Dear Ms. Coakley:

The Board of Directors of the Nashua River Watershed Association is writing to ask for your assistance in preventing Kinder Morgan from proceeding with the currently proposed route for the Tennessee Gas pipeline in northern Massachusetts, which would cross through the Nashua River watershed towns of Ashburnham, Ashby, Dunstable, Groton, Pepperell and Townsend. The proposed route of this 30-inch or larger high-pressure pipeline transmitting natural gas to the metro-Boston area -- in addition to several proposed lateral pipelines -- would largely pass through open spaces including wetlands, water bodies and conservation lands of exceptionally high natural resource value to the commonwealth. Our primary concern with this pipeline is the negative impacts it would have to these critically sensitive environmental areas, especially when there are alternative routes that could use existing rights of way with far less irreversible impact.

Egregiously, the negative environmental impacts would be occurring in a region where there are many tracts of conservation land, often purchased with public dollars expressly to protect their natural resources. Some of the conservation properties through which the proposed pipeline has been shown to pass include the Ashburnham, Willard Brook and Townsend State Forests; the Nissitissit, Squannacook River and Townsend Hill Wildlife Management Areas; and the Heald Pond and Keyes Conservation Areas. Some tracts through which the pipeline would pass are encumbered by conservation restrictions which legally and permanently prohibit disturbance.

Furthermore, the pipeline's proposed route bisects the two largest Massachusetts state-designated Areas of Critical Environmental Concern (ACECs): the Squannassit and Petapawag ACECs. The Squannassit ACEC has 23 state-listed rare species, and the Petapawag has 16 state-listed rare species occurring within it.

Both of these ACECs are defined by their extraordinary natural habitat and highly significant drinking water supply and groundwater aquifer resources. The two ACECs include much BioMap Core Habitat and Supporting Natural Landscape. The designation of these ACECs as authorized under 301 CMR 12.00 (promulgated by the Secretary of the Executive Office of Environmental Affairs pursuant to M.G.L. c. 21A, s. 2(7)), resulted from an unprecedented amount of positive public input from residents of the involved towns, including Ashby, Dunstable, Groton, Pepperell and Townsend.

Additionally, the proposed pipeline would cross two state-designated Outstanding Resource Waters -- the Squannacook and the Nissitissit Rivers -- which are protected by the 1975 Squannacook-Nissitissit Rivers Sanctuary Act (M.G.L. 132A:17) and are cold water fisheries. The pipeline would also cross the Nashua River. Sections of these three rivers -- Nashua, Squannacook and Nissitissit -- are currently being considered for study for inclusion in the federal National Park Service Partnership Wild and Scenic Rivers system given their high-quality characteristics and broad public support.

The proposed pipeline corridor would be at least 50 feet wide and would be kept free of vegetation above ground level in perpetuity. Clear cutting of the land would result in permanent habitat loss and forest fragmentation, and, because of this, interior forest wildlife species that are dependent on contiguous forest blocks will be endangered. While in certain instances creating a clear corridor can have benefits for those species seeking forest edges, a corridor is not acceptable along the pipeline route currently proposed. Loss of forest cover is well known to have a detrimental impact on water quality. Surface water and groundwater flows will be altered, which will adversely impact the numerous wetlands, rivers and streams the pipeline will cross.

During the construction phase of the proposed pipeline project (including access roads and compressor stations), numerous negative environmental impacts are likely to occur despite best efforts to avoid them, especially with regard to stream crossings and wetland involvement. Sedimentation and other inevitable runoff problems associated with erosion would be an anticipated consequence. Pollutants may be discharged during construction or as a result of accidents, including methane leaks. Such impacts would be greatly lessened or eliminated by routing the pipeline through existing rights of way, such as along roadways or by other utility easements as Kinder Morgan is now proposing to do for the section of this pipeline to run through New York state.

The Nashua River watershed's northern lands and water bodies are of particular environmental importance to the commonwealth, as attested to by the two ACECs. The proposed pipeline route would be irrevocably harmful to public and private lands of remarkable ecological sensitivity. If it is determined that a new natural-gas pipeline is essential and is in the best interest of the citizens of our commonwealth, the Nashua River Watershed Association will steadfastly oppose the current proposed route, and urges that Kinder Morgan be directed to utilize alternative routes less damaging to the environment such as existing infrastructural corridors.

Lucy B. Wallace

President