Rover Hits Back at Ferc for Commissioning Delays
Rover Pipeline has fired back at staff of the US Federal Energy Regulatory Commission (Ferc) for delaying requested approvals to commission two key laterals of the 3.3bn ft3/day pipeline designed to move Appalachian gas to market.
In a July 2 letter to the commission, Chris Sonnenborn, Rover’s senior vice-president, engineering, said the pipeline was “deeply disappointed” in the contents of a June 28 letter from Ferc regarding the progress of final right-of-way restoration on the Market Segment of the pipeline that appeared to ignore the fact that restoration work on both the Burgettstown and Majorsville laterals was essentially complete.
“At the outset, we are concerned that the letter implies that, somehow, Rover will not meet all its restoration commitments. That is inaccurate and untrue,” Sonnenborn wrote. “Rover will honor and meet all of its restoration commitments – whether those are scheduled to occur before or after Rover is fully in service. Any implication to the contrary is simply untrue.”
The inaccurate implications of the Ferc letter, Sonnenborn writes, appear to stem from a fundamental misunderstanding of how restoration work is conducted on any major pipeline project.
“Restoration is not a “plug and play” process,” he writes. “The pipeline does not hit a button and watch bulldozers and graders magically restore the land. Instead, it is a process that requires a lot of advance planning and resources.”
And it’s a process that is almost entirely dependent on restoration crews enjoying good weather – conditions that have not been enjoyed by Rover’s restoration crews. Already delayed by extended winter weather, those crews weren’t able to start restoration work until early May, and in April, May and June were hit with excessive amounts of rain – as much as 1.7 inches in a single day, with as many as 19 days seeing at least a half-inch of rain falling.
“To state the obvious, the rainfall has been very significant and has impacted the restoration schedule,” Sonnenborn writes, noting that it appears from the June 28 letter from Ferc that commission staff have made the assumption that the restoration work will not be completed “until at least July 30, 2018.”
“In fact, Rover did not state to Ferc that restoration activities would be extended to “at least” July 30, 2018,” Sonnenborn wrote, adding that, in fact, Rover told Ferc on June 26 that “because of the continuous rain this season, the schedule for repairing the subsidence on Market will be extended to July 31, which is still weather-dependent.”
Rover can’t perform the decompaction activities, test the subsoil and replace the topsoil when the soil is excessively wet, Sonnenborn wrote, and “Rover cannot predict the weather.”
“This means that the July 31, 2018 date remains dependent upon weather,” he wrote. “Rover is committed to completing the full restoration of the Market Segment as soon as conditions allow it to be restored diligently, responsibly, and in compliance with the Ferc-approved plans, for the benefit of the environment and the affected landowners.”
Finally, Sonnenborn said, it appears the June 28 letter from Ferc was triggered by the company’s June 21 request to authorise service on the Burgettstown and Majorsville laterals by June 25 – authorisations which have yet to be issued by the commission.
“But rather than address those in-service requests, or respond to the substance of that letter, staff instead chose to divert attention away from the fact that these facilities are mechanically complete, and have been ready for operation for months,” Sonnenborn wrote. “At a time when natural gas storage remains at alarmingly low levels heading into next winter… it is bewildering that the staff would rely on information regarding the Market Segment restoration progress that was already known to staff as the reason for not granting in-service authorisation on the laterals.”
Since restoration on both those laterals is essentially complete, Sonnenborn concluded, “we therefore renew our request that Rover be authorised immediately to place these facilities in service to benefit the nation’s consumers.”