# Roving through the evidence:

## Q. If the ET Rover pipeline suffered an explosion, how big would it be?

A. The impact of a gas explosion depends a lot on the pipeline's pressure and size. This pipeline will be pressurized at approximately 1400 psi (pounds per square inch), and is 42 inches in diameter. If a pipeline of the same size, pressurized at 1200 psi --(a lower pressure than Rover)-- were to suffer an explosion, the blast radius would be approximately 1,100 feet (nearly a half-mile in diameter). The explosion would be comparable to an air-burst of a tactical nuclear missile explosion, and would result in a firestorm similar to Hiroshima. Because Rover is expected to run at an even higher pressure than that, we can expect that if it were to suffer an explosion, the impact would be larger.

Within this area of spontaneous combustion nearly everything would be incinerated. This estimate is from a PhD in Engineering who carefully studied previous gas explosions. It is larger than the "Potential Impact Radius" term used by FERC to describe the area of risk. You can read the original study by C. Rhodes, P. Eng., Ph.D, , Calculation of Safety Setbacks from Large Diameter High Pressure Natural Gas Pipelines,

The impact would be even greater in Ohio. In Ohio, the Rover pipeline actually consists of TWO 42-inch pipelines co-located side-by-side. So in the event of an explosion in the Ohio segment, the blast would be double the force noted above.

## Q. Will a scent be added to the gas flowing through the Rover pipeline, so that we might be able to detect a leak in the pipeline early enough to prevent loss of life to an explosion, fire, or carbon monoxide poisoning?

A. No. According to Rover, they will not add scent to the gas because they are not required to add it by law. Although they could still choose to add it, they have opted not to do so in order to save money, even though this puts the lives and safety of all the people living along the pipeline route at greater risk. Rover states:

“Once Rover Pipeline begins operations in late 2017, the pipeline will be regulated by the U. S. Department of Transportation's (USDOT) Pipeline and Hazardous Materials Safety Administration (PHMSA), which establishes rules and standards governing the design, construction, operation, safety and maintenance of pipelines.

"Under USDOT regulations, odorization is not required for Rover Pipeline and therefore, will not be added. Rover Pipeline will follow USDOT regulations for classifications that are based on population areas where the pipeline traverses. Class locations range from 1 (rural) to 4 (densely populated). These class locations are determined by counting the number of buildings suitable for human occupancy within 660 feet.

"The Vector Meter Station and tie-in is located in a Class 2 location and all the Rover Pipeline routes comply with 49 CFR 192.625 (b)(1) are applicable, except for Exception 1 (below):

(b) After December 31, 1976, a combustible gas in a transmission line in a Class 3 or Class 4 location must comply with the requirements of paragraph (a) of this section unless:

(1) At least 50 percent of the length of the line downstream from that location is in a Class 1 or Class 2 location;

"This DOT regulation is from 49 CFR 192.625(b)(1), regulation for the odorization of gas paragraph, 192.625.”

## Q. Why am I just now hearing about the pipeline?

A. Perhaps the biggest reason is because the pipeline company (Energy Transfer / ET Rover) controls most of the information, and it is not in their interest for you to hear about it. The less informed the general public is, the less opposition there will be. To our knowledge, Rover has not informed anyone about the pipeline whom they are not legally required to inform--including residents of pipeline-affected communities. Nor have they publicly released maps of the pipeline's route that would allow local residents to learn for themselves exactly where the pipeline's route will run throughout its route, and who it will affect. They have only released maps of individual mini-segments of the route, and scattered these pieces across local libraries in different pipeline-affected communities. A list of these libraries can be found here. (If you live in the Pinckney area, you can download your map here.)

Bureaucracy at FERC (the Federal Energy Regulatory Commission) is another reason. Most people who attempt to locate specific pipeline-related documents on FERC's website become frustrated because FERC's eLibrary is designed primarily for FERC's internal purposes, and not for public transparency and user-friendliness. (FERC's eLibrary can be accessed here: https://www.ferc.gov/docs-filing/elibrary.asp. Rover's docket number is CP15-93-000).

