PPA Comments Submitted to the Pinelands Commission 2017

The Pinelands Preservation Alliance submitted the following comments and reports to the Pinelands Commission regarding the proposed South Jersey Gas pipeline project. Public comment closed February 8, 2017.

PPA submitted comments to the Pinelands Commission on 1/24/2017 regarding the high pressure gas pipeline proposed for construction in a portion of the Pinelands National Reserve.

PPA reminded the Commission that after more than a year of reviews in 2013 the Commission found that proposed South Jersey Gas pipeline violates the Comprehensive Management Plan (CMP) rules for development in the Forest Area of the Pinelands because it is not designed to “primarily serve only the needs of the Pinelands”. This type of infrastructure is barred because such development creates more pressure for development along its length (2) strikes at the integrity of the CMP and (3) creates a precedent for future violations.

We state that the Commission cannot find the pipeline will primarily serve only the needs of the Pinelands and meets CMP resource protection rules for each of the following reasons:

  1. The pipeline is designed to carry four times as much gas as the BL England plant could use, and more than twice the capacity that SJG has contracted to provide to the BL England power plant.
  2. The mere fact that BL England is inside the Pinelands boundary does not mean gas to the plant primarily serves the “needs of the Pinelands” (even if the pipeline did primarily serve the power plant).
  3. SJG has consistently said the pipeline is being built for – and most of the cost paid by – its ratepayers, the vast majority of whom are outside the Pinelands.
  4. Ratepayers have first claim on all gas transported by the new pipeline, and SJG’s agreement for BL England is not even a firm contract.
  5. The great majority of South Jersey Gas customers are outside the Pinelands.
  6. The vast majority of electricity customers and demand to be served by BL England are outside the Pinelands.
  7. Repowering the BL England plant is not necessary, either to Pinelands customers or anyone else, according to updated PJM Interconnection findings, so the pipeline would not “primarily serve only the needs of the Pinelands” even if it only went to the power plant.
  8. When the Pinelands Commission staff found the pipeline violates the CMP, it had all the information then as it has now – so there is no valid justification for doing an about-face.
  9. The pipeline will bring impacts and risks to water and other resources that neither SJG nor the Pinelands Commission has addressed or resolved.

Details on each point can be found in our submissions to the commission here:

PPA Cover Letter and Summary Jan. 24 2017

PPA Expert Reports Jan. 24 2017

PPA Comments Feb. 8, 2017

Due to public pressure the Pineland Commission extended public comment until February 8th. PPA submitted additional comments on 2/8/17 showing that the BL England plant will shut down entirely as of April 30th with PJM’s approval and without causing reliability problems arising from the shutdown. It is also clear that RC Cape May Holdings is now considering, though not committed to build, a brand new 447 MW power plant at the BL England site at some point in the future – not to retrofit or repower the existing generation facilities as was previously claimed.

Given that BL England’s existing operation is shutting down with PJM’s permission, it is impossible to argue that a pipeline to the site would primarily serve a need of the Pinelands.

Additionally the proposed pipeline would have a capacity far exceeding the demand of a new power plant at the BL England site. Even a new BL England power plant could not use most of the electricity of the pipeline as proposed. Therefore, the pipeline cannot be said to primarily serve the power plant.

PPA Additional Comments Feb. 8 2017

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