This legal action should reserve the right of WWALS to participate in legal hearings, file briefs on legal actions by others, or even to bring legal action. In addition to all the county and city resolutions listed here, Hamilton County, Florida also just moved to intervene.

Filed with FERC 16 December 2014 as Accession Number: 20141216-5051, “Motion to intervene and request for extension of filing deadline, by WWALS Watershed Coalition, Inc. under CP15-17.”

WWALS Watershed Coalition, Inc.
a 501(c)(3) nonprofit corporation
3338 Country Club Road #L336
Valdosta, GA 31605
16 December 2014

VIA ELECTRONIC FILING
Ms. Kimberly Bose
Federal Energy Regulatory Commission
888 First Street NE
Washington, DC 20426

Re: Sabal Trail Transmission, LLC Docket No CP15-17

Dear Ms. Bose,

WWALS Watershed Coalition files these objections in response to FERC’s NOTICE OF APPLICATION for Sabal Trail in Docket CP15-17, with a deadline of 24 December 2014.

http://elibrary.ferc.gov/idmws/file_list.asp?accession_num=20141203-3021

WWALS asks FERC to extend that deadline for at least 90 days. Sabal Trail has had a year to develop the hundreds of pages it filed, and it is unreasonable to expect interested parties to develop coherent responses to that mass of material in the three weeks indicated by FERC.

WWALS continues to object to the Sabal Trail pipeline for the same basic reasons from WWALS’ attempt a year ago to file as an intervenor on Sabal Trail’s pre-filing docket (accession number 20131118-5008; please find a copy attached), including:

http://elibrary.ferc.gov/idmws/file_list.asp?accession_num=20131118-5008

"Profits for fossil fuel companies elsewhere are no reason to violate property rights of local people, or to destroy our local watersheds, or to risk contamination of our aquifer."

Sabal Trail still has failed to demonstrate any need other than corporate profit for their proposed hazardous and destructive pipeline of Docket CP15-17. Therefore WWALS asks FERC to deny Sabal Trail any and all permits.

In particular, this letter and its attachments address these points:

1) Lack of Need
2) Threats by Sabal Trail of Georgia Eminent Domain
3) Massive formal opposition to Sabal Trail
4) Sinkhole, aquifer, and drinking water issues
5) Corrosion issues in our acidic soil and blackwaterrivers
6) Conclusion

1. Lack of Need

The only alleged ‘‘need’’ in Sabal Trail’s formal filing of 21 November 2014 in docket CP15-17 is that it says FPL and Duke Energy have agreed to buy almost all the gas.

http://elibrary.ferc.gov/idmws/common/OpenNat.asp?fileID=13691099

Sabal Trail’s several-hundred-page cover letter to that filing in which it alleges that ‘‘need’’ does not mention solar power even once, even though Florida is the Sunshine State, with even more insolation than Georgia, while Georgia is moving ahead with installing solar panels on rooftops and in solar farms.

Even if FPL and Spectra Energy’s Sabal Trail could sell all its gas to FPL and Duke Energy, that would not change the point WWALS made in its 17 November 2014 FERC filing (accession number 20141117-5041; copy attached):

http://elibrary.ferc.gov/idmws/file_list.asp?accession_num=20141117-5041

‘‘There is no reason anyone in WWALS’ watersheds should accept any risk for the profit of Williams Company, Spectra Energy, and FPL, when any need for the Sabal Trail pipeline is unproven, and in any case the pipeline does not serve anyone in Georgia.’’

Those profits may not even be derived from selling gas in Florida. Despite Sabal Trail and FPL and FERC continuing to refuse to discuss it, there are three liquid natural gas (LNG) export operations in Florida right where this pipeline chain would go, all three already authorized by the U.S. Department of Energy’s Office of Fossil Energy (FE):

27 July 2011 DOE/FE Order No. 2993 for FE Docket No. 11-71-LNG, Carib Energy, now owned by Crowley Maritime

http://www.crowley.com/content/download/14440/94698/version/2/file/Carib+Energy+-+FTA+License.pdf

14 November 2013 DOE/FE Order No. 3360 for FE docket No. 13-104-LNG, Floridian LNG (FLiNG)

http://www.fossil.energy.gov/programs/gasregulation/authorizations/Orders_Issued_2013/ord3360.pdf

12 December 2013 DOE/FE Order No. 3371 for FE Docket No. 13-122-LNG, Goven

http://www.fossil.energy.gov/programs/gasregulation/authorizations/2013_applications/Goven_Natural_Gas_Holdings,_LLC_-_FE_Dkt.html

The head of the Office of Fossil Energy that ordered those three LNG export authorizations and one of FERC’s own Commissioners have testified before Congress that the purpose of new pipelines is to market a glut of fracked methane to higher-priced markets overseas.