Putnam Township has a special section on its homepage devoted to informing the public about the pipeline project. This can be accessed here: http://www.putnamtwp.us/

Despite these challenges, we are seeking to raise public awareness about the Rover pipeline, with an aim to stop it.

## Q. How does a private, export-oriented company like Rover have the right to seize people's land? I thought the Constitution protects against this.

A. The Constitution is indeed where the answer starts. The 5th Amendment allows the government to take private property under certain circumstances. It states: "...nor shall private property be taken for public use, without just compensation." Eminent domain is the power of the government to take your property, even if you don't agree to it, as long as they are taking it for public use, and as long as they provide you with just compensation. Eminent domain is what allowed most of our freeways, airports, and other large public-use infrastructure to be built.

But the ET Rover pipeline is different. In this case, it's not the government doing the taking; Energy Transfer is a private company. And they are not taking land for "public use"; the pipeline is a private, for-profit export project that will supply the residents of another country (Canada) and benefit ET's shareholders. How did a company get the right to use eminent domain?

In 1938, Congress passed the Natural Gas Act. Section 7 of this Act gives FERC (the Federal Energy Regulatory Commission) the power to issue "Certificates of Public Convenience and Necessity" for interstate gas pipelines. This means that as far as the Fifth Amendment is concerned, FERC has the power to legally define these pipelines as being in the public interest, even if they are not really.

But what about the export aspect of the Rover project? Rover is, after all, transporting gas to Canada. How can an export project be considered "public interest"? The answer is NAFTA. Ever since it came into effect in 1994, NAFTA has treated export projects destined for either Canada or Mexico as legally equivalent to domestic projects.

So there you have it. Through these legal contortions, the powers-that-be have (thus far) deemed Rover's dangerous, private, for-profit export project to be tantamount to "public use." And we disagree with that.

## Q. Where does the Rover pipeline construction process currently stand?

A. On February 3, 2017, FERC issued a provisional Certificate of Public Convenience and Necessity for the Rover pipeline, allowing construction to begin.

Soon thereafter, Rover began staking the path of the pipeline and the right-of-way area for tree clearance.

In March 2017, Rover has been cutting down trees along the pipeline route in the Pinckney area.

## Q. What do I do if I notice Rover cutting down trees after March 31?

A. For ecological reasons, Rover is prohibited from clearing trees anywhere along the pipeline route after March 31. If you observe Rover clearing trees after March 31, document the incident in every way possible, and then contact us immediately. We will help you to report the incident to Rover and FERC, and also will have our attorney contact you.

## Q. What will the Rover pipeline be transporting, and where?

A. It will carry "fracked" natural gas from the Marcellus and Utica Shale (Ohio, West Virginia, and Pennsylvania) into Canada.

## Q. Will the pipeline be contributing to US energy independence?

A. No. This is an export pipeline. The gas is being transported to Canada.

## Q. Who is behind the Rover pipeline?

A. Energy Transfer Partners, a Texas-based pipeline firm. It is the same company that is building the Dakota Access pipeline that was the focus of the Stand with Standing Rock movement.

## Q. How big is the ET Rover pipeline?

A. It will be 42 inches in diameter, even bigger than the Keystone XL pipeline.

## Q. Where are all the pipelines near me?

A. Use the National Pipeline Mapping System (NPMS) Public Viewer to see the pipelines in your county and state. https://pvnpms.phmsa.dot.gov/PublicViewer/

## Q. How closely is the ET Rover pipeline being built to people's houses?

A. In our area (Putnam Township, Michigan), Rover is being built within 100 feet of people's homes.

## Q. Will the pipeline be safe?

A. We have reasons to fear for our safety.

Pipeline accidents occur in the US disturbingly often. There is, on average, one pipeline accident every 11 days in the United States. Many of these accidents are fatal, and many more cause serious injuries and damage. To understand what even a small gas pipeline explosion looks like, here is a video of an explosion in Bakersfield, California that killed one person and injured three.

