Key info for December 14th Public Comment Hearing
For the Zoom link for the remote public comment hearing on December 14th at 6 pm, click here.
For Audio-only Participation, Dial in at 1-646-558-8656 (not toll free) and then enter the Webinar ID 847-8155-4962
Join our Comment Workshop to get prepared for the hearing and written comments on December 12th at 6 pm! Click here for our Zoom link
Eversource Gas has filed with the Energy Facilities Siting Board (EFSB) for approval to build its proposed “Western Massachusetts Gas Reliability Project”. They want to build (1) a new “point of delivery (POD)” meter station in Longmeadow, (2) a new 16” 200 psi pipeline beneath the streets of Longmeadow into Springfield to (3) an upgraded regulator station in downtown Springfield.
On May 26th, Eversource filed with the EFSB in Docket No. EFSB22-05. On November 4th, the EFSB Hearing Officer issued a Notice of Adjudication and Public Comment Hearing defining only one “remote” public comment hearing to be held via Zoom on December 14, 2022 at 6:00pm for the project, and a public comment period that runs until 5pm on January 17, 2023.
As published on November 4th and updated on December 2nd, the EFSB will hold only one remote public hearing on Zoom despite the EFSB Handbook stating “the Siting Board holds one or more public comment hearings in the project area where a facility is proposed.” This shortcoming of no in-person hearings in the impacted area, of course, disrespects the impacted communities of Longmeadow and Springfield.
Help us fight back against this dangerous and unnecessary proposed gas expansion project by either testifying at the public hearing on December 14th, or by sending a written comment to the EFSB by January 17th (or both!) on this new gas infrastructure which would only intensify the climate emergency!
If you anticipate providing comments via Zoom during the public comment hearing on the 14th, we strongly advise that you send an email to geneen.bartley@mass.gov with your name, email address, and mailing address by December 13, 2022. Note that they typically take unregistered commenters only after those who signed up.
Often, the most effective comments are those that come from the heart, that speak to issues that you care about and/or that impact you and your loved ones.
Scroll down to see the 5 main points we are asking people to comment on. All of this is here to inform and inspire your comments to EFSB. You don’t need to include all or any of these points!
Rather, we invite you to choose a couple talking points or pieces of information from the key points below, or the additional background information that you can find further down in this toolkit, and use them as building blocks for a comment on the aspects of this proposed pipeline that concern you personally.
Although the EFSB is mainly concerned with a project’s siting, it is key to understand that we don’t want the proposed new infrastructure sited anywhere so commentary suggesting alternate locations is not recommended. The EFSB also has jurisdiction over the need for and cost of the proposed project and is required to review whether plans for expansion and construction are consistent with current health, environmental protection, and resource use and development policies of our Commonwealth. Feel free to also comment on the incompatibility of new gas infrastructure in this time of climate crisis, especially in already overburdened Environmental Justice communities.
Here are some suggested key points to include in your EFSB comments.
Key points
- Environmental Justice (EJ): This proposed pipeline – a new 200 psi high-pressure 16” pipeline main – would run through many EJ neighborhoods in Springfield and would impose yet another inequitable environmental burden on a city already targeted by multiple toxic and polluting industries. We need to remind the EFSB about their responsibility to protect EJ communities.
- Environmentally damaging: Methane, the main component of gas, is a greenhouse gas 86 times more potent than CO2 over 20 years. When this pipeline leaks, as all pipelines do, and when the meter stations vent gas, they all release methane into the atmosphere, trapping heat and worsening the climate crisis. This pipeline project would increase greenhouse gas emissions at a critical moment when both climate experts and the MA state legislature say that we must reduce our greenhouse gas emissions to net zero by 2050 in order to reach a livable climate future. This is no time to be doubling Eversource’s capacity to ship gas to their Springfield Territory.
- Unhealthy: Methane, the main component of gas, and the nitrogen oxides released during its combustion can cause and exacerbate respiratory illnesses like asthma. Springfield already suffers from high rates of respiratory illness, and ranked 12th on the Asthma and Allergy Foundation of America’s list of asthma capitals in 2021, after two previous years ranking first. The new meter station in Longmeadow will increase air pollution venting methane directly into the air sited less than a mile from an elementary school. The new pipeline and expanded meter station in Springfield would increase air pollution, indoors and outdoors, and worsen respiratory illness throughout the city.