25 March 2014, "Statement of Paula Gant, Deputy Assistant Secretary for Oil and Natural Gas, Office of Fossil Energy, U.S. Department of Energy, Before the Subcommittee on Energy and Power, Committee on Energy and Commerce, United States House of Representatives, The Department of Energy’s Program Regulating Liquefied Natural Gas Export Applications",

http://docs.house.gov/meetings/IF/IF03/20140325/101953/HHRG-113-IF03-Wstate-GantP-20140325-U1.pdf

The boom in domestic shale gas provides unprecedented opportunities for the United States. Over the last several years, domestic natural gas production has increased significantly, outpacing consumption growth, resulting in declining natural gas and LNG imports. Production growth is primarily due to the development of improved drilling technologies, including the ability to produce natural gas trapped in shale gas geologic formations….

Today, domestic natural gas prices are lower than international prices of delivered LNG to overseas markets. As in the United States, demand for natural gas is growing rapidly in foreign markets. Due primarily to these developments, DOE has received a growing number of applications to export domestically produced natural gas to overseas markets in the form of LNG.

5 December 2013, "Written Testimony of Commissioner Tony Clark, Federal Energy Regulatory Commission, Before the Committee on Energy and Commerce Subcommittee on Energy and Power United States House of Representatives, Hearing on Evaluating the Role of FERC in a Changing Energy Landscape",

http://ferc.gov/CalendarFiles/20131205094327-Clark-12-05-2013.pdf

As you might expect, the shale revolution in both liquids and natural gas production is having a tremendous impact on the work of the FERC. We see this in a number of our different jurisdictional areas, which I will now highlight.

One of the areas where the FERC is seeing an impact on our operations as a result of these activities is with regard to pipelines….

The large amount of natural gas in the U.S. is also creating an impetus for something that was nearly unimaginable ten or fifteen year ago, LNG export, as opposed to import terminals. This is an area of significant workload increase for the Commission.

Presently, the FERC has thirteen proposed LNG export terminals and three LNG import terminals in some phase of the permitting process.

Once a pipeline is built, it can decide to sell to whomever it pleases, regardless of any former alleged sales contracts. So LNG export is still very much an option for Sabal Trail, and is even less of a reason for domestic environmental destruction.

2. Threats by Sabal Trail of Georgia Eminent Domain

Meanwhile, Sabal Trail has for at least a year been sending letters to local landowners threatening Georgia eminent domain, either directly from Sabal Trail or from a law firm in Atlanta. Sabal Trail claimed that wasn’t so.

19 November 2014, ‘‘Sabal Trail: Eminent domain accusation ‘hard to believe’,’’ by Joe Adgie, Valdosta Daily Times,

Andrea Grover, director of stakeholder outreach for Sabal Trail, said allegations from homeowners that surveyors threatened eminent domain on their properties was ‘‘hard to believe.’’

In response, local landowners provided copies of the letters they had received that contained threats of eminent domain by Sabal Trail.

26 November 2014, ‘‘Residents share eminent domain letters,’’ by Joe Adgie, Valdosta Daily Times,

Letters submitted to the Valdosta Daily Times and to the Federal Energy Regulatory Commission could contradict a recent statement by Sabal Trail’s Andrea Grover.

Property owners state that these letters contradict a recent statement by Grover to the Times that accusations that they had been threatened with eminent domain on their properties was ‘‘hard to believe.’’

‘‘I would really disagree with any of those accusations,’’ Grover said.

However, several property owners shared a form letter that was sent to them by Sabal Trail, and their representing law firm, Hunton & Williams.

Please find attached the example letter quoted by the Valdosta Daily Times, from Hunton & Williams to local Lowndes County, Georgia landowner Larry Rodgers, dated 26 November 2013, which cites Georgia Code O.C.G.A. 22-3-88 and claims:

‘‘Natural gas pipeline companies such as Sabal Trail are expressly granted eminent domain rights under Georgia law.’’

