In a previous post, I described the options that Sunoco considered following the DEP’s insistence that the company choose an alternative to the HDD drilling that polluted Marsh Creek Lake. The DEP told Sunoco to consider a route that the company had already admitted was “technically feasible.” (That’s the route I am calling the “original re-route” in this post, and the one I believe Sunoco should have chosen.)
So what did Sunoco do? It proposed a route that is more convenient and quicker to build, but that requires trenching through a wetland and diverting two streams. Sunoco’s proposed route is actually closer to Marsh Creek Lake than any of the 10 other routes the company claims to have evaluated.
In contrast to its chosen route, Sunoco failed to take seriously the original re-route. The company says it “does not consider it practicable”, based on “desktop review”. In other words, it never sent anyone out to look at the route in the field.
Sunoco has provided a map of the original re-route (which it calls the “1.01-mile Reroute Alternative”). The map (on p. 40 of the “105” document—the link is in the previous post) indicates that the route crosses two wetland areas, but Sunoco has not shown their boundaries, and it cannot be determined from the map whether the wetlands even exist. The company must be required to do a field assessment of the wetlands and map them properly. (The wetlands along Sunoco’s preferred route have been mapped—it is just the ones Sunoco claims may exist along the original re-route that haven’t been mapped.)
If Sunoco had taken the original re-route seriously, they would have noticed that it only crosses two small streams (which feed a pond, not Marsh Creek Lake), and it keeps the entire route far from the edge of the lake. The impact on the streams (as Sunoco states in a footnote) “cannot be calculated without in-field delineation of stream banks and bed.” Fair enough: then the DEP must insist that the impact be assessed in the field, just as Sunoco did with its preferred alternative.
Sunoco’s chosen route and the original re-route. The map below shows the now-abandoned HDD route, the original re-route, and the alternative Sunoco is proposing. It also shows the site of the frac-out that resulted in the release of thousands of gallons of drilling fluid into Marsh Creek Lake.
Sunoco’s own marketing materials show how close to the lake its proposed route comes. The image below is from one of Sunoco’s flyers. In addition to the proximity to the lake (lower left), it also shows the additional workspace that will be needed for heavy equipment (inset map).
Here’s how to make your voice heard. The DEP is holding a (virtual) public hearing on the evening of June 16. Please sign up to speak (see instructions below). Here are some ideas for points you may want to make:
- If you are a recreational user of Marsh Creek Lake, talk about the importance of avoiding lake pollution. Not only did a massive spill of drilling mud into the lake result from Sunoco’s HDD attempt, drilling mud continues to seep out along the banks of the lake, causing continuing pollution.
- If you are concerned about the quality of drinking water, let the DEP know that Marsh Creek Lake is a source of water for a large population.
- Sunoco did not follow the DEP’s instruction to properly evaluate the “original re-route”. Ask why the company only did a “desktop review”.
- Tell the DEP that Sunoco should be required to do a full field evaluation of the original re-route, including geophysical testing.
- Sunoco failed to assess the impact the original re-route would have on streams, and compare that impact with the route it is proposing. The DEP should require the company to do that analysis.
- Sunoco mapped the wetlands along its preferred route. Why didn’t it do so along the original re-route? The DEP should require expert mapping.
- The route that is farther from the lake should be given preference.
- The route that does not require cutting through streams that feed the lake should be given preference.
It isn’t necessary to mention all these points, of course. Choose the ones you feel are most important.
The hearing will begin at 6 p.m. on June 16 and (depending on how many people want to speak, I assume) could last until 10 p.m.
In order to reserve a speaking slot, you must contact John Repetz, Community Relations Coordinator, at email@example.com or 717-705-4904 to register at least 24 hours prior to the hearing. Testimony will be limited to 3 minutes for each person.
If you are not comfortable speaking or cannot be there on June 16, you can submit a written comment. Written comments may be submitted until June 23, 2021 and can be sent electronically to RA-EPWW-SERO@pa.gov.
Please participate in this hearing. Sunoco will be lining up plenty of pipeline workers to speak up for the company’s position, so we need to make sure our message comes through even more strongly.