ACTION ALERT: Urge NJ DEP to Withdraw the Air Pollution Control Permit


Urge NJDEP to withdraw the air pollution control permit (Permit Activity Number: PCP170001; PI Number: 36396) and require  Williams/Transco to submit a new air pollution permit application that will need to adhere to the new, more protective thresholds.

Use the attached letter to tell NJDEP that you want them to withdraw the Air Pollution Control Preconstruction Permit and  Certificate to Operate Construction of a New Source that was issued to Williams/Transco on September 2017.

Letter to send to NJDEP:
   –Snail Mail (docx)
Email (docx)

  • Send it to the list of people at NJDEP provided below.
  • Review the memo that Franklin Township’s Town Manager sent to the NJDEP on August 28, 2018 for more details.


N.J.A.C. 7:27-8, “Permits and Certificates for Minor Facilities”

  • Section 8.16 – Revocation:
    (b)    The Department may withdraw its approval of a preconstruction permit or permit revision if the permittee:
    1. Does not begin the activities authorized by the permit or permit revision within one year from the date of its approval
  • Section  8.13 – Conditions of approval:
    (b)  The Department may change the conditions of approval of a certificate:
    3. At any time during the period a certificate is in effect, if the Department determines that such change is necessary to protect human health or welfare or the environment.


Catherine R. McCabe, NJDEP Commissioner
401 E. State St.
7th Floor, East Wing
P.O. Box 402
Trenton, NJ 08625-0402

Ruth W. Foster, PhD., P.G., Acting Director
Office of Permit Coordination and Environmental Review
401 East State Street
PO Box 420
Trenton, NJ 08625

Kenneth Ratzman, Assistant Director – Air Quality Regulation & Planning
Bureau of Stationary Sources: Regulation & Planning
401 E. State Street, 2nd Floor;  P.O. Box 420
Mail Code 401-02
Trenton, NJ 08625

Office of Governor Murphy,
P.O. Box 001
Trenton, NJ  08625

NJDEP’s commitment is to assist in preserving, sustaining, protecting and enhancing the environment to ensure the integration of high environmental quality, public health and economic vitality in partnership with the general public, businesses, environmental communities and government entities through aggressive environmental protection and conservation efforts; and

The proposed Northeast Supply Enhancement (NESE) Project is incompatible with the State’s goal to reduce emissions by 80% from the 2006 baseline by 2050 or Governor Murphy’s Executive Order 28 goal for the State to use 100% clean energy sources by January 1, 2050.

Though the NJDEP issued an air pollution control permit to Williams/Transco for the proposed Compressor Station 206 on September 7, 2017, they have the power to withdraw this permit and require Williams/Transco to submit a new application that will require adherence to stricter (more protective) air pollution standards.

Note that the NJDEP adopted stricter air pollution control standards that went into effect in February 2018 to protect human health, and the anticipated Hazardous Air Pollution (HAPs) emissions from one compressor unit for the NESE Project exceed all of them.  At this facility, there will be two compressor units.  The permit was issued under older standards, and the permitting was for each compressor unit separately.

Emissions of caustic chemicals predicted by Williams/Transco for two (2) Solar MARS 100 turbines

at proposed Compressor Station 206 with the NJDEP Reporting Thresholds (old & new)



To be emitted

from Compressor Station 206

Reporting Thresholds (NJDEP)



from one turbine

from two turbines

N.J.A.C. 7:27-17.9

N.J.A.C. 7:27-8

(February 12, 2018)

(February 27, 2015)




















87.6  (0.01 lbs/hour)











Propylene Oxide














14,790 *

29,580 *

* No threshold standards

Though FERC decided that there was no need to complete a Health Impact Assessment for people around the proposed Compressor Station 206 site, they still expect to issue a final Environmental Impact Statement on January 25, 2018 without:

  • Clarifying misrepresentation of emission estimates from Williams/Transco for CS206
  • Assessing toxic impact to nearby environment, human health and water pollution
  • Assessing local air quality impact on MARS 100 combustion efficiency and emissions
  • Validating actual chemical and greenhouse gas emissions using Natural Gas mixtures in Williams/Transco lines in the New Jersey/Pennsylvania area
  • Obtaining actual emissions of MARS 100 turbines in the New Jersey/Pennsylvania area.  Data used is obtained from Solar test runs in lab located in San Diego, California.
  • Revising environmental impacts from toxic chemical emissions recently issued in research studies directly correlating human health impacts and immune disorders with natural gas fired compressor turbines.