See also the response to Huston & Williams from Rodgers’ attorney Bill Langdale, dated 4 December 2013 (copy attached), which says in part:

‘‘The code section would appear to require Sabal Trail to actually furnish the natural gas in the State of Georgia as a condition of exercising eminent domain rights in Georgia. As Sabal Trail’s proposed use does not appear to furnish any natural gas in the State of Georgia, it is not authorized to exercise eminent domain rights pursuant to O.C.G.A. 22-3-88. Therefore, even if Sabal Trail obtains and furnishes my client with a Certificate of Public Convenience and Necessity, it is our opinion, based on information we currently have, that Sabal Trail would not have the right to exercise eminent domain, and any entry on our client’s Property would be an unauthorized entry.’’

See also local landowner Bill Kendall’s FERC filing of 30 September 2014 (accession number 2014-0929-0059) in which he makes the same point as Bill Langdale.

http://elibrary.ferc.gov/idmws/file_list.asp?accession_num=20140929-0059

See especially the page of Bill Kendall’s filing that FERC initially lost, and the he filed again 3 October 2014 (accession number 20141003-5029).

http://elibrary.ferc.gov/idmws/file_list.asp?accession_num=20141003-5029

Sabal Trail Transmission, LLC did use ‘‘threatening’’ and ‘‘intimidating’’ language in ensuing letters to people by insisting STT had the absolute right to use Georgia’s eminent domain law, O.C.G.A. 22-3-88 to force property owners to allow STT onto their property for survey purposes. The letters implied, to the average property owner, that they would be taken to court if they did not sign allowing STT personnel on their property for surveying purposes. It is unknown how many property owners signed the letter under duress. In our opinion, STT did abuse and misuse 0.C.G.A. 22-3-B8 to gain entry to some properties for surveying purposes.

See also local landowner Sandra Jones’ FERC filing of 2 December 2013 (accession number 20131202-5006) containing a letter from her to Sabal Trail’s law firm Huston & Williams saying in part:

http://elibrary.ferc.gov/idmws/file_list.asp?accession_num=20131202-5006

‘‘Any entry onto either of these two properties will be deemed a trespass.’’

19 November 2014 local landowner Sandra Jones responded to Sabal Trail’s ‘‘hard to believe’’ in a FERC filing (accession number 20141119-5122) that details a long series of threats of eminent domain from Sabal Trail and Huston & Williams, including copies of the letters she quotes, and her responses.

http://elibrary.ferc.gov/idmws/file_list.asp?accession_num=20141119-5122

1 December 2014, Sabal Trail’s Lisa A. Connolly responded in a FERC filing (accession number 20141201-5276) claiming all those letters to Jones from Sabal Trail and Huston & Williams were merely for surveying which had nothing to do with emiment domain, despite the obvious connection that the surveying is required by FERC in the permitting process that would result in Sabal Trail being able to use eminent domain on the surveyed property.

http://elibrary.ferc.gov/idmws/file_list.asp?accession_num=20141201-5276

3 December 2014, Sabal Trail’s Andrea Grover doubled down on this line of argument in ‘‘Sabal Trail: Accusations ‘lack any substance’,’’ by Joe Adgie in the Valdosta Daily Times,

‘‘I am quite confident that any objective reading of the letters will determine that the letters are intended to be informational and not threatening as suggested by a few people,’’ Grover wrote in an email on Monday. ‘‘The letters are a pro forma process developed to fully and transparently inform the remaining property owners who refused survey permission of the state law related to the survey process.’’

The property owners remain in possession of their own property, including their ability to fend off trespassers such as pipeline companies from some other state, regardless of Sabal Trail’s attempts to use Georgia law against them.

21 November 2014, after a year of threatening local landowners with Georgia eminent domain, Sabal Trail’s formal FERC filing in docket CP15-17 claims that it does have a customer in Georgia now, namely the Georgia Municipal Gas Authority (MGAG), and that Sabal Trail or MGAG:

‘‘has identified Dougherty and Colquitt Counties as having the greatest potential to need additional gas supplies in the future.’’

Sabal Trail’s Andrea Grover amplified by naming Albany and Moultrie, Georgia, the county seats and MGAG customers in those counties.

28 November 2014 ‘‘Sabal Trail to install taps in Georgia,’’ Joe Adgie, Valdosta Daily Times,

Sabal Trail director of stakeholder outreach Andrea Grover said Wednesday the decision was made as the result of ongoing discussions with the Municipal Gas Authority of Georgia….

