I am writing to express my opposition to the proposed East Tennessee Natural Gas (ETNG) Ridgeline Expansion Project, a 122-mile gas pipeline that would be built by Enbridge, Inc. to feed a proposed TVA methane gas power plant.

The Federal Energy Regulatory Commission (FERC) and U.S. Army Corps of Engineers should deny Ridgeline’s Certificate of Public Convenience and Necessity and Section 404 Permit, respectively. This pipeline is unnecessary because there are cleaner, cheaper and safer options for producing electricity to replace the retiring Kingston coal plant.

Regulators must consider the cumulative impacts of the proposed gas plant and pipeline because they are connected actions. And the Environmental Protection Agency (EPA) has called out “serious deficiencies” in TVA’s analysis, which are so severe that the EPA says TVA didn’t meet legal requirements. If TVA’s analysis broke the law, then Ridgeline is based on a faulty premise.

Working families across the Tennessee Valley would pay for the gas plant and pipeline with their power bills. But economists and the EPA agree that gas would cost over $1 billion more than clean energy replacement options for the coal plant. This is unjust.
Ridgeline would cross Tennessee waterways around 400 times, threatening the water that communities use for drinking, fishing, kayaking and more. These biodiverse waterways are also home to cherished wildlife. Ridgeline was found likely to adversely affect at least four federally endangered or threatened species — the spotfin chub, sickle darter, Tennessee bean and Alabama lampmussel.

At one single crossing of the Emory River, Enbridge wants to trench through federally-recognized critical habitat for the spotfin chub and proposed critical habitat for the sickle darter. During a survey of this crossing, consultants found five Alabama lampmussels. This incredibly rare, endangered mussel — located in only four rivers globally — was thought to be extinct from Tennessee until some were found in the Emory in 2011. It is unacceptable to allow Enbridge to put these species at greater risk of extinction.

Pipeline construction will threaten dozens of wells and springs that people depend on for their drinking water. If these are contaminated or dewatered during construction, people may be left with no other options. The pipeline company should be required to provide pre- and post- construction testing free of charge and the public should be able to hold the company accountable for any change in quality or quantity.

Enbridge has documented 75 structures in the project’s proposed path, including numerous chicken coops, sheds, garages and more. It is wrong for Enbridge to expect landowners to pay to remove and replace those within the existing 3100 Line right-of-way. Not only were many landowners not present when the existing pipeline was put in, but the old easements did not specify that such structures were forbidden.

Now, landowners are facing both the threat of land seizure and the economic burden of moving their own structures. Enbridge, a multibillion-dollar corporation, can certainly afford to compensate landowners for this hardship, especially as they ask to profit from rural Tennesseans’ land for decades.

Neither the gas plant nor pipeline will bring jobs to the region. Enbridge says Ridgeline would provide only one permanent, full-time job, and that only half of the temporary construction jobs, at most, would go to local workers. While the Kingston plant closure will cause the loss of approximately 200 jobs, the proposed Kingston gas plant would likely provide only 25 to 35 long-term jobs. Meanwhile, an Appalachian Voices study found that a clean energy replacement could create 20 to 30 times more long-term jobs.

There are also serious unanswered questions about the design of this pipeline. For example, the pipeline company wants to dig a one-mile-long tunnel under the Cumberland River, even though its own geotechnical experts have raised concerns — which still have not been resolved — about whether the plan is feasible.
It was disappointing to see FERC conclude that the Flynn Creek Impact Crater, one of the best-preserved ancient meteorite impact craters on Earth, is not threatened by this pipeline. In addition to the effects of construction through the crater, the pipeline also poses risks of exploding, like the existing pipeline owned by Enbridge did in Smith County, Tennessee, both in 1949 and 2018.

This pipeline will be responsible for over 1.6 million tons of downstream greenhouse gas emissions each year for decades. Reviewing agencies cannot hide this climate pollution by subtracting it from the historic emissions of the retiring coal-fired Kingston Fossil Plant. The coal plant must retire within a few years regardless of whether the pipeline is built.

Recent studies show that upstream greenhouse gas emissions from gas pipelines are higher than previously thought and can swallow up any supposed climate benefit of methane gas replacing coal. These foreseeable emissions must not be left off the ledger.

Please deny the requested permits for this dangerous, unnecessary and burdensome pipeline. Thank you for considering my comments.