WWALS Watershed Coalition

WWALS Watershed Coalition, Inc. (WWALS) is Suwannee RIVERKEEPER® WWALS advocates for conservation and stewardship of the surface waters and groundwater of the Suwannee River Basin and Estuary, in south Georgia and north Florida, among them the Withlacoochee, Willacoochee, Alapaha, Little, Santa Fe, and Suwannee River watersheds, through education, awareness, environmental monitoring, and citizen activities.



Thanks to WWALS member Janet Barrow for filing this document with FERC.




To Whom It May Concern:


PHOTO IS NOT MP 252:  In reviewing the latest Sabal Trail Monthly Report, Sabal Trail presented false information to the FERC. In their Monthly Report for October, 2017 (Accession Number 20171107-5073) Sabal Trail entitles a photo of a flooded wetland “Spread 4: MP 252.00 (wetland, facing South).” If Sabal Trail’s April 7, 2016 Alignment Sheets are correct, there is no way this photo is for MP 252, since MP 252 is in a cleared crop field that has had a center-pivot irrigation system in it for decades.

I recalled the Sabal Trail Monthly Report for August, 2017 (Accession Number 20170911-5088), where Sabal Trail has one photograph labelled “SP4 MP-349.8 flooded WL.” I can see that the August, 2017 MP 349.8 location is one-in-the-same with the location described as “MP 252” for the photo in the Monthly Report for October, 2017. This makes me wonder if Sabal Trail is being deceptive, incompetent, careless, or all three!

PHOTO IS NOT FACING SOUTH:  Further into the Monthly Report for October, 2017, Sabal Trail has a photograph they call “Spread 5: MP 383.00 (facing South.)” There is no way that photograph can be facing South. If you are standing on the Sabal Trail easement at a fence in the pastures we call Lancala Woods, where MP 383 is located, the nearby line of trees will be on your right if you are looking to the South, not on your left. Again, is Sabal Trail being deceptive, incompetent, careless, or all three? Perhaps their employee does not know North from South, although with the sunshine we have in Florida, it is generally pretty easy to figure out if you know the time of day. The photo was taken on a sunny Florida day. Perhaps the Sabal Trail employee just does not think accuracy or detail matters. As citizens who live and work near these dangerous high-pressure gas pipelines, we think accuracy and detail matter!

MANY PHOTOS INACCURATELY LABELLED:  Checking the Monthly Report further, I find that Sabal Trail repeatedly states that their photos are taken facing South, yet in many cases I know this cannot be true due to certain features in the photographs. For example, I know the photo taken by Sabal Trail for MP 406 is facing to the East, and it does not show the MP sign at all. If you go to the field, which I did, the milepost marker looked like it was a half mile or more beyond where they took the photo at that gate, which is inaccurate according to the April 7, 2016 Alignment Sheets.

SLOPPY WORK OR DECEPTION? HOLD SABAL TRAIL ACCOUNTABLE.  If Sabal Trail cannot be trusted to provide FERC accurate information in their Monthly Reports and other documents, and FERC does not hold Sabal Trail accountable to tell the truth, and FERC permits this slipshod reporting by Sabal Trail, how can the public trust either Sabal Trail or FERC to operate this pipeline in a safe manner?


Here is the Alignment Sheet for MP 252.0. MP 252.0 is in a 70-acre crop field with about 56 acres under a center pivot irrigation system. It is ridiculous to believe that the photo called “Spread 4: MP 252.00 (wetland, facing South)” in Sabal Trail Monthly Report for October, 2017 is MP 252.0.

Here is the Alignment Sheet for MP 349.8. MP 349.8 is just South of Hwy 27 as the pipeline continues into what remains of what was once a cypress pond and pine stand.


Here are some photos that were taken by Sabal Trail and submitted in the August and October Monthly Reports and some of my own photographs of MP 349.8 (where Sabal Trail has placed a marker sign that says “MP 350.”) Again, this MP 349.8 / MP 350 is located on the South side of Hwy 27 near Bronson, Florida, where Sabal Trail cleared part of a cypress pond and drilled under Hwy 27 to place their 36” gas pipeline.

