andover drill area 12-4-17
This Google Earth image shows the route of the pipeline (red line) where it crosses between Delaware and Chester counties. It goes through the heart of a densely-populated area. Why didn’t Sunoco consider the sparsely-populated areas nearby?

You have just a week to respond to the Sunoco’s latest plan for HDD (horizontal directional drilling) at the border of Delaware and Chester Counties. The deadline to respond to the DEP is December 11, and it’s important to have your voice heard because there is a fundamental flaw in this plan and others like it.

The horizonal drilling in this case would begin adjacent to the Andover subdivision at the corner of Routes 352 and 926 and would surface again near Route 3. For most of that route, it would run directly underneath Route 352.

The fundamental flaw: lack of alternative route analysis. One of the important requirements placed on Sunoco in submitting this plan, like others required by the August 9 settlement agreement, is the discussion of alternative routes. Just as with the Exton plan, submitted a few weeks ago, Sunoco has failed to properly examine alternatives.

The key problem with this new plan is that Sunoco has used the wrong priorities in its analysis. The first priority should have been avoiding populated areas. Instead, Sunoco has prioritized following existing pipeline easements. This simplifies the considerations for Sunoco, but it puts lives at risk needlessly.

Sunoco claims that “safety is our #1 priority”, but its actions—and this plan—show that’s not true. This was obvious in the Exton plan as well.

There is an opportunity to route this pipeline through a far less settled area a little to the southwest, just as there were far less populated routes available near Exton. Sunoco has ignored those possibilities, despite the fact that the settlement agreement requires their consideration.

Not only would a route that runs near fewer houses drastically reduce the risk in case of a leak, it would also reduce the number of private wells that might possibly be affected by drilling.

Sunoco’s willful rejection of alternative routes is explicit in this report. “Any alternate route considered to the southwest would require the clearing of a new ‘greenfield’ corridor through existing woodlands and croplands, increase the number of stream crossings, and possibly encroach on additional private residences before it could rejoin the current route,” according to the report. But that is being disingenuous. No new “clearing of a corridor” would be required. HDD can be used to go under woodlands and croplands, just as it is being proposed to go under homes, schools, and roads. Sunoco just isn’t willing to consider it, presumably because they would have to go to the trouble of obtaining new easements.

Tell the DEP and the governor: Sunoco must consider alternative routes. That is what they agreed to do in the August 9 settlement agreement, but they are not doing it. Not only do they need to do it for this particular drill site, they need to do it for every plan they submit, including ones they’ve already filed.

Email your comments to the DEP at this address:

ra-eppipelines@pa.gov

Tell them to make Sunoco do a real analysis of alternative routes. But don’t stop there. To have greatest effect, it is important to send copies of your DEP comments to several other places:

This is important!

You can read Sunoco’s full report here.