Comment Opposing the Southeast Supply Enhancement Project (SSEP) – Clean Water Act Section 404 Permit Application (SAW-2024-01961)

FracTracker AlliancePublished August 29, 2025

Overview

FracTracker Alliance submitted a formal comment to PHMSA opposing the reconsideration of regulations that would allow liquefied natural gas (LNG) to be transported by rail (Docket No. PHMSA-2025-0050). The comment stresses that LNG-by-rail presents irreducible public safety risks.

Southeast Supply Enhancement Project

FracTracker Alliance respectfully submits the following comments in firm opposition to the proposed Southeast Supply Enhancement Project (SSEP) and its associated Section 404 permit application, currently under review by the Norfolk and Wilmington Districts of the U.S. Army Corps of Engineers. FracTracker is a nonprofit research organization dedicated to mapping, analyzing, and communicating the risks of fossil fuel infrastructure and its intersection with environmental impacts, public health, and climate resilience.

This pipeline expansion, spearheaded by Transcontinental Gas Pipe Line Company, LLC (Transco), poses significant risks to water quality, public health, climate, and procedural fairness—risks that are neither adequately disclosed nor mitigated in the current application. FracTracker’s digitized SSEP pipeline route map [1] has been viewed more than 80,000 times on ArcGIS, demonstrating widespread public interest and concern over SSEP. Our key concerns are as follows:

Scale of Infrastructure and Compressor Station Expansion

In addition to 55.3 miles of new, 42-inch diameter high-pressure methane gas pipeline across Virginia and North Carolina, would likely result in the expansion of multiple compressor stations across four states. Compressor stations are one of the most pollution-intensive components of gas infrastructure, emitting Nitrogen oxides (NOx), volatile organic compounds (VOCs), hazardous air pollutants like formaldehyde and benzene, and methane, a potent greenhouse gas, through venting and leaks. These emissions are often under-regulated, and nearby residents frequently report increased rates of asthma, headaches, fatigue, and nosebleeds.

Land and Wetland Impacts

The permit, as currently detailed, would authorize discharge of dredged/fill material into over 2.17 acres of stream channels, 21.8 acres of wetlands, 2.42 acres of permanent forested/scrub‐shrub wetland conversion. Over 1,500 acres would be impacted, including wetlands and more than 100 waterbodies in 16 watersheds, with disproportionate impacts to communities in Iredell and Davidson Counties, North Carolina that are already facing some of the worst air pollution in the state. [3]

Lack of Cumulative Impact Analysis

Siting the SSEP adjacent to the proposed Mountain Valley Pipeline Southgate extension without any cumulative impact assessment contradicts the intent of NEPA for holistic environmental review and undermines public transparency, especially given overlapping routes and potential co‐located emissions sources.

Insufficient Public Engagement and Procedural Flaws

The comment period is too short to allow meaningful public participation, particularly in light of the project’s size and complexity. Multiple agencies—including the Virginia Marine Resources Commission and North Carolina DEQ—are still reviewing the application’s completeness.

Inappropriate Use of Environmental Assessment in Lieu of EIS

The federal Environmental Assessment (EA) process is similarly premature and insufficient for a project of this scale and potential impact. An EA offers only a limited review and does not require a robust analysis of alternatives or cumulative risks—despite SSEP’s overlapping footprint with other major pipelines and its disproportionate effect on environmental justice communities. A full Environmental Impact Statement (EIS), with comprehensive public input and a detailed review of long-term impacts, is the most appropriate path forward.

The project also lacks demonstrated public need. Independent research by the Institute for Energy Economics and Financial Analysis and London Economics International has shown that gas infrastructure expansions like SSEP are being driven by speculative demand—driven by speculative demand—particularly from emerging energy-intensive sectors like AI data centers—rather than clear evidence of regional energy shortfalls. [4,5] Communities across the Southeast are being asked to shoulder long-term environmental and health costs to meet short-term market speculation.

Local Opposition from Elected Officials

We join local elected leaders in formally opposing the project. The Guilford County Board of Commissioners unanimously (9–0) passed a resolution urging thorough safety and environmental review of SSEP, and the Midway Town Council was the first municipality to oppose it, with a 4–1 vote citing concerns over safety and impacts to land and water. [6,7] These communities deserve a public hearing—not only to ensure procedural transparency, but to create a record of the lived experiences and environmental burdens residents are already navigating.