Here is the Sabal Trail photo in the Sabal Trail Monthly Report for October, 2017, claiming to be “Spread 4: MP 252.00 (wetland, facing South).”

Obviously the photo is not in the MP 252 crop field, so where was that photo taken? I say that it was taken on the South side of Hwy 27 near Bronson, Florida, where Sabal Trail drilled under the highway and put their pipeline through a cypress pond and pines next to power lines – MP 349.8 / MP 350.

Here is the Sabal Trail photo submitted in the Sabal Trail Monthly Report for August, 2017, correctly claiming to be “SP4 MP-349.8 flooded WL.” I agree that this photo is MP 349.8. Notice how similar the previous photo and the following photo are. Water levels differ because that is the nature of Florida wetlands, and I presume that Sabal Trail employees took these photos at different times.

I have also taken photos of this site (MP 349.8) at different times. Compare my photos, which I know are photos of the South side of Hwy 27 where the Sabal Trail pipeline crosses near Bronson, because I took the photos. I even returned to this site on November 8, 2017 to take photos to compare to the Sabal Trail photos.

In this photo of mine, you see Sabal Trail’s pipeline marker sign, and you can also see that the tree line and water and silt fence match the Sabal Trail photos.

On November 8, 2017 when I was at MP 349.8, I used my zoom on my camera to get a photo of the silt fence in the distance. Like all the silt fence Sabal Trail abandoned throughout Florida, it is falling down and the weeds are growing into and over it. I also took a screenshot of the Sabal Trail photo which claims to be MP 252. When I zoomed into the screenshot to see the silt fence, guess what – the contours of where it is falling down match my photo which I took looking South from MP 349.8. No surprise to me! Has anyone at FERC noticed that the photo Sabal Trail claims is MP 252 is actually MP 349.8?

Look at the silt fence contour in the Sabal Trail photo of what they claim is MP 252. It is NOT  MP 252.

Now look at the silt fence contour from my photo, which I took looking South from MP 349.8 on Nov. 8, 2017.


As I previously stated, there is no way that the Sabal Trail photograph for MP 383 in the Monthly Report for October, 2017 was taken facing South. If you are standing on the Sabal Trail easement at the cross-fence in the pastures we call Lancala Woods where MP 383 is located, any line of trees on your left would be 850 feet from the pipeline corridor, so it would NOT appear like this in a photograph taken facing South. (There is a line of trees adjacent to the pipeline corridor, but it is on your right if you are looking to the South, not on your left.) In Sabal Trail’s photo, which they claim is facing South, the tree line is on the left. Impossible. I can also tell by the trees in the distance, the brace-post, and some other tell-tale signs, but how would FERC know? Well, they could look at the short shadow cast by the pipeline marker sign and they would know that if this photographer took the photo in Florida, he is not facing South.

The photo below is Sabal Trail’s photo.

The following is a true photo of MP 383, and this really facing South. The line of trees along the pipeline route is on the right and another line of trees is in the distance. The brace post and gate are to the right (west) of the pipeline marker sign.

Perhaps FERC will dismiss these careless deceptive erroneous inaccurate falsehoods, but they shouldn’t. If the FERC does not hold Sabal Trail to a reasonable standard when it comes to honesty and accuracy, the public cannot have confidence in either Sabal Trail or the FERC, especially for protecting our safety.


Just look at a few other photographs in the Monthly Report for October.

Sabal Trail claims that the photograph for MP 397 is facing South, but if you look at the photograph, you are looking down the power lines, which run East and West there. Sabal Trail lied.

Sabal Trail claims that the photographs for MP 400 and MP 401 are taken facing South, but that does not make sense, because when you look at the photograph, you are looking down the pipeline corridor, which runs East and West in that area for 5 miles there. The fence and a road sign are on the right of the pipeline corridor in the photographs of MP 400 and 401, so these photographs were taken facing West on the Marion Mitigation land. Sabal Trail again lied.

