South Jersey Gas seeking a 4 lane highway to serve as a private driveway
If Pinelands Commissioners somehow can’t figure this out – or can’t see through Wittenberg’s smokescreen – it is a sure bet that a judge will.
Expert reports submitted to the Pinelands Commission found that the South Jersey Gas Co.’s (SJG) proposed Pinelands pipeline – a contractually dedicated pipeline that would exclusively serve the BL England power plant -would have huge excess capacity, more than 5 times the capacity necessary to serve the BL England plant.
That would be like constructing a 4 lane highway to serve as a private driveway.
Huge Excess Capacity In High Pressure Pipeline Exceeds BL England Need by a Factor of 5
The Report: “South Jersey Gas Pipeline Review: Analysis of Likely Actual Use of Proposed South Jersey Pipeline by BL England Plant and Assessment of Excess Capacity Available to Serve Customers Primarily Outside of Pinelands” (January 2017) was prepared by energy consultant Skipping Stone, LLC, for the Pinelands Preservation Alliance (PPA).
The SJG proposed 24 inch diameter pipeline is a high pressure pipeline. It is designed for 700 psig.
The higher the pressure in the pipeline, the more capacity to transmit gas. The relationship is non-linear, i.e. a 700 psig pipeline carries more that twice a 350 psig pipeline.
SJG has claimed it will currently operate the pipeline at a far lower pressure, just 437 psig. They made no commitments about the future.
The PPA consultant Report concluded (it’s complex, but strongly recommend you read the whole thing):
Moreover, should the two SJG suggested upgrades occur and the line operated at 700 psi, then SJG could serve (1) the 67,000 Mcfd to the [BL England] Plant, (2) ~145,000 Mcfd to the north (i.e., into Atlantic County), (3) another 74,400 Mcfd to the south (i.e., into Cape May County); and (4) still have nearly 100,000 Mcfd (~95,000 Mcfd) serve a currently unidentified load. This represents more than 380,000 Mcfd of potential capacity for the proposed 24-inch pipeline. (@ p. 12)
So the pipeline has a huge excess capacity to serve future growth.
Executive Director’s Recommendation Report acknowledges excess capacity and includes loopholes for future expansion
Now here’s where it gets interesting.
Thus far, the debate about whether the SJG pipeline complies with the Pinelands CMP regulatory standard to “serve primarily only the Pinelands” has been limited to basically two things: 1) whether the BL England plant is located in the Pinelands; and 2) whether the electric power produced by BL England would serve residents and businesses in the Pinelands.
Arguendo, even if these arguments are assumed to be true, i.e. that the BL England plant is located in and serves primarily only the Pinelands, the huge excess capacity CAN NOT SERVE THE PINELANDS!
The excess capacity argument is a killer. No way the pipeline would “primarily serve only the Pinelands“.
Also keep in mind that ratepayers are picking up the tab for 60% of the $100 million pipeline. – or $60 million. Given that the BL England dedicated capacity is about 16% of the total pipeline capacity, 60% of the dedicated BL England capacity would be just $9.6 million (we challenge readers to do the math!)
Executive Director Wittenberg’s “Recommendation Report” (scroll to the end of this) explicitly acknowledges the existence of huge excess capacity, thereby validating the PPA consultant Report’s analysis:
3) although the natural gas pipeline is designed at a maximum allowable operating pressure of 700 psig, it will operate at a maximum pressure of 437 psig due to constraints in the applicant’s gas transmission system (@ p.3) ….
In particular, the submitted information states that, although the pipeline is designed at a maximum allowable operating pressure of 700 psig, the 24 inch pipeline will operate at a maximum pressure of 437 psig due to constraints in the applicant’s natural gas transmission system. The submitted information further establishes that the applicant is contractually obligated to provide the capacity for 125,000 MCF per day of natural gas to the existing BL England Plant electric generating facility for a minimum of 350 days per year for 20 years. Lastly, the applicant has established and the New Jersey Board of Public Utilities has confirmed that 125,000 MCF is the maximum flow capacity of the proposed 24 inch pipe based upon a maximum pressure of 437 psig. These representations were confirmed by the BPU in its December 16, 2015 Order. (@ p.5)
Note that BPU’s analysis is based on SJG’s claim to operate at the lower pressure (437 psig), not the full design capacity pressure of 700 psig.
Wittenberg not only acknowledged the excess pipeline capacity.
Wittenberg built conditions into the approval that would essentially create loopholes that would allow SJG to expand gas service and utilize this excess capacity in the future.
Specifically, here are the “conditions” Wittenberg recommended regarding excess capacity (@p.24)
9. Any future natural gas system infrastructure improvements, whether those improvements occur within or outside of the Pinelands Area, that may result in changes such as additional gas flow to the proposed 24 inch gas main or redirection of the proposed 125,000 MCF gas flow shall only be approved by a State agency if such approval is consistent with the standards of the Pinelands Comprehensive Management Plan (N.J.A.C. 7:50-4.81 (a)).
10. Within the Pinelands Area, any development, including but not limited to additional gas flow to the proposed 24 inch gas main or redirection of any portion of the proposed 125,000 MCF gas flow from the BL England plant requires application to the Pinelands Commission.
Condition #9 appears to restrict future expansion, but it actually facilitates it. Given the precedent of the proposed SJG approval, a future Pinelands Commission would virtually have to issue an approval of a future SJG expansion.
Condition #10 is not enforceable because it would not apply to future SJG expansion gas service to customers located outside the Pinelands, because the Commission lacks jurisdiction there.
Accordingly, condition #10 is meaningless –
These conditions are extremely disturbing and not only with respect to the future use of the excess capacity built into the pipeline.
It is possible that the pipeline would be built and the BL England plant could be cancelled and would not be built.
In that case, ratepayers would be stuck wth a $60 million tab for a pipeline to nowhere!
If Pinelands Commissioners somehow can’t figure this out – or can’t see through Wittenberg’s smokescreen – it is a sure bet that a judge will.
Stick a fork in it, folks. This dirty deal is dead.