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.

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