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Dear Secretary Bose:

I oppose the construction of the proposed RH Energy Trans LLC, Risberg Pipeline Project ("Project") due to the contractor selection of Elkhorn Construction by RH Energy Trans LLC ("RH Energy").

I have several concerns about the installation of this nearly twenty-eight (28) miles of new pipeline and related equipment throughout Pennsylvania, as well as, Erie and Ashtabula Counties in Ohio. RH Energy engaged local community members by promoting its intent to employ a "local" contractor and workforce to build the proposed Project. The Project was awarded to Elkhorn Construction, a Wood Group owned company, based in Evanston, Wyoming. As a result, there is a serious question about RH Energy’s commitment to the local community and the promised benefits to local businesses.  

I am also concerned about the lack of pipeline training of this workforce. For example, Pipeliners Local 798 spends hundreds of hours each year training members in all aspects of pipeline construction and welding safety. It is clear Local 798 is committed to ongoing apprenticeship and training programs, making them the most qualified, highly skilled and safest option for this proposed project. Because Elkhorn Construction does not list or even advertise safety as a priority of their operations, there is also a serious question about its commitment to safety.

In addition to pipeline training, environmental responsibility is also a critical consideration in the construction process. Construction of the pipeline would affect about 242 acres of land for above-ground facilities, access roads and the line itself, according to the FERC documents. Once the pipe is in place and operational, RH would retain about 171 acres “for permanent operation of the project’s facilities.” When it comes to respecting the environment, Local 798 members are trained on how to perform tasks while also caring for the surrounding environment. For example, this labor force is educated in the identification of different types of soil and the importance of keeping them separate during the construction and remediation processes. The environmental impact surrounding this Project is extremely important to our members because it is literally in the backyards of their family and friends. Local 798 members treat the land as if it were their own during all aspects of the construction process.

Because Elkhorn's employees lack a local connection and personal interest, there is a real risk that they will cut corners during the construction of this Project. Once completed, their workforce will return home not caring about the future impact of this large scale Project or the local residents.

I forcefully oppose the building of this Project by an out­-of-state contractor who does not utilize an Ohio or Pennsylvania workforce. I strongly encourage the FERC, and all associated regulators, to look into this matter and help support the real local workforce, by creating pipeline jobs throughout Ohio and Pennsylvania.