NED Pipeline Comments by Warwick Planning Board Chair Cady


Ted Cady, Chair, Warwick Planning Board

The Town of Warwick Planning Board and the Warwick Building and Energy Committee oppose the Department of Public Utilities (DPU) granting Tennessee Gas Pipeline (TGP) the right to enter onto property without the landowner’s consent to conduct various surveys for the Northeast Energy Direct Pipeline (NED FERC Docket CP16-21) at this time.  The pipeline will pass through the Town of Warwick, so town residents have a significant stake in the proceedings.  We, the herein mentioned boards, will show that there is no cost basis for the project, no need for it, inadequate supply of natural gas to support it; that it is financially not in the Commonwealth’s best interest, and it is inappropriate for the DPU to become involved in the proceedings at this time.  Therefore, the DPU should not grant TGP the right to survey lands without the landowner’s permission.


TGP has proposed that the NED pipeline will reduce energy costs.  This issue has been carefully looked at, and it has been found that the likely outcome will be to increase costs.  The Mass. Attorney General’s Report found that the pipeline was not the most economical solution to meeting peak loads for electrical generation.

Irving Oil Terminals Operations, Inc. of Canada recently signed on to take 10,600 dekatherms of gas per day of NED capacity.  Irving Oil is a minority owner (with Repsol, the Spanish oil giant being the majority owner) of Canaport LNG, in St. John, New Brunswick.  Irving Oil also owns a very large crude oil refinery in St. John.  Canaport LNG came on line in 2010 to IMPORT liquid natural gas just as the shale gas boom took off in the United States.  The lower prices for US shale gas have resulted in the natural gas pipeline running from St. John to Dracut, MA being empty 90% of the time, and only used for peak energy needs in winter.  Canaport LNG has received approval of the environmental permits necessary to construct a $1.2 billion(US) LNG EXPORT Facility.   Irving Oil’s representation of the 10,600 dekatherms for industrial use has been challenged and apparently will go to either a hearing or court.  Assuming Irving Oil prevails, natural gas from NED will be exported out of this country.

The US Energy Information Agency (EIA) on January l9, 2012 released a report entitled, “Effect of Increased Natural Gas Exports on Domestic Energy Markets.”  It concluded that consumers would see a 3 to 9% increase in price and a 1 to 3% increase in electricity prices if NG is exported.

A Department of Energy (DOE) study found significant externalities from exporting natural gas including a decline in wages and return on capital for individuals and businesses outside of the natural gas industry. Almost all sectors of the economy (other than NG) will suffer job losses and decreased output.

According to this industry source, the energy industry supports exporting natural gas (

“The U.S. is now one of the largest natural gas producers in the world, and our excess supply and inability to export has pushed prices artificially low.  The ability to begin the export process from Liquefied Natural Gas would help equalize domestic gas markets while allowing producers access to foreign markets where gas sells for a much higher rate.  This would have the dual effect of relieving some of the commodity price pressure on baseload energy production at home while also opening entirely new export markets to the U.S. trade sheet.”  The translation is that energy prices would go up in the US and the energy sector will make more money.

The New England Governors have proposed a 2% tariff on electricity to help pay for the pipeline.  The details, such as duration of the tariff, which users of electricity would be subject to paying, have not been made clear.  It is clear that if you add the 2% tariff to the cost of electricity that is already projected to go up by 1 to 3 percent if exports are allowed will significantly increase the cost of electricity to end users.

A recent National Grid filing is requesting a 2.75% tariff.

In a February 5, 2016 press release Senator Markey (D-MA) stated, “DOE Approval of Natural Gas Exports Out of New England Will be Devastating for Region.”  He further stated that exports could increase natural gas prices to Mass. users by 39%.

Based on the DPU’s mandate to protect users, it should oppose the pipeline. Contrary to TGP’s claims if exports are allowed, it will raise the cost of natural gas to end users, and significantly raise electrical rates for Massachusetts’ customers.


There is no need for the NED pipeline.  The original proposal was for a 36” diameter gas line.  Lack of support resulted in a reduction of size to 30”, and firm commitments are in place for only 41% of capacity.