Reasons for withdrawing the air pollution control permit:

  • Transco applied for the NJDEP CS206 air compressor emissions air permit on January 6, 2017.   NJDEP approved Transco’s air permit application on September 7, 2017, based on Williams/Transco’s wording in dialogue with NJDEP with misleading emission estimates and no actual emission data.  NJDEP permit application correspondence with Williams/Transco indicates that NJDEP did not evaluate or cross reference estimates and NJDEP did not detect the emission reporting irregularities in the data provided by Williams/Transco.
  • Williams/Transco received their air pollution permit before stricter air quality standards in N.J.A.C. 7:27-17.9 were operative in February 2018.  These new, lower reporting thresholds for Hazardous Air Pollutants (HAPs) were adopted due to the rapid decrease in air quality and the urgent need to tighten air emissions in New Jersey
  • In the NJDEP permit application and also included in Williams/Transco’s application to FERC were test results provided by Solar for two (2) test runs on Solar Mar 100 units.  Testing was performed in Solar’s labs located in San Diego, CA.  Test run results indicate a high dependency with temperature producing a highly variable emission output.  Tests did not account for the impact of environmental factors such as relative humidity, air quality and elevation at the actual proposed site on the natural gas combustion despite having significant impact and consequential emissions of chemicals and greenhouse gasses.  Additionally, data was missing in the emissions reporting of each test run.  Additionally, Solar, FERC, and Williams/Transco did not consider or assess the difference between the location where test runs were performed (San Diego, CA) versus the target location where the Compressor Station 206 is proposed to be installed (Franklin Township, NJ).  Neglecting the factors of installation location air quality, relative humidity, temperature patterns and elevation at the proposed CS206 site means that to date, there is no legitimate estimate of emissions or chemical and greenhouse emissions for MARS 100 turbines installed at the proposed location.
  • NJDEP did not receive any actual data of existing MARS 100 turbines (CS206 proposes 2 MARS 100 turbines) from existing MARS 100 turbines deployed along Williams/Transco’s pipelines throughout Pennsylvania, which would have a much more accurate representation of emissions for the CS206 proposed location.
  • Without current air quality measures at the proposed location, the emissions estimates have no bearing or accuracy for actual emissions at the proposed location.
  • Humidity and ambient air quality directly impact combustion, yet data was only provided for 60% humidity, and the ambient air quality measures were not taken at the immediate site that is next to an air polluting facility (Trap Rock Quarry).
  • In the FERC application, Williams/Transco provided emission estimates on one table claiming estimates were for both turbines and on a table one (1) page later showing emissions represented a single turbine.  The emissions for VOCs turned out to be for one (1) turbine.  Additionally, some of the emissions were inconsistent with emission estimates provided by manufacturer emissions. 
  • Test run data and Specification Sheets provided by Solar, show that both RPM and HP are lower at higher (average: 59°F) temperatures which suggests that combustion is converting less fuel to energy.  This indicates there is a possibility that increased unburned fuel, primarily Methane, would be released as exhaust.
  • Solar does not warranty emissions for SO2, PM10, PM2.5, VOC and formaldehyde according to their Predicted Emission Performance pages.  This means that the Solar MARS 100 emissions of SO2, PM10, PM2.5, VOC and formaldehyde are highly variable and subject to environmental and variability of older combustion technology used in MARS 100 turbines.
  • Williams/Transco referenced air quality monitors used for the ambient air quality readings that were not the closest monitors to the proposed Compressor Station 206 site, and wind direction is a relevant factor.  For example, there are monitoring stations at Edison’s EPA building and at the Rutgers station at Cook College which are closer than Elizabeth, NJ or Philadelphia, PA.
  • NJDEP did not indicate any validation or analyses of the Ammonia emissions, which is estimated under San Diego generated test runs to be 29,580 pounds per year.
  • If Volatile Organic Compounds (VOCs) are higher, or other contaminants such as Particulate Matter (PM2.5 and PM10) are higher in New Jersey than where the testing occurred and the efficiency of combustion conversion to energy is reduced; then it is very likely that the MARS 100 turbines will emit more pollutants and unburned fuel in the exhaust on an ongoing basis for the expected lifetime operation of the Compressor Station 206.
  • Over the past seven years, Williams/Transco has frequently upgraded and expanded turbines at existing compressor stations throughout New Jersey.  This indicates that there is a high likelihood that Williams/Transco will attempt add more MARS 100 turbines to the CS206 location.


