Longmeadow Pipeline Awareness Group Creates a Public Comment Toolkit to call on the MEPA to fight against Proposed Springfield-Longmeadow Pipeline

Longmeadow Pipeline Awareness Group Creates a Public Comment Toolkit to call on the MEPA to fight against Proposed Springfield-Longmeadow Pipeline

We hope you had a great holiday season! 2023 has just started, but there is already so much to do to protect our communities in the Northeast. We wanted to share with you an opportunity to act against a pipeline project that will threaten communities in Springfield and Longmeadow. 

Longmeadow Pipeline Awareness Group, an environmental community group we work with, is fighting against a proposed high-pressure gas expansion pipeline. The proposed pipeline would run beneath the streets of Springfield and Longmeadow in a residential neighborhood close to Wolf Swamp Elementary School. Help us fight back against this proposed pipeline expansion project by sending a comment to MEPA by Tuesday, January 17th on this dangerous and unnecessary project which would only intensify the climate emergency! Please use this great public comment toolkit below created by Longmeadow Pipeline Awareness Group.

Public Comment Toolkit for MEPA on Proposed Springfield-Longmeadow Pipeline

Eversource Gas has started seeking the state permits it needs to proceed with its proposed high-pressure gas expansion pipeline that would run beneath the streets of Springfield and Longmeadow. On May 16th, they filed with the Massachusetts Environmental Policy Act office, or MEPA, whose role it is to discern the potential adverse environmental impacts of proposed projects.

Help us fight back against this proposed pipeline expansion project by sending a comment to MEPA by July 28th on this dangerous and unnecessary project which would only intensify the climate emergency! 

Often, the most effective comments are those that come from the heart, that speak to issues that you care about and/or that impact you and your loved ones. 

Scroll down to see the 5 main points we are asking people to comment on.  All of this is here to inform and inspire your comments to MEPA. You don’t need to include all of these points! 

We invite you to choose a couple talking points or pieces of information from the key points below, or the additional background information that you can find further down in this toolkit, and use them as building blocks for a comment on what parts of this proposed pipeline worry you personally. 

Here are some suggested key points to include in your MEPA comments. 

Key points

1. Climate Roadmap Act: The MA Next Generation Climate Roadmap Act mandates that MEPA conduct an environmental impact review for any proposed project within 1 mile of an Environmental Justice (EJ) population, which must assess “existing unfair or inequitable environmental burden[s]” in the impacted EJ communities (source). This proposed pipeline would run through many EJ neighborhoods in Springfield and would impose another inequitable environmental burden on a city already targeted by multiple toxic and polluting industries. We need to remind MEPA about their responsibility to protect EJ communities and conduct an Environmental Impact Review, as required by the Climate Roadmap Act
2. Environmentally damaging: Methane, the main component of gas, is a greenhouse gas 86 times more potent than CO2 over 20 years. When this pipeline leaks, as all pipelines do, it will release methane into the atmosphere, trapping heat and worsening the climate crisis. This pipeline would increase greenhouse gas emissions at a critical moment when both climate experts and the MA state legislature say that we must reduce our greenhouse gas emissions to net zero by 2050 in order to reach a livable climate future.
3. Unhealthy: Methane, the main component of gas, and the nitrogen oxides released during combustion can cause and exacerbate respiratory illnesses like asthma. Springfield already suffers from high rates of respiratory illness, and ranked 12th on the Asthma and Allergy Foundation of America’s list of asthma capitals in 2021, after two previous years ranking first. This pipeline would make our air even more polluted and worsen respiratory illness throughout Springfield.
4. Dangerous: Gas is highly flammable and explosive. The Springfield community has already been impacted by the gas explosion of 2012, which injured 18 people and damaged 42 buildings. Communities in the Merrimack Valley are still recovering from the disastrous and deadly natural gas explosions and fires of 2018. This pipeline would be larger and higher-pressure than any other pipeline in Springfield, meaning that any fires or explosions could be much larger and more disastrous than the 2012 explosion.
5. Unnecessary: Eversource does not claim that Springfield needs any more gas. Instead it says the pipeline is needed for “redundancy”, i.e., a back-up system. However, the proposed pipeline would go through the same Bliss Street Regulator Station as the current pipeline; that regulator station would still be a single point of failure for all of Springfield’s gas supply. This isn’t about reliability; It’s about Eversource making more money for their shareholders

How to submit your comment

Here are two ways that you can submit a public comment to MEPA. A comment submitted through the portal will be visible to the public, whereas there is no guarantee that an emailed comment will be publicly accessible.

