Stop the Bayou Bridge Pipeline!

Re: US Army Corps of Engineers Permit Application Number MVN-2015-02295-WII Louisiana Department of Environmental Quality WQC Application 160921-03

I am writing to express my concern for the proposed Bayou Bridge oil pipeline. The current Joint Public Notice for the project is deeply flawed. As the applicant for the proposal, Bayou Bridge has ignored significant and unacceptable impacts to surrounding wetlands, waterbodies and communities while also neglecting its necessary legal responsibilities. The Corps and LDEQ cannot issue permits to Bayou Bridge, due to the following:

The pipeline right-of-way to be used by Bayou Bridge traverse the Atchafalaya Basin is out of compliance with prior permits, affecting the hydrology of thousands of acres of wetlands. No new permits should be issued on an out-of-compliance right-of-way until those rights-of-way are brought back into compliance.

No public need for the pipeline exists. Bayou Bridge repeatedly cites “energy independence” as its motivating factor, though reality shows that our country is a net exporter of petroleum products. We are in fact already producing more energy than we need. With no project benefits apparent, it is essential for the Corps and LDEQ to weigh all project costs. Additionally, the regulatory branch of the New Orleans District of the Corps of Engineers lacks the resources to enforce the permits they issue. This is why so many pipelines and oil canals are out of compliance with their permits, devastating the Atchafalaya Basin and our coast.

The installation of over 160 miles of pipe and supporting infrastructure, across 11 parishes, will impact more than 600 wetland acres and cross almost 700 waterbodies. Yet there presently exists no plan to mitigate this disruption “commensurate with the scale and scope of the impacts” (33 C.F.R. § 332.4(c)).   Degrading wetland habitat reduces buffer from regional flooding. Impeding the natural flow of the Atchafalaya Basin will block the drainage of floodwaters. The increased risks presented by this notion of water management are unacceptable.  

Bayou Bridge is inconsistent with Louisiana’s Comprehensive Master Plan for a Sustainable Coast and Executive Order No. JBE 2016-09. Louisiana state agencies must do all in their power to prevent further coastal erosion. LDEQ cannot issue a 401 certification and follow the executive order.

There are alternative routes for the pipeline that would be less destructive to the environment and more protective of communities. Bayou Bridge even examined a route that would reduce impacts to wetlands and waterbodies.

The Bayou Bridge project is a joint venture, where Energy Transfer Partners (ETP) possesses a majority interest. ETP wholly owns Sunoco as well as Southern Union Company. Since this merger in 2012, there have been repeated safety violations:

On January 12, 2012, a Sunoco pipeline ruptured, spilling some 117,000 gallons of gasoline in Wellington, Ohio. Residents were evacuated for a week.

On February 19, 2013, maintenance on a Sunoco pipeline led to the unexpected release and consequent ignition of crude oil in Wortham, Texas. At least one worker was hospitalized.

On November 28, 2013, a natural gas pipeline exploded in Hughesville, Missouri. Nearby buildings caught fire and local populations were evacuated. The pipeline is managed by Panhandle Eastern, a subsidiary of Southern Union Company.

On October 13, 2014, a Sunoco crude oil pipeline ruptured, releasing roughly 168,000 gallons in Caddo Parish. The spill killed fish, reptiles, and other flora and fauna. The very same pipeline also ruptured near Cincinnati, Ohio in March of 2014.

On August 12, 2016, 7 contractors suffered injuries and severe burns while working on a Sunoco pipeline in Nederland, Texas.

On September 10, 2016, a Sunoco pipeline ruptured, spilling about 33,000 gallons of crude oil near Sweetwater, Texas. The pipeline was installed just a year prior.

ETP has a joint partnership with Kinder Morgan too, called Florida Gas Transmission Company. This entity has also experienced its share of safety violations:

On February 13, 2012, a Florida Gas Transmission Company pipeline burst north of Baton Rouge. Residents in the area were evacuated.

On December 26, 2012, a Florida Gas Transmission Company pipeline ruptured near Melbourne, Florida. The incident suspended operations.

On June 18, 2013, a Florida Gas Transmission Company pipeline exploded in Washington Parish. Homes were evacuated, and the blast upended and set fire to trees.

On May 17, 2014, a Florida Gas Transmission Company pipeline ruptured near Port St. John, Florida. Homes were evacuated, traffic was halted, and the incident led to over $170,000 in property damage.

Bayou Bridge has yet to develop disaster-response plans, despite the inherent vulnerabilities of pipelines and ETP’s past incident record.

As a federal agency, the Corps must consider climate change during its decision-making process. The climate contribution from Bayou Bridge must be comprehensively quantified, from the point of oil extraction all the way through the end-use of refined products. Conversely, the threats posed by climate change to the long-term viability of Bayou Bridge must also be evaluated.

For these reasons and more, I urge the Corps to prepare an Environmental Impact Statement for the proposed Bayou Bridge pipeline. Multiple public hearings must also be held, ideally in the greater Lafayette and Atchafalaya regions. The Corps and LDEQ are obligated to protect the environment, health and safety of Louisiana residents. Our lives are in danger if development of these facilities continues like this.

Sincerely,