Final Pipeline Construction Guidance
DEP started developing the guidance in July 2018 as a result of a settlement of litigation with the Clean Air Council, the Delaware Riverkeeper Network, and Mountain Watershed Association related to DEP’s permits issued for the Mariner East II Pipeline Project.
The construction of the Mariner East Pipeline across Pennsylvania resulted in Sunoco/Energy Transfer Partners being convicted of criminal charges for environmental violations and resulted in an additional $31 million in penalties. Read more here.
Natural gas pipeline construction projects have the worst environmental compliance record of any type of development and have been fined over $70 million. And violations are continuing. Read more here.
On January 18, DEP released the final version of technical guidance on using trenchless technology to construct natural gas, other pipelines and underground utilities. Read more here.
Andrew Foley, Water Program Specialist, DEP Regional Permit Coordination Office, will make a presentation to the Council on the guidance.
Foley told the DEP Water Resources Advisory Committee in January, “The TGD itself outlines for project proponents, things to consider or possibly implement when necessary, when they're proposing the use of trenches, technology installation or when they're proposing that methodology on any project or any portion of a project.”
“The guidance was drafted in concurrence with the existing regulations, so it doesn't stipulate or provide new recommendations outside of what exists, but it does help bring together the best practices and provides a more consistent departmental stance on trenches, technology and utilization of trenchless technology, which has long been needed,” added Foley.
“We believe the guidance will help improve the quality of application submissions by reviewing or removing a lot of the ambiguity that goes into the planning and preparation that applicants do to prepare for submission of a permit that involves trenchless technology,” said Foley.
“We believe it should help foster a more consistent approach by our staff as they review these permits on what we expect and what we consider to be above average risk for these types of projects,” explained Foley.
“The guidance provides, as I said, very necessary information that helps clarify while also providing a consistent message that we think will help applicants develop a more solid and defensible permit submission, bringing the two together so that we're working on the same page,” said Foley.
From the guidance-- “The guidance document outlines the steps and options to consider, and implement as appropriate, when proposing to use a trenchless technology installation method, including horizontal directional drilling, on any portion of a project.”
“The level of analysis needed for a project should be commensurate with the level of environmental risk. It is the project proponent’s responsibility to perform the due diligence, but DEP may request this, if necessary, to determine compliance with the statutes or the rules and regulations administered by DEP.
“Some of the guidance provided herein may not be appropriate for the scope of a proposed project. Each project that proposes trenchless technology (e.g., HDD) should be prepared in consideration of project-specific and site-specific issues, impacts, and public and agency comments.”
Click Here for more from Foley’s presentation.
Carbon Sequestration/Hydrogen
Nita Raju with the federal Office of Pipeline Safety from the Pipeline and Hazardous Materials Safety Administration will discuss pipeline issues related to carbon sequestration and hydrogen.
Electrification
Rashi Akki, CEPO of Ag-Grid, will do a presentation on the Partnership for Electric Pathways, a group looking to decarbonize transportation and electricity.
Public Comment Period
Individuals interested in providing public comment during the meeting must sign up in advance of the meeting by contacting Ian Irvin at iirvin@pa.gov.
The Citizens Advisory Council encourages the submission of a written copy of public comments prior to the meeting.
Join The Meeting
The meeting will be held in Room 105 of the Rachel Carson Building starting at 12:30 p.m. Options for joining the meeting remotely are available.
Visit the DEP Citizens Advisory Council webpage for available handouts. Questions should be directed to Ian Irvin, Executive Director, iirvin@pa.gov.
[Posted: February 1, 2024] PA Environment Digest
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