This would supply natural gas from Sabal Trail to customers in the Albany and Moultrie area, she said, and could also serve to counter arguments from property owners that they had been illegally served with eminent domain threats.

27 October 2014, the Dougherty County Commission had already passed Resolution 14-019 and filed it with FERC 5 November 2014 (accession number 20141105-0025).

http://elibrary.ferc.gov/idmws/file_list.asp?accession_num=20141105-0025

FERC’s online copy of that filing is missing the second page of Dougherty County’s resolution. Please find attached a complete copy of that FERC filing with the missing page interpolated. Dougherty County’s resolution says in part:

SECTION II Thus, we are in opposition to the construction of the proposed pipeline in Dougherty County and request that FERC give serious consideration and analysis to alternative routes (1) that avoid unstable geologic areas such as karst and sink-hole prone areas, (2) that minimize impacts to drinking water and agricultural water supplies, (3) that minimize impacts to wildlife habitat, forest, wetlands, streams and rivers and (4) that do not compromise socio-economic and cultural issues.

SECTION III We ask that serious consideration and analysis be given to the alternative route through the Panhandle of Florida, a copy of which is attached hereto.

28 October 2014, the Commissioners of the City of Albany had already passed Resolution 14-R 175, a copy of which is attached, and which reads in part:

SECTION 4, Sabal has failed to present any evidence of the need to expand natural gas in this area. The City understands Sabal has failed to show that there are any definitive plans for natural gas service other than for the State of Florida,

SECTION 8. The Resolution passed yesterday by the Board of Commissioners of Dougherty County, a copy of which is attached hereto and incorporated herein by reference, describes many concerns with this Project. The Resolution describes in detail the burdens that this Project will impose on citizens of Albany/Dougherty County and the Mayor and Board of Commissioners of the City of Albany wholeheartedly endorse the Resolution.

See also the objections of Georgia State Representative Winfred Dukes, District 154, including Dougherty County, filed with FERC 14 November 2014 (accession number 20141114-5012)

http://elibrary.ferc.gov/idmws/file_list.asp?accession_num=20141114-5012

Based on all of the above. it does not require much of a leap to assume that SST is planning to take people’s private property for private profit by enabling one of its parent owners.

These resolutions and letters indicate Albany and Dougherty County do not want Sabal Trail’s pipeline nor any gas from it.

The other county Sabal Trail claimed wanted Sabal Trail gas via MGAG was Colquitt County.

4 March 2014, the Colquitt County Commission passed Resolution 2014-R-6 (copy attached) expressing concerns about agriculture, and resolving:

NOW, THEREFORE BE IT RESOLVED, that the Colquitt County Board of Commissioners adamantly urge that Sabal Trail Natural Gas Pipeline should make every effort to ensure that the Sabal Trail Natural Gas Pipeline is buried with a minimum of five (5) feet of top cover when traversing agricultural properties to include pasture land, cultivated lands, surface drains, diversions, waterways, open ditches and streams.

BE IT FURTHER RESOLVED, that the Sabal Trail Natural Gas Pipeline obtain required permits from the Colquitt County Roads and Bridges Department prior to crossing any county roads or public access.

That is not an expression of any ‘‘need’’ for Sabal Trail’s pipeline; instead, Colquitt county expressed opposition to Sabal Trail’s pipeline plan.

The Mayor of Moultrie, the county seat and MGAG customer in Colquitt County, directly refuted Sabal Trail’s assertions:

2 December 2014, ‘‘New Sabal Trail Project Has Many South Georgia Residents Worried About Eminent Domain,’’ by Winnie Wright on WCTV,

http://www.wctv.tv/home/headlines/One-Year-After-Sabal-Trail-Announces- Pipeline-Plans-Activists-Begin-Monthly-Protests-279974602.html

‘‘There’s been no discussion about any of the ramifications of whether we’d want it, or whether we wouldn’t want it’’, said Moultrie Mayor, Bill McIntosh.

So the MGAG customers and county seats of both counties Sabal Trail named ‘‘as having the greatest potential to need additional gas supplies in the future’’ say either they weren’t consulted about the MGAG deal or they don’t want Sabal Trail’s pipeline. Colquitt County had already passed a resolution opposing Sabal Trail’s plans for that county. And Albany and Dougherty County had already passed resolutions saying they don’t want the Sabal Trail’s pipeline or compressor station anywhere in their city, their county, or the state of Georgia.

