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 – Noise during construction and operation of proposed Compressor Station 206
Reports of the noise that would potentially be generated from construction as well as operations of the compressor station are provided in terms of averages without clearly analyzing the impact of sound at different frequencies or during different hours (i.e., for different operational activities or functions).
Since there are studies showing that low frequency sound impacts wildlife and humans, and high frequencies disrupt human sleep and flying living creatures in the area of the noise, requiring reports of average sound emission is not adequate for revealing potential impacts on humans and wildlife.
Therefore, I request that the Commission require that Williams-Transco perform a comprehensive peak and average noise output study, at full power, that includes the full spectrum audio emissions from an existing MARS 100 compressor station including Ultra Low (1 – 100 Hertz), Audible (100 – 14,000 Hertz) and High Frequency (14,000 to 32,000 Hertz) distinctions. Williams operates many MARS 100 16,000 HP compressors, and there have been many complaints to FERC about their MARS 100 Compressor Station 515 in White Haven, PA under Docket No. CP 12-30 (Northeast Supply Link). FERC should require that Williams-Transco specifically provide (a) further noise research on 1 to 20 Hertz impacting structures, people and wildlife in the immediate area of existing MARS 100 compressor stations, and (b) further noise research on 20,000 to 32,000 Hertz impacting people and wildlife in the immediate vicinity. These studies should address Williams-Transco’s notation in the Resource Report 9 of their Application that “The magnitude and frequency of environmental noise may vary considerably over the course of the day and throughout the week, in part due to changing weather conditions and the effects of seasonal vegetative cover.” (Section 9.3.1)
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.