ACTION ALERT: Send Comments to NJDEP by November 20, 2018

DO SOMETHING YOU’LL BE THANKFUL FOR

Speak up for the health, safety & environment of your family, friends and future generations.

Deadline:  Tuesday, November 20, 2018

This is the last date that the NJDEP will consider comments on the Freshwater Wetlands Permit Application of Williams/Transco for the Compressor Station 206 and onland part of the pipeline by Raritan Bay.

REMEMBER:  If all permits are not obtained, the Compressor Station 206 and pipeline near and under the Raritan Bay cannot be built. 

Over 300 concerned residents went to the NJDEP Hearing on November 5, and the 3-minute comments were still being made past 11:00 PM.  That was an amazing showing, but more is needed.

As Abraham Lincoln said in the Lincoln-Douglas debate of 1858,

Public sentiment is everything.
With public sentiment, nothing can fail; without it, nothing can succeed.”

This is the time for all to make their concerns known to the NJDEP.  The power of many is needed to stop the Northeast Supply Enhancement Project from creating risks to our health and safety.  Every comment matters!

COMMENT SAMPLES (.docx):

  1. Incomplete Application that is also not compliant with Stormwater Management Rules
  2. Application does not meet “public need” or “public interest” requirements – long & short versions
  3. Application has concerning impacts on wetlands
  4. Application threatens habitats for threatened & endangered species
  5. Health issues related to Freshwater Wetlands Permit Application
  6. Safety issues related to Freshwater Wetlands Permit Application
  7. Summary of Concerns with the Freshwater Wetlands Permit Application

As Margaret Mead said,

“Never doubt that a small group of thoughtful concerned citizens can change the world.
Indeed it is the only thing that ever has.”

ACTION ALERT: Message the NJDEP

TAKE A FEW MINUTES TO PROTECT THE HEALTH & SAFETY OF YOUR FAMILY, FUTURE GENERATIONS, AND THE ENVIRONMENT THAT WE LOVE IN NEW JERSEY!

The proposed Compressor Station 206 and pipeline under Raritan Bay will not be built if Williams/Transco does not get all permits needed from the New Jersey Department of Environmental Protection (NJDEP) & New York Department of Environmental Conservation (NYSDEC).  To stop the NESE Project, your participation is needed by November 20.

Many voices need to tell NJDEP to deny the Freshwater Wetlands permit application for the Northeast Supply Enhancement (NESE) Project.

Gratitude is extended to over 300 people who shared their concerns about the NESE Project at the NJDEP hearing on November 5, and special thanks go to those who organized the pre-hearing rally.  A huge shout-out goes to folks from Princeton Manor – 125 of the participants came from there.  The hearing lasted for over 5 hours, and people from New York joined us to speak out.  However . . . This is not the end. 

We have until November 20 to send messages to the NJDEP. 

Please see the attached talking points and comment ideas and send them to: matthew.resnick@dep.nj.gov

  • Anyone who spoke at the hearing with prepared comments could also send the NJDEP their comments and/or more written comments.
  • You can also email your elected representatives to urge them to do whatever they can to stop NESE.
  • Please share this message and attachment with your friends and on social media.

Numbers matter! 

We want to be thankful for a large outpouring of comments to the NJDEP on Thanksgiving, so – 

Please copy/paste part(s) of the attached document and add personal comments to let the NJDEP know that we do not want this risky Northeast Supply Enhancement’s Compressor Station 206 or pipeline near and under the Raritan Bay.

Attachments: 

ACTION ALERT: Review NJDEP Application Documents

For the NJDEP hearing, you can review application material from Williams/Transco to NJDEP at:

https://drive.google.com/drive/folders/1Bm6kTq6Fv0JJIC-ra2pOXBH5SPYGWf0c?usp=sharing

These were obtained from the NJDEP through an OPRA request.

The hearing on November 5 is for the Freshwater Wetlands application.

Application for Freshwater Wetlands

Read full ACTION ALERT for the November 5 meeting on TAPinto

Note:  Files on the Google drive with “2017” contain material from the original application that was withdrawn.  The current applications, submitted June 20, 2018, should be marked as 2018.  Not all files are clearly labeled, however.

ACTION ALERT: NJDEP Hearing Monday, November 5

NJDEP scheduled a Hearing for the Wetlands Permit Application for NESE and Compressor Station 206.  See the attached notice.

Show up to let NJDEP know what you think about the proposed Compressor Station 206 & the pipeline in Sayreville & Old Bridge that is planned to also go through Raritan Bay.