New Jersey’s Attorney General and others wrote to FERC about their Policies & Procedures.

New Jersey’s Attorney General joined with 6 other Attorneys General in a 36-page submission to FERC when FERC asked for input about revising their policies and procedures.  (on 7/25/18 on Docket No. PL18-1). In it, they detail and support their recommendations:

First, regarding project need, we recommend that the Commission assess need on a comprehensive, regional basis, and expand its analysis beyond the current dependence on precedent agreements, employing heightened scrutiny of precedent agreements with affiliates of project proponents.

Second, we urge the Commission to conduct a more thorough and robust NEPA analysis, comprehensively assessing on a regional basis the impacts of, and alternatives to, a proposed project, considering clean energy and other non-pipeline alternatives, thoroughly analyzing upstream and downstream greenhouse gas emissions, and considering state greenhouse gas emission-reduction policies.

Third, we recommend that the Commission consider environmental harm, including climate impacts quantified using the best available measure—the Social Cost of Carbon—and more heavily weigh the harm from use of eminent domain takings in its public interest assessment when balancing project benefits and harm in making a Certificate decision.

Fourth, we urge the Commission to better incorporate and consider state environmental and land use policies, no longer issue Certificates conditioned on later receipt of state certifications and permits under federal statutes, and to condition Certificates on obtaining and complying with state and local permits that do not unreasonably conflict with or delay approved projects.

Finally, we recommend that the Commission no longer issue partial notices to proceed with construction when Certificate rehearing requests are pending and limit the use and time of tolling periods for rehearing requests.

Click to read the full document from the Attorneys General (7/25/18, PDF)

Status of Applications to NJDEP for water permits

Approximately 2,000 mailed and emailed letters were sent to the NJDEP requesting fact-finding meetings (“hearings”) on the water quality permit applications submitted by Williams/Transco on June 20, 2018.  THANK YOU!

NJDEP has started their review of the applications and, on July 18, 2018, they sent a letter to Williams/Transco and FERC identifying deficiencies with the applications.  

NJDEP has one calendar year to grant or deny the permit applications that they received on June 20, 2018, and Williams/Transco now expects to hear the decision in April 2019.

Since NJDEP has 90 days after holding fact-finding meetings to issue their decision, we are anticipating that the fact-finding meetings will be scheduled in the winter of 2018 once they have adequate information for the application reviews.  However, the meeting could be sooner. We’ll let you know when we learn more. Stay tuned!

Fact-Finding Meetings:

  • NJDEP staff will facilitate the meeting at a place that can hold many people.
  • People usually get 3 minutes to speak at a microphone in front of the group about their concerns, and a stenographer records it.  It’s not like the FERC meeting where you went into a separate room.
  • Pre-written comments can be submitted at the meeting & can be sent after the meeting.
  • We do expect that pro-NESE people will be there to voice their support (like they were at the FERC public meetings), so we want to have many concerned folks there to tell NJDEP why we do not want NESE.
  • It’ll probably start around 5:30 PM.  However, you can come later. If you want to speak, you will need to sign-up at the meeting to do this.

Recent Letters to the Editor – Summer 2018

Please review the letters to the editor that were published in TAPinto.  Similar letters were also published from the end of July to August 2 in the Franklin Advocate & Reporter.

July / August 2018 Series of letters to the editor – concerns about NESE & what you can do


Send comments to the NJDEP

  • Commissioner Catherine McCabe:
  •  Director Ruth Foster:

Williams/Transco submitted new applications for water permits (Freshwater Wetlands, Flood Hazard Area Control, Coastal Wetlands, & Waterfront Development) on June 19, 2018.

