MLUI / Articles from 1995 to 2012 / Michigan Public Service Commission on H2S Safety
Michigan Public Service Commission on H2S Safety
I. The Michigan Land Use Institute (the "Institute") is a Michigan non-profit corporation originally known as "Connections". Some of its members live and own property in close proximity to the proposed route for the pipeline. Filer Township also is a member of the Institute. II. Connections facilitated the negotiation of the limited oil and gas management plan for the Sand Lake Quiet Area in Whitewater Township, Grand Traverse County, Michigan. Since its reorganization in May, 1995 in the Michigan Land Use Institute, the organization has focused on establishing oil and gas policies that are compatible with land use, the environment and the public interest has been a central part of its work. The Institute conducts research on the environmental, cultural, and socio-economic impacts and benefits of hydrocarbon development. The Institute holds community meetings on oil and gas issues and publishes a quarterly magazine which provides independent news on Michigan’s energy industry. The Institute also has a history of activities supporting civic, protective and improvement purposes related to the preservation of the quality of life in Ocean, Mason and Manistee counties.. Among these, the Institute supported Filer Township in a case heard before the Manistee Circuit Court concerning transmission and processing of sour gas. III. One of the Institute’s primary areas of emphasis is the threat to public health from accidental and intentional releases of hydrogen sulfide contained in natural gas. The Institute has presented a plan for managing risks associated with hydrogen sulfide (H2S) to the Public Service Commission (PSC) and Department of Environmental Quality (DEQ). The Institute is submitting this report into the public record along with this testimony (attached). IV. It is incumbent upon the PSC to consider public health and safety, in addition to convenience, when considering the Basin Pipeline, LLC ("Basin") application. The PSC considers health and safety when permitting distribution lines for natural gas, and regulates gas flowing through these lines so that it cannot contain concentrations of H2S in excess of 4 ppm. The PSC also requires utilities to prevent exposure of customers to concentrations of H2S in excess of 1 ppm. Certainly, the PSC should provide the same protection the Michigan residents living near the proposed pipeline that it extends to the customers of the utility companies it regulates. V. In August, the United States Environmental Protection Agency (EPA), at the request of Representative Peter Hoekstra, conducted a health and safety analysis of the proposed pipeline. Based on preliminary information, the EPA found Michigan residents living up to six miles downwind from the pipeline could be exposed to unsafe levels of H2S. Some of these residents also are utility customers. It is unconscionable that the PSC will protect these people against H2S poisoning from a distribution line near their homes but allow them to be poisoned by the same gas if it is carried in a transmission line.