Some of the firm commitments are questionable.  Berkshire Gas is owned by Iberdrola, a Spanish oil giant, which has agreed to pay for part of the cost of the NED pipeline and has an LNG IMPORT facility in Spain.  The shortest distance between the North American Continent and Europe is from New Brunswick/Nova Scotia.  The Massachusetts Attorney General (AG) is looking into these relationships and the possibility of inappropriate or illegal activity.  If found to be inappropriate the reduced firm commitments would make the pipeline even more expensive for users.

The Massachusetts Attorney General has requested $250,000 to study National Grid’s request for approval by DPU of a firm commitment.  Based on the prior AG study that determined natural gas pipelines were not the least cost alternative for meeting peak electrical demand, one could suppose the AG will oppose the firm commitment.
Federal Court cases brought by opponents of the pipeline challenging the legality of some firm commitments by companies are currently pending.    If successful there might not be enough firm commitments to justify building the NED pipeline.

Berkshire Gas had in prior years proposed to DPU a plan as part of its annual submission to deal with anticipated supply constraints by building a facility in the Town of Whately to store LNG.  It poured a pad for five tanks, but only partially built it out as the need was not sufficient to justify building all tanks at that time. It also proposed to DPU building a short pipeline if needed to tap into additional supplies.  Since being acquired by Iberdola, it has abandoned those plans, and prohibited all new connections to the system or expansions of existing use until the NED pipeline is built.  It has also agreed with KM to fund part of the NED pipeline costs.  This is viewed by many, possibly to include the Mass. AG, as an inappropriate activity, and legal enforcement action may be pending.  The net result could be elimination of Berkshire Gas’s firm commitment for NED gas.

Mass. is a national leader of renewable energy installations.  The fierce opposition by electric companies to legislation to expand renewable solar energy credits in Mass. is a measure of the success of the program.  The payback period for solar installations is now short enough so that people are installing additional solar capacity to their homes for heating in winter and cooling in summer.  One example of the impact of these advancements is that high efficiency air-to-air heat exchanges powered by electricity are now viable.

The cause of extreme price spikes in the winter of 2013-2014 have been addressed successfully.  The winter of 2014-2015 was in many ways worse than the prior winter but there was no spike in prices.  The Independent System Operator (ISO) New England had solved the problem.  Many independent electrical generators now have dual fuel capability to hold their fuel costs down, and LNG imports to Everett Terminal are better coordinated.  The AG’s report reflects these electrical generating industry enhancements.

The most recent ISO bids for electrical generation are below previous years there are sufficient resources including three new plants to meet demand in 2019-2020.

Contrary to the impression that some give, Massachusetts electric rates are below the national average.  We do not have the highest electric rates in the country, far from it.   More than half the states have electric rates higher than in Massachusetts.

In addition, major progress is being made in energy conservation.  More houses are better insulated and sealed. This holds down both heating and cooling energy use.  The trend from incandescent light bulbs to Compact Fluorescent Light Bulbs, and now to Light Emitting Diode light bulbs, is significantly reducing electric bills.  At the same time advances are being made in reducing energy consumption of most common items from industrial motors to refrigerators, air conditioners and other home appliances.

On the following page is an EIA table showing gas consumption in Massachusetts for a five year period ending in 2014.   Contrary to what some say, natural gas use in Massachusetts peaked in 2011 and has declined since that time.   Natural Gas used for electrical generation also peaked in 2014 and has been going down since that time.  The decline in use of natural gas is explained clearly in the Attorney General’s Study which found that more flexible sourcing of energy supplies and dual fuel capability electric generation plants have greatly increased the reliability of electrical generation and stabilized prices.

 Show Data By:  
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  Natural Gas Consumption by End Use
  (Million Cubic Feet)
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Click on the source key icon to learn how to download series into Excel, or to embed a chart or map on your website.



- = No Data Reported;   = Not Applicable;  NA = Not Available;  W = Withheld to avoid disclosure of individual company data.
Notes: Gas volumes delivered for use as vehicle fuel are included in the State annual totals through 2009 but not in the State monthly components. Estimates of gas volumes delivered for use as vehicle fuel are included in the State monthly totals for January 2010 forward.  See Definitions, Sources, and Notes link above for more information on this table.
Release Date: 1/29/2016
Next Release Date: 2/29/2016

In a situation analogous to the MDC water shortages, which were solved by encouraging conservation, the problem of local distribution gas line leak repair will greatly increase available local gas supplies.  Gas companies have not had to pay for gas that was lost from their system and had no incentive to repair leaks.  The Mass. Legislature has passed laws which are expected to rectify this very significant problem.  Fixing the leaks will provide more than the estimated future natural gas needs.  (While at the same time significantly reducing the global warming impact of leaked natural gas which will help achieve the reduced global warming goals set by the legislature.)