• Online through MEPA’s public comment portal
  1. Create an account by choosing a username, password, and entering your email
  2. Activate your account using an activation code that they will send to your email
  3. After activating your account, you will be able to log-in
  4. On the “Make a Comment” page, click on the “search for projects” button and enter the project number, 16556, in the “project no/ID” field
  5. This will pull up information about the “Western Massachusetts Gas Reliability Project”; click on the “comment” button, which is at the far right of the project information 
  6. Now you are on the page where you can submit your comments! You can enter your name and address if you want to, or you can submit it anonymously. 
  7. You can type up your comments in the comments box, which has a maximum limit of 4000 characters, or add your comments in a document as an attachment. PDF is the best form to submit as an attachment
• As an email sent to the MEPA Analyst alexander.strysky@mass.gov, including “Western Massachusetts Gas Reliability Project” and EEA# 16556 in the email subject
  1. Attaching your comment in PDF format is preferred, but not required
  2. You can submit your comments in the body of the email, if you would prefer to do so
  3. Please Bcc rusty@arisespringfield.org, so we know that you have made a comment

If you have any questions or concerns, please contact rusty@arisespringfield.org. 

This toolkit was last updated 6/8/22

If you want more information about the Springfield-Longmeadow pipeline, the MEPA process, many reasons why we are fighting this pipeline and why MEPA must conduct an Environmental Impact Report on this project, keep scrolling down.

Additional Background Information

Eversource’s proposed Springfield-Longmeadow pipeline is a gas expansion pipeline that would start in a residential neighborhood in Longmeadow, a quarter of a mile away from Wolf Swamp Elementary School. It would travel under public roads through the Forest Park and the South End neighborhoods in Springfield, including many environmental justice communities, ending at the Bliss Street Regulator Station in downtown Springfield.

Eversource Gas claims that their proposed pipeline is a “reliability project.” Eversource claims that the existing pipeline that brings gas into Springfield under the Memorial Bridge is a potential point of failure for Springfield’s entire gas supply. However, the proposed pipeline would go through the same Bliss Street Regulator Station as the current pipeline; that regulator station would still be a single point of failure for all of Springfield’s gas supply and there are no plans to modify it. This pipeline would not improve energy reliability for Springfield and Longmeadow.

Why are we fighting against this pipeline?

This proposed project faces strong resistance from both the Springfield and Longmeadow communities because it is unhealthy, dangerous, climate-changing, costly, and unnecessary. 

Unhealthy:

• Methane, the main component of gas, and the nitrogen oxides released during combustion can cause and exacerbate respiratory illness.
• Springfield, as a city full of Environmental Justice communities, has been targeted by many toxic and polluting industries. Springfield’s current air quality is poor.
• Springfield already suffers from high rates of respiratory illness, and ranked 12th on the Asthma and Allergy Foundation of America’s list of asthma capitals in 2021 after two previous years ranking first.

Dangerous:

• Gas is highly flammable and explosive
• This pipeline would be the largest and highest pressure pipeline in Springfield, running at 200 psi whereas the current pipeline supplying gas to Springfield is only 60 psi. The increased pressure increases the risk of explosions and the potential magnitude of any explosions
• The Springfield community has already been impacted by the gas explosion in 2012, which injured 18 people and damaged 42 buildings
• Communities in the Merrimack Valley are still recovering from the disastrous and deadly natural gas explosions and fires of 2018, which killed 1 person, injured 25 more and resulted in the evacuation of 30,000
• The recent Marshfield pipeline fire of 2021 burned for nine hours because Eversource didn’t know the shut-off valve location

Climate-Changing;