This formal opposition corroborates widespread public opposition. Sabal Trail in its 21 November 2014 permit application mentions ‘‘more than 40 stakeholder informational meetings and open house meetings for affected landowners and other stakeholders, including municipal, county, state and federal officials, in Alabama, Georgia, and Florida,’’ ‘‘20 open house meetings,’’ and ‘‘in March 2014, the Commission Staff hosted 10 formal scoping meetings’’ without mentioning that the public response at those meetings, and at others hosted by the Dougherty County Commission, the Gilchrist County, Florida Commission, and others elsewhere, was overwhelmingly against Sabal Trail’s pipeline.

3. Massive formal opposition to Sabal Trail

Opposition to Sabal Trail does not end just with the counties and cities Sabal Trail named. Quitman is an MGAG customer and the county seat of Brooks County, Georgia.

4 April 2014, Brooks County Commission Minutes:

http://www.brookscountyga.us/Minutes/2014/April%207%202014.pdf

B. Sabal Trail Pipeline Resolution — A copy of a resolution from Colquitt County regarding the Sabal Trail Pipeline was received by Administration. The resolution adamantly urges that the pipeline be buried with a minimum of 5 feet of cover for only certain parcels of land. A majority of parcels in Brooks County would be covered by this resolution, the County may consider asking for the 5 feet cover throughout Brooks County, regardless of property type or use. The Board can approve or disapprove the resolution regarding the Sabal Trail Natural Gas Pipeline. Mr. Wingate made the motion to approve the Sabal Trail Natural Gas Pipeline Resolution for Brooks County, Mr. Maxwell seconded. Vote was unanimous.

Dawson, Georgia is an MGAG customer and the county seat of Terrell County, Georgia.

5 November 2014, the Terrell County Commission passed a resolution against the Sabal Trail pipeline and filed it with FERC 13 November 2014 (accession number 20141113-5035). A copy is attached, and it reads in part:

http://elibrary.ferc.gov/idmws/file_list.asp?accession_num=20141113-5035

WHEREAS, it is clear to this board that the Sabal Trail will not service any of the needs of the residents of Terrell County, Georgia or any residents of Georgia, and:

WHEREFORE IT IS RESOLVED by the Board of Commissioners of Terrell County, Georgia as follows:

The Board feels that the Sabal Trail will not provide any benefit to Terrell County, Georgia for the construction of the gas pipeline through the county. Further, many of our residents oppose the pipeline including many agricultural and agritourism businesses which would be impacted by the construction of the same. Thus, we are in opposition to the construction of the proposed pipeline in Terrell County and request the Federal Energy Regulatory Commission (FERC) give serious consideration and analysis to alternate routes that avoid the impact to Terrell County, Georgia including those that affect wildlife habitat, forests, wetlands, streams and creeks and that do not compromise socioeconomic cultural issues.

See also the objections of Georgia State Representative Gerald Greene, District 151, including Terrell County, filed with FERC 18 November 2014 (Accession Number 20141118-0021).

http://elibrary.ferc.gov/idmws/file_list.asp?accession_num=20141118-0021

Far from wanting any Sabal Trail gas from MGAG, two counties whose county seats are MGAG customers (Dougherty and Terrell) have said they don’t want it anywhere in their county, one (Dougherty) has said it doesn’t want it anywhere in the state, as did MGAG customer Albany. Two other counties with MGAG customers (Colquitt and Brooks) have said they see no need for this pipeline in Georgia, while the Mayor of MGAG customer Moultrie has said Moultrie wasn’t consulted before Sabal Trail’s claimed agreement with MGAG.

So both the counties and both the cities named by Sabal Trail in conjunction with its alleged agreement with MGAG have refuted Sabal Trail’s claims of consultation and of need, and that refutation also extends to at least three other counties which have MGAG customers.

Why, then, would MGAG make a deal with Sabal Trail? Perhaps that would be related to what MGAG’s About web page says:

http://www.gasauthority.com/cms/About+MGAG/43.html

Members’ systems are located on three interstate pipelines: Southern Natural Gas Company (Southern Natural), Transcontinental Gas Pipeline Company, LLC. and Texas Eastern (TETCO).

