Category: NESE

Send comments to the NJDEP

  • Commissioner Catherine McCabe: Commissioner@dep.nj.gov
  •  Director Ruth Foster: Ruth.Foster@dep.nj.gov

Williams/Transco submitted new applications for water permits (Freshwater Wetlands, Flood Hazard Area Control, Coastal Wetlands, & Waterfront Development) on June 19, 2018.

  • Tell NJDEP that you want them to hold two (2) public fact-finding meetings – one by the Raritan Bay (Old Bridge / Sayreville) and one by the proposed Compressor Station 206 area (Franklin Township / South Brunswick).
  • Tell NJDEP that you expect them to deny the permits unless they obtain and carefully review all needed information and actually find that the proposed project would not cause harm to the environment, people or wildlife.
  •  Tell NJDEP that an increase in reliance on fossil fuels for energy does not support New Jersey’s goal to transition to renewables and clean energy.

Sign the letter to NJDEP and either mail it or give it to a member of the Task Force to mail
Click here for link to the letter to print, sign & mail

NOTE: A request for fact-finding meetings needs to be in writing to NJDEP and received in Trenton by August 3.

Keep sending comments to FERC

Send comments to FERC that request a “reset” for the DEIS by asking them to publish a revised/supplemental DEIS that addresses all new information and all concerns of the public. Tell FERC that the March 23, 2018 DEIS was missing critical information, dismissed comments of the public & elected officials, and lacked supportive studies or data for FERC’s conclusions. Additionally, Williams/Transco submitted thousands of pages of new information and reports that needs to be reviewed and analyzed in a document that FERC publishes during the time period when the public can truly provide meaningful comments. These submissions were in May and June 2018 – after the DEIS was published & after the end of the “official” time period for sending comments to FERC.

FERC claims that they consider ALL comments they receive. Many people need to let them know that the DEIS was not acceptable.

SEND COMMENTS TO FERC NOW, AND COPY NJDEP.

The DEIS was incomplete & misleading.  Tell FERC that you want a revised or supplemental DEIS and an additional comment period of at least 45 days.

When you send a comment to FERC, also forward that comment to the NJDEP –

  • Commissioner Catherine McCabe: Commissioner@dep.nj.go
  • Director Ruth Foster: Ruth.Foster@dep.nj.gov

You can also forward your comments to your elected officials and ask them to support the opposition to NESE.

Action Alert – Tell NJDEP and FERC about new concerns.

Dear Fellow Concerned Opponents of the NESE Project,

Thank you for sending comments to FERC and raising your voices about the proposed dangerous Northeast Supply Enhancement (NESE) Project!  Though FERC listed May 14 and the official final day to file to be an intervenor & send comments, FERC does continue to review comments submitted after then.  Since the DEIS was incomplete and misleading, we still believe it is important to let FERC know that as well as let them know that we need a revised or supplemental DEIS that incorporates the thousands of pages that Williams/Transco sent on May 11 & May 30.  We have a right to participate in this environmental review process in a meaningful way, and that should include time to review all critical information. 

Letting FERC gather extra information and then publish it, along with their “independent evaluation & analyses” in the final EIS is not acceptable since the time for true public engagement is after the DEIS. That’s why we’re pointing out the issues and asking for a revised or supplemental DEIS to be published by FERC with an additional comment period of at least 45 days.

REQUESTED ACTION:  SEND MORE COMMENTS TO FERC

Please take one or more of the attached comments and send them to FERC.  They are all short enough to go “as is” as eComments.  Feel free to copy/paste ideas from different comments to generate new ones.  Each of the eComments starts with a bold ISSUE:  and ends with the same paragraph.  Just copy one comment at a time to send in.