• Methane, the main component of gas, is a greenhouse gas 86 times more potent than CO2 over 20 years
• When this pipeline leaks, as all pipelines do, it will release methane into the atmosphere, trapping heat and worsening the climate crisis
• According to the latest IPCC report, in order to have any chance at limiting global warming to 1.5 degrees Celsius, we need our greenhouse gas emissions to peak by 2025 and fall by 43% by 2030
• According to the Massachusetts Next Generation Climate Roadmap Act, which went into effect in 2021, all cities and towns in MA must reduce greenhouse gas emissions by 50% by 2030 and reach net zero by 2050
• The permitting process for this pipeline will take up to 2 years, meaning they could begin construction in late 2023 or in 2024, and have the pipeline up and running by late 2024 or in 2025; This would increase our greenhouse gas emissions at the critical moment when we must rapidly reduce those emissions

Costly:

• This expansion pipeline would cost $65.1 million to build, all of which would be funded by Eversource Gas ratepayers.
• Eversource has a financial incentive to construct this pipeline. MA regulations allow Eversource a return on equity of 9.67% annually for new capital investment, such as new pipelines in the ground. 
• That 9.67%, just like the upfront bill for the pipeline, would be funded by MA ratepayers for the benefit of Eversource shareholders.
• Ratepayers would pay even more over time for the “stranded assets” of this gas infrastructure as the transition to green energy proceeds and the gas customer base shrinks.

Unnecessary: 

• Eversource does not claim that Springfield needs any more gas. Instead it says the pipeline is needed for “redundancy”, i.e., a back-up system.
• However, the proposed pipeline would go through the same Bliss Street Regulator Station as the current pipeline; that regulator station would still be a single point of failure for all of Springfield’s gas supply
• Eversource is fear mongering about energy scarcity and power outages to justify this pipeline, following the strategy they proposed to other gas utility companies to keep their  industry profitable during the transition to clean energy. Source

What is MEPA’s role in all of this?

The intent of MEPA review is to inform project applicants and state agencies of potential adverse environmental impacts while a proposal is still in the planning stages.The MEPA information gathering process includes taking input from the impacted municipalities and the public. MEPA can conduct environmental impact reviews for any projects requiring state permitting, financial assistance, or land disposition. After the review process, MEPA has the authority to conclude that the project does not comply with MEPA regulations.

Eversource submitted an Environmental Notification Form outlining the environmental impacts of their proposed project to MEPA on May 16th, 2022. The deadline for public comment is July 28th, 2022. After that comment period, they will decide whether the project can move forward, and whether draft and final Environmental Impact Report (EIR) will be required for the project. 

New mandates from the Climate Roadmap Act

The Massachusetts Next Generation Climate Roadmap Act gave MEPA additional responsibilities and imperatives when a proposed project is in or near an Environmental Justice (EJ) population. These new policies mandate that any proposed project within 1 mile of an EJ population must undergo an environmental review, which must assess “existing unfair or inequitable environmental burden[s]” in the impacted EJ communities (source).

The Climate Roadmap Act also mandates that EJ communities should not face inequitable environmental burdens, which are defined as “any destruction, damage, or impairment of natural resources that is not insignificant, resulting from intentional or reasonably foreseeable causes, including but not limited to climate change, air pollution, water pollution…or other activity that contaminates or alters the quality of the environment and poses a risk to public health” (source). 

Given that the pipeline runs through EJ neighborhoods in Springfield, that Springfield is already dealing with the inequitable environmental burdens of multiple toxic and polluting industries, and that this project would increase air pollution and likely increase rates of respiratory illness, these portions of the Climate Roadmap Act apply to Eversource’s proposed pipeline. 

These pieces of the Climate Roadmap Act are supposed to be enforced by an Environmental Justice Advisory Council, meant to be appointed by Governor Baker. Yet, over a year after that act was signed into law, he has yet to fill a single seat. Since Governor Baker has impeded the enforcement of this law, we will have to call on MEPA to follow the Climate Roadmap Act ourselves, through our public comments on this project

Toolkit brought to you by the folks at the Springfield Climate Justice Coalition