Sabal Trail claims that the photograph for MP 406 was taken facing South, but it could not have been taken facing South. The gate at that location is oriented North-South, and the photo was taken looking across the gate. The photograph was taken facing East. According to the April 7, 2016 Alignment Sheets, that gate is at MP 406.1, yet the MP 406 marker sign is at least a half a mile further along the pipeline corridor, maybe more. That stretch of pipeline is a straight line heading East for about two miles to where the power lines head Southeast and the pipeline takes a turn. Sabal Trail again lied.

When I took a photograph from the gate (MP 406.1 by the Alignment Sheets), I used my zoom on my camera, and you can read the MP 406 marker sign and see the power lines in the photo. This is my photo where I zoomed in to MP 406. Notice that there is no gate there, but there is wetland and you can see the power line in the distance. It looks very different from what Sabal Trail presented in their Monthly Report, doesn’t it!

While misstating the orientation of these many photographs may seem like a minor thing, it represents something bigger. Sabal Trail repeatedly presents false information to the FERC, and it seems to the public like the FERC is just RUBBER-STAMPING everything that passes through their offices with regard to Sabal Trail (and other) pipeline(s). I have seen much more egregious errors and omissions pass through the FERC on behalf of Sabal Trail pipeline over the past four years of permitting and approval for Sabal Trail. FERC is failing to administer the conduct of the regulated company, Sabal Trail, LLC.


I have to admit that I am amused by the photograph of the Citrus County Line MP 20. The cattle are doing what cattle do everywhere pipelines and pipeline markers are put in their fields. They tear them up. Notice the bent pipeline marker post next to the calf in this photograph.

The following photos are several that I took of where cattle have damaged the Sabal Trail pipeline markers. All of these photos were taken in less than 6 miles of the Sabal Trail pipeline, and they just lay there in the field for weeks or months, and Sabal Trail does not repair them or secure them. What is the function of these markers other than showing pipeline workers where the route is? Some had the caps knocked off and there were wires exposed. It sure looks bad for the public to see how the visible reminders of Sabal Trail pipeline are pushed into the dirt by animals, and Sabal Trail neglects to fix them. I hope these are not critical to the “safe” operation of the pipeline. Now, tell me, what is the function of those wires? Cathodic protection, perhaps? Safety monitoring? They aren’t for decoration.


What kind of marker is this one? Is it a test station? Is it part of the cathodic protection system? What kind of damage does it do when the cattle break the end-cap off of the marker post?


Sabal Trail called this wetland W2ECT194. Sabal Trail excavated the clay hardpan, put in the pipeline, built a road through the wetland, and now it is dry, in spite of the rains and hurricane we had. The contour of the land has changed, and the wetlands around here are fractured by the pipeline and road they created. The Florida sandhill cranes (Listed Species) that have frequented these ponds for decades are noticeably absent since Sabal Trail started construction. So is the water.

The following photos tell a story about the wetland Sabal Trail called W8ECT117 and its “restoration.” Look at it now, verses how it looked when Sabal Trail began construction.

This is the west berms Sabal Trail needlessly built in what they call W8ECT117. It totally corrupts this pond, but then, so does the pipeline. These berms should be removed. This area has a very gentle slope, and there is no need for these berms.

This is the east berm at W8ECT117 looking west into the pond, now dry and full of weeds.

This is W8ECT117 on March 14, 2017, during Sabal Trail construction. Even in the drought, there was water.

This is W8ECT117 on March 2, 2017. It was not full of the 6-10’ tall weeds that it now has. I call this photo, the “Sabal Trail Rape of the Wetlands.”

This is W8ECT117 on Feb. 22, 2017. Again, you can see that there were not weeds 6-10’ tall back then. The pond held water, which can be seen behind the Ecobags, if you zoom in.

W8ECT117, Jan. 7, 2017. There were no 6-10 foot weeds in the pond then, like there are now.

Until Sabal Trail started construction, this heron had been spotted daily for years in the wetland that became known as W8ECT117. It is gone. I have not seen it since Sabal Trail construction began.

No, FERC and Sabal Trail, restoration is not satisfactory. Your promises that everything would be the same as before and we wouldn’t even know you were there are empty promises and lies.