  • Tell NJDEP that you want them to hold two (2) public fact-finding meetings – one by the Raritan Bay (Old Bridge / Sayreville) and one by the proposed Compressor Station 206 area (Franklin Township / South Brunswick).
  • Tell NJDEP that you expect them to deny the permits unless they obtain and carefully review all needed information and actually find that the proposed project would not cause harm to the environment, people or wildlife.
  •  Tell NJDEP that an increase in reliance on fossil fuels for energy does not support New Jersey’s goal to transition to renewables and clean energy.

Sign the letter to NJDEP and either mail it or give it to a member of the Task Force to mail
Click here for link to the letter to print, sign & mail

NOTE: A request for fact-finding meetings needs to be in writing to NJDEP and received in Trenton by August 3.

Keep sending comments to FERC

Send comments to FERC that request a “reset” for the DEIS by asking them to publish a revised/supplemental DEIS that addresses all new information and all concerns of the public. Tell FERC that the March 23, 2018 DEIS was missing critical information, dismissed comments of the public & elected officials, and lacked supportive studies or data for FERC’s conclusions. Additionally, Williams/Transco submitted thousands of pages of new information and reports that needs to be reviewed and analyzed in a document that FERC publishes during the time period when the public can truly provide meaningful comments. These submissions were in May and June 2018 – after the DEIS was published & after the end of the “official” time period for sending comments to FERC.

FERC claims that they consider ALL comments they receive. Many people need to let them know that the DEIS was not acceptable.


The DEIS was incomplete & misleading.  Tell FERC that you want a revised or supplemental DEIS and an additional comment period of at least 45 days.

When you send a comment to FERC, also forward that comment to the NJDEP –

  • Commissioner Catherine McCabe: Commissioner@dep.nj.go
  • Director Ruth Foster:

You can also forward your comments to your elected officials and ask them to support the opposition to NESE.

Information About FERC’s Incomplete and Misleading DEIS

Click to open PDF documents containing the following information:

Action Alert – Tell NJDEP and FERC about new concerns.

Dear Fellow Concerned Opponents of the NESE Project,

Thank you for sending comments to FERC and raising your voices about the proposed dangerous Northeast Supply Enhancement (NESE) Project!  Though FERC listed May 14 and the official final day to file to be an intervenor & send comments, FERC does continue to review comments submitted after then.  Since the DEIS was incomplete and misleading, we still believe it is important to let FERC know that as well as let them know that we need a revised or supplemental DEIS that incorporates the thousands of pages that Williams/Transco sent on May 11 & May 30.  We have a right to participate in this environmental review process in a meaningful way, and that should include time to review all critical information. 

Letting FERC gather extra information and then publish it, along with their “independent evaluation & analyses” in the final EIS is not acceptable since the time for true public engagement is after the DEIS. That’s why we’re pointing out the issues and asking for a revised or supplemental DEIS to be published by FERC with an additional comment period of at least 45 days.


Please take one or more of the attached comments and send them to FERC.  They are all short enough to go “as is” as eComments.  Feel free to copy/paste ideas from different comments to generate new ones.  Each of the eComments starts with a bold ISSUE:  and ends with the same paragraph.  Just copy one comment at a time to send in.

If you are an intervenor, you can use the other set of comments that have bullets and numbers by saving one as a PDF and then using eFiling to upload the PDF comment.  That preserves the formatting, and there’s no length limit for eFiling.  You just have to be registered with FERC (where they gave you a FERC ID #).  Being an intervenor means that you are already registered.

eFiling comment samples

(save as PDF to upload to FERC)

eComment samples

(6,000 characters or less)


Public denied opportunity for meaningful commenting – missing information, NYSDEC denied permit, FERC dismissed comments, shortcomings of DEIS



Incomplete DEIS & data dump – missing information + Incomplete DEIS


Incomplete DEIS & data dump – shortcomings of DEIS


Public denied opportunity for meaningful commenting (different format)


Public denied opportunity for meaningful commenting




FERC disregarded / dismissed comments: list


FERC disregarded comments: safety analysis of increased velocity of gas in pipeline


FERC disregarded comments: safety analysis of increased velocity of gas in pipeline


FERC disregarded comments: air monitoring directly at CS206


FERC disregarded comments: air monitoring directly at CS206


FERC disregarded comments: validate estimates of chemical emissions


FERC disregarded comments: validate estimates of chemical emissions


FERC disregarded comments: Health Impact Assessment (chemical emissions + heat/volume of emissions from smokestacks)