There is another pipeline (SPECTRA) which will supply NG to Mass.  FERC has been asked to incorporate both pipelines into a single review as required by law and case law but no answer has been received to that request at this time.  Failure of FERC to consolidate the two projects for environmental review into one review may result in legal action which clouds the viability of NED pipeline.

The shutting down of fossil fuel and atomic electrical generating facilities is claimed as a victory by environmentalist, but actually it is measure of the falling demand for electricity.  If demand remained high or was increasing, the price for electricity would be higher and the needed improvements to existing plants would be cost effective.  Contrary to what the natural gas folks say, electrical demand is being efficiently managed on many levels in Mass.  ISO New England has been very active and effective in this effort.

It should be recognized that New England is at the end of all hydrocarbon supply lines, whether gas, or oil.  Our prices will always be higher than those areas closer to the supply of gas and oil. To think otherwise does not reflect the cost of transportation.

Attached (Appendix A) is a petition by the Franklin Regional Council of Governments asking for an Evidentiary Hearing on the Need for the NED Pipeline.  They do not believe there is adequate demand to justify it.  A part of Appendix A is a letter from Sen. Markey (D-MA) supporting FRCOG’s petition.

Clearly Massachusetts does not need two new Major NG pipelines, and various petitions for hearings are before FERC on this issue.


Any gas coming to Mass. through the NED pipeline will be predominantly from the Marcellus Shale Gas Play.  Shale gas wells have a unique production profile first publicized by J. David Hughes.  The well is drilled down to the relatively narrow shale deposit holding the natural gas (and usually some oil) and then horizontally drilled in the gas bearing shale deposit.  However, this does not produce any gas to speak of.  The horizontal bore is then fractured using explosives and very high pressure to open seams in the rock and pump in special fluids which carry sand that hold the seam open and other fluids to enhance gas flow.  Great advances have been made in the fracking process so better yields are obtained from wells.  However, it is still the case that about 80% of the natural gas yield of the well is in the first 3 years.  This means that new wells must be constantly drilled to maintain the output of the field. Attached as Exhibit B are two EIA monthly reports showing Marcellus output.  Note that “Production from legacy wells” declines exceed “Production from new wells.”  Also note that “legacy gas well production change,” which is the production from old wells, is significantly declining.  This is bad news, since these older wells are not being replaced fast enough to maintain production.

The chart below shows the peak production of the major gas plays in shale in the US.  Note that peak shale gas production would have been 2012.  The Marcellus Play has moved that peak to 2015.  This chart is taken from a draft submission by Arguimbau, Appendix C.

From -deeper/  is a 315 page report that takes issue with long term domestic abundance of shale gas and tight oil based on in-depth assessment of all drilling and production from all major shale plays through early 2014.  The report determined future production profiles by analyzing assumed rates of drilling, average well quality by area, well- and field-decline rates, and the estimated number of available drilling sites.  From the Executive Summary, page 4: “This report provides an extensive analysis of actual production data from the top seven tight oil and shale gas plays in the U.S. (These plays account for 89% of current tight oil production and 88% of current shale gas production – 89% of forecast tight oil and 88% of forecast shale gas through 2040.)

It concludes that the current boom in domestic oil and gas production is unsustainable at rates projected by EIA, and that the EIA’s tight oil and shale gas forecasts to 2040 are extremely optimistic.  What this means is that the country’s current energy policy – which is largely based on the expectation of domestic oil and natural gas abundance far into the future – is badly misguided and is setting the country up for a painful, costly, and unexpected shock when the boom ends.”

According to J. David Hughes “New USGS Marcellus Shale Analysis Drastically Cuts DOE Estimates,”  “The 84 Tcf technically recoverable undiscovered resource for the Marcellus is a considerable downgrade from the 262 Tcf technically recoverable resource reported by DOE in 2009.  Others have been using numbers for the Marcellus in the mid-400s of Tcf (see for example Engelder (2009)) who claims the Marcellus has 480 Tcf of P50 technically recoverable resources.”

