Re: CP17-101 Northeast Supply Enhancement Project
Pursuant to Senator Cory Booker’s and Senator Bob Smith’s submissions, I am hereby notifying FERC of gaps in data not submitted for CP17-101 and missing analysis required for a full and accurate Draft Environmental Impact Statement (DEIS).
Issue: Missing Data – Impact Analysis and Reporting of Emissions (specifically fugitive) for Compressor Station 200 where the plan is to add a 21,902 HP electric compressor.
For a true environmental impact analysis to be performed, it requires reporting of full emissions of the entire CP17-101 project, including those from the CS 200 added electric compressor. All emissions from the added aboveground buildings and valves need to be accounted for. The missing data about expected emissions from CS 200’s added turbine is a significant omission in necessary data of emissions for this project. Williams should also provide CS200 overall emissions for all of the compressor units at this site along with those from the proposed added compressor to enable a full cumulative impact of emissions from CS200.
NASA has a web page called “Methane Matters” which identifies Methane as 84 times impact compared to CO2. In order to assess the Methane emissions impact on climate change and weather patterns adjacent to compressor stations, Williams must first publish the full Methane emissions for each compressor station (200 and 206). Then a complete impact analysis of Methane emissions can be performed as the most significant Green House Gas impacting the environment and climate change. Without this full data and analysis, it is impossible to provide an accurate draft environmental impact statement. Additionally, in light of the ruling in the recent District of Columbia Court of Appeals case, Sierra Club et al. v. Federal Energy Regulatory Commission, decided on 8/22/2017, it is imperative for FERC to require Williams to provide full Methane emissions for each compressor location and quantify the Methane emission impact on environment and global warming.
As was noted in the Atlantic Sunrise’s FEIS:
In publishing Subpart OOOOa, the EPA established a new rule to reduce emissions of CH4, VOCs, and toxic air pollutants such as benzene from new, reconstructed, and modified oil and gas sources. The CH4 reductions from Subpart OOOO build on the EPA’s 2012 rules (Subpart OOOO) to curb VOC emissions from new, reconstructed, and modified sources in the oil and gas industry. Subpart OOOOa was notably expanded over the previous 2012 rules to include sources at oil and gas transmission and storage facilities. For example, leaks from compressors, storage vessels, and fugitive sources at transmission compressor stations are now subject to the NSPS.
The above missing data and analysis are significant gaps for CP17-101 application. This project is meant to be a convenience, not to harm people, damage the environment or increase climate change. I urge FERC to pursue all highlighted gaps in data and analysis for this project to provide a comprehensive DEIS.
I very much appreciate your vigilance and oversight in fully assessing all potential risks, heath threats and environmental impacts that this project poses.