If you are an intervenor, you can use the other set of comments that have bullets and numbers by saving one as a PDF and then using eFiling to upload the PDF comment.  That preserves the formatting, and there’s no length limit for eFiling.  You just have to be registered with FERC (where they gave you a FERC ID #).  Being an intervenor means that you are already registered.

eFiling comment samples

(save as PDF to upload to FERC)

eComment samples

(6,000 characters or less)

1

Public denied opportunity for meaningful commenting – missing information, NYSDEC denied permit, FERC dismissed comments, shortcomings of DEIS

1a

 

Incomplete DEIS & data dump – missing information + Incomplete DEIS

1b

Incomplete DEIS & data dump – shortcomings of DEIS

2

Public denied opportunity for meaningful commenting (different format)

2

Public denied opportunity for meaningful commenting

 

 

3a

FERC disregarded / dismissed comments: list

3

FERC disregarded comments: safety analysis of increased velocity of gas in pipeline

3b

FERC disregarded comments: safety analysis of increased velocity of gas in pipeline

4

FERC disregarded comments: air monitoring directly at CS206

4

FERC disregarded comments: air monitoring directly at CS206

5

FERC disregarded comments: validate estimates of chemical emissions

5

FERC disregarded comments: validate estimates of chemical emissions

6

FERC disregarded comments: Health Impact Assessment (chemical emissions + heat/volume of emissions from smokestacks)

6a

FERC disregarded comments: Health Impact Assessment (heat/volume of emissions from smokestacks)

6b

FERC disregarded comments: Health Impact Assessment (chemical emissions)

7

FERC disregarded comments: year-after-year Trap Rock Quarry blasting impacts

7

FERC disregarded comments: year-after-year Trap Rock Quarry blasting impacts

8

FERC disregarded comments: waste heat recovery

8

FERC disregarded comments: waste heat recovery

9

Incomplete DEIS:  environmental, social & economic impacts – Raritan Bay Loop

9a

Incomplete DEIS:  environmental, social & economic impacts – Raritan Bay Loop

9b

Incomplete DEIS:  environmental, social & economic impacts – Raritan Bay Loop

10

Incomplete DEIS:  ecological impacts – forest removal & wetlands

10

Incomplete DEIS:  environmental, social & economic impacts – Raritan Bay Loop

11

Incomplete DEIS:  contaminated groundwater – Higgins Farm Superfund Site

11

Incomplete DEIS:  contaminated groundwater – Higgins Farm Superfund Site

12

Incomplete DEIS:  short & long-term impacts – Raritan Bay Loop (noise, marine vessels, sediment disturbance, horseshoe crabs)

12a

Incomplete DEIS:  short & long-term impacts – Raritan Bay Loop (noise, marine vessels)

12b

Incomplete DEIS:  short & long-term impacts – Raritan Bay Loop (sediment disturbance)

12c

Incomplete DEIS:  short & long-term impacts – Raritan Bay Loop (horseshoe crabs)

13

Incomplete DEIS:  impact of increased GHGs & methane leaks

13a

Incomplete DEIS:  impact of increased GHGs & methane leaks

13b

Incomplete DEIS:  impact of increased GHGs & methane leaks – NYS & NYC goals

13c

Incomplete DEIS:  impact of increased GHGs & methane leaks – Social Cost of Carbon

 

 

OTHER ACTION:  TELL NJDEP TO REJECT PERMIT BY JUNE 22, 2018

  1. Send a message to Governor Murphy.  Please call Food & Water Watch’s # – 888-724-8943 – to be connected to the Governor’s office & tell him that you want him to know you oppose the NESE project & want NJDEP to deny the Freshwater Wetlands permit application.
  1. Send a message to NJDEP.  We’re pushing for NJDEP to deny the Freshwater Wetlands permit application by June 22.  Versions of those letters are attached for you to email or mail, and they are on our website, www.scrap-NESE.org.    Just clearly add your name, address, etc.  The email addresses for the people at the NJDEP are:

Ruth.Foster@dep.nj.gov

Commissioner@dep.nj.gov

You can also call NJDEP and tell them that you want them to deny the Freshwater Wetlands permit by June 22, 2018 – Call Commissioner McCabe directly at 609-292-2885.

