Kimberly D. Bose, Secretary 

Federal Energy Regulatory Commission 

888 First Street NE, Room 1A 

Washington, DC 20426 

Re:  Commonwealth Energy Connector and Virginia Reliability Project under number CP22-502-000 and CP22-503-000

Dear Secretary Bose: 

On behalf of the Chesapeake Climate Action Network (CCAN) and our undersigned members, we urge the Federal Regulatory Energy Commission (FERC) to seriously consider the “no action” alternative when conducting its Environmental Impact Statement for the Virginia Reliability Project and Commonwealth Energy Connector. The alternatives analysis in the environmental review is “the heart of the environmental impact statement.” FERC must “[r]igorously explore and objectively evaluate all reasonable alternatives,” including a “no action” alternative, and “[d]evote substantial treatment to each . . . so that reviewers may evaluate their comparative merits.” 

These two projects would bring 1 trillion gallons of fracked gas into our region every year. Fracked gas is primarily made up of methane, a greenhouse gas 86 times more potent than carbon dioxide over a 20-year period. These greenhouse gasses are trapping heat in the atmosphere and warming the Earth at an unprecedented rate. 

Climate change is already harming the Hampton Roads region, home to the pipeline proposals. The coastal area has been experiencing record-breaking flooding with the increased frequency and intensity of hurricanes and other storms, with people unable to utilize roads as a means of egress because of high water. This coastal region also must combat a shrinking riparian zone as sea levels rise. This endangers the livelihoods of historic oystermen communities, and other industries, as they are unable to turn a profit. Those who are less financially able will be left behind as a changing climate threatens their homes.

The two pipeline proposals would negatively impact environmental justice communities. As part of their proposals, the developers would either increase capacity or build entirely new compressor stations in regions that have higher than state population averages of poverty, elderly inhabitants, and minorities. These regions tend to have higher than average rates of pulmonary and cardiovascular issues – all of which are exacerbated by the pollutants that compressor stations emit. 

The only way to mitigate against these,and other harms from the pipeline is to take the no-action alternative. 

CCAN and its undersigned members request that you seriously consider this “no action” alternative when conducting your environmental review of the pipeline projects. Our communities and our planet deserve better.



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