However, I still want something to change, something to be done. Fast.

Today’s note contained printout of a new op-ed from Emily Norton of The Sierra Club in CommonWealth Magazine with my favorite title of the year, so far: Kill the Access Northeast Pipeline. I would ad in Atlantic Bridge as well. This is my favorite, and true, pull-quote from the piece:
Even the Baker administration concedes that energy demand is expected to remain flat in coming years, but points to “peak usage” as the area of concern. What this means is that for about 10 days per year – the coldest winter days when Massachusetts residents are using more natural gas than usual for both heating their homes and powering their electricity – there may be a shortfall in natural gas which could cause a spike in price.

Building a $6.6 billion pipeline to cover these few days of possible shortages is like putting an addition on your home for the few weekends a year when your in-laws come to visit, rather than putting them up for a few days in a nearby hotel.

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Also in the envelope was a draft of my letter to MassDEP in response to their recent “proposed” Air Permit Plan granted to Spectra. If you want to send a comment as well, and live in MA, please check out how to comment, right here. The text of my letter is below:

Dear MassDEP/Mr. Thomas Cushing:

Thank you so much for allowing a comment period regarding this proposed air permit approval. I really appreciate it! There are a few very important points I’d like to make:

Regarding Massachusetts’ responsibility to reduce green house gasses
Per the Global Warming Solutions Act of 2008, “In considering and issuing permits, licenses and other administrative approvals and decisions, the respective agency, department, board, commission or authority shall also consider reasonably foreseeable climate change impacts, including additional greenhouse gas emissions, and effects, such as predicted sea level rise.” (Section 7) MassDEP, you are legally responsible and required to protect MA from projects that would cause an increase in green house gasses—like this proposed gas compressor. Have you seen recent studies pointing to dangerous emissions from fracked gas compressor stations? (see next section below)

Regarding air pollution
I emphatically do not feel neither Algonquin nor MassDEP has taken the addition of a compressor into consideration with already present pollutants in the Fore River area. Spectra stating that their proposed compressor alone does not exceed maximum ambient pollutants does not mean anything, especially since Algonquin took their air samples from ROXBURY, and not the ACTUAL SITE. That’s nuts! Per the Proposed Approval letter: “In evaluating cumulative impacts with respect to the NAAQS, maximum modeled impacts were added to representative ambient background concentrations and compared to the applicable NAAQS. The Applicant used background data obtained from MassDEP’s existing monitoring station on Harrison Avenue in Roxbury. The background data, when added to the modeled impacts found that the maximum impacts from emissions from the proposed facility will be below the NAAQS.

If a permanent air monitor had been sited in the Fore River area—as many citizens requested last year—MassDEP would know that this area is already overburdened with polluting sites and cannot bear one more (much less a planned horsepower upgrade to that same compressor). Does MassDEP do its own air testing lacking the presence of a permanent air monitor, or does it only go by the applicant’s data?

A recent study* of “ambient air methane levels measured with mobile cavity ring-down spectrometry” found the following:

  • Elevated ambient air methane levels attributed to natural gas compressor stations
  • Emissions from infrastructure associated with unconventional [read: fracked] gas development influence regional air quality and contribute to atmospheric greenhouse gas burden

Study abstract: The extraction of unconventional oil and natural gas from shale energy reservoirs has raised concerns regarding upstream and midstream activities and their potential impacts on air quality. Here we present in situ measurements of ambient methane concentrations near multiple natural gas compressor stations in New York and Pennsylvania using cavity ring-down laser spectrometry coupled with global positioning system technology. These data reveal discernible methane plumes located proximally to compressor stations, which exhibit high variability in their methane emissions depending on the weather conditions and on-site activities. During atmospheric temperature inversions, when near-ground mixing of the atmosphere is limited or does not occur, residents and properties located within 1 mile of a compressor station can be exposed to rogue methane from these point sources. These data provide important insight into the characterization and potential for optimization of natural gas compressor station operations.

Regarding sound pollution
This compressor will be heard throughout the entire Fore River area, especially since the proposed site is located right next to the water (sound refraction). From Georgia State University: Sound propagates in all directions from a point source. Normally, only that which is initially directed toward the listener can be heard, but refraction can bend sound downward. Normally, only the direct sound is received. But refraction can add some additional sound, effectively amplifying the sound. Natural amplifiers can occur over cool lakes.**

Often the design of a compressor—all of the sound mitigation, especially—do not match up to the reality. One study in by Thomas Gabrielson, PE at Penn State University found that the design of the Pennsylvania compressor he studied said it would produce 47 dBA at 300 ft, but in use, the sound was measured at 56 dBA at 300 ft.*** This compressor was in the middle of the woods. The proposed Weymouth site is emphatically not.

Please do not make the Fore River area wait until the compressor is in (when a “post-construction compliance demonstration for sound impacts” will be required) to say “oh, yeah, well, this thing really is too noisy”. One of the main mitigators of sound (distance from residents and barriers) is not present as it’s on such a small site and so near to humans—so we’re starting with a huge deficit. The blowdowns and venting alone are incredibly loud, sounding like a jet engine which is estimated at about 125 dBA. What about those?

Regarding Algonquin/Spectra’s capacity to properly monitor, test, and report
I have zero confidence in Algonquin/Spectra’s ability to properly monitor, test, and report on this compressor. I have not read about or witnessed one explosion, leak, or malfunction that Algonquin/Spectra could not have prevented with proper monitoring, repairs, upgrades, replacements, adequate and thorough testing, as we have seen in multiple instances that make the news media in states in which Spectra operates. Spectra is in the business of reacting to disasters, not being proactive in preventing them.

Another thing to note: we see the news about leaks, but we don’t see any reports in the Pipeline Hazardous Materials Safety (PHMSA) records—Algonquin/Spectra do NOT report their leaks. Not even when the incidents exceed the PHMSA requirements (one example is Searsmont, ME).

Regarding the recent massive gas leak in Providence, RI: people were smelling gas as early as 6:00pm, but the first call came in at 8:15pm. The average citizen has no way of knowing when the gas they’re smelling is an emergency, but Algonquin/Spectra should. If Algonquin/Spectra is monitoring their equipment & infrastructure as closely and diligently as they claim to be doing, why were they the last to know? The same thing happened this January with a gas leak at Spectra’s metering station right next to the proposed Weymouth compressor site: the public reported it when the smell got bad enough, and Algonquin/Spectra had NO idea anything was wrong.

If Algonquin/Spectra has the most up to date technology, which they assure us enables them to shut gas off quickly, why did it take HOURS to shut the gas off? I have a real problem that the responsibility is placed on the unsuspecting/untrained public to report Algonquin/Spectra’s gas leaks and explosions—the same public whose health and safety are at risk by Algonquin/Spectra’s unreliable business operations…and it’s the same public that pays for this company’s product, operations and mistakes, in so many ways.

MassDEP, please do not grant a final air permit approval to Algonquin/Spectra. If you still feel that Algonquin/Spectra has checked all the boxes and met all of the federal air/noise pollution regulations, please step back and acknowledge that the regulations and federal oversight are empirically lousy and they do little to protect the land nor the residents from harm. MassDEP, we depend on YOU to protect us. Please do not let us all down.

Thank you,
Andrea

 

*http://bit.ly/PACompressorNoise
**http://bit.ly/SoundRefraction
***http://bit.ly/CompMethanePlumes

Lastly, feet!

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