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20181119-5180 FERC PDF (Unofficial) 11/19/2018 3:02:02 PM



Docket #CP19-7-000




The City ofNorthampton, Massachusetts, a municipality organized under the laws of the

Commonwealth of Massachusetts, with offices at 210 Main Street, Northampton, Massachusetts,

("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

system by approximately 72,400 dekatherms per day ("the Project").

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:

1. The earth is in a climate emergency, facing rising temperatures, droughts, massive

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

City's children, adults, and families.

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

City and surrounding communities to expand our already-established commitment to 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%

renewable alternatives to provide our energy.

6. Northampton and its neighbors are on a successful course of establishing a sustainable

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%

renewable energy goal.

20181119-5180 FERC PDF (Unofficial) 11/19/2018 3:02:02 PM

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

associated with gas leaks.

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


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

gas than carbon dioxide over a 20 year period.

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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.

Dated: November 20, 2018


Al Seewald, BBO # 546790

Northampton City Solicitor
71 King Street
Northampton, MA 01060
T: (413) 584-4455
F: (413) 582-6881
20181119-5180 FERC PDF (Unofficial) 11/19/2018 3:02:02 PM
Document Content(s)

City of Northampton Motion to Intervene.PDF...........................1-4