Fractracker Alliance Urges The U.S. Army Corps To:

Deny the Clean Water Act Section 404 permit for the Southeast Supply Enhancement Project.
Require a full Environmental Impact Statement (EIS) in coordination with FERC and state agencies, to thoroughly assess the project’s cumulative impacts.
Extend the public comment period to at least 60 days to allow for genuine public participation.
Hold public hearings in directly impacted communities.

Notes

FracTracker Alliance, Southeast Supply Enhancement Project Route Map, ArcGIS Web App (ArcGIS Online), viewed July 2025,
https://ft.maps.arcgis.com/apps/webappviewer/index.html?appid=cba2acecab2f4a4c86a6396da46b299e&extent=-8958452.5401%2C42894
53.1975%2C-8730058.6996%2C4425358.2338%2C102100.
Concerned Health Professionals of New York, The Compendium on Health Risks and Fracking: A Collection of Peer‐Reviewed Studies, Healthy Policy Project, October 2023,
https://concernedhealthny.org/wp-content/uploads/2023/10/CHPNY-Fracking-Science-Compendium-9.pdf.
Sierra Club, Overburdened & Overlooked: A Report on the Disproportionate Environmental Burdens Facing America’s Communities, Spring 2025, https://www.sierraclub.org/sites/default/files/2025-03/overburdenedoverlooked_spring2025.pdf
IEEFA. Data Centers Drive Buildout of Gas Power Plants and Pipelines in the Southeast, January 29, 2025,
https://ieefa.org/articles/data-centers-drive-buildout-gas-power-plants-and-pipelines-southeast—highlighting more than 20 GW of planned gas capacity and 3,300 MMcf/day of new pipeline volume in VA, NC, SC, and GA, largely driven by speculative data center demand, with risks that costs fall to ratepayers if growth falls short
London Economics International LLC, Uncertainty and Upward Bias Are Inherent in Data Center Electricity Demand Projections (for SELC), July7,2025, https://www.selc.org/wp-content/uploads/2025/07/LEI-Data-Center-Final-Report-07072025-2.pdf—finding that projected U.S. data center load would require 90% of global chip supply by 2030, indicating implausible and inflated forecasts
Haw River Assembly, Guilford County Board of Commissioners Passed a Resolution on SSEP 9-0. June 6, 2025. https://www.hawriver.org/news/guilford-county-board-of-commissioners-passed-a-resolution-on-ssep-9-0
Town of Midway, Opposition to the Proposed Southeast Supply Enhancement Project. March 25, 2025. https://drive.google.com/file/d/1m5Th-C4uAs4U8C6Cm2FMc4khJPAWWCxc/view

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FracTracker mapped gathering lines in Bradford County, PA. Public data on gathering lines are incomplete, leaving us to fill in the gaps.

Trends in fracking waste coming to New York State from Pennsylvania

April 20, 2021

2 Comments

Over the past decade, New York State has seen a steep decline in the quantity of waste products from the fracking industry sent to its landfills for disposal. Explore FracTracker's 2020 updated data.

2021 Pipeline Incidents Update: Safety Record Not Improving

April 14, 2021

The map below shows 6,950 total incidents since 2010, translating to 1.7 incidents per day. Pipelines are dangerous, in part because regulation around them is ineffective.

New York State Oil & Gas Well Drilling: Patterns Over Time

April 1, 2021

5 Comments

In this article, we look specifically at spatial and temporal patterns in oil and gas drilling across New York State.

Risky Byhalia Connection Pipeline Threatens Tennessee & Mississippi Health, Water Supply

March 17, 2021

2 Comments

The proposed Byhalia Connection pipeline project is situated in a particularly problematic intersection where environmental justice, hydrology, geology, and risks to human and environmental health intersect.

Shell’s Falcon Pipeline Under Investigation for Serious Public Safety Threats

March 17, 2021

Shell’s Falcon Pipeline, which is designed to carry ethane to the Shell ethane cracker in Beaver County, PA for plastic production, has been under investigation by federal and state agencies, since 2019.

Kern County’s Drafted EIR Will Increase the Burden for Frontline Communities

March 4, 2021

Built on sound data and ample research, FracTracker recommends several measures be taken to protect the health of California's overburdened Frontline Communities.

FracTracker Alliance, 2021

Pennsylvania’s Waste Disposal Wells – A Tale of Two Datasets

February 26, 2021

VIEW MAP & DATA Overview Access to reliable data…

California Oil & Gas Setbacks Recommendations Memo

February 23, 2021

The purpose of this memo is to recommend guidelines to CalGEM for evaluating the economic value of the social benefits and costs to people and the environment in requiring a 2,500 foot setback for oil and gas drilling (OGD) activities.