We do not trust Energy Transfer, the company building the Rover pipeline, to build the pipeline in a safe way, because at every step of the way, we have observed them cutting costs at the expense of public safety. (They have done this with their choice not to add scent to the gas; to use cheaper compressor generators that will create more permanent noise and vibrations than necessary for residents; and to locate the pipeline close to houses when other, safer routes are available.)

If an explosion occurred and ignited, there is virtually nothing that can be done within the "blast radius". Some recent studies by the Pipeline Safety Trust of pipeline failures suggest that pipelines built in the last 10-15 years fail at over 4 times the rate of failure of the preceding 50 years.

A. Yes.

## Q. Are there other dangers to human life I should know about?

A. Yes. Pinckney Recreation Area has a large beach and picnic area with 500 parking spaces on Silver Lake's southern shore, which is heavily used in the summer. The only way in and out of this area is a road that runs for a distance within the potential blast zone. If a serious incident occurred on the wrong day at the wrong time, hundreds of people would be trapped with no escape. The current ET Rover route thus places potentially hundreds of lives at Silver Lake beach at unnecessary, avoidable risk.

## Q. How would a serious incident (such as an explosion or leak) be handled?

A. First responders would immediately contact the pipeline company, which would cut the supply of gas to the area of the leak as quickly as possible. In the meantime, first responders would coordinate their response in conjunction with the pipeline company.

If you live in the affected area in Livingston County, and if you have a landline published in the White Pages, in the event of a pipeline emergency you would receive an automatic phone call from the Livingston County Emergency Management department. If you'd like to opt in to the system --in order to be notified via text, or via a call to your cell phone or unpublished number-- you can register here.

## Q. Would it be possible for Rover not to put people's lives in danger?

A. Yes. We have identified three options that would be better than the current plan, in order of our preference:

1. The pipeline should not be built at all. We believe Rover's continued construction is in violation of FERC rules. (See the question below: "I've heard that by continuing to build..."). Also, a competing TransCanada gas pipeline is slated to supply the same market (in Ontario, Canada) as Rover, so if Rover is not built, it will not deprive anyone of their desired supply of natural gas.
2. In all cases, the pipeline route should be moved so that it does not place houses, parks, or schools in danger in the event of an explosion. In Livingston and Washtenaw Counties in Michigan, this means that the pipeline route should be moved to co-locate with the ITC power lines, which already have a legal right-of-way, and which are farther away from houses than Rover's present route. This would be safer than the current plan.
3. In any case, Rover absolutely ought to add a scent to the gas that would alert residents to a leak in the event of an accident.

The pipeline could have followed an entirely different route, avoiding these more settled counties and population areas and State Parks and connected with the Vector pipeline through an agricultural area to the west, AND been about 20 miles shorter.

## Q. Where can I find maps of Rover's route?

A. If you live in the greater Pinckney area, you can download a map of the local route here. Other Pinckney-area maps are available by clicking on this link, and then, on the right hand side, clicking "Map Updates."

Maps for Washtenaw Counter were delivered to the Ann Arbor Public Library in 2014. Note that the route most closely following where trees are being felled is "Route Alternate 2 (February 2015)".

If you live elsewhere along the route, you can find your segment's map at your local library. A list of libraries holding map sections can be downloaded here.

## Q. I've heard that by continuing to build the pipeline, Rover may be violating federal rules because its finances are too shaky. Is this true?

A. We believe so. Here's why:

An oil or gas company that uses a pipeline is called a "shipper." Shippers are companies that have signed a contract promising to use a particular percentage of the pipeline's total carrying capacity.

FERC (the Federal Energy Regulatory Commission) only allows pipeline construction to go forward if there is strong evidence that the pipeline will actually be used once it's built. For that reason, FERC requires that a pipeline's shippers meet a minimum standard of creditworthiness. In other words, there has to be evidence that the shippers who are promising to use a pipeline's capacity a few months or years down the line, are not right now on the verge of financial collapse.

For that reason, the minimum credit ratings allowed for ANY of Rover's shippers is Baa3 by Moody's, and BBB- by S&P, both of which mean the same thing: "adequate capacity to meet its financial commitments". (Source of that requirement is here, p. 6).

