Sierra Club responds to Shell's Falcon Pipeline application


Shell proposes to build, own and operate the 98-mile Falcon Ethane Pipeline Project in Ohio, Pennsylvania and West Virginia. The Project would connect three sources of ethane in Ohio and Pennsylvania to a planned petrochemical plant in Monaca, PA. More than 43 miles of pipeline would be located in the Ohio counties of Harrison, Carroll and Jefferson. Pipeline construction and operation would affect more than 550 acres of soil and water resources. Shell estimates that while 1,000 workers (who would likely come from the Gulf Coast and other locations that are far removed from the Ohio Valley) would be necessary to construct the pipeline, only 8-10 permanent jobs would be directly created by the Project.

Ohio and our neighbors have already been negatively affected by pipeline spills and other incidents associated with the petrochemical industry. For example, in November 2017, Ohio EPA cited Rover Pipeline, LLC for spilling contaminants into the Black Fork of the Mohican River. In March 2018, the Pennsylvania Department of Environmental Protection (DEP) issued the 40th Notice of Violation to the owners and operators of the Sunoco Mariner pipeline. Shell’s proposed Falcon Project will also result in adverse long term and short term impacts on water quality in the states where it is built and operated.

Surface Water

The Project should not be permitted to change the quality or characteristics of any wetlands. As proposed, the Project would result in the impermissible loss of both wetland acreage and functions.

Shell’s Preferred Design Alternative would cost an estimated $80-90 million, a Minimal Degradation Alternative would include 18 Horizontal Directional Drill (HDD) crossings at a cost of $90-100 million, and Shell states that while the No Degradation Alternative is technically feasible, it is cost prohibitive at more than $2.7 billion. Shell does not present an alternative to the Project that includes more than 18 HDD crossings but that costs between $100 million and $2.7 billion.


While HDD crossings may sometimes be preferred to surface crossings in order to minimize impacts to surface waters, HDD crossings have a potential to negatively affect groundwater resources, especially in areas with limestone karst. Additional information and/or studies related to the proposed HDD crossings are necessary before Ohio EPA and the public can adequately analyze Shell’s application.

Aquatic Wildlife

While some landscape features might feasibly be restored to a degree of pre-construction conditions, local populations of sensitive and native wildlife species may be permanently affected or even eliminated by the Project. Shell’s application does not include an adequate analysis of impacts to aquatic wildlife.

Cumulative Impacts

The Project is anticipated to be one component of a vast petrochemical network that would stain and scar our Ohio Valley for generations, yet only 7.5 miles of the Project are expected to be colocated with existing utility right-of-ways. The public must be afforded the opportunity to examine Shell’s application in the context of other petrochemical projects that may be constructed in the region.

Request For Public Hearing

There is significant public interest in a public hearing regarding this Project. Pennsylvania DEP will hold at least three meetings to elicit public input about the project, but Ohio EPA has not planned a single public meeting in our state. We have requested that Ohio EPA schedule at least one public meeting in Harrison, Carroll and/or Jefferson County immediately.


Shell’s application does not include a reasonable alternative to the proposed Project. Shell has failed to adequately analyze the potential impacts of its proposed Project, including impacts from the Project’s operations. Because Shell’s application cannot demonstrate that the Project would comply with state regulations for ensuring the maintenance of existing uses or compliance with water quality standards, because Shell has failed to provide Ohio EPA and the public with a complete application for review, and because the public has not been afforded an adequate opportunity to participate in the water quality certification process, Ohio EPA should deny Shell’s application for a permit under the federal Clean Water Act.