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 – Migratory Birds at/near the proposed Compressor Station 206 Site
Williams-Transco has not completed a bird survey/study in the area of the proposed Compressor Station 206, yet they make an assumption that there are only relatively common birds in the area. However, in their 9/7/17 supplemental submission, in Table A-2 of their Draft Migratory Bird Plan in FERC Accession No. 20170907-5176 (32387000), they note that two (2) Birds of Conservation Concern are “likely” to be in the proposed CS206 area: Bald Eagle (year-round) & Wood Thrush (breeding & migration). They also list that eight (8) other Birds of Conservation Concern are “possible” in the area of CS206: Short-eared Owl (winter & migration); Eastern Whip-poor-will (breeding & migration); Peregrine Falcon (year-round); Blue-winged Warbler (breeding & migration); Kentucky Warbler (breeding & migration); Cerulean Warbler (breeding & migration); Prairie Warbler (breeding & migration); and Rusty Blackbird (winter & migration).
The potential impact on birds from toxic and heated emissions was downplayed in their assertion that, since the air quality impacts from Compressor Station 206 are less than the concentration value of the primary and secondary standards under the National Ambient Air Quality Standards, migratory birds are not expected to be adversely affected by air emissions. Yet, Williams-Transco provided no documentation to support this claim, and a reliance on standards that are averages over time and space, and were developed for humans and not for birds, provides a dubious basis for determining how and if birds would be impacted by emissions from the proposed compressor station. Measures of toxic emissions at the site are needed to fully understand what the potential impact on migratory birds might be.
The potential impact on birds from noise during both construction and operation of the proposed Compressor Station 206 was also downplayed when Williams-Transco concluded that the birds occurring there are likely habituated to the existing noise even though the existing noise is not continuous as would be the noise from the compressor station if it is constructed. They listed sources of anthropogenic noise nearby as automobile traffic from Route 518 to the west, Route 27 to the east, and Trap Rock Quarry’s activity to the south that involves use of heavy machinery and blasting. Yet, though they touted the benefits of trees as noise buffers when reporting on noise to nearby residences, this was not mentioned here. Williams-Transco did acknowledge, in FERC Accession No. 20170601-5277(32193497) on page 46, in response to Question # 33, that “Research suggests that the presence of continuous, anthropogenic noise can alter bird behavior, predator-prey interactions (Francis et al. 2009), nesting species richness (Francis et al. 2009), pair bonding success (Habib et al. 2007), avian abundance (LaGory et al. 2001; Bayne et al. 2008), and population densities (Bayne et al. 2008), and reduce the ability of avian species to find food and avoid predators. However, avian responses to anthropogenic noise sources and noise-tolerance is likely species-specific (Francis et al. 2009).”
To minimize any potential impact on migratory birds in the area of the proposed CS206 site, Williams-Transco noted that they are developing measures that will be incorporated into various Project construction and mitigation plans to minimize environmental impacts on sensitive resources during construction and operation of the Project. They also listed proposed Migratory Bird-Specific Measures to avoid and minimize impacts on migratory birds.
The Commission should require that Williams-Transco provide supporting studies about the added noise and emissions impact on birds and wildlife from their other Compressor Stations which are similar to the proposed CS206 and, additionally, account for any differences in landscape that would need to be taken into account in this analysis. Such studies and analyses should be posted to the FERC Docket and be viewable by the public.
To avoid and minimize impacts on migratory birds, I am requesting that the Commission require Williams-Transco to
(1) firmly commit to USFWS’s recommendation that trees and scrub/shrub clearing only be conducted from September 1 through March 31, and to minimize impacts on federally listed bats, only clear forested lands at the Compressor Station 206 site between October 1 and March 31 per USFWS recommendation;
(2) firmly commit to the listed Migratory Bird-Specific Measures that they and any of their contracted groups/workers will take (not just state those that they “propose” to take);
(3) provide scientific studies pertaining to the range of influence of both continuous noise and light on alterations in bird behavior at their other compressor station sites that are sited in similar locations with similar components; and
(4) provide scientifically- and/or data-based studies to document the impact of emissions from compressor stations like the proposed CS206 on birds and their habitats.
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.