Emissions, Including Fugitive

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 (including fugitive) for Compressor Station 206

Reports are missing environmental and health impact of proposed compressor station 206 leaking 132,720 tons of Natural Gas per year, of which is 123,429 tons is Methane (which is known to impact global warming 84 times the impact of CO2).

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.