The lower number fits with that of Powers who was citing around 60 Tcf.  84 Tcf is, of course, less than 4 years of US consumption.  And, the question is, how long will it take to produce it? And at what environmental costs?   As with all USGS estimates this is a probabilistic estimate, with 84 Tcf being a P50 estimate (ie. 50% chance of having at least 84 Tcf).  The P95 number is 43 Tcf (ie. 95% chance of having at least 43 Tcf).  So, as always with undiscovered resource estimates, roll the dice and take your chances.

we welcome this from the USGS as it puts a bit more rigor into the hype on the Marcellus and radically reduces some of the numbers floating around. “

Note that the EIA Marcellus Region Drilling Productivity Report (Appendix B) for February, 2016 is 15,222 Million cubic feet per day and declining.  Arguimbau (See Appendix C), Hughes and others have argued that the decline in legacy gas production from the Marcellus Play will exceed the amount added by new drilling.  In other words, Marcellus is now at peak production.  The implication is that when gas and oil supply and demand are again normalized, the base price of Marcellus Shale Gas will be significantly higher and the price will continue to go up as the production declines.

In a sworn Affidavit J. H. Hughes states, “the cost of natural gas in the medium and long term will be much higher than today, and higher than projections of EIA, which will negatively impact investments … in (facilities) that are expected to function for 30 or more years.”  (Appendix D)

TGP has recognized the future supply constraints and has publicly and repeatedly explained that the pipeline is a temporary bridge fuel to a renewable energy future.  Oddly NED pipe line opponents have taken issue with the statement.  However, it is true that the pipeline would disrupt the current relatively smooth transition to a renewable energy future that is now happening in Mass.

Why would TGP build a pipeline when the gas supply will not last for the depreciation period of the pipeline?  One theory seems to make sense.  The situation is analogous to the drug dealer who gives free drugs to get a person “hooked” and then raises the price.  When TGP gets electrical generation plants, manufactures and those using natural gas for heating and cooking connected and using gas, they will have them “hooked.”  It is inevitable that gas prices will go up, and eventually they will go high enough so the flow of the pipeline will be reversed and LNG will be imported and pumped through the pipeline to serve the connected customers.

Clearly there is not enough Marcellus Shale gas to support the pipeline for its depreciation period.


TGP correctly claims that natural gas is cleaner burning.  NG produces  56% less carbon dioxide per kilowatt hour than coal.  However, it is not cleaner overall, and is now ranked in the same category as coal.  In 2011 Robert Howarth at Cornell concluded that 1.9% of the gas in a typical fracked well escapes to the atmosphere during fracking compared to 0.01% in a conventional gas well.  (Robert Howarth, Renee Santoro, and Anthony Ingraffea, “Methane and the Greenhouse-Gas Footprint of Natural from Shale Formations,” Climate Change 106, no. 4 (June 2011): 679-690, doi: 10.1007/s10585-011-0061-5

A study by the National Oceanic and Atmospheric Administration (NOAA) reported that fully 4% of the gas being produced in the Wattenborg field was leaking to the atmosphere, and 9% from a field in Utah.

A study in New York, NY concluded that the “total of production losses and transmission losses for natural gas used in New York City must be above 5%.”  Supporting results were found in Boston, MA.  Richard Heinborg in Snake Oil, pg.90, states “gas leaked to the atmosphere (from all phases of production and distribution) must remain below 3.2% of all gas produced if natural gas is to have a climate advantage over coal . . .” The amount of gas lost from long distance pipelines such as NED proposed by TGP is not known, but would add to the total.

It is clear that gas from TGP NED pipeline would make it significantly more difficult to comply with the Massachusetts Legislature’s policy to reduce global warming emissions.  While natural gas burns cleaner its net profile is worse than coal.   DPU should take seriously the legislatures’ legal mandate through The Global Warming Solutions Act to reduce carbon pollution by 25%.  It should become part of DPU’s project review protocol.


In the l970s Massachusetts got 70% of its electric power from oil.  The Arab Oil Embargo showed the importance of a diversified base for generating electricity.   Currently our electricity is about 40 to 50% generated from natural gas.  As a result of the Arab Oil embargo Mass. developed a policy of avoiding reliance on a single fuel source.  We should learn from the past and avoid dependence on a particular fossil fuel.

Given the shaky long term outlook for Marcellus gas, and past experience with oil shortages, it seems logical to not move strongly in the direction of over reliance on a single fuel such as natural gas.


