Pace Environmental Litigation Clinic Submits Scoping Comments on Behalf of Stop the Pipeline in regards to the proposed Constitution Pipeline DEIS - docket# PF12-9.
10/09/2012PACE ENVIRONMENTAL LITIGATION CLINIC, INC. PACE UNIVERSITY SCHOOL OF LAW 78 NORTH BROADWAY WHITE PLAINS, NEW YORK 10603 PHONE: 914.422.4343 FAX: 914.422.4437 SUPERVISING ATTORNEYS ADMINISTRATORS KARL S. COPLAN MARY BETH POSTMAN DANIEL E. ESTRIN JENNIFER RUHLE ROBERT F. KENNEDY, JR. October 9, 2012 VIA eFiling to FERC in Docket No. PF12-9 Kimberly D. Bose, Secretary Federal Energy Regulatory Commission 888 First Street, NE, Room 1A Washington, DC 20426 Re: Stop the Pipeline Comments on the Scope of Work for the Constitution Pipeline Draft Environmental Impact Statement. Dear Secretary Bose: On behalf of our client, Stop the Pipeline (STP), the Pace Environmental Litigation Clinic, Inc. respectfully submits the following comments on the scope of work for the Constitution Pipeline Draft Environmental Impact Statement. STP is a grass-roots coalition formed to stop the construction and operation of the proposed Constitution Pipeline. Its members live, work, and recreate in the six counties that would be affected by the construction and operation of this pipeline: Susquehanna County, PA, and Broome, Chenango, Delaware, Otsego, and Schoharie Counties in NY. We request that you also consider this letter a statement of status as an interested or affected person or party under the National Environmental Policy Act1 (NEPA) and, pursuant to the regulations promulgated by the Council on Environmental Quality, notify us of all NEPA related documents, as they become available, and NEPA related meetings, as they are scheduled.2 1 42 U.S.C. 4321, et seq. (2012). 2 40 CFR 1506.6(b) (2012). Kimberly D. Bose, Secretary, FERC October 9, 2012 Page 4 of 4 The FERC held two scoping hearings within the lower third (southwest end) of the proposed 120-mile long Constitution Pipeline, and another scoping hearing near the northeast end. Specifically, a hearing was held on September 24 in Afton, NY, which is located in Chenango County; on September 25 in Schoharie, NY, which is located in Schoharie County; and on September 26 in New Milford, PA, which is located in Susquehanna County. (See Appendix A, Location of Scoping Hearings.) These three hearings were held within 50 miles of the two ends of the proposed route. Not one hearing was held in the 70-mile middle portion, in either Delaware or Otsego Counties, where there has been significant vocal opposition to the project. The proposed Constitution Pipeline has generated substantial controversy. Dozens of articles and letters to the editor expressing citizen opposition to this project have appeared in The Daily Star, a newspaper that mainly serves Delaware and Otsego Counties. Hundreds of comments have been filed with the ...