Wild places sustain and define us; we, in turn, must protect them.
For the past two years, Kentucky Heartwood has been active in the effort to stop Kinder Morgan's plans to repurpose the roughly 70 year-old Tennessee Gas Pipeline as it crosses 6 states and 18 Kentucky counties. The company's plan is to take this aging 24" line that was built to transport natural gas from the gulf coast to the northeast, and reverse the direction of flow to send hazardous natural gas liquids, or "NGLs," to processing and export facilities in Louisiana and Texas. These NGLs are hydrocarbon byproducts of fracking in the Marcellus and Utica shales, and pose unique and increased environmental and safety risks over the natural gas currently transported in the line. Of particular concern is that a significant portion of the NGLs remain liquid under ambient pressure and can severly contaminate water and soil. You can learn more about the project by reading Kentucky Heartwood's detailed comments on the Environmental Assessment (EA) by clicking here.
Kentucky Heartwood's involvement, as an organization, is in large part due to the risks this pipeline repurposing project poses to the extraordinary biodiversity of the Green River upstream and through Mammoth Cave National Park, as well as its connected karst ecosystem. The Green River is a world biodiversity hotspot. Historically the river harbored 66 mussel species, or 22 percent of North America’s mussel fauna, and today provides habitat 151 species of fish. While it is one of the healthiest remaining refuges for freshwater mussels, twenty-nine of the Green’s mussel and fish species are considered imperiled or vulnerable, and seven are listed as endangered under the U.S. Endangered Species Act. Either a slow leak or major rupture of the Tennessee Gas Pipeline where it crosses the Green River, or across the karst (cave and sinkhole) plain that connects its surface and subsurface waters, could be catastrophic. In the EA, the Federal Energy Regulatory Commission decided that pipeline failures were uncommon, and the effects not worth considering.
But Kentucky turned up and spoke out. And we have a lot to be proud of.
Over the course of the comment period on the EA, over 500 people submitted comments. And since the beginning of the formal proceedings by FERC, more than 900 comments have been submitted. Nearly all of these comment letters expressed concern over the risks posed by the NGL conversion, requested a full EIS, or opposed the project outright. Nearly every comment letter is from someone in Kentucky, despite the pipeline crossing five other states.
And the number of county and municipal governments, agencies, and associations that have taken strong stands on this issue is remarkable, reflecing an impressive level of community-level organizing, education, and outreach. Among those who submitted comments expressing serious concerns about the project are:
The Madison County, Fiscal Court, the Clark County Fiscal Court, the Boyle County, Fiscal Court, the Marion County Fiscal Court, the Barren County Fiscal Court, Kentucky State Senate Majority Whip Jimmy Higdon, the Bluegrass Areas Development District (representing elected officials and citizen members in a 17-county area), the Danville-Boyle County Chamber of Commerce, the City of Danville, the Danville Independent School District and Danville Schools Board of Education, and the Rowan County Board of Education. In addition, planning and zoning ordinances relating to hazardous liquids pipelines were adopted by Madison and Boyle Counties out of concern for risks posed by NGL pipelines, with the Madison County ordinance supported by Eastern Kentucky University and Madison County Schools. Clark County is considering a similar ordinance.
It is also notable that our Kentucky State Nature Preserves Commission and Kentucky Department of Fish and Wildlife provided thoughtful comments that recognized that pipeline failures are a real risk and need to be considered. Other natural resources agencies from other states failed to address this critical issue. The U.S. Fish and Wildlife Service, through the Kentucky Field Office, has also been excellent in demanding that FERC consider the ACRP (the abandonment decision) and UMTP (the conversion to NGLs) as a single action, despite FERC wrongfully separating the two. And the National Park Service at Mammoth Cave (Kentucky, of course) also raised serious questions about pipeline failures and the effects on the area’s important aquatic and karst fauna.
And, of course, an excellent list of organizations played a major part, including Frack Free Foothills, the Kentucky Environmental Foundation, the Kentucky Resources Council, Kentuckians for the Commonwealth, and the Kentucky Waterways Alliance. The Allegheny Defense Project and Center for Biological Diversity joined Kentucky Heartwood in writing our comments on the project.
Kentucky Heartwood will stay on top of this project. We are one of only two organizations in Kentucky with “intervenor status,” giving us standing to bring an administrative and legal challenge if FERC fails to properly follow the National Environmental Policy Act or other rules and laws in making a decision. But our technical arguments are backed and strengthened by the outpouring opposition from you and everyone else that submitted comments opposing the project.
So well done, Kentucky. You’re awesome.
And if you support this work, please consider joining Kentucky Heartwood. We can't do it without you!