Assessing Pipelines: Students Prepare an Environmental Impact Statement

By Brittany Ryan

Students in the Environmental Assessment capstone course at Ramapo College were given a bittersweet taste of the “real world” for the Spring 2013 semester. The environmental studies majors were finally granted the opportunity to put all four years of our education to the test and integrate our knowledge into a project being implemented in the college’s backyard. While the work was daunting and the demand high, the reward of successfully completing such a rigorous assignment triumphed over the pain.

The class, under Professor Michael Edelstein, was named the Ramapo Environmental Research Collaborative (RERC). The student environmental research firm worked diligently all semester to produce an Environmental Impact Assessment for the major pipeline projects traversing the NJ Highlands Region. The three pipeline projects assessed were the project upgrades of Tennessee Gas Pipeline Company (TGP), Transcontinental Pipeline Company and Algonquin Gas Transmission. 

This document was requested by our clients, the NJ Highlands Coalition and Ramapough Conservancy, a local conservation group based in Oakland, NJ. The Environmental Impact Assessment was designed to reveal the ecological, physical, and social impacts as a result of construction of the pipelines to the public, to suggest mitigation measures and to assess how the pipeline projects fit into the requirement of completing a comprehensive environmental impact assessment of major federal projects. 

It was the intention of the Ramapo Environmental Research Collaborative to produce an Environmental Impact Statement that properly assessed the cumulative impacts of a major federal action, as required under the National Environmental Policy Act. We acted as an independent firm that addressed the project objectively, and revealed impacts that were deliberately disregarded prior to the implementation of the pipeline projects in the NJ Highlands Region. 

Findings Presented at Campus Conference

RERC demonstrated their findings at the “Distributing Gas, Limiting Impact: Responding to the Proliferation of Pipeline Projects” Conference, which was held at the Alumni Lounges on campus on May 2. The event was a success as several spectators commended our thorough research and presentation. The three main groups of physical, ecological, and social were comprised of multiple indicators that each student honed in on. These indicators ranged from toxicology to groundwater and psycho-social impacts.

As manager of the Social Group, I presented on our behalf at two additional conferences, including the Ramapo River Watershed Conference, and was able to witness the findings my team members have compiled. The Social Group studied six different indicators that were responsible for highlighting the adverse impacts in the socio-economic-political realm.

The environmental justice indicator assessed the impacts on socially vulnerable communities, which consists of minority, low-income, lower educational attainment and concentrated youth populations. 

Impacts on Local Communities

A primary focus was placed on the Ramapough Mountain Indian Community, which has already been burdened by existing hazards, such as industrial waste dumped along area streams. These include the Ringwood Mines/Landfill Superfund Site, the Ramapo Landfill Superfund Site and the Suffern Village Wellfield Superfund Site. The Social Group found impacts to include compromised medicinal resources from the Highlands forest, disturbance of cultural reverence, such as burial sites, affected personal finances and the local economy, a decrease in house value, and a disrupted spiritual connection to the land.

Similarly, the psycho-social indicator researched how the project would alter the mental and emotional attachment to place that creates self and community identity. It is important to understand how a community instills values and establishes rootedness, and how this is jeopardized by construction and other project actions. The impacts they found included stress and anxiety about pipeline safety, social distrust, decreased enjoyment of home and lifestyle, changes in social dynamics, and a loss in social interactions among neighbors.

Assessing the key scenic views and related impacts was completed by the visual indicator. This group analyzed how construction links to the diminished values of the nature in the region. And the economic indicator analyzed the strain on public services, influx of jobs, tax increase and revenue, and land compensation.

Finally, the political indicator, which was my responsibility, is a unique component to the Environmental Impact Statement. The political indicator is uncommon, few assessments include this as a category, but Professor Edelstein added this because of the nature of this project. His reasoning proved its purpose after delving into the policies and structure of the permit process and project implementation.

Two of the primary findings revolved around the issues of segmentation and cumulative impact assessment. Segmentation can be defined as the division of a project, program, or decision into component parts or temporal phases. This is a tactic frequently executed by industry to avoid the requirement of a full Environmental Impact Statement. 

The Council on Environmental Quality (CEQ), which is a council in the executive branch that works with federal agencies to develop environmental policies, has set regulations under the National Environmental Policy Act regarding these assessments. The CEQ states that the preparation of an EIS is required for “major federal actions significantly affecting the quality of the human environment.” They specifically outline that significance cannot be avoided through the breaking down of a project into component parts.

In our assessment, we found that TGP had intentionally applied for four separate permits for four connected projects: the 300 Line, the Northeast Supply Diversification Project, the MPP Project and the Northeast Upgrade Project. The company stated in reports that these projects are interdependent and confirmed their reliance on one another to carry the increased capacity of natural gas. 

Segmenting Projects Avoids Full Environmental Report

However, in looking at these segmented proposals, the Federal Energy Regulatory Commission (FERC), which approves energy projects and issues permits, only required Environmental Assessments for each permit request. Environmental Assessments are much less comprehensive than EISs and are utilized as a guide to determine whether an EIS should be conducted or not. Given the projects were assessed individually, they concluded a “Finding of No Significant Impact” or a FONSI.

Cumulative impacts are relevant to segmentation, except a cumulative assessment requires looking at a much larger picture. Cumulative impacts are defined under the National Environmental Policy Act as impacts that result from individually minor but collectively significant actions over a period of time.

There are three pipeline projects currently being implemented in the NJ Highlands region and the Federal Energy Regulatory Commission approved each project without considering that they traverse the same environmentally sensitive region. 

Additionally, the Commission’s assessment did not factor in already existing pipeline structures and the potential for future lines to be developed.  Conjointly, these projects impose significant environmental impacts to the area. So aside from reviewing each pipeline project in segments, the agency avoided reviewing the collective impacts from all three projects in the NJ Highlands Region. In several legal cases the courts have upheld such division as a violation of NEPA. This approval was a failure to review the project as a whole.

Perhaps one of the most crucial teachings absorbed from this course was the need to approach situations with objectivity. Throughout the process we shared visits and gathered material from representatives of both the pipeline companies and the environmental advocates. 

After witnessing this, it became clearer the importance of maintaining a balanced approach, which earns more respect from all parties and facilitates any deal-making process. Because my understanding of this was expanded, I know I can be even more successful and exceed further than if I did not grasp this concept. My future as someone who advances environmental policy is much brighter.

Balance is undoubtedly the connecting element of all functions on earth. Without balance stability is lost and certainly no good can come from that. Balance in our ecosystems, in our political institutions and in our personal relationships is essential for improving the quality of life overall. The interdisciplinary nature of this course, as experienced in our EIS process and our team building, is the most powerful teaching component of the semester; the lessons learned are invaluable.  


Brittany Ryan is a senior majoring in Environmental Studies at Ramapo College of New Jersey.