Transcontinental Gas Pipeline Company is the same Transco of the Hillabee Expansion Project of FERC Docket CP15-16, which would feed gas to Sabal Trail and is one of the three components along with Sabal Trail in the Southeastern Market Pipelines Project. Texas Eastern is a subsidiary of Spectra Energy, co-owner of Sabal Trail. A Sabal Trail deal with MGAG might help Spectra’s and Transco’s profits by enabling Georgia eminent domain and thus speeding permits from FERC and other agencies. Yet such a deal seems to have nothing to do with actual need or want by any of the counties or cities Sabal Trail named, all of which object to Sabal Trail’s pipeline, and such objections extend to at least three more counties in MGAG territory.

Formal refutation of Sabal Trail’s alleged customers in Georgia and opposition to Sabal Trail’s pipeline anywhere Georgia does not stop with MGAG customers, either.

13 November 2014, the third MGAG interstate supplier, Southern Natural Gas (SONAT), the one that actually supplies all the MGAG customer cities on Sabal Trail’s proposed paths in Georgia, filed with FERC (accession number 20141113-5199), objecting to Sabal Trail’s plans to bore under SONAT’s pipelines an excessive number of times, risking stresses, corrosion, and pipeline failure, plus SONAT complained that Sabal Trail proposed a substandard crossing method merely to reduce costs at the expense of safety.

http://elibrary.ferc.gov/idmws/file_list.asp?accession_num=20141113-5199

Moreover, disturbing the soil around, and under, the SNG pipeline during construction of each crossing creates the additional possibility that the soil around the pipeline could become de-stabilized, which could then cause undue stresses on the pipeline, potentially resulting in a failure of the pipeline at some future date. This possibility of creating undue stress on the pipeline segment is exacerbated when the crossing is accomplished by using the open-cut method rather than boring. In this case, Sabal Trail is proposing to open-cut the crossings, as that is less expensive, while SNG is insisting that all crossings be bored, as that is safer construction method for protecting the integrity of SNG’s existing pipeline facilities. Crossings also complicate the cathodic protection systems of both pipelines, making it more difficult to ensure that both pipelines are adequately protected from external corrosion.

So even another pipeline company says Sabal Trail’s proposed pipeline plan is too risky.

9 December 2014, the Lowndes County Commission unanimously passed the resolution it already filed with FERC 21 November 2014 (accession number 20141121-5242; copy attached) in Docket CP15-17, which reads in part:

http://elibrary.ferc.gov/idmws/common/OpenNat.asp?fileID=13692695

WHEREAS, The State of Georgia and Lowndes County has not been shown to benefit from the availability of natural gas from the Sabal Trail pipeline at this time, and;

NOW THEREFORE, be it resolved that the Lowndes County Board of Commissioners opposes the construction of the Sabal Trail pipeline in any portion of Lowndes County. The Lowndes County Commission has concerns with fundamental property rights and does not believe that citizens with small tracts should be forced to lose the use of large portions of their property for the Sabal Trail pipeline. The Lowndes County Commission does not see any long term benefit to the citizens of Lowndes County, The Lowndes County Commission formerly asks the Federal Energy Regulation Commission (FERC), and our state and federal legislators to support us in this effort to have Lowndes County and The State of Georgia bypassed.

11 December 2014, City Council of Valdosta, the county seat of Lowndes County, passed ‘‘A RESOLUTION IN SUPPORT OF THE LOWNDES COUNTY BOARD OF COMMISSIONERS REGARDING THE SABAL TRAIL PIPELINE PROJECT’’, citing all the same concerns and requests as Lowndes County, plus one.

Valdosta and Lowndes County are not MGAG customers. However, Lowndes County is the most populous county along any of Sabal Trail’s routes in Georgia, and anywhere between Auburn, Alabama and Gainesville, Florida. Sabal Trail’s preferred route and all but one of Sabal Trail’s alternative routes would go through Lowndes County, crossing the Withlacoochee River. Three of those alternative routes (Greenlaw Alternatives 1, 2, and 4) would go through the City of Valdosta.

Both Valdosta and Lowndes County, like Albany (the most populous city on the proposed pipeline paths in Georgia) and Dougherty County (the second most populous county), want the Sabal Trail pipeline out of their city, their county, and their state.

4. Sinkhole, aquifer, and drinking water issues

22 August 2014, the Board of Commissioners of Hamilton County, Florida passed Resolution 14-10 (please see copy attached) asking for Sabal Trail to move the pipeline off of the Withlacoochee River in Florida, and Sabal Trail seems to have agreed to move it.