Some people say there is a strong push to position the U.S. to supply our European Allies by making low cost LNG available to them to counter any possible moves by Russia.  The European Commission’s Energy Security Strategy looks to reduce dependence on Russia.  Gunther Oettinger, Energy Commissioner, said Europe must “accelerate the diversification of external energy suppliers, especially for gas, to avoid falling victim to political and commercial blackmail.”  The U.S. has responded and significant LNG export agreements have been signed to be shipped out of Southern U.S. ports.

It is not in Massachusetts gas user’s best interest to encourage LNG exports`.  The Marcellus will run out of gas soon enough, so there is no need to hasten it.  If Mass. participates in exporting, it will make our landing after the Marcellus gas runs out that much harder.  The Mass. DPU should not participate in harming our future.  If the federal government wants to support Europe, let them handle it.  The DPU should stay out of it.


TGP is a wholly owned subsidiary of Kinder Morgan.  Kinder Morgan (KM) has recently found itself in an awkward financial situation.  It is not correct to call it a Ponzi Scheme, but the company is $44 billion in debt.  It recently received notice that if it went to the debt market again its bond rating would be reduced to junk bond status.  In the past it has been a favored stock because of more generous dividends than similar companies.  In his annual report Richard Kinder said that dividends would continue to increase in the coming year.  However, when faced with the inability to access the debt market, the company reduced its dividend yield by 75% which resulted in its stock dropping from a high of $44/ share to around $16/share.  It has significantly reduced its capital budget for this year.  Most financial analysts are recommending holding the stock.  However, some insiders are saying that the “hold” recommendation is more to prevent a Lehman Bros. type meltdown within the NG industry, than anything to do with the company itself.

KM has admitted it does not have adequate insurance, and opponents of the pipeline may submit this data to FERC during the pipeline approval process.  In addition, financial analysts have found that a major reason that KM has such high dividends is that it spends half as much on pipeline maintenance as other pipeline companies, and its safety record reflects this.

This may be a matter best left to FERC to sort out.


All conservation groups, land trusts, impacted towns, and other groups are fiercely opposed to allowing the pipeline to cross conservation land.  This includes state owned land, land owned by land trusts and conservation groups, and private land with conservation restrictions or agricultural preservation restrictions.   This will go before the state legislature and both houses must approve the pipeline route across the conservation land.  Lobbying on this issue is heavy.  If the legislature does not vote to allow the pipeline to cross conservation land, then the route must be changed or it will go to court and eventually wind up before the U.S. Supreme Court since there are no precedents.

It is premature for the DPU to override the rights of private land owners until the pipeline route is finalized, and it will not be finalized until the legislature votes, and the likely court cases are resolved.  If the legislature does not approve crossing Article 97 lands the DPU will have violated private property rights without a good reason.  The DPU will have plenty of time to grant permission to survey at a later time if it so chooses.


The National Gas Act gives permission to survey when it is found that “public necessity and convenience” requires it.  As things now stand there are many elements that remain to be worked out at the federal and state level.  FERC has required an alternative route analysis that might prove to be a preferred route, making the proposed DPU action to allow surveying unnecessary.  On February 26, 2016 FERC issued a seventy page letter to TGP of deficiencies in TRG’s application, including many that were identified in earlier deficiency letters and not addressed by TGP, which seems to indicate much additional work is needed by TGP before private property rights should be overridden.   If the SPECTRA pipeline and NED are combined into a single analysis, which may be required by court action to meet federal standards, it may not be necessary to build NED to meet the alleged natural gas shortfall.  There are several actions pending before FERC regarding NED.   The Marcellus Shale Gas is not going anywhere at this time as it is safely in the ground.  There is no rush.  We are not at war.  DPU should not get involved in stirring someone else’s (FERC’s) pot.


FERC relies solely on Firm Commitments to judge the need for a gas pipeline.  In overseeing regulated utilities the DPU carefully looks at proposed rate increases to make sure they are valid and needed to protect the consumer.   It is currently involved in this procedure regarding firm commitments proposed by regulated utilities in Massachusetts for NED gas.  However, this is not the total impact on citizens of the Commonwealth.  Once built the pipeline will be with us for longer than the Marcellus Shale Gas Play will be productive.  What will the impact be on consumers in Massachusetts as the Marcellus gas output declines?  Since the gas will be exported after the pipeline is built, what impact will that have on prices consumers pay?

