Vermont Gas’ proposed pipeline expansion is an ill-conceived pipe dream that would exacerbate Vermont’s contribution to climate change and fuel our continued reliance on non-renewable energy. Adding insult to injury, this fundamentally misguided expansion would pose both immediate and sustained threats to vital wetland ecosystems, state-significant natural communities, and threatened plant populations. The pipeline demands a full NEPA review and environmental impact statement, just as Governor Shumlin called for environmental review of the Portland Montreal Pipe Line reversal in a recent letter to Secretary Kerry.
As Conservation Law Foundation articulates in this letter to the Army Corps of Engineers, the pipeline expansion would have undue adverse impacts on aquatic resources and fails to meet the criteria established by federal law for a Section 404 individual wetland permit.
The proposed route impacts 25.16 acres of wetlands and streams, including 5.29 acres of Class II wetlands deemed “significant” under the Vermont Wetland Rules and an additional 6.22 acres of Class II wetland buffers. Testimony from Alan Quackenbush, Wetlands Program Manager for the Department of Environmental Conservation, says trenching poses permanent risks to wetland hydrology:
“If the hydrology changes or the soil layers are not removed and replaced in order, these impacts will be permanent.”
Vermont Gas plans to use open cut trenching throughout the majority of the pipeline route, even though horizontal directional drilling (HDD) is a far less environmentally damaging practicable alternative. Despite the availability of HDD, the invasive open trenching method will be used in areas up to 75 feet wide, including parts of state-significant natural communities.
Even testimony submitted by Vermont Gas recognizes the “permanent Project impacts” to state-significant natural communities. These permanent impacts extend to four areas, totaling 3.68 acres, of Pine-Oak-Heath Sandplain Forest designated by ANR as an S1 “extremely rare natural community.” Vermont Gas testimony acknowledges that this ecosystem is “appropriate to be considered RINA,” or a Rare and Irreplaceable Natural Area under 10 V.S.A. § 6086(a)(8).
Testimony from botanist Robert Popp adds that the pipeline construction and permanent removal of forest canopy pose risks to seven state-listed “Threatened” plant species, as well as an additional seven “Rare” species:
“There is concern about the pipeline acting in some areas as a conduit for invasive, exotic species to spread into the interior of what were formerly unfragmented forests and wetlands.”
We’ve been down this road before – the pipeline would rely in part on sections of the same wetland-rich right-of-way of the thwarted CIRC Highway project. The EPA came down hard on the CIRC’s wetland impacts:
“Even if the mitigation were fully implemented, the proposed project will cause or contribute to significant degradation of waters of the U.S. in violation” of federal law.
Vermont needs to maintain in tact wetland ecosystems and actively pursue forward-thinking climate solutions. Let’s wake up from this pipe dream before we get sucked down its slippery slope.