However, the Rover pipeline's largest shipper, Ascent Resources, was downgraded by Moody’s and S&P to Ca and CCC-, respectively, both of which mean "default imminent, with little prospect for recovery." (Source here.)

According to FERC’s statement on the Rover order, if one of its main shippers cannot meet the creditworthiness standard, pipeline construction can't begin. (Source here, p. 17).

That's why we are calling for an immediate halt to Rover pipeline construction.

## Q. What does the Rover pipeline have to do with fracking?

A. Fracking is a method of natural gas extraction, and the natural gas that Rover will be transporting to Canada comes from fracking in the Marcellus and Utica Shale region. People who are concerned about the environment and the future of the climate often oppose fracking because this method of gas extraction tends to leak methane into the atmosphere. Methane is problematic because a little of it goes a long way: methane is 72 times more powerful in harming our atmosphere than the same amount of carbon dioxide (CO2) over a 20-year period.

Other reasons to be concerned about fracking are its detrimental affects on the environment and human health. (See here and here.)

## Q. By opposing the Rover pipeline, aren't you trying to take people's jobs away?

A. No. Quite the opposite. Everyone needs to work to live-- and we all have to recognize that economic forces (including automation and the market's shift toward renewable energy) are causing jobs in the fossil fuel industry to decline, while jobs in the renewable energy sector are on the rise. Instead of investing in dead-end jobs in the fossil-fuel industry, then, we want energy companies, legislators, financiers, entrepreneurs, and chambers of commerce to acknowledge this change, and invest in job training and job creation in the renewable energy sector, which are the jobs of the future. These are the jobs of the future, not the jobs of the past!

## Q. What do you hope to accomplish?

A. Our goals are twofold:

• Fighting the pipeline: We believe the Rover pipeline project is a textbook example of injustice, and is also in violation of FERC rules. We are mobilizing people and funds to oppose it peacefully, legally, politically, and in the court of public opinion. This includes our three demands, in order of preference:
• The pipeline should not be built at all.
• If it is built, the route should be moved a safe distance away from houses, and
• Scent should be added to the gas to allow residents to detect a leak early.
• Defending our members: We provide resources (including information, contact lists, "how-to," networks of mutual aid, and in some cases legal support) to strengthen our members' ability to protect themselves against infringements by the pipeline company.

In addition to these primary goals, we also seek to build solidarity with fellow organizations across the country that are fighting new oil and gas pipeline construction.

## Q. What can I do to help?

A.There is a lot you can do. Visit our homepage to see our current calls to action!

## Q. Why should I donate at fwap.org/donate?

A. At least five reasons:

• It's an efficient investment. 100% of your donation goes to fund our legal fight against the Rover pipeline. This efficiency is possible thanks to the fact that we are all volunteers, and our fiduciary --the Fresh Water Accountability Project (FWAP), which is a legal intervenor in Rover-- has zero overhead costs.
• It offers "bang" for your buck. In addition to the benefit of legal victories your donation can help us to win against Rover, we've been told that for every \$1 we spend on legal challenges to Rover, the pipeline company has to spend \$50 just to counter it. That's because our incredibly devoted and experienced environmental attorney works for us on a pro-bono & "low-bono" basis, whereas Rover's attorneys work for the rate of corporate lawyers. That means that if we raise just \$5,000, we could potentially cost Rover a quarter of a million dollars!
• It's the right thing to do. Your donation will help strengthen our David-versus-Goliath struggle. We need to show that the little guy can prevail, and win victories that can be used as legal precedent to bolster the cases of other groups that are fighting pipelines around the country.
• It feels good! Acts of generosity release "feel-good" hormones in your brain (dopamine, seratonin, and oxytocin). These hormones naturally boost your mood, and also benefit your heart, immune system, and longevity.
• It's tax-deductible. Our fiduciary, FWAP, is a registered 501(c)(3), so your receipt will make you feel good a second time around when tax-time comes! :o)

## Five ways to stop that "I've been Rovered" helpless feeling:

1. LIKE US ON FACEBOOK for info on upcoming meetings and events.
2. Share OVER WITH ROVER on your own page, and with your elected officials.