See the poor grass cover over pipeline route (which is through the middle of the photo from left to right, in case it is not obvious to city-folk.) Note the erosion. This is near MP 382.4. (The top of the hill and the bottom of the photo where the grass is growing well are NOT within the Sabal Trail easement. That is what the entire are should look like, and it would, if Sabal Trail pipeline did not bisect this ranch.)

In the foreground is an area of erosion due to pipeline construction and failed restoration. The background where grass is growing well is pasture that was not within the Sabal Trail easement. This is near MP 382.4.

Sabal Trail “restoration” looking North from approximately MP 381.4.

Photo looking to the South from approximately MP 381.4. It is easy to pick out the pipeline corridor, isn’t it!

Close-up of the poor “restoration” near MP 381.4. This will get worse over the winter dry season.

On Nov. 8, 2017, I decided to visit Levy County and check the restoration there, since Sabal Trail doesn’t seem to know the difference between MP 349.8 and MP 252. Here is the MP 349 marker.

Here we find some more bare ground. There are native wetland plants that Sabal Trail could have sprigged and planted in there to establish some cover, but that would have cost them time and money. How long does Sabal Trail leave the “Wetland Boundary” signs and the black plastic silt fence in the wetlands? The sand will bury it. Their silt fence is falling down.

Weeds and poor ground cover; black plastic; “X” marks a spot on Sabal Trail pipeline.

More inadequate revegetation, and we are going into the dry season of Florida winter. Does anyone at FERC take the Environmental Condition # 9 seriously? Poor revegetation at MP 353 is typical of what is seen on the Sabal Trail route.

Neglected silt fence on the Sabal Trail route.

Weeds and poor restoration on the Sabal Trail route.

Abandoned silt fence, bare ground, and a lot of weeds on the Sabal Trail pipeline route.

This is some of Sabal Trail’s abandoned black plastic. It was never removed, and it has fallen flat, torn, and weeds are growing all around it and through it. Disgusting!

More Sabal Trail handiwork – weeds, bare sand, and abandoned black plastic. At least a few native bluestems are going to seed on the edges of the pipeline easement. Maybe the native bluestems will do a better job of seeding the pipeline route than Sabal Trail did.

What good does this do? It just trashes up the rural lands of Florida. How many thousands of miles of black plastic trash was created for this project? Isn’t plastic made from fossil fuel? Did Sabal Trail recycle all the black plastic they did remove? Is nature going to have to recycle what they did not remove? Did the miles of black plastic end up in Florida landfills?

More poor revegetation and abandoned plastic silt fence. Again, the vegetative cover will get worse over the coming dry season, and the plastic will deteriorate in the field.

Looks like a little erosion or minor subsistence starting on this bare (poorly restored) site, typical of what is seen in the Florida sand hill areas that Sabal Trail excavated.

MP 356 will also get a lot worse in the months to come, as we are entering our dry season in Florida.

Sabal Trail pipeline crews left their calling card in these unfortunate people’s yard – a weedy mess surrounded by abandoned black plastic.

Who wants to live near a pipeline?

More signs along the pipeline route. Pipelines affect people’s lives and their real estate values and sales.

Here is a little free advertising for the poor soul that owns this land on the power lines and the Sabal Trail Citrus County Line gas pipeline. (This is Citrus County, not Levy County, but the real estate issues are everywhere that gas and oil pipelines condemn private property.)

Now back to Levy County. Do they really still need these access roads, or did they just neglect to remove their sign?

Here is another abandoned Sabal Trail pipeline sign. Price Gregory did not bother to take it down. This one is in Marion County.

This is how the locals feel about Sabal Trail pipeline coming through their rural lands. (Although this is in Levy County, the feeling is the same throughout the pipeline route.)

One little millet plant is all that remains from the Sabal Trail “restoration” here. This is in Marion County, near the Marion – Sumter County Line.

Sabal Trail “restoration” is inadequate in Marion County, too. Pathetic!

This is a view from MP 405.6 (using the April 7, 2016 Alignment Sheets), looking North over the water body that was never given a reference number on the alignment sheets. I took this photo on November 13, 2017. There were bubbles coming up in the little water body. Let’s hope they were from natural causes, not natural gas causes.

