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Comment to FERC Docket on Northeast Energy Direct Pipeline by Aug. 31

The comments below were presented at the FERC Environmental Impact Scoping Session for the Northeast Energy Direct Project, Docket No. PF14-22-000, held at Lunenburg High School auditorium on August 12:

According to the U. S. Energy Information Administration, the six New England states consumed a total of 889 billion cubic feet (Bcf) of natural gas in 2013. Their data also show that New England’s natural gas inflow capacity is currently 1,709 Bcf/yr. This is exclusive of the region’s three liquefied natural gas (LNG) import facilities which, although virtually idle of late, in the past have contributed additional capacity of up to 150 Bcf/yr. So why, despite a natural gas inflow capacity that is nearly twice the region’s annual demand, does Gordon Van Welie, CEO of ISO New England, persist in his claim that we must expand our gas pipeline infrastructure to keep electricity prices down and avoid the threat of rolling blackouts?

It is well known that during a handful of days each winter, generators in New England who have not contracted for firm pipeline capacity may be forced to sit idle. They do not commit to long-term contracts with their suppliers, and are thus lower on the priority list than local distribution companies that commit to firm supply to heat people’s homes. What this means is that electricity price spikes in winter have much more to do with market practice than pipeline constraints, especially given that the same winter price spikes have been observed in parts of the United States where supply and access to natural gas is abundant, like Pennsylvania.

If you were to add up all of the gas required to get through these so called “peak-shaving” intervals during the course of one winter, it is estimated to total on the order of 5-10 Bcf, or about 1 percent of the region’s annual demand, roughly the equivalent of one or two LNG tankers.

To the businessman looking to export natural gas to global markets, the Northeast Energy Direct pipeline, sized to deliver up to 800 billion cubic feet of gas each year, looks like the perfect solution to the 10 Bcf peak shaving problem. However, to the MA and NH homeowners whose lives are about to be turned upside-down due to a forcible land-taking via eminent domain, it is unconscionable. The sword dangling over the heads of the working families that find themselves in the path demands that we ask, “Is there another way?”


Energy efficiency, demand response, recovery of gas lost to leaks, and commercially available storage technology all combine to refute the specious case for need of this pipeline. Federal Energy Regulatory Commission (FERC), your job is not to “put steel in the ground” as FERC Chairman Cheryl LaFleur quipped at an Energy Roundtable held in Boston last October. Your job is to regulate! Confirm what the numbers clearly show — the case for need is not made.

The export plan of a wealthy Texan is no justification to impose eminent domain on OUR WORKING FAMILIES. China may need this gas. But the New England ratepayers that will bear the burden surely DO NOT.

The deadline for filing comments to the Federal Energy Regulatory Commission pertaining to the Environmental Impact Scoping Sessions on the Northeast Energy Direct Project is August 31. FERC is required by law to cover any issues that are brought up before this date in their Environmental Impact Statement. File your comments at and be sure to reference the Northeast Energy Direct Project, Docket No. PF14-22-000, as directed. For more information, ideas for comments, and guidance on how to draft and submit your comments, please visit the No Fracked Gas In Mass website at

Please take the time to support our neighbors in Western and Eastern Massachusetts, and New Hampshire. Eminent domain to support the business plan of a private corporation is wrong. If it can happen to someone else, it can happen to you.

Vince Premus


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