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: Incomplete Data – Access to Water and Disposal of Waterwaste at the proposed Compressor Station 206 site
Though Williams-Transco recently acknowledged that there are no sewer lines in the area of the proposed CS206 and that they would need to construct a septic system, they have not yet submitted plans for the septic system that account for impacts on things like wetlands as well as the ongoing cleanup of contaminated water at the Higgins Farm Superfund Site.
Williams-Transco also claims that they will use a municipal water source even though the plans of Franklin Township to address the lack of working fire hydrants along Route 27 and the pitiful allowable water pressure in the pipelines that supply water to nearby residents has not yet become a bid and has not yet been constructed. Additionally, there are no fire hydrants along Route 518 where Williams-Transco proposes to start their access road to the CS206 site.
As Williams-Transco has noted, the planned site for Compressor Station 206 is over large aquifer, the Northwest New Jersey SSA (also known as the Fifteen Basin aquifer systems of New Jersey), and the EPA defines sole-source aquifers (SSAs) as those aquifers “which supply at least 50% of the drinking water consumed in the area overlying the aquifer.” For these aquifers, no alternative drinking water source(s) is reasonably available to all who depend on the aquifer should the aquifer become contaminated.
Thus, the draft Environmental Impact Statement and any consideration by NJDEP for permits should not occur until Williams-Transco submits their plans for the septic system, and the public has adequate time to review and comment on it; there is a published approval for the repair of the water mains and fire hydrants along Route 27; and Williams-Transco publishes the amount of water they anticipate needing during both construction and operation of the proposed CS206 as well as the amount of wastewater they expect to generate and how they plan to dispose of it.
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.