In this area three holes formed in a straight line, each about a hundred feet from the other. It is minor subsistence now, but perhaps the soil around this section of the pipeline was not packed well, or perhaps there is something going on underground. This is a highly karstic area. Three holes in a row in the direction of the pipeline indicate that it is related to the previous digging for the pipeline.

There is no good reason for this mess to still be on this property.


This gate is at MP 406.1 (according to the April 7, 2016 Sabal Trail Alignment Sheets.) This is the gate Sabal Trail called MP 406, but the MP 406 sign is around the bend and much further down the corridor. According to another report, there was a “dig-up” between MP 406 and MP 406.1. Which MP 406-406.1 is it? Was it before this gate or was it down by where Sabal Trail put the MP 406 sign?

Facing South, approaching MP 406 (according to the April 7, 2016 Sabal Trail Alignment Sheets.) Was the dig-up here?

Or was the dig-up here?

Or was it here?

Ah, it was here:

I figured this one out.

I hear that they hit a rock and damaged the pipe, although some folks say they hit a cavern. That may be another location, though.



It will be a long time before rehabilitation and restoration of the right-of-way and other areas affected by the project are proceeding satisfactorily. Do not sign off on this restoration prematurely.


Sabal Trail Citrus County Line, W. Amman Street.


Sabal Trail Citrus County Line, W. Hunterhill Street.

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If FERC fails to impose the Environmental Conditions regarding restoration of the pipeline easement and hold Sabal Trail accountable, the easement will look like the Duke Energy power lines, which are collocated with the Sabal Trail Citrus County Line.  


Sabal Trail Citrus County Line is just over the hill from this barren dune, which is under the collocated Duke Energy power lines. If the Citrus County Line restoration fails, and it becomes like this adjacent dune, that sand will shift in the wind, risking shallow cover or exposure of the pipeline, creating an even more unsafe situation.


“7. Beginning with the filing of their Implementation Plans, the Applicants shall file updated status reports with the Secretary on a biweekly basis until all construction and restoration activities are complete. On request, these status reports will also be provided to other federal and state agencies with permitting responsibilities. Status reports shall include:

“a. an update on the Applicants’ efforts to obtain the necessary federal authorizations;

“b. the construction status of each spread, work planned for the following reporting period, and any schedule changes for stream crossings or work in other environmentally-sensitive areas;

“c. a listing of all problems encountered and each instance of noncompliance observed by the EI(s) during the reporting period (both for the conditions imposed by the Commission and any environmental conditions/permit requirements imposed by other federal, state, or local agencies);

“d. a description of the corrective actions implemented in response to all instances of noncompliance, and their cost;

“e. the effectiveness of all corrective actions implemented;

“f. a description of any landowner/resident complaints which may relate to compliance with the requirements of the Order, and the measures taken to satisfy their concerns; and

“g. copies of any correspondence received by the Applicants from other federal, state, or local permitting agencies concerning instances of noncompliance, and the Applicants’ response.”

MY COMMENT:  Contrary to Environmental Condition 7, Sabal Trail switched from Biweekly Reports to Monthly Reports, yet restoration is not complete. Sabal Trail has been deceptive in their Reports. They provide false information, distort the real conditions of the restoration, and omit problems they have encountered from their reports. Descriptions of landowner/resident complaints and measures taken to satisfy their concerns are often vague, and in some cases they are never reported. I personally called Sabal Trail Construction Hotline and made complaints to Sabal Trail via this and other channels, and those were not reported in the Biweekly Reports, even though in some cases I specifically told them I wanted the issues reported. Sabal Trail restoration efforts show continuing problems, and they are far from complete. In many areas the restoration job appears to have been neglected and abandoned, as evidenced by fallen, crumpled, torn, buried black plastic silt fence that has weeds growing around and even through it. Sabal Trail’s restoration reports are distorted and biased, and they fail to present a fair representation of how restoration is proceeding.


“9. The Applicants must receive written authorization from the Director of OEP before placing each phase of their respective projects into service. Such authorization will only be granted following a determination that rehabilitation and restoration of the right-of-way and other areas affected by the project are proceeding satisfactorily.”