Oil and Gas Wells on California State Lands

February 12, 2021

The fossil fuel industry has historically taken advantage of…

Industrial Impacts in Michigan: A Photo Essay & Story Map

January 29, 2021

Southwest Detroit and neighboring South Rockwood in Monroe County…

People and Production: Reducing Risk in California Extraction

December 17, 2020

2 Comments

Executive Summary New research shows that low-income communities…

Documenting emissions from new oil and gas wells in California

November 18, 2020

Working with the environmental nonprofit Earthworks,…

Energy Security, International Investment, and Democracy in the US Shale Oil & Gas Industry

October 15, 2020

FracTracker in the Field: Building a Live Virtual Map

August 14, 2020

August 19, 2020 Update: The virtual story map is live! In…

The Loyalsock Watershed Project

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Mapping gathering lines in OH and WV feature

Mapping Gathering Lines in Ohio and West Virginia

July 2, 2020

As a spring 2020 intern with FracTracker, my work mostly involved…

Oil & Gas waste tank operated by SWEPI and Enervest at the Hayes pad, Otsego County, Michigan May 21st, 2016

The North Dakota Shale Viewer Reimagined: Mapping the Water and Waste Impact

June 18, 2020

2 Comments

We updated the FracTracker North Dakota Shale Viewer with current…

Falcon Pipeline Construction Releases over 250,000 Gallons of Drilling Fluid in Pennsylvania and Ohio

June 16, 2020

Part of the Falcon Public Environmental Impact Assessment - a…

Systematic Racism in Kern County Oil and Gas Permitting Ordinance

June 8, 2020

Kern County, California has approved at least 18,356 illegal…

Fracking Water Use in Pennsylvania Increases Dramatically

May 29, 2020

1 Comment

Unconventional wells in Pennsylvania were always resource-intensive,…

North Brooklyn Pipeline demographics map

New Yorkers mount resistance against North Brooklyn Pipeline

May 18, 2020

3 Comments

By Kim Fraczek (Sane Energy Project), with input and mapping…

Map of New 2020 Fracking Permits in California

California, Back in Frack

May 7, 2020

California is once again a fracked state. The moratorium on well…

California Setback Analyses Summary

April 2, 2020

2 Comments

FracTracker Alliance has conducted numerous spatial analyses…

Compressor station within Loyalsock State Forest, PA.

Air Pollution from Pennsylvania Shale Gas Compressor Stations – REPORT

March 19, 2020

Air pollution from Pennsylvania shale gas compressor stations…

New York State Oil & Gas Wells – 2020 Update

March 11, 2020

4 Comments

We’ve recently updated the New York State Oil and Gas Well…

National Energy and Petrochemical Map

February 28, 2020

1 Comment

This map from FracTracker Alliance is filled with energy and petrochemical data. Explore the map, continue reading to learn more, and see how your state measures up!

California Governor Gavin Newsom looks at surface expression oil spills

Governor Newsom Must Do More to Address the Cause of Oil Spill Surface Expressions

February 24, 2020

1 Comment

Chevron and other oil and gas companies in western Kern County…

Governor Newsom Well Watch website for California drilling

Oil & Gas Well Permits Issued By Newsom Administration Rival Those Issued Under Gov. Jerry Brown

February 22, 2020

FracTracker Alliance and Consumer Watchdog worked together to…

destroyed home following pipeline explosion in San Bruno, CA

Pipelines Continue to Catch Fire and Explode

February 21, 2020

2 Comments

For the past decade, petroleum operators in the United States…

The Hidden Inefficiencies and Environmental Costs of Fracking in Ohio

January 13, 2020

3 Comments

Ohio continues to increase fracked gas production, facilitated…

Fracking in Pennsylvania: Not Worth It

January 7, 2020

4 Comments

Despite the ever-increasing heaps of violations and drilling…

Photo by Ted Auch, FracTracker Alliance

Fracking Threatens Ohio’s Captina Creek Watershed

December 20, 2019

FracTracker's Great Lakes Program Coordinator Ted Auch explores…

California is Frack Free, for the Moment

November 19, 2019

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How State Regulations Hold Us back and What Other Countries are doing about Fracking

October 10, 2019

3 Comments

While it might be tempting to welcome an industry that often creates a temporary economic spike, the costs of mitigating the environmental damage from fracking far out-weighs the profit gained.