There are also letters to NJDEP that you can use from the Watershed Institute and New Jersey League of Conservation Voters.  They’ve been distributed on social media & are provided below for you to use.

The Watershed Institute’s message:

We need your help to contact the New Jersey Department of Environmental Protection about a proposed pipeline in Franklin Township that would harm wetlands, forests and streams.

Last year, Williams Transco proposed a pipeline project to transport large volumes of natural gas from Pennsylvania, through New Jersey and ending in New York. 

The proposed project would require building a compressor station near the Trap Rock Quarry in Franklin Township and would involve cutting down forests, crossing three streams and impacting wetlands. Additionally, this project would construct a new pipeline under the Raritan Bay.

Transco’s submitted applications for permits to the New Jersey Department of Environmental Protection, but failed to include all of the information that is necessary for the agency to rule on the application.

The deadline for New Jersey to act on the application is rapidly expiring. If NJDEP does not deny the application and direct Transco to resubmit it with complete and necessary information, DEP will have forfeited its right to review the project. 

Please contact NJDEP and urge the agency to act now to reject Transco’s application for this environmentally damaging fossil fuel project.

We have a sample letter below for your use and send to:

Eric Wachter, Chief of Staff- eric.wachter@dep.nj.gov
Ruth Foster, Office of Permit Coordination- Ruth.Foster@dep.nj.gov

Eric Wachter, Chief of Staff
Ruth Foster, Office of Permit Coordination
New Jersey Department of Environmental Protection
401 West State Street
Trenton, NJ

RE:  Transcontinental Gas Pipe Line Company, LLC Northeast Supply Project

Flood Hazard Area Control Act, Freshwater Wetlands Protection Act Permits & Water Quality Certification

NJDEP File #: 0000-01-1001.3 FHA/ 17002

Dear Mr. Wachter and Ms. Foster:

I am writing to you regarding the permit application submitted by Transco for the Northeast Supply Enhancement Project. In its application, Transco failed to include all of the information needed for the Department to review the project. 

The proposed project would require building a compressor station near the Trap Rock Quarry in Franklin Township and would involve cutting down forests, crossing three streams and impacting wetlands. Additionally, this project would construct a new pipeline under Raritan Bay.

Under the Clean Water Act, the Department must respond to Transco’s application within a fixed period of time. Failing to do so, would result in the application’s automatic approval. Please don’t let this happen.

In order to preserve New Jersey’s right to protect our streams, wetlands, forests and our communities, it is critical that the Department deny the application at this time.

We urge the Department to protect the state’s rights and deny Transco’s application before it is too late. Only when all the information is complete should the Department reconsider any resubmitted application by Transco.

Sincerely,

Your Name________________________________________

NJLCV’s message and letter (online, a click sends it to the NJDEP Commissioner) –

LINK = https://secure.everyaction.com/zCIcBvMxxkqnqv4Fplm9vw2

There’s a new fracked gas pipeline project being proposed right in the heart of Central New Jersey that’s going to put our health and safety at risk. 

The Williams Transcontinental Company’s Northeast Supply Enhancement (NESE) Project would add 35 miles of pipeline and a new gas compressor station to its existing Transco pipeline system to move gas through New Jersey to New York via the Raritan Bay.

NJDEP has until June 23 to decide if it will give Williams Transco the permits it needs to move forward with Raritan Bay pipeline and compressor station, which means we still have time to stop it.  If we get loud enough, we can convince NJDEP to shut down this project.

Send a message to NJDEP urging it to reject ALL permits for the Raritan Bay Gas Pipeline and Compressor Station 206 >>

Major pipeline projects like this one are terrible for our communities. They threaten our drinking water sources, harm marine life, expose our families to air pollution, and could affect home values. The compressor station alone would spew dangerous toxins into the air that will settle into the ground where our children play, increasing the risk of asthma, skin irritation, and cardiovascular disease. 

