The Falcon Public EIA Project

  • The Falcon Public EIA Project

    Expanding Engagements with the Shell Ethane Cracker Pipeline

A FracTracker Feature Series

Published on January 28, 2018

In August 2016, Shell Pipeline Co. (a subsidiary of Shell Appalachia) announced plans for the “Falcon Ethane Pipeline System,” a 97-mile pipeline network intended to feed Shell’s ethane cracker facility in Beaver County, Pennsylvania. The Falcon will carry more than 107,000 barrels of ethane per day through Pennsylvania, West Virginia, and Ohio, to Shell’s facility, which would then “crack,” or break apart, ethane molecules to create ethylene and polyethylene. The Shell cracker would be the first step in building a regional petrochemical hub, which FracTracker has written about in previous articles.

Shell submitted permit applications to the Pennsylvania Department of Environmental Protection (PA DEP) and the U.S. Army Corps of Engineers in September 2017. Applications state that tree clearing will commence in fall 2018, construction will occur  from spring 2019 through fall 2019, and that the Falcon will be operational by spring 2020.

Click here to view the Falcon permit applications on the PA DEP website

Lack of Transparency

Shell representatives present the Falcon at a public meeting in 2017

Building pipelines is a highly disruptive process to the natural environment, as they must pass through sensitive areas such as streams, wetlands, and protected forests. Furthermore, ethane is classified by the federal government as a hazardous and a highly volatile liquid. You can read the MSDS for ethane here.

The Falcon pipeline would cross through 25 municipalities in three states, in some cases through residential neighborhoods. Should a leak occur, ethane is not easily detected because it is a colorless and odorless gas. Slightly heavier than air and extremely flammable, triggers such as ignition of a car engine, cell phones, doorbells, or light switches can provide an effective ignition source if concentrations are high enough.

Public participation in pipeline risk assessments is therefore critical. However, pipeline routes are rarely revealed until late in planning stages.

More often than not, the public is given few real opportunities to influence how impacts are assessed or to meaningfully shape a project. Part of the problem is that operators are required to provide paper and PDF maps in permit application that can contain hundreds of such maps. But they are not required to provide the underlying GIS (geographic information system) data used to produce those maps in most cases.

While the public can stitch paper maps together to understand a pipeline in its broader context, this can take many months to execute and comprehend. It is exceptionally rare for the public to have access to GIS data that might allow for independent assessments. Furthermore, all of this work must be done in within a narrow window of time when permits are posted by regulatory agencies for public comment.

PA DEP’s comments on the release of ME2 pipeline GIS data

An example can be seen in how the public obtained GIS data pertaining to Sunoco’s contentious Mariner East 2 pipeline (above). The PA DEP published the GIS data in response to mounting public pressure only two weeks prior to the close of public comments, also with the caveat that the release was not standard operating procedure.

Late-game transparency and antiquated permitting procedures provide little leverage for questioning the merits of the project. However, having access to this data has since allowed communities to mount challenges related to ME2’s water impacts and drilling spills that ultimately led the DEP to temporarily suspend Sunoco’s construction permits.

A Resource for Public Engagement

The Falcon Public EIA Project offers for the first time a highly detailed view of how a pipeline comes together from its infancy.

The resources on this page are meant to foster deeper engagements with regulatory agencies as they begin to evaluate the Falcon’s permit applications. The Falcon Public Environmental Impact Assessment (EIA) Project is meant to expand public dialogue about what should be included in EIAs and how they should apply to pipeline projects. The project also serves as a model for how data transparency ought to be done by regulatory agencies when engaging the public.

The maps and articles below raise a number of question: should we route a pipeline through the headwaters of a reservoir that provides drinking water to 30,000 people? Is it safe to locate pipelines in actively mined areas? Should the Beaver County Conservation District allow pipelines on public-owned property? Is the Falcon pipeline necessary at all? These are the kinds of discussions we hope emerge from the Falcon Public EIA Project.

Exploring the Data

FracTracker began monitoring the Falcon in December 2016, when we discovered a significant cache of GIS data related to the pipeline.

Through many months of recreating the data as it evolved, we developed a rich series of interactive maps and analysis illustrating the many components of the project. In January 2018, FracTracker obtained copies of Shell’s permit applications from the PA DEP. These documents, consisting of thousands of pages that pertain to only areas in Pennsylvania where the Falcon will be built, demonstrate how complicated public engagements with pipelines can be.

In order to make sense of the many components in Shell’s data and permit applications, we have organized our analysis along themes that explore how impacts would likely be critiqued in a more comprehensive EIA. We also include information from a spectrum of other sources to expand the conversation about what ought to be accounted for in defining impacts. You can read more about our methods in the last section below, as well as how to get involved in engaging with the Falcon pipeline proposal at the end of this page.