15 October 2014, FERC filed a Notice of Intent for Sabal Trail (accession number 20141015-3017) including "Withlacoochee River Crossing Route Alternative (Hamilton and Suwannee Counties, Florida)" that would move the pipeline off of the Withlacoochee River in Florida.

http://elibrary.ferc.gov/idmws/file_list.asp?accession_num=20141015-3017

21 October 2014, Sabal Trail held an Open House about this route alternative in Jasper Florida, with FERC personnel in attendance, in which Sabal Trail said it would bypass the Withlacoochee River in Florida.

Especially given that Sabal Trail’s proposed paths would cross that same Withlacoochee River in Georgia either in Valdosta or at the border of Lowndes County and Brooks County, and all of those three have passed resolutions of opposition to the Sabal Trail pipeline, WWALS recommends even more strongly than before that the Sabal Trail pipeline not cross the Withlacoochee River anywhere.

22 October 2014, Item 9, ‘‘WITHLACOOCHEE RIVER & FLORIDAN AQUIFER: Gas Pipeline Threatens Southwest Georgia Water, Way of Life’’, in Dirty Dozen 2014, by the Georgia Water Coalition (GWC); see the WWALS ecomment of 17 November 2014 (accession number 20141117-5041; copy attached), which notes GWC is

http://elibrary.ferc.gov/idmws/file_list.asp?accession_num=20141117-5041

‘‘a consortium of 217 conservation and environmental organizations, hunting and fishing groups, businesses, and faith-based organizations that have been working to protect Georgia’s water since 2002. Collectively, these organizations represent more than 300,000 Georgians.’’

Especially together with the Brooks, Lowndes, Valdosta, Colquitt, Dougherty, Albany, and Terrell County resolutions, this is massive opposition to the Sabal Trail pipeline crossing the Withlacoochee River or any other river in Georgia or the Floridan Aquifer.

And the opposition extends beyond Georgia.

4 March 2014, "TRI-STATE SIERRA CLUB CHAPTERS OPPOSE GAS PIPELINE: Statement of the Georgia, Florida, and Alabama Sierra Club Chapters Opposing the Sabal Trail Pipeline.", read to FERC at the Valdosta Scoping Meeting. Here is the full text:

ATLANTA, GA–The Georgia, Florida, and Alabama Chapters of the Sierra Club oppose the 650 mile Sabal Trail Transmission natural gas pipeline that would carry fracked natural gas extracted from Pennsylvania and Texas through Alabama, Georgia, and Florida. Sabal Trail Transmission, LLC is a joint venture between Spectra Energy Partners, LLC and and NextEra Energy, Inc. Spectra Energy and its related companies have been fined repeatedly for safety and environmental violations throughout the United States including one fine of $15,000,000.

The proposed pipeline would cut a wide swath through pristine lands with resulting negative impacts on endangered species, critical wildlife habitat, invaluable wetlands, longleaf pine forests, the fragile and irreplaceable Floridian Aquifer, streams, rivers, and springs, and private property rights. Furthermore, expanded reliance on fracked natural gas only serves to feed the increasingly destructive effects of drilling for and fracking of shale deposits that have destroyed drinking water resources and entire communities across the country. The Sunshine State, which will be the sole recipient of the fracked natural gas transported through this pipeline, should expand energy efficiency measures and solar power capacity rather than increase its dependence on natural gas which already accounts for more than 60% of Florida’s electricity generation.

Additional information about the Spectra Pipeline project can be found through our partner’s website at http://spectrabusters.org/. Spectrabusters is citizen-led organization that spans multiple counties and states, which opposed the Sabal Trail Pipeline proposed from Alabama to Florida.

The Sierra Club is America’s largest and most influential grassroots environmental organization, with more then 2.4 million members and supporters nationwide, and with over 100,000 in Georgia. In addition to creating oppoortunities for people of all ages, levels and locations to have meaningful outdoor experience, the Sierra Club works to safeguard the health of our communities, protect wildlife, and preserve our remaining wild places through grassroots activism, public education, lobbying, and litigation. For more information visit, http://www.sierraclub.org

3 March 2014, Valdosta City Council Tim Carroll filed a letter with FERC (accession number 20140303-5005; copy attached), which reads in part:

http://elibrary.ferc.gov/idmws/file_list.asp?accession_num=20140303-5005

3. South Georgia’s greatest resource, the Floridan Aquifer from which we receive all our potable water is held in fragile karst limestone. Potential damage during construction and maintenance of this proposed pipeline could cause pollution and sinkholes. The health, safety and welfare of our local citizens clearly outweighs those of a private company in this matter.