The federal agency in charge of telling the public all the health and environmental risks associated with this project did the bare minimum analysis. Given that Williams Transco already has a long history of violations and incidents with its pipelines, what’s to say that a leak or explosion can’t happen again if there’s been no proper risk assessment?

If NJDEP approves the NESE project, it would be a huge step backwards for New Jersey’s progress to reach 100% clean energy by 2050. We’ve got to get a handle on all the dirty infrastructure we already have and keep our communities safe instead of building new projects that aren’t even meant to serve New Jerseyans in the first place. 

We must act NOW before the June 23 deadline. Urge NJDEP to promptly deny all permit applications for the Northeast Supply Enhancement Project >>

Thanks for all you do to protect our water, air, and open spaces.

Ed Potosnak
Executive Director, New Jersey LCV

Message –

Please reject all permits for the Northeast Supply Enhancement Project

Dear Commissioner McCabe,

I am urging the NJDEP to promptly deny the permit applications of Williams/Transco for the Northeast Supply Enhancement (NESE) Project.  These applications are for Freshwater Wetlands, Flood Hazard Area, Coastal Wetlands, and Waterfront Development.

The draft Environmental Impact Statement issued by FERC cannot be considered valid as it does not provide a thorough independent environmental impact analysis, nor does it present mitigation for the very real threats that this project poses immediately and for the duration while in service to the people in New Jersey and NYC.  This project is not a public convenience – it is a public threat.

Furthermore, FERC could overrule NJDEP’s right and responsibility to protect the waters of New Jersey if NJDEP does not issue its denial of permit applications quickly.  This has occurred to the New York State Department of Environmental Conservation (NYSDEC) when they did not render a decision within one year of receiving permit applications for the Valley Lateral component of the Millennium Pipeline Project.  Please do not let this occur with NJDEP.

I stand with the Governor in support of increasing energy efficiency and renewable energy sources to protect our water and air.  Unless you can determine that the permit applications for Freshwater Wetlands, Flood Hazard Area, Coastal Wetlands, and Waterfront Development are complete and truly protective of the environment, according to all that NJDEP is required to comply with, please reject these applications promptly.

Thank you for your consideration.

2018-05-08 Montgomery Township posts to FERC opposition

Special thanks to Montgomery Township for posting resolution #18-5-112 opposing CP17-101 to FERC on 5/8/2018.  

Includes Memorandum from Montgomery Township Mayor

MT-Mayor_Conforti_Memo

Montgomery Resolution #18-5-112 

MT-Montgomery_res-18-5-112

Map of area where proposed compressor CS206 is relative to Montgomery Township.

MT-map with cs206

FERC acknowledges adverse impact to Princeton Area, but refuses to perform environmental impact analyses.  Instead the Draft Environmental Impact Statement (DEIS) issued by FERC on 3/24/2018 states reasons why FERC doesn’t believe assessing the toxic chemical emissions and high heat/ high discharge of the 50-foot smokestacks.  The DEIS acknowledges real threats, but doesn’t bother to analyze impact or mitigation possibilities – core components of a legitimate DEIS.  The DEIS only underscores that CP17-101 is a Public Threat to New Jersey and not a public convenience.

Montgomery Township and Franklin Township have both sent strong rebukes of the none-material DEIS.  We need more municipalities standing up to this sham to protect the residents of New Jersey.

 

10 days left to comment on NESE DEIS – Ends May 14, 2018

2 Comments

Excellent note from EELC today.  Excellent results from Princeton University team efforts, I love seeing the motions to intervene and comments cascading in my inbox.  Great news that Montgomery Township passed RESOLUTION #18-5-112 opposing CP17-101.  Now we need them to post it to FERC.

