CALL TO ACTION TO ALL WHO OPPOSE NATURAL GAS PIPELINES TO HAVE A COMBINED ENVIRONMENTAL REVIEW OF ALL NATURAL GAS PIPELINE PROJECTS IN MASSACHUSETTS
- State and Federal regulators are considering several projects to increase natural gas pipeline, storage, and delivery capacity in Massachusetts. The same large energy companies are behind these projects: Spectra Energy proposed the Atlantic Bridge, Access Northeast, and Algonquin Incremental Market (AIM) projects; Kinder Morgan proposed the Connecticut Expansion and the Northeast Energy Direct projects, which it shelved for the time being. These few companies are proposing many interconnected infrastructure projects. A single cumulative environmental review is necessary.
- Developers typically cannot break up or phase a project into pieces or segments to evade or limit environmental review. The state’s Secretary of Environmental Affairs should not allow these large national energy companies to do what other regulators would never permit other local developers to do.
- Although environmental regulators review each project, neither federal nor state regulators are reviewing the cumulative impacts of all natural gas pipeline projects. Mayor Bob Hedlund’s request for an advisory opinion seeks to change that oversight. Please support his request.
- Massachusetts needs no new natural gas capacity according to well-respected sources, such as the Massachusetts Attorney General, the Conservation Law Foundation, and others. New natural gas pipelines will have a myriad of impacts to local residents, communities, conservation lands, and natural resources. No regulator, state or federal, has analyzed whether all the impacts of these pipeline projects is worth it when we do not even need the natural gas.
- The Massachusetts Environmental Policy Act (MEPA) requires that state agencies determine the environmental impact of all works, projects, or activities the agencies permit. This environmental review must “consider reasonably foreseeable climate change impacts, including additional greenhouse gas emissions, and effects, such as predicted sea level rise.” G.L. c. 30, § 61. The plethora of natural gas infrastructure projects underway and proposed in the Commonwealth must be considered in total for MEPA to effectively protect Massachusetts residents.
- More natural gas will significantly increase greenhouse gas emissions. Massachusetts must step back and consider all the impacts of all these projects, including need, alternatives, and impacts. This big-picture analysis will allow consideration of alternatives such as fixing gas leaks and increasing reliance on renewable energy, both of which studies show to have the potential to play a significant role.
- The MEPA regulations provide a number of options for combining review of interrelated activities. < >Specifically, environmental regulations prohibit segmentation, requiring the Secretary to “consider the entirety of the Project, including any likely future Expansion, and not separate phases or segments thereof.” 301 CMR 11.01(2)(c). These regulations also provide for “fail-safe” review, allowing the Secretary to require MEPA review for projects that do not trigger MEPA thresholds but nonetheless have the potential to cause damage to the environment and merit MEPA analysis. 301 CMR 11.04. Finally, the MEPA regulations provide for special review procedures, allowing the Secretary the flexibility to put in place a MEPA review process to address, for example, “cumulative environmental impacts of Projects requiring individual Actions” that “may not otherwise be subject to adequate MEPA review or may have similar environmental impacts such that a common assessment may be necessary or appropriate.” 301 CMR 11.09(4)(a). email@example.com and firstname.lastname@example.orgThanks.