FERC disregarded comments: Health Impact Assessment (heat/volume of emissions from smokestacks)


FERC disregarded comments: Health Impact Assessment (chemical emissions)


FERC disregarded comments: year-after-year Trap Rock Quarry blasting impacts


FERC disregarded comments: year-after-year Trap Rock Quarry blasting impacts


FERC disregarded comments: waste heat recovery


FERC disregarded comments: waste heat recovery


Incomplete DEIS:  environmental, social & economic impacts – Raritan Bay Loop


Incomplete DEIS:  environmental, social & economic impacts – Raritan Bay Loop


Incomplete DEIS:  environmental, social & economic impacts – Raritan Bay Loop


Incomplete DEIS:  ecological impacts – forest removal & wetlands


Incomplete DEIS:  environmental, social & economic impacts – Raritan Bay Loop


Incomplete DEIS:  contaminated groundwater – Higgins Farm Superfund Site


Incomplete DEIS:  contaminated groundwater – Higgins Farm Superfund Site


Incomplete DEIS:  short & long-term impacts – Raritan Bay Loop (noise, marine vessels, sediment disturbance, horseshoe crabs)


Incomplete DEIS:  short & long-term impacts – Raritan Bay Loop (noise, marine vessels)


Incomplete DEIS:  short & long-term impacts – Raritan Bay Loop (sediment disturbance)


Incomplete DEIS:  short & long-term impacts – Raritan Bay Loop (horseshoe crabs)


Incomplete DEIS:  impact of increased GHGs & methane leaks


Incomplete DEIS:  impact of increased GHGs & methane leaks


Incomplete DEIS:  impact of increased GHGs & methane leaks – NYS & NYC goals


Incomplete DEIS:  impact of increased GHGs & methane leaks – Social Cost of Carbon




  1. Send a message to Governor Murphy.  Please call Food & Water Watch’s # – 888-724-8943 – to be connected to the Governor’s office & tell him that you want him to know you oppose the NESE project & want NJDEP to deny the Freshwater Wetlands permit application.
  1. Send a message to NJDEP.  We’re pushing for NJDEP to deny the Freshwater Wetlands permit application by June 22.  Versions of those letters are attached for you to email or mail, and they are on our website,    Just clearly add your name, address, etc.  The email addresses for the people at the NJDEP are:

You can also call NJDEP and tell them that you want them to deny the Freshwater Wetlands permit by June 22, 2018 – Call Commissioner McCabe directly at 609-292-2885.

There are also letters to NJDEP that you can use from the Watershed Institute and New Jersey League of Conservation Voters.  They’ve been distributed on social media & are provided below for you to use.

The Watershed Institute’s message:

We need your help to contact the New Jersey Department of Environmental Protection about a proposed pipeline in Franklin Township that would harm wetlands, forests and streams.

Last year, Williams Transco proposed a pipeline project to transport large volumes of natural gas from Pennsylvania, through New Jersey and ending in New York. 

The proposed project would require building a compressor station near the Trap Rock Quarry in Franklin Township and would involve cutting down forests, crossing three streams and impacting wetlands. Additionally, this project would construct a new pipeline under the Raritan Bay.

Transco’s submitted applications for permits to the New Jersey Department of Environmental Protection, but failed to include all of the information that is necessary for the agency to rule on the application.

The deadline for New Jersey to act on the application is rapidly expiring. If NJDEP does not deny the application and direct Transco to resubmit it with complete and necessary information, DEP will have forfeited its right to review the project. 

Please contact NJDEP and urge the agency to act now to reject Transco’s application for this environmentally damaging fossil fuel project.

We have a sample letter below for your use and send to:

Eric Wachter, Chief of Staff-
Ruth Foster, Office of Permit Coordination-

Eric Wachter, Chief of Staff
Ruth Foster, Office of Permit Coordination
New Jersey Department of Environmental Protection
401 West State Street
Trenton, NJ

RE:  Transcontinental Gas Pipe Line Company, LLC Northeast Supply Project

Flood Hazard Area Control Act, Freshwater Wetlands Protection Act Permits & Water Quality Certification

NJDEP File #: 0000-01-1001.3 FHA/ 17002

Dear Mr. Wachter and Ms. Foster:

I am writing to you regarding the permit application submitted by Transco for the Northeast Supply Enhancement Project. In its application, Transco failed to include all of the information needed for the Department to review the project. 