There are only 10 days including today.  Several communities have stated they will try to get comments in from their communities.  If anyone has questions or wants clarifications, send it out to the team (stopftcompressor [at] yahoo [dot] com) and you will receive a response.  Surfrider has great comment suggestions and our team has provided a few.  If you have not submitted comments and you are on this distribution list, please make those comments now.

Good attributes for comments:

  1. I oppose this project, I am a registered intervenor.
  2. How it directly impacts you – this will impact people in many different ways even people not in PA/NJ/NYC and that is completely legitimate.
  3. Highlight areas where FERC decided not to assess impact or completely missed.
  4. Identify areas where FERC acknowledges impact as rational that this is currently a Public Threat (not a public convenience) until FERC assesses and mitigates impacts.
  5. Reject the notion that this DEIS statement reflects an actual draft environmental impact statement.  It doesn’t.

Please also email NJDEP and ask why your elected officials have not sent comments after the DEIS.  This is also their critical time to take a stand to protect New Jersey.

10 days,
please make your voice count against
this imminent threat to our area.

Confused about FERC terminology…these quick tips might help

(Details at https://www.scrap-nese.org/actions-to-take/)

Intervenor: A stakeholder, a taxpayer, directly affected by Compressor/pipeline, or anyone from the public whose participation is in the public interest.  Being an intervenor legally empowers your comments and ensures that FERC registers the concern.  You must be registered with FERC, see below.  We encourage everyone to file for intervenor status.


eRegistration (https://ferconline.ferc.gov/eRegistration.aspx)

The process of identifying to FERC, you will be issued a FERC ID Number via your email.  Keep the email and password you used to register for future communications with FERC.
Once eRegistered, you can:

  • eSubscribe, to receive email notifications of new items posted about NESE (CP17-101).
  • eFile – file a Motion to Intervene, requiring answer from FERC, or
  • eFile – submit simple comments for FERC’s attention only.


eFiling (https://www.ferc.gov/docs-filing/efiling.asp)
Motion to Intervene:

  • On the Filing Type page, select General – Intervention – (doc-less) Motion to Intervene.
  • Copy and paste (or write your own) reason why you should be an intervenor.

NOTE:  Save comments to post as a separate action at a later stage.

Comment:

  • Have a comment ready as a Word document to upload.
  • On the Filing Type page, select general – comment
    (on Filing, Environ, Report or Tech Conf) – Comment.
  • On the File Upload page, select Browse … go to your documents and select the one you want to send … select Upload.


eComment (https://www.ferc.gov/docs-filing/ecomment.asp):

  • There’s no need to be registered or an intervenor to submit just comments.
  • Best is to copy & paste prepared comments from a text file into the text box.

Note: You may eFile comments/interventions as frequently and as many times as you want.
Use material provided by Franklin Twp Task Force (FTTF) to include in your comments.

 

Northeast Supply Enhancement Project (NESE) Overview

Goal of Williams/Transco for the Northeast Supply Enhancement Project (NESE):

  • Deliver 400,000 dekatherms/day of natural gas to NYC
  • Williams/Transco already has a commitment from National Gas to buy this gas.

In Pennsylvania, they plan to add:

  • a 10-mile, 42-inch pipeline loop of Mainline D in Lancaster County, PA; and
  • a 21,902 horsepower electric-powered compressor unit at STA200, Chester County, PA (where there are already 13 compressor units)

Plans for New Jersey

Raritan Bay Loop Pipeline
Sayreville, NJ into Raritan Bay

Madison Loop Pipeline
Old Bridge & Sayreville, NJ
23.49-mile, 26-inch loop (0.16 mile onshore and 23.33 miles offshore) of Transco’s Lower New York Bay Lateral from Mile Post 12.00, southwest of the Morgan Meter & Regulator (M&R) Station in Sayreville, NJ to the Rockaway Transfer Point in New York State waters 3.43-mile, 26-inch loop of Transco’s Lower New York Bay Lateral from Compressor Station 207 at Mile Post 8.57 to Mile Post 12.00, southwest of the Morgan M&R Station