DATE:  Monday, November 5, 2018

STARTING TIME:  6:00 PM

PLACE:  Franklin Twp. High School – Auditorium – 500 Elizabeth Ave., Somerset, NJ 08873

Fact-Finding Meetings: 

  • NJDEP staff will facilitate the meeting.
  • 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.
  • You do not need to be there at 6:00, but if you want to speak, you’ll need to sign-up when you arrive.

Then, NJDEP will give a time period and address for sending them more written comments. 

NJDEP has 90 days after holding fact-finding meetings to issue their decision.

From another hearing, NJDEP provided the following directions:

PUBLIC HEARING RULES OF CONDUCT

The purpose of the hearing is to gather public comment from anyone who wishes to speak. Any action taken by any person that prevents the public from commenting is unacceptable and will not be tolerated. Anyone who violates these rules of conduct may be removed from the hearing.

  • No signs mounted on sticks, or otherwise attached to an object, are allowed within the auditorium
  • No food or drink is allowed within the auditorium
  • Please remain seated until called forward to provide comment
  • No interrupting when someone is speaking
  • No unruly/disruptive behavior (i.e. yelling, chanting, use of foul language)
  • Testimony will be limited to three minutes per speaker

The Department thanks you for your cooperation and participation in this public process

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)

Send comments to the NJDEP

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

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.

SEND COMMENTS TO FERC NOW, AND COPY NJDEP.

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: Ruth.Foster@dep.nj.gov

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

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.

REQUESTED ACTION:  SEND MORE COMMENTS TO FERC

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)

1

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

1a

 

Incomplete DEIS & data dump – missing information + Incomplete DEIS

1b

Incomplete DEIS & data dump – shortcomings of DEIS

2

Public denied opportunity for meaningful commenting (different format)

2

Public denied opportunity for meaningful commenting

 

 

3a

FERC disregarded / dismissed comments: list

3

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

3b

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

4

FERC disregarded comments: air monitoring directly at CS206

4

FERC disregarded comments: air monitoring directly at CS206

5

FERC disregarded comments: validate estimates of chemical emissions

5

FERC disregarded comments: validate estimates of chemical emissions

6

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

6a

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

6b

FERC disregarded comments: Health Impact Assessment (chemical emissions)

7

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

7

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

8

FERC disregarded comments: waste heat recovery

8

FERC disregarded comments: waste heat recovery

9

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

9a

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

9b

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

10

Incomplete DEIS:  ecological impacts – forest removal & wetlands

10

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

11

Incomplete DEIS:  contaminated groundwater – Higgins Farm Superfund Site

11

Incomplete DEIS:  contaminated groundwater – Higgins Farm Superfund Site

12

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

12a

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

12b

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

12c

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

13

Incomplete DEIS:  impact of increased GHGs & methane leaks

13a

Incomplete DEIS:  impact of increased GHGs & methane leaks

13b

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

13c

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

 

 

OTHER ACTION:  TELL NJDEP TO REJECT PERMIT BY JUNE 22, 2018

  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, www.scrap-NESE.org.    Just clearly add your name, address, etc.  The email addresses for the people at the NJDEP are:

Ruth.Foster@dep.nj.gov

Commissioner@dep.nj.gov

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- eric.wachter@dep.nj.gov
Ruth Foster, Office of Permit Coordination- Ruth.Foster@dep.nj.gov

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.

Sincerely,

Your Name________________________________________


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

LINK = https://secure.everyaction.com/zCIcBvMxxkqnqv4Fplm9vw2

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.

2018-05-08 Montgomery Township posts to FERC opposition

Special thanks to Montgomery Township for posting resolution #18-5-112 opposing CP17-101 to FERC on 5/8/2018.  

Includes Memorandum from Montgomery Township Mayor

MT-Mayor_Conforti_Memo

Montgomery Resolution #18-5-112 

MT-Montgomery_res-18-5-112

Map of area where proposed compressor CS206 is relative to Montgomery Township.

MT-map with cs206

FERC acknowledges adverse impact to Princeton Area, but refuses to perform environmental impact analyses.  Instead the Draft Environmental Impact Statement (DEIS) issued by FERC on 3/24/2018 states reasons why FERC doesn’t believe assessing the toxic chemical emissions and high heat/ high discharge of the 50-foot smokestacks.  The DEIS acknowledges real threats, but doesn’t bother to analyze impact or mitigation possibilities – core components of a legitimate DEIS.  The DEIS only underscores that CP17-101 is a Public Threat to New Jersey and not a public convenience.

Montgomery Township and Franklin Township have both sent strong rebukes of the none-material DEIS.  We need more municipalities standing up to this sham to protect the residents of New Jersey.