11 December 2014, the City of Valdosta added this item to its resolution (copy attached) beyond the Lowndes County resolution:

WHEREAS, the City of Valdosta has concerns regarding any potential effect the proposed pipeline or its construction might have on the Floridan aquifer, the primary source of the drinking water supply for our City, County and the south Georgia area; and

The Floridan Aquifer is also the main source of drinking water for all of WWALS’ watersheds, as well as for most of the region the Sabal Trail pipeline would traverse in south Georgia or south Alabama by any of its routes, and for all of Florida.

18 April 2014 FERC filing (submission number 20140418-5237) by the Florida Department of Environmental Protection, includes a letter of 27 March 2014 through Jon Arthur, Florida State Geologist.

http://elibrary.ferc.gov/idmws/file_list.asp?accession_num=20140418-5237

That letter spells out many reasons why the Sabal Trail pipeline is inappropriate in the fragile karst limestone geography of north Florida. That letter is illustrated by the "Florida portion of the Southeast Markets Pipeline Project superimposed on Floridan Aquifer Vulnerability Assessment Map", which is also included on the next page of the present letter. While that map stops at the state line, the geology does not, and the same risks apply in south Georgia as in north Florida.

17 November 2014, see WWALS ecomment (accession number 20141117-5041; copy attached) for further detail on sinkhole, aquifer, and drinking water issues.

http://elibrary.ferc.gov/idmws/file_list.asp?accession_num=20141117-5041

5. Corrosion issues in our acidic soil and blackwater rivers

See the WWALS 17 November 2014 ecomment (copy attached) for corrosion issues in our acidic soil and blackwater rivers.

6. Conclusion

There is no reason anyone in WWALS’ watersheds should accept any risk for the profit of Williams Company, Spectra Energy, and FPL, when any need for the Sabal Trail pipeline is unproven, and in any case the pipeline does not serve anyone in Georgia.

There is no excuse for yet another gas pipeline when solar power is already less expensive, doesn’t require a hundred foot right of way, emits no pollution, doesn’t use massive amounts of water, risks no spills or fires, and provides cheaper electricity and jobs right here in south Georgia and north Florida.

Sabal Trail’s pipeline does not belong anywhere in our acidic blackwater rivers or our acidic soil or our fragile karst sinkhole-prone limestone containing our Floridan Aquifer drinking water.

WWALS Watershed Coalition strongly recommends FERC deny any and all permits related to Sabal Trail’s Docket CP15-17.

Sincerely,

John S. Quarterman

President
WWALS Watershed Coalition, Inc.
229-242-0102

WWALS is an advocacy organization working for watershed conservation of the Willacoochee, Withlacoochee, Alapaha, and Little River Systems watershed in south Georgia and north Florida through awareness, environmental monitoring, and citizen advocacy.

Attachments:

2013-11-18–wwals-prefiling-motion.pdf WWALS pre-filing motion, accession number 20131118-5008

2014-11-17–wwals-gwc-to-ferc-long.pdf WWALS filing including Georgia Water Coalition Dirty Dozen Item #9, accession number 20141117-5041

2013-11-26–calvert.pdf Letter from Matthew J. Calvert of Hunton & Williams to Larry Rodgers Investments

2013-12-04–langdale.pdf Letter from Bill Langdale to Hunton & Williams on behalf of Larry Rodgers Investments

2014-11-05-dougherty-county-resolution-filed-ferc.pdf Dougherty County, Georgia Resolution 14-019, accession number 20141105-0025

2014-10-28-albany-resolution.pdf Albany, Georgia Resolution 14-R 175

2014-11-13-terrell-county-resolution.pdf Terrell County, Georgia resolution, accession number 20141113-5035

2014-03-04-colquitt-county-resolution.pdf Colquitt County, Georgia Resolution 2014-R-6

2014-08-19-hamilton-county-resolution-14-10.pdf Hamilton County, Florida Resolution 14-10

2014-03-03-carroll.pdf Letter from Valdosta City Council Tim Carroll to FERC, accession number 20140303-5005

2014-12-09-lowndes-county-resolution.pdf Lowndes County, Georgia resolution, accession number 20141121-5242

2014-12-11-valdosta-resolution.pdf Valdosta, Georgia resolution

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