We know that there is no way for Williams/Transco to build NESE’s pipeline and compressor station without threatening our water quality, threatened & endangered species, and wetlands.   We will continue to fight this dangerous and unnecessary project to the end.   

The NESE Project has been stopped twice in New York and three times in New Jersey when prior applications for permits were withdrawn and/or denied.  Now, following the 4^th set of applications in January 2020, it’s time for the NJDEP to deny the permit applications with prejudice (a.k.a. “for good”).  YOUR COMMENTS ARE NEEDED!

Many of the concerns of people in NJ & NY have been heard, and they need to be voiced again about the 2020 permit applications.

NJDEP has issued a comment period for the January 2020 applications that ends on April 6, 2020 at 5PM.  

NJDEP has until May 6, 2020 to issue their decisions about the permit applications.

TO DO NOW

1) Submit your comment in opposition to the project today via these easy online links where the letter is already written, and you just need to add your identifying information + any additional comments you’d like.

2) Attached are sample written comments/points that are relevant to the NJDEP’s current review of applications as well as political points (such as climate change impacts).

Recommendations

1. Write separate comments for each topic or point.
   • Using the attached comment statements, you could do a “word search” for a topic or concern of interest to you.
   • On the next page is a list of the attached comment topics with provided information.
2. Choose points from what is provided on the attached comment ideas/points & use them to create your own individual comments by copying/pasting what you want to use into a Word document and adding to it.  Save it.  
3. Include your full name and address at the end of all comment letters.
4. Send each comment as an attachment (the Word document or that document saved as a PDF) via email to NESEcomment@dep.nj.gov
5. Send your comments to the following people in NJDEP & the Governor, too, by email.  Emails are listed below so that you can copy & paste them into your email.  You could also copy your local State Senators and Representatives.  
   • Commissioner@dep.nj.gov
   • Ruth.Foster@dep.nj.gov
   • Christopher.Jones@dep.nj.gov
   • Diane.Dow@dep.nj.gov
   • Ginger.Kopkash@dep.nj.gov
   • Constituent.relations@nj.gov 
6. For the Subject of your email, copy & paste this into the space – Transco NESE Comments

You’re sending Comments on NESE – Program Interest # 0000-01-1001.3; Activity #: LUP 200001

Comment Topics – Elaborated Points are in the attached documents.

COMMENT 1: Construction of the NESE Project threatens water quality, increased stormwater flooding, and threatened & endangered species.

• Construction of a stormwater basin at the proposed Compressor Station 206 site does not include complete plans that account for the specific soil type that exists there.
• Impacts to the habitat for the State threatened barred owl as well as protected vernal pool habitats at the proposed Compressor Station 206 site were not adequately assessed or avoided.
• Construction Schedule of the Raritan Bay Loop was reduced from 12 months to 7 months.
• A shortened timeline increases the intensity of work, so the overall impacts will be magnified.  
• Noise Impacts from Pile Drivings – It is not clear if the construction schedule for these activities has changed with the compressed construction schedule for the Raritan Bay Loop, but their requests for harassment permission have increased.
• Dredging up toxics has not been avoided by construction of the Raritan Bay Loop, and this will likely cause long-term harm that was not accounted for in the applications.
• To reach a conclusion that the impacts on water quality would be short-lived, temporary and localized neglects to consider the unusual tidal flows in Raritan Bay, the chain-reactions from destroyed habitat and food sources for marine life, and the contamination of food sources for marine life and people.
• NESE’s Raritan Bay Loop’s Undisputed, Devastating Impact on Shellfish Beds and Benthic Communities 
• Williams/Transco has not sufficiently identified permanent, temporary, and secondary/indirect impacts from onland construction, and they have not shown plans to avoid and/or mitigate these impacts.
  • Acid Producing Soils
  • Construction through or near Superfund Sites & other toxic sites

COMMENT 2: Williams/Transco did not demonstrate a “compelling public need” for the NESE Project that meets requirements of NJ’s Freshwater Wetlands Protection Act Rules at N.J.A.C. 7:7A-10.4 or, alternatively, demonstrate an extraordinary hardship from denial of a permit.

The NESE Project does not serve an essential health or safety need of the municipality in which it would be constructed, and its proposed use does not serve existing needs of residents of the State.  

• Air Quality & Health Impacts
• Safety Risks – Fires or Explosions

Additionally, the “need” for the NESE Project has been refuted by reports, and the needs of the State that are currently focused on fighting climate change impacts would be harmed by the NESE Project despite claims by Williams/Transco about “benefits” to New Jersey.

COMMENT 3: NESE is not in the Public Interest.

• Need to preserve natural resources
• Relative extent of the public and private need for the regulated activity
• Practicability of using reasonable alternative locations and methods
• Economic value
• Ecological value of the freshwater wetlands and probable impact on public health and fish and wildlife.  

COMMENT 4: Contaminants that would be unearthed, suspended and redistributed in the Raritan Bay exceed “acceptable” levels.  Exceedances were found by the NYSDEC for heavy metals (copper & mercury) in New York waters, too.   Thus, construction of the Raritan Bay Loop of the NESE Project would (a) negatively impact surface water quality, and (b) harm threatened and endangered species and their habitat.

Additionally, the shortening of the in-water construction schedule raises serious concerns about impacts from increased vessel traffic and noise as well as adhering to time-of-year restrictions to protect threatened and endangered species if the schedule needs to be altered due to unforeseen circumstances.

Furthermore, the unique tidal flows in the Raritan Bay do not seem to have been given appropriate consideration.

COMMENT 5: Other Concerns about In-Water Construction

• Time of Year Restrictions
• Thermal Discharges

COMMENT 6: There is a Questionable “Need” for additional natural gas in National Grid’s NY area.

COMMENT 7: There is no real consideration of climate crisis-mitigating renewable alternatives by the Federal or State agencies.

Additionally, the impact of the NESE Project on climate change effects should be considered in light of the threats facing New Jersey as well as the State’s goals to reduce greenhouse gases.