Wednesday, May 24, 2017

Virtual Transmission Lines

To: Pipeline Safety Trust listserv

I know this group is about pipelines, but this seems related and some of you may be interested in knowing this.

A group of investigators (including myself) have uncovered a brand new type of interstate commerce in natural gas. A privately held company called XNG is taking gas by trucks from production fields in NE Pennsylvania and trucking it 130 miles and injecting it onto the Iroquois Pipeline. It is literally a virtual transmission line using trucks. 

This required space age materials.  A company called Hexagon Composites based in Norway has engineered a new type of CNG transport, which they call the Titan XL. The use carbon fiber containers, similar to how rocket motors are contained, and shipping gas at 3,600 psi. 12 tons of methane per trailer! Each trailer costs $500k USD. 

XNG told everyone their business model was shipping gas from the pipeline to local customers. 

And while this is happening to a small degree, they have just started in mid Feb'17 a massive new operation to ship 100x trucks per day along the same route that the Constitution Pipeline would have taken from Susquehanna County PA to the Manheim station in Herkimer Co NY.

Why trucks instead of Pipelines?

NY Sustainable Energy activists, environmentalists, and Constitutional conservatives were able to defeat the Constitution Pipeline by convincing NY Governor Andrew Cuomo it was a threat to property rights, and to the environment; it was being forced on the government literally at gunpoint while the Federal Energy Regulatory Commission (FERC) violated federal law (National Environmental Policy Act, Natural Gas Act) in dozens of ways.

In addition to the "Unconstitutional Pipeline", NY activists have successfully defeated many other similar projects: Crestwood's methane storage expansion at Seneca Lake, the Millennium Pipeline "I-81" project, Port Ambrose LNG, The Kinder Morgan NED, Empire's Northeast Access.

The Pipeline Resistance is international. From KXL to DAPL, new pipelines are facing "unprecedented opposition", according to FERC commissioner Cheryl Lafleur. 

So the industry has found a way, using state-of-the-art high-pressure intermodal CNG shipping containers, to build "Virtual Transmission Pipelines", which:
  • Avoid almost all regulatory oversight,
  • Can be built in 6 months instead of 6 years, 
  • and for 1/10th the capital costs of pipelines
A capitalist triple play!

High tech intermodal trailers -- UNREGULATED! -- Flexible

These trailers are also 40' ISO intermodal shipping containers, so they can be shipped by truck, train, or boat. They can also be used for storage.

The evil genius here is that while FERC-jurisdictional natural gas facilities must go through a lengthy siting process, and environmental review, which can take years, and allow citizen groups to organize around and delay and sometimes kill the project entirely....

These new virtual pipelines are so new, there is no regulatory scheme in place. FERC says shipping CNG by trucks is "non-jurisdictional". US DOT/PHMSA has no special regs for these heavy HAZMAT 1971 vehicles. At the state level, the NY PSC says "non-jurisdictional". The NYS DEC looks the other way. So does the state DOT. 

There is no EIS for this massive operation at either the federal level under NEPA, or at the NY State level under SEQRA. 

Also a pipe in a ground has a fixed route forever. These "Bomb Trucks" can change routes instantly. Also they are STEALTH. They look like ordinary box trailers, not like a traditional tanker. So unless you are astute and notice the DOT 1971 placard, these trucks are indistinguishable from any other 40' box trailer. 

In addition to the brand new, 3 month old XNG virtual transmission line, there are two new proposed facilities nearby, a Pentagon Energy site in New Milford PA, with 8 compressors, and a new site in at the Town of Fenton, Broome County NY, near Binghamton where I live, with 12 compressor engines. The present XNG site in Forest Lake is servicing around 100 trucks/day with only one of two compressors operational.


In sum:
  • This is brand new activity
  • High tech trailers transporting 12 tons of methane per load
  • Totally unregulated!! (except regulations on any commercial vehicle)
  • Might be used for export
  • Being done nearly in secret, no chance for communities to organize opposition
  • Extremely rapid expansion
  • Stealth trucks don't look like tankers
  • This scheme was literally just exposed in the past 2 weeks, so no one is writing about "virtual transmission lines". 
  • Many technical experts say this is "impossible", or "utter nonsense", but this information has been confirmed by multiple sources.

Watch for a virtual transmission line coming soon to YOUR town! 


May you, and all beings
be happy and free from suffering :)
-- ancient Buddhist Prayer (Metta)

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