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 – Accounting for the Wetlands where it is proposed that Compressor Station 206 will tie-into the existing pipeline(s)
Diagrams and maps of the area where Williams-Transco proposes to construct inlet and outlet pipelines that would connect Compressor Station 206 to Transco’s existing Mainline pipeline system are in wetlands, but these wetlands do not appear to have been accounted for in the tables in submissions by Williams-Transco to FERC. Wetlands were only noted for the proposed access road in the tables even though, in their Application, Williams-Transco did note that “Wetland W-T09-001 is within the Compressor Station tie-in footprint.” This tie-in area is not on the 52-acre lot that they have purchased for the construction of CS206. Additionally, it is assumed from reviewing diagrams in their application submissions for permits to the NJDEP, and in correspondence to FERC on 9/7/17, that the plan is to tie-into both Mainline A and Mainline C, but this should be more clearly stated in their description of the Project so that the alternatives that were rejected could be reviewed more fully.
To allow for meaningful review and comments, I am requesting that the Commission require Williams-Transco to specifically account for the wetlands in the area of the proposed tie-in / suction and discharge pipe in all of their calculations about impacts and possible need for mitigation and submit a Supplemental Report that clearly shows this accounting. Additionally, I request that the Commission ask Williams-Transco to clearly specify which Mainline(s) are proposed to be connected to the proposed CS206 and how these lines are connected to other completed and proposed Projects of theirs.
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.