The Mass. Attorney General’s study found that the pipeline is not the least cost alternative to meeting peak demand well into the future.  How does this match with DPU analysis?  Pipeline opponents and gas industry experts agree that when the natural gas gets exported the price of the natural gas will go up as rates are “equalized” among foreign and domestic prices.  How will this influence DPU decisions?  If the DPU required Berkshire Gas to implement its plan to use stored LNG to handle peak need, as it has previously proposed to the DPU, it would not need the additional gas.  How does the DPU handle this?  Is the DPU bound to work to ensure compliance with the Commonwealths’ laws regarding reducing our carbon footprint and reducing global warming?  These issues are quite complex and court action has been initiated

to help sort them out.  It is premature to authorize survey rights on land against the landowner’s will until these issues are sorted out.  Without adequate demand there cannot be a project.


Currently the natural gas lines serving Massachusetts are, on average, at about 50% of capacity, and the gas line from Canaport LNG is empty 90% of the time.   The transition to renewable energy, energy conservation, and reduced electric demand devices (such as LED light bulbs) is happening faster than previously anticipated, and thereby reducing the projected demand curve by more than was previously considered possible.  This means that probably the firm commitments for NED capacity are optimistic.  What happens in the short term to the surplus gas? In the longer run when export raises prices and renewable energy projects and conservation reduce demand there will be a huge problem.  Pipelines are designed to flow within a limited range, so if the demand is low, it can present a problem.  This could become a serious problem in the not too distant future.  To protect us, the citizens, DPU should consider these weighty scenarios, just as they carefully review a regulated utilities request for a price rise.  In the short term, for example, would a National Grid resale to the export market of part of its firm commitment still allow for the tariff to be applied?  Should National Grid even be allowed to sell out of state a firm in state commitment?


The DPU should not get involved at this time in granting survey permission to TGP for access to land whose owners have refused it.  Granting survey permission is premature.  Events have yet to unfold which may have a significant impact on the route of the pipeline.  FERC may find that the pipeline is not needed, and if they do find need, that conclusion may be challenged in court. It may be found because of hearing or court action that because of low firm commitments there is no documented need for the NED pipeline.  In fact, there are many irons in the fire including needed legislative action by the Massachusetts Legislature, requested FERC hearings and multiple Federal Court cases   The alternative route analysis required by FERC may result in a different route entirely, as may the Mass. Legislature Article 97 vote.  The impact of the pipeline may violate the Commonwealth’s Energy Policy.  It remains to be worked out how the pipeline’s gas supply will last through the depreciation period of the pipeline.  It is dangerous to become overly dependent on a single fossil fuel, whether it was oil in the l970s or natural gas now.  The direct impact of approving the pipeline will be a steep increase in the cost of natural gas as the price becomes more “equalized” with international natural gas prices.  As the AG’s study found, it may not even be the least cost solution to solving our energy needs.  As this document has pointed out, it is certainly not the least cost long term solution.

Respectfully Submitted,


Edwin B. Cady, Jr                                            Janice Kurkowski

Chair, Warwick Planning Boad                    Chair, Warwick Building and Energy Committee


Additional references:
Rafael Sandrea, “Evaluating Production Potential of Mature US Oil, Gas Shale Plays,” Oil and Gas Journal, Dec. 3, 2012.

J. David Hughes, “Drill, Baby, Drill:  Can Unconventional Fuels Usher in a New Era of Energy Abundance?” Post Carbon Institute (website), Feb 2013.

USEIA, “Annual Energy Outlook Retrospective Review: Evaluation for 2012 and Prior Reference Case Projections.”

Stephen Lacey, “After USGS Analysis, EIA Cuts Estimates of Marcellus Shale Gas Reserves by 80%,” Think Progress (blog), August 26, 2011



Appendix B –    eia Marcellus Region Drilling Productivity Report January 2016, February 2016

Appendix C –   “It’s Time to Call the Shale Gas Revolution as Well as “the Mighty Marcellus” a                            Bust”.  And Time is Long Overdue to Ask What We’re Paying the US Energy                                   Information For,” Draft submission to Counter Currents by Nicholas C.

Arguimbau, February 2016

Appendix D –   AFFIDAVIT by J. David Hughes










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