MY COMMENT: Sabal Trail’s rehabilitation and restoration of the right-of-way is NOT proceeding satisfactorily.


14. Prior to construction, the Applicants shall each provide a plan describing the feasibility of incorporating plant seeds that support pollinators into the seed mixes used for restoration of construction workspaces. These plans shall also describe the Applicants’ consultations with the relevant federal and/or state regulatory agencies. (Section 3.5.8)

MY COMMENT: I have seen no effort by Sabal Trail to incorporate pollinator plants into seed mixes and in restoration. Sabal Trail has not complied with Environmental Condition 14. Was Environmental Condition 14 just a paperwork exercise? I had submitted comments to FERC when Florida Southeast Connection attempted to get out of meeting Environmental Conditions 9 and 14. See FERC Accession Number 20170531-5025.


20. Prior to construction, Sabal Trail Transmission, LLC shall file correspondence from the applicable Florida National Scenic Trail (FNST) trail manager(s) (e.g., U.S. Forest Service) regarding the final crossing plans and construction and restoration methods for the designated segments of the FNST crossings at Mainline MPs 267.3R and 384.9. (Section


What was MP 384.9 in Appendix B, Volume 2 is now MP 387.9 in the April 7, 2016 Alignment Sheets. Here are some photos of that site (looking South onto the Florida National Scenic Trail) taken on Nov. 18, 2017.

Looking onto the Sabal Trail pipeline easement at the Florida National Scenic Trail crossing. This “restoration”

Sabal Trail isn’t putting pictures like this in their Monthly Reports, are they?

A close of view of the poor excuse for “restoration.”  The actual trail can be seen next to the pipeline marker in this photo.

Halpata Tastanaki Preserve is supposed to get native plant and pollinator restoration, too. It is not going well.

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This was MP 393 (facing Southwest) on Jun. 26, 2017, where initial plantings of wiregrass and other native plants had largely died. The sparse green grass is a non-native annual Sabal Trail planted.


This was MP 393 (facing Southwest) on Nov. 16, 2017, where subsequent re-plantings are still struggling.


This is looking down the pipeline right of way at MP 393 (the Halpata Tastanaki Preserve SR 200 entrance) on Nov. 16, 2017. Native plant restoration is not going so well.

At the base of the poles is evidence of recent re-plantings – seedling trays.


According to FERC’s website, https://www.ferc.gov/about/ferc-does.asp , FERC has, among other things, the following responsibilities and duties (emphasis using italics  is mine):

  • Administers  accounting and financial reporting regulations and conduct of regulated companies .
  • Promote Safe, Reliable, Secure,  and Efficient Infrastructure
  • Mission Support through Organizational Excellence

By ignoring the deceptive conduct of Sabal Trail in their Monthly Reports, FERC is failing to administer the conduct of this regulated company.

By overlooking deceptive, false statements as well as errors and omissions, FERC is failing in its duty to promote a safe, reliable, secure infrastructure.

FERC has failed to exhibit organizational excellence.

I am publicly calling for FERC to stop being a rubber-stamp agency for the gas and oil industries and do your duties to act on behalf of the American People. Open your eyes! Read and scrutinize the documents Sabal Trail submits. Question what they are telling the FERC. Check up on them. Hold Sabal Trail (and other regulated companies) accountable. Bring integrity and organizational excellence to your agency so the public can have greater confidence in our infrastructure.

Even the US District Court has found that the FERC failed to properly do its job, in this case with the calculation of greenhouse gas emissions for Sabal Trail pipeline. FERC has earned its reputation as a rubber-stamp agency for the gas and oil industry by its widespread failures, from overlooking the accuracy of construction reports to failing to properly write the Environmental Impact Statements. FERC doesn’t work. FIX IT!

I understand why our country is having so many leaks, explosions, and pipeline failures. The pipeline companies cut corners and the oversight is deficient. The citizens who are forced to live and work by the pipelines are the first to pay the price. That is why I have taken the time to write this brief  Citizen’s Monthly Report to begin to bring notice to the shortcomings of the “official” Monthly Reports Sabal Trail submits. Believe me, I have plenty more I could say, but this is a start.


Janet Barrow