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Docket #CP19-7-000
The City ofNorthampton, Massachusetts, a municipality organized under the laws of the
("the City") hereby moves, pursuant to 18 C.F.R. § 385.214(b), to intervene in the proceeding for
Tennessee Gas Pipeline LLC, Docket #CP19-7. On October 19, 2018, Tennessee Gas Pipeline
Company, LLC ("TGP") filed with the Commission an Abbreviated Application (the
"Application") for the 261 Upgrade Projects (the "Projects") pursuant to sections 7(b) and 7(c) of
the Natural Gas Act ("NGA"), and Part 157 of the Commission's regulations, for authorization to
construct, install, modify, operate, and maintain certain pipeline and compression facilities
located in Massachusetts and Connecticut that would increase natural gas capacity on its pipeline
The City seeks to intervene in this proceeding to oppose the Project in the public's
interest, as a natural gas customer, and as a representative of natural gas consumers and
customers residing in the City. The City opposes the Project for the following reasons:
storms, forest and wild fires, and rising seas, in which the extraction, processing,
transport, and burning of fossil fuels not only plays an enormous role, but pollutes our air
by releasing noxious substances that cause many harmful and life-threatening medical
conditions such as asthma, COPD, cardiovascular disease, and poor pregnancy outcomes.
20181119-5180 FERC PDF (Unofficial) 11/19/2018 3:02:02 PM
2. The City recognizes the dangerous outcomes of climate change and supports a rapid
attainment of a goal of 100 percent clean, renewable energy for the State of
Massachusetts and the City of Northampton, and the City urges FERC to avoid taking
actions that could increase the use of fossil fuels or delay the transition to 100 percent
renewable energy.
3. The attainment of 100 percent renewable, clean energy will contribute to the mitigation
of climate change, improve the City's air and water quality, and protect the health of the
4. The transition to 100 percent renewable energy will promote employment opportunities
and economic growth in Massachusetts and in Northampton, facilitate local control and
ownership over energy options, and bring tangible benefits to low-income residents and
others who have historically been disadvantaged by fossil fuel-based energy systems.
5. Columbia Gas's long-standing moratorium on new gas service installations compelled the
aggressive pursuit of green energy modalities including energy retro-fits, solar energy
generation, air-sourced heat pumps, and methane capture, the use of which has reduced
our dependency on natural gas while conforming to the goal of using only 100%
energy infrastructure that does not rely on fossil fuels, thus significantly reducing the
demand for natural gas and challenging the stated need for expanded gas pipeline
infrastructure, and increasing natural gas supply to Northampton would slow and possibly
have adverse effects on the progress of the City's commitments to realizing a 100%
7. Repairing existing pipelines will eliminate the need for the installation of any new
pipeline infrastructure, and the City's position is that gas companies should not build new
pipeline, but rather to repair the current pipeline infrastructure to eliminate the leakage of
natural gas and in so doing reduce the health, safety and environmental dangers
8. Public pressure compelled Columbia Gas to identify and fix large methane leaks in its
distribution area, yet the company continues to claim capacity shortage issues in the
Northampton Lateral pipeline on peak days thus justifying the launch of what it is calling
a "reliability project" - the building, at the cost of $24 million to Columbia Gas rate-
payers - of a new 6-mile, 12-inch "alternate backfeed" pipeline through the city of West
Springfield.
9. A research report released in 2013 by the office of Senator Edward Markey documents
that between 2000 and 2011, by not replacing leaking natural gas pipelines, gas
companies have passed on to Massachusetts ratepayers between $640 million and $1.5
billion in costs for ''unaccounted for" gas that never reached their homes, businesses, and
municipalities, and that this leaked gas has contributed irreparably to the degradation of
the public's health; climate change; and between 2004 and 2012, caused over 250
explosions; and
10. According to the U.S. Environmental Protection Agency, in 2011, leaks and other
processes of the natural gas distribution system were the largest source of methane
emissions in the U.S., accounting for 19 percent of total methane emissions, methane
being a gas that possesses global warming potential far greater than other greenhouse
gases, specifically: it has been measured to be over 80 times more powerful a greenhouse
11. This unaccounted for gas, if captured through repair and upgrade of the current pipeline
infrastructure, could likely meet a significant portion, if not all, of our energy needs.
Based upon the foregoing, the City submits that, as a consumer of natural gas and as
representative of the residents of the City who are natural gas consumers and customers, the City
has or represents an interest which may be directly affected by the outcome of this proceeding.
Movant,
CITY OF NORTHAMPTON
Byl