The proposed project would require building a compressor station near the Trap Rock Quarry in Franklin Township and would involve cutting down forests, crossing three streams and impacting wetlands. Additionally, this project would construct a new pipeline under Raritan Bay.

Under the Clean Water Act, the Department must respond to Transco’s application within a fixed period of time. Failing to do so, would result in the application’s automatic approval. Please don’t let this happen.

In order to preserve New Jersey’s right to protect our streams, wetlands, forests and our communities, it is critical that the Department deny the application at this time.

We urge the Department to protect the state’s rights and deny Transco’s application before it is too late. Only when all the information is complete should the Department reconsider any resubmitted application by Transco.


Your Name________________________________________

NJLCV’s message and letter (online, a click sends it to the NJDEP Commissioner) –


There’s a new fracked gas pipeline project being proposed right in the heart of Central New Jersey that’s going to put our health and safety at risk. 

The Williams Transcontinental Company’s Northeast Supply Enhancement (NESE) Project would add 35 miles of pipeline and a new gas compressor station to its existing Transco pipeline system to move gas through New Jersey to New York via the Raritan Bay.

NJDEP has until June 23 to decide if it will give Williams Transco the permits it needs to move forward with Raritan Bay pipeline and compressor station, which means we still have time to stop it.  If we get loud enough, we can convince NJDEP to shut down this project.

Send a message to NJDEP urging it to reject ALL permits for the Raritan Bay Gas Pipeline and Compressor Station 206 >>

Major pipeline projects like this one are terrible for our communities. They threaten our drinking water sources, harm marine life, expose our families to air pollution, and could affect home values. The compressor station alone would spew dangerous toxins into the air that will settle into the ground where our children play, increasing the risk of asthma, skin irritation, and cardiovascular disease. 

The federal agency in charge of telling the public all the health and environmental risks associated with this project did the bare minimum analysis. Given that Williams Transco already has a long history of violations and incidents with its pipelines, what’s to say that a leak or explosion can’t happen again if there’s been no proper risk assessment?

If NJDEP approves the NESE project, it would be a huge step backwards for New Jersey’s progress to reach 100% clean energy by 2050. We’ve got to get a handle on all the dirty infrastructure we already have and keep our communities safe instead of building new projects that aren’t even meant to serve New Jerseyans in the first place. 

We must act NOW before the June 23 deadline. Urge NJDEP to promptly deny all permit applications for the Northeast Supply Enhancement Project >>

Thanks for all you do to protect our water, air, and open spaces.

Ed Potosnak
Executive Director, New Jersey LCV

Message –

Please reject all permits for the Northeast Supply Enhancement Project

Dear Commissioner McCabe,

I am urging the NJDEP to promptly deny the permit applications of Williams/Transco for the Northeast Supply Enhancement (NESE) Project.  These applications are for Freshwater Wetlands, Flood Hazard Area, Coastal Wetlands, and Waterfront Development.

The draft Environmental Impact Statement issued by FERC cannot be considered valid as it does not provide a thorough independent environmental impact analysis, nor does it present mitigation for the very real threats that this project poses immediately and for the duration while in service to the people in New Jersey and NYC.  This project is not a public convenience – it is a public threat.

Furthermore, FERC could overrule NJDEP’s right and responsibility to protect the waters of New Jersey if NJDEP does not issue its denial of permit applications quickly.  This has occurred to the New York State Department of Environmental Conservation (NYSDEC) when they did not render a decision within one year of receiving permit applications for the Valley Lateral component of the Millennium Pipeline Project.  Please do not let this occur with NJDEP.

I stand with the Governor in support of increasing energy efficiency and renewable energy sources to protect our water and air.  Unless you can determine that the permit applications for Freshwater Wetlands, Flood Hazard Area, Coastal Wetlands, and Waterfront Development are complete and truly protective of the environment, according to all that NJDEP is required to comply with, please reject these applications promptly.

Thank you for your consideration.