Here’s another 5-day public comment period that is drawing to a close. Don’t let it slip by without commenting! I hope as many of you as possible will file comments about Sunoco’s plans for drilling in the Andover/Westtown area. Instructions for how to do so are at the end of this post.
Sunoco has filed a response to the questions from the Department of Environmental Protection (DEP) about the horizontal directional drilling (HDD) plans for the stretch between Route 3 and Route 926 along Route 252. These are the questions following up the initial public comment period for that HDD site, and the new 5-day comment period ends on Sunday (May 27).
If you read the DEP’s questions, you will see that the DEP is asking for much more detail in its questioning of Sunoco than it previously has. In this case, 23 specific questions posed, some with several sub-parts. In many cases, Sunoco is responding by suggesting that the DEP questions are not valid.
You may want look at Sunoco’s response, at least briefly. Later in this post, I will point out some of the issues that I find troubling, and I provide general suggestions for comments you could make.
It is most useful if you put your comments into your own words.
Two great resources for comments. Before I discuss the issues I find in Sunoco’s response document, let me point you to two other public comment documents that are full of useful local information about the inadequacy of Sunoco’s plans. One is the Thornbury Township public comment, which (among other things) details the problems with the adjacent HDD site at Slitting Mill Road. The other is the Andover Homeowner’s Association public comment, which details issues such as Sunoco’s failure to consider alternative routes, to deal with historic resources, and to provide a credible warning and evacuation plan.
There are plenty of excellent points in both documents that you may want to include in your comments.
Additional comments you might want to make. My own suggestions for comments, below, deal more specifically with Sunoco’s responses to the DEP’s questions. Here are some examples of places where I find Sunoco’s responses inadequate:
On page 1, the DEP says that a licensed Professional Geologist needs to sign and seal the opening part of Sunoco’s report. Sunoco’s response is that the text also includes material generated by engineers and HDD experts, so it is not appropriate for a geologist to sign it. You may want to suggest that the DEP insist that a Professional Geologist sign off on the parts of the text that relate to geology.
On page 4, the DEP asks for “an analysis private water supply well production zones and how the proposed HDD activities will interact with them”. Sunoco’s response is more than two pages of vague text and references to scientific papers. It does not attempt to describe the local well production zones in the area of the HDD, and how they will be affected. You could suggest that the DEP ask for a real analysis of this issue.
On page 7, the DEP asks for “water quantity tests (pump yield tests) of the private water supplies that may be affected”. Sunoco’s response is that no well owners have asked for that test. You could tell the DEP that it should not be up to the well owners to ask for it. If the DEP thinks it is important, Sunoco should do it.
On page 8, the DEP asks for more information on bedrock geology. Sunoco says “further fracture trace analysis, geotechnical bore analysis, and investigations of local hydrogeological studies have been and will be done”. But exactly what is Sunoco promising to do, and how will that shed light on the bedrock geology? You might tell the DEP to insist on a list of specific steps Sunoco will take, beyond what it has already done.
On page 10, the DEP asks for “water well depths, casing depths, and water-level depths (based on a water-level survey)”. Sunoco responds that its Attachment 4 contains “water-well depths and water levels if known”. But Sunoco has not done a water-level survey. The table of private wells in Sunoco’s Attachment 2 lists 45 wells, but the water level in 36 of them is “unknown” or “unavailable”. You might tell the DEP to require Sunoco to do a real water-level survey.
On page 15, the DEP tells Sunoco to “provide a geophysical survey” to help delineate fractures in the rock. (A geophysical survey involves using techniques such as sound waves to map underground features.) The test borings (rock core samples) that have been done are too far apart and (in some cases) too shallow. Sunoco refuses to do the geophysical survey, saying that its existing borings give it enough information. You could tell the DEP to insist on a geophysical survey.
On page 16, there is a similar request for a geophysical survey, which Sunoco again refuses.
If you look through Sunoco’s response, you will probably find other issues you will want to comment on. For example, you will see that this HDD is very likely to damage wells, since Sunoco’s own (limited) data on water levels from its test borings taken on the hill between Routes 3 and 926 indicates that the level of ground water in that area is actually higher than the HDD drill sites at either end of the HDD run. It is only common sense that the ground water will seek a lower exit point (one or both of the drill sites) if it can find a path there.
Overall, this document suggests a general willingness on Sunoco’s part to ignore the DEP’s requests. The company is determined to do as it pleases.
We need to provide the DEP with ammunition to fight back. Tell the DEP to insist that Sunoco comply with its requests. The DEP has the power to revoke Sunoco’s drilling permits, and now is the time to begin applying that leverage.
How to submit your comments. Let the DEP know what you think, at this address:
Tell the DEP about the problems you see with these plans. Feel free to use the ideas listed above, but it is most effective if you put it in your own words.
Tell the DEP you are commenting on Sunoco’s plan for the “Arch Bishop / South Chester Road Crossing” HDD.
- To have greatest effect, it is important to send copies of your DEP comments to several other places:
- To the Clean Air Council, who needs your comments as ammunition in its fight against the pipeline. Send copies to Kathryn Urbanowicz (email@example.com)
- To Governor Wolf, who has the power to stop this pipeline if he wants to. You can use this contact form: https://www.governor.pa.gov/contact/
- Send copies of your comments to your state senator and representative too. They can help put pressure on the DEP, the PUC, and the governor.