- Dangerous: Gas is highly flammable and explosive. The Springfield community has already been impacted by the gas explosion of 2012, which injured 18 people and damaged 42 buildings. Communities in the Merrimack Valley are still recovering from the disastrous and deadly gas explosions and fires of 2018. This pipeline would be larger and higher-pressure than any other pipeline in Springfield, meaning that any fires or explosions could be much larger and more disastrous than the 2012 explosion.
- Unnecessary: Eversource does not claim that their Springfield Territory needs any more gas. Instead it says the pipeline is needed for “redundancy”, i.e., a back-up system. However, the proposed pipeline would go through the same Bliss Street Regulator Station as the current pipeline that brings gas from Agawam; that regulator station would still be a single point of failure for all of Springfield’s gas supply. This isn’t about reliability; It’s about Eversource making more money for their shareholders by putting more pipe in the ground to earn guaranteed return on equity.
Additionally, this project is out of alignment with the Massachusetts Commission on Clean Heat Report released November 30th. That Report made the following Recommendations: “Investments that would support new or increased natural gas infrastructure or capacity should instead be deployed to advance measures that help support the net zero future”, “The Commonwealth should also avoid future investments in gas pipeline infrastructure that will disproportionately burden LMI households” and “The Commonwealth’s long-term building decarbonization strategy requires transitioning customers from existing pipeline gas infrastructure to electric infrastructure.” Take your pick, nothing about Eversource’s Western Mass “Reliability Project” complies with the recommendations of the Report.
How to submit your comment
Written comments to the Energy Facility Siting Board are submitted via email to the DPU Filing Room at dpu.efiling@mass.gov and the EFSB Hearing Officer andre.gibeau@mass.gov. For this project, comments must be received no later than the close of business (5:00 p.m.) on Tuesday, January 17, 2023.
- The text of the email must specify:
- (1) the docket number of the proceeding: “EFSB 22-05/D.P.U. 22-69”
- (2) the name of the person or entity submitting the comment
- (3) a brief description of the document.
E.g. “Please find attached comments for EFSB22-05/DPU22-69 from Jane Doe.”
- The subject of the email should specify “EFSB22-05“ and “Western Massachusetts Gas Reliability Project”
- Any email attachment should also include the name, title, and telephone number of a person to contact in the event of questions about the filing.
- The email must CC: the counsel for Eversource: drosen@keeganwerlin.com.
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If you want more information about the Springfield-Longmeadow pipeline, the EFSB process and the many reasons why we are fighting this pipeline, keep scrolling down.
Additional Background Information
Eversource’s proposed Springfield-Longmeadow pipeline is a gas expansion pipeline that would start in a residential neighborhood in Longmeadow, a quarter of a mile away from Wolf Swamp Elementary School. It would travel under public roads through the Forest Park and the South End neighborhoods in Springfield, including many environmental justice communities, ending at the Bliss Street Regulator Station in downtown Springfield.
Eversource Gas claims that their proposed pipeline is a “reliability project.” Eversource claims that the existing pipeline that brings gas into Springfield under the Memorial Bridge is a potential point of failure for Springfield’s entire gas supply. However, the proposed pipeline would go through the same Bliss Street Regulator Station as the current pipeline; that regulator station would still be a single point of failure for all of Springfield’s gas supply and there are no plans to modify it. This pipeline would not improve energy reliability for Springfield and Longmeadow.
Why are we fighting against this pipeline?
This proposed project faces strong resistance from both the Springfield and Longmeadow communities because it is unhealthy, dangerous, climate-changing, costly, and unnecessary.
Unhealthy:
- Methane, the main component of gas, and the nitrogen oxides released during combustion can cause and exacerbate respiratory illness.
- Springfield, as a city full of Environmental Justice communities, has been targeted by many toxic and polluting industries. Springfield’s current air quality is poor.
- Springfield already suffers from high rates of respiratory illness, and ranked 12th on the Asthma and Allergy Foundation of America’s list of asthma capitals in 2021 after two previous years ranking first.
