Heron Hill

Letter to the DEC from John Ingle regarding Proposed Finger Lakes Liquefied Petroleum Gas Underground Storage Facility in Reading, NY

September 30, 2011

I am writing to voice my concern over this proposed project on Seneca Lake. As a longtime winery owner and grape grower I have watched this region change and grow over the years, becoming stronger and more vital along the way. Never has the change been threatening or unwelcome, until now. The people and business owners in this region have worked tirelessly for decades, investing both energy and assets into gaining world-wide recognition for the quality of Finger Lakes agricultural products. Agriculture and tourism are the lifeblood of our economy and are responsible for the much-envied quality of life that we enjoy. And now as we are finally reaping the rewards that come with international respect, we come face-to-face with a threat to our way of life and our livelihood. Noise, truck traffic, pollution, and an industrial landscape are not why people choose the Finger Lakes as a vacation destination. We are in competition with tourist destinations all over the US and it takes but a bit of tarnish on our reputation to cost us dearly in both desirability and economic return. I understand that the gas industry has its place in the American landscape but that place is not here. I’m sure that there are non-tourist communities who would welcome 8-10 industrial jobs with open arms, but not here. All is takes is a simple risk vs. reward analysis. Who is taking all the risk and who is reaping all of the reward?

I’m sure by now you’ve received plenty of letters detailing the following risks:

1. Who is responsible for maintaining the roads that will have increasing amounts of heavy truck traffic? Who will pay for this? How will the already congested main streets of Watkins Glen deal with added traffic and pollution?
    
2. Are our small local fire departments expected to deal with catastrophic failure at this facility? Who will pay for training and equipment needed? Is our small local hospital equipped to handle an industrial catastrophe? Why put such a facility near a highly populated town that would have to be evacuated in a major failure?
    
3. What are the risks of building this facility on a steep hillside versus a flat location? The lake shores and water create a “bowl” shape. In the event of an accidental release, and since LPG is heavier than air, what are the risks if a vapor fog forms and sinks over the lake? What will the impact be in this scenario, and is there an evacuation plan in place?
    
4. What are the risks associated with hydrocarbon storage next to a compressed air storage facility? Will any fires or explosions that ignite at the gas storage facility be magnified if they come into contact with the compressed air stored nearby?
    
5. What impact will the volatile organic compounds produced by the diesel trucks have on our crops and agriculture? Will these trucks or any portion of the Inergy proposal, including pipeline, impact Grade A farmland?
    
6. What kind of security measures have been established for the 24-32 railcars per day carrying thousands of gallons of flammable LPG traveling over miles of track near residences and also over a bridge across Watkins Glen Gorge? The Route 329 Bridge that the trains plan to use is in poor condition and is unsafe for transport of hazardous material. Have security measures been established for the pipelines or off-site aspects of the project?
    
7. There are fault lines on the Western shore of Seneca Lake. In light of the recent seismic activity felt in Watkins Glen, what would be the impact of an earthquake involving those fault lines and the gas stored within the caverns so close by? How adequately have these fault lines been studied? The application to store spent nuclear rods in these caverns was denied due to these fault lines. Why then is storing LPG in these same caverns being considered?
    
8. How will this facility affect local property values and the tax base—on the lake, near the facility, and along the roads leading to the facility? How will added traffic and industrial activity affect tourist businesses in the area? Franklin Street, the main street in Watkins Glen, has applied to be a Historic District. How can added LPG truck traffic coexist with a historic site designation? How much more traffic can the retail shops and homes on Franklin Street withstand?
    
9. On top of the aesthetic damage to a pristine hillside overlooking Seneca Lake, a brine pond on the side of a hill can spill or leak into the lake and local water sources, leaving the village and local residents without potable water. The water table is very high where the proposed brine pond is to be located. How porous or permeable is the soil beneath the brine pond? In the event of a brine leakage, how long would it take for the brine to contaminate the water table?

According to a paper submitted to US Fish and Wildlife, there is high morbidity and toxicology associated with salt water and migratory birds and waterfowl. The impact of the brine pond to our migratory birds and waterfowl, including the threatened loon, is not adequately addressed in the dSEIS. How would this facility impact the recently established Bald Eagle? What about the ecological health of nearby wetlands? The dSEIS suggests that since our wetlands are small, no impact or mitigation measures are required, but there is no reason to claim this. The dSEIS does not adequately assess the flora and fauna at the site. An independent study should be undertaken and completed over several seasons

Gas produced from the Marcellus Shale contains some of the toxins used in its extraction. Some, if not all, of the propane, butane, and natural gas stored in the salt caverns will come from drilling in the Marcellus Shale. Toxins from the gas could also leak into our lake. Seneca Lake is a Class AA drinking water resource for over 100,000 people. Why take such a risk?

My main winery facility is located on Keuka Lake with one of my tasting rooms located on Route 14 on Seneca Lake. Increased truck traffic is of major concern to me, because of the nature of Route 14 traffic. Much of Route 14 is designated as 55mph, however if you’ve spent any time in this region you know that there are those that drive 65mph (locals or thru-drivers) and those that drive 45mph (namely tourists looking for the next sign or winery). These same tourists often make abrupt turns or stops, which locals have become accustomed to. What happens when there are more trucks on the road? Will they be able to stop quickly and avoid accidents? What about when customers are pulling out of driveways onto Route 14? Will the truck drivers be alert enough to slow down ahead of time? Truck drivers are often tasked to work long shifts with little down time between runs; this seriously impacts alertness and makes driving in unpredictable situations all the more dangerous.

Is Inergy’s economic claim true that heating costs will go down for upstate New Yorkers? If so, by how much? Is saving $1000/year on my winery’s heating bill worth losing tens of thousands of dollars in revenue? What happens if I have to start laying off some of my 50+ employees, including 14 full-timers? What happens to the state and local governments when my sales tax revenues decrease?

This is a long list of risks for no quantified reward.

Considering the serious impact this project could have, it is prudent to have an independent Qualitative and Quantitative Risk Analysis (QRA) that thoroughly and impartially evaluates the risk and impact this facility would have on the region. Local governments, residents and business owners should select the people who make this risk analysis, and it should be paid for by Inergy. There are a lot of important questions to be answered and I see no reason not to take the time and energy to make sure that each one is thoroughly addressed.

Thank you for your time and consideration.

Sincerely,

John Ingle, Jr.
Owner/CEO
Heron Hill Winery