Pipeline Regulations & Impact Assessments, a Primer

Pipelines are regulated by different federal, state, and local agencies depending on what they carry and where they go. This primer gives a rundown of these different agencies and their respective roles. We also explore what an EIA entails, as well as what often gets lost when conducting EIAs.

The Falcon Pipeline Route, Facilities & Easements

This segment introduces the route of the Falcon ethane pipeline system, other routes that were considered in the planning process, and the properties along the route that required easements. We locate facilities that will be built, such as metering stations and shutoff valves, as well as construction areas and access roads needed to build the pipeline.

Water Body Crossings, Geology & Hydrology

In this segment we explore the many streams, wetlands, and ponds the Falcon must cross, as well as the techniques Shell will likely use in these crossings. Also explored are the geological and hydrological conditions of these areas, such as porous karst limestone and shallow groundwater that can complicate construction.

Class Locations, Buildings & Recreational Areas

In this segment we begin to examine the ways that pipelines are assessed for potential risk to populated areas. We outline a method called “Class Locations” that determine how a pipeline is constructed, based on proximity to occupied structures and public facilities, then identify locations of highest risk along the Falcon’s route.

High Consequence Areas & Potential Impact Zones

Continuing our examination of risk assessment, this segment utilizes an additional method used in pipeline construction called “high consequence areas” (HCAs) that take into consideration proximity to population centers, drinking water systems, and sensitive habitats. We also calculate the potential impact radius (aka “blast zone”) for the Falcon.

Habitats, Ecological Areas & Species of Concern

As part of the planning process, operators are required to consult with state and federal agencies to identify threatened, endangered, and protected species that may be impacted by a proposed pipeline. In this segment, we investigate how Shell conducted detailed field surveys to comply with special protection guidelines.

Cumulative Development & Compounded Risks

In this final segment, we explore entanglements with a region already impacted by a long history of energy development. Featured here are where the Falcon intersects mining facilities, well pads, and other pipelines. These tell a story of cumulative development and compounded risk.

Methods: Falcon Mapping & Analysis

FracTracker strives to maintain transparency in all of our projects so the public understands how we obtain, analyze, and mapped our data. This methods section describes our process in working with the Falcon data.

Shell Pipeline: Not Quite the “Good Neighbor”

ADDITIONAL ANALYSIS (4/2/18): As the Falcon continues to gain the public’s attention, Shell has stressed their reputation as a good neighbor—committed to building and operating the pipeline in a safe manner. This article reviews federal data on pipeline incidents since 2002 and finds Shell’s safety record is actually one of the worst in the nation.

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Assessing the Impacts of the Shell Falcon Ethane Pipeline System

TECHNICAL COMMENTS (4/16/18): This document by FracTracker Alliance outlines some of the most prominent risks related to the proposed Falcon ethane pipeline that deserve close regulatory scrutiny by the Pennsylvania Department of Environmental Protection. It was submitted as Public Comments on the Shell Falcon Ethane Pipeline System – Permit #: E02-1773, E04-369, E63-710

Image of Falcon Pipeline and deficiencies along the route

Explore problems the DEP found with Shell’s Chapter 105 application

TECHNICAL DEFICIENCIES (10/03/18):  In January of 2018, the DEP began reviewing Shell’s Chapter 105 application for water obstruction and encroachment. On June 1st, the DEP sent Shell technical deficiency letters listing 101 issues with the application. Shell responded to these deficiencies on August 1st. In this part of that project, we map out and explain all 101 deficiencies.

How to Get Involved

Submit Public Comments

Public participation has played a crucial role in the application process of the Falcon Pipeline. Due to the amount of public interest, the DEP hosted more public hearings than normal, provided documentation of its correspondence with Shell,  and delayed the public comment period, allowing more time for residents to learn about the pipeline.

Residents of Pennsylvania, and in particular those living in communities likely to be impacted by the Falcon, are encouraged to explore the contents of the Falcon Public EIA Project and contact the DEP with your concerns.

Questions on the Falcon should be directed to Dana Drake, DEP Southwest Regional Office Waterways and Wetlands Program Manager; 400 Waterfront Drive, Pittsburgh, PA 15222; 412-442-4000. Public comments can be emailed to RA-EPWW-SWRO@pa.gov.

Be a Citizen Watchdog

In addition to submitting comments, we encourages concerned residents to get involved in tracking the Falcon pipeline’s potential impacts by using the FracTracker mobile app. The app is a free tool for documenting issues near you. It provides a way for people to submit geolocated photographs, descriptions, and more that can be shared with other users of the app and the broader community.

FracTracker has added the proposed Falcon pipeline route to the mobile app’s interactive map for reference in the field.

Mobile app feature image

For more information on this project, contact Kirk Jalbert: jalbert@fractracker.org