Dangerous:
- Gas is highly flammable and explosive
- This pipeline would be the largest and highest pressure pipeline in Springfield, running at 200 psi whereas the current pipeline supplying gas to Springfield is only 60 psi. The increased pressure increases the risk of explosions and the potential magnitude of any explosions
- The Springfield community has already been impacted by the gas explosion in 2012, which injured 18 people and damaged 42 buildings
- Communities in the Merrimack Valley are still recovering from the disastrous and deadly natural gas explosions and fires of 2018, which killed 1 person, injured 25 more and resulted in the evacuation of 30,000
- The recent Marshfield pipeline fire of 2021 burned for nine hours because Eversource didn’t know the shut-off valve location
Climate-Changing;
- Methane, the main component of gas, is a greenhouse gas 86 times more potent than CO2 over 20 years
- When this pipeline leaks, as all pipelines do, it will release methane into the atmosphere, trapping heat and worsening the climate crisis
- According to the latest IPCC report, in order to have any chance at limiting global warming to 1.5 degrees Celsius, we need our greenhouse gas emissions to peak by 2025 and fall by 43% by 2030
- According to the Massachusetts Next Generation Climate Roadmap Act, which went into effect in 2021, all cities and towns in MA must reduce greenhouse gas emissions by 50% by 2030 and reach net zero by 2050
- The permitting process for this pipeline will take up to 2 years, meaning they could begin construction in late 2023 or in 2024, and have the pipeline up and running by late 2024 or in 2025; This would increase our greenhouse gas emissions at the critical moment when we must rapidly reduce those emissions
Costly:
- This expansion pipeline would cost $65.1 million to build, all of which would be funded by Eversource Gas ratepayers.
- Eversource has a financial incentive to construct this pipeline. MA regulations allow Eversource a return on equity of 9.67% annually for new capital investment, such as new pipelines in the ground.
- That 9.67%, just like the upfront bill for the pipeline, would be funded by MA ratepayers for the benefit of Eversource shareholders.
- Ratepayers would pay even more over time for the “stranded assets” of this gas infrastructure as the transition to green energy proceeds and the gas customer base shrinks.
Unnecessary:
- Eversource does not claim that Springfield needs any more gas. Instead it says the pipeline is needed for “redundancy”, i.e., a back-up system.
- However, the proposed pipeline would go through the same Bliss Street Regulator Station as the current pipeline; that regulator station would still be a single point of failure for all of Springfield’s gas supply
- Eversource is fear mongering about energy scarcity and power outages to justify this pipeline, following the strategy they proposed to other gas utility companies to keep their industry profitable during the transition to clean energy. Source
What is the EFSB’s role in all of this?
The Massachusetts Energy Facilities Siting Board (“Siting Board”) is an independent state review board located administratively within the Massachusetts Department of Public Utilities (“DPU”). By reviewing specific requests for approval to construct certain types of jurisdictional energy facilities, the Siting Board is charged, by state statute, with ensuring that the proposed facility will provide a “reliable energy supply for the Commonwealth with a minimum impact on the environment at the lowest possible cost.”
The nine-member Siting Board is made up of the Secretary of Energy and Environmental Affairs (EEA), who serves as the Chair, two Commissioners from the DPU, the Secretary of Housing and Economic Development, the Commissioner of the Department of Environmental Protection, the Commissioner of the Department of Energy Resources, and three public members – one each representing Labor, Energy and Environment – who are appointed by the Governor.
For intrastate natural gas pipelines, the scope of the Siting Board’s review includes not only environmental impacts and mitigation, but also the need for and cost of the proposed facility, and alternatives, including other means of meeting the identified need, and alternate routes or sites for such facilities. For all proposed jurisdictional facilities, the Siting Board is required to review whether plans for expansion and construction are consistent with current health, environmental protection, and resource use and development policies, as adopted by the Commonwealth.
See “The Energy Facilities Siting Handbook: An Overview of the Energy Facilities Siting Board Review Process” available at: https://www.mass.gov/doc/energy-facilities-siting-handbook/download
Toolkit brought to you by the Springfield Climate Justice Coalition. Latest revision: Dec 9, 2022