VI. Woodward-Clyde, consulting engineers, reviewed the EPA study on behalf of Basin Pipeline. They concluded that the "maximum potential hazardous impact area extends to less than 1 mile in the downwind direction."

Any air dispersion assessment requires assumptions that may be called into question. But it is hard to imagine that the DEQ assumptions would be more liberal with respect to level of acceptable risk to public health than those made by consultants to the regulated industry.

That said, the PSC should not approve a project that will endanger Michigan residents living within a mile downwind of this lengthy pipeline.

While the Institute does not recommend a "zero risk policy," there are extensive safety measures that Basin Pipeline could take to provide a greater level of protection. This includes removing hydrogen sulfide from gas before sending it through the pipeline.

VII. Given the level of public awareness concerning this application, Basin’s submission is incomplete and at a minimum shows a great disregard for the public’s concern.

Basin’s application failed to contain environmental and public health data that would allow citizens and governmental regulators to make an informed decision.

At worst, it shows that Basin may not exercise an appropriate level of oversight over their operations with respect to health and safety.

Environmental and public health studies were submitted at the prehearing, several months after the application was received. The Institute urges the PSC to reject the application as incomplete in order to send a message to Basin that health and safety are serious matters in the eyes of the State.

VIII. Lastly, part of the health risk occurs not just along the proposed route for new pipeline connections but also in existing pipeline routes. According to preliminary information provided by Basin Pipeline to concerned citizens and local governments, the proposal would increase the concentration of H2S contained in gas flowing through existing pipes.

Many area residents consented to the installation of these existing pipelines. They chose not to intervene when the developers and operators sought state approval for pipeline construction. At the time, the risk of H2S poisoning was low.

Now the risk has changed and this public hearing is their only opportunity to voice objection.

IX. The Institute believes that the PSC should approve no additional flow lines for natural gas that in the event of a release, would expose the public to concentrations of hydrogen sulfide greater than the PSC’s own residential exposure limit of 1 part per million.