Compressor Station 206    Franklin Township (Somerset County)

new compressor station near Transco’s mainline,
consisting of two natural gas-powered turbine-driven compressor units
total horsepower: 32,000

Two 50-foot smokestacks where:

  • exhaust exits at 210,000 cubic feet per minute
  • exit temperature is 849.2 degrees Fahrenheit
  • Per Hour Release:  13 pounds of Carbon Monoxide

Williams/Transco:
Transcontinental Gas Pipe Line Co. LLC (Transco) is a wholly-owned subsidiary of Williams Partners Operating LLC, which is a subsidiary of Williams Partners L.P., which is a subsidiary of the Williams Companies, Inc.

 

Issues

  • The proposed compressor station would create air and noise problems that would affect Franklin Twp., South Brunswick, Montgomery & Princeton. Measurements of air quality are completed regionally and are averaged over time. Thus, monitoring of emissions in the air is not proposed to occur near the site, and measurement is not proposed to account for fluctuations where peak emissions are especially problematic. Additionally, all known carcinogenic emissions from compressor stations are not measured at nearby residences, places of workshop, etc.
  • Compressor stations pose serious health risks, especially for pregnant women, the elderly and the young, due to emissions that are planned, fugitive and accidental. Chemicals emitted from compressor stations include known carcinogens.
  • There is a history of catastrophic accidents at compressor stations and transmission pipelines, and an accident could result in deaths/injuries, destruction of property, limited potential for residents to evacuate, and devastation to the waterfront and waters of the Raritan Bay.
  • Increasing compression to transport natural gas through aging pipelines is a safety concern due to the increased velocity/heat of the moving gas and hastening of pipeline corrosion that could result in an explosion.
  • Though a segment of pipeline on Trap Rock Quarry property was replaces in the late 1980’s, there is no publicly available information about the age of the other pipeline associated with this project which, as far as it is known, were constructed in the 1950’s and 1960’s. Additionally, according to a Pipeline Safety Trust analysis of federal data, new pipelines are failing at a rate on par with gas transmission lines installed before the 1940s.
  • The NJ Buddhist Vihara & Medication Center borders the property where CS 206 is proposed. The noise, odor and emissions from the compressor station threaten their religious practice of walking meditation on trails which extend to the site of the compressor station. It is not known what effect the noise and pollution could have on their Buddha Statue which is the largest outdoor Buddha statue in the Western Hemisphere and a Cultural Landmark in Franklin Township.
  • Plans for construction of the compressor station and pipelines are near Superfund Sites.
  • There is not adequate water service in the area of the proposed compressor station to address potential accidents.
  • The habitat in/near the Bay would be disrupted during construction for marine mammals, fish, shellfish and horseshoe crabs that rely on it. Dangers of vessel strikes, accidental fluid releases, and disruption of the seafloor are concerns.
  • Sea mammals (Gray Seal, Harbor Seal, Harp Seal, North Atlantic Right Whale, Bottlenose Dolphin, Harbor Porpoise, & Short-Beaked Common Dolphin) are expected to be affected by exposure to seismic activity such that Williams/Transco will apply for an Incidental Harassment Authorization (IHA) to account for sound pressure from construction that has the potential to disturb a marine mammal or marine mammal stock in the wild by causing disruption of behavioral patterns, including, but not limited to, migration, breathing, nursing, breeding, feeding, or sheltering [Level B harassment].
  • Tourism and commercial fishing activities in the Raritan Bay area would be impacted by construction that is planned to occur for 9 months, 7 days a week, 24 hours a day (weather permitting).
  • For a project like this, there is no public vote; local ordinances can be ignored; and there is limited public input. The US Congress is working to increase the authority of FERC while lessening the rights of States to protect the public through their determinations about required air and water permits.

Learn more, read the information packet from the South Brunswick Informational Meeting held by Food and Water Watch.