The Northeast Supply Enhancement (NESE) Project – Pollution without Justification

Williams/Transco is proposing to build a massive new fossil fuel expansion project called the Northeast Supply Enhancement (“NESE”) Project. 

If approved, the project will result in widespread significant environmental harm. The project also poses risks to public health and safety from the resuspension of toxic sediment.   

What is Being Proposed?

  • The construction of: (1) a massive new gas-fired compressor station in Franklin Township, Somerset County, NJ, and (2) a 23.4 mile fossil fuel pipeline that will rip through New Jersey, Raritan Bay, and Lower New York Bay to bring fracked-methane gas from Pennsylvania through New Jersey to New York City and Long Island, NY.   

Williams Failed to Show Need for Project:

  • Williams/Transco failed to justify the project as needed to meet growing energy needs in NYC and Long Island.
  • Williams claims natural gas consumption will increase by 10% over the next decade; however, the company has refused to provide evidence to support this claim and has requested the data be kept from the public record. 

False Demand:

  • 350 Brooklyn produced an independent report that outlines that the project is not needed. The report utterly rejects Williams’ playbook of disinformation and holding energy needs hostage.  
  • NY Independent System Operator (the independent body in charge of tracking NY’s energy demand) and the US Energy Information Administration both forecast a flat or decreased natural gas demand in the region. 
  • The report criticizes the underlying assumptions used by Williams to justify the unneeded pipeline. Williams maintains NESE is needed to meet a growing demand which will be jump-started by upcoming conversions from home heating oil to natural gas. The report shows that virtually all home heating oil customers have already converted years ago.  

Williams Profits Regardless of the Demand for Natural Gas:

  • Even if the project is unnecessary, Williams and Transco will profit. Federal regulations allow for Williams to receive 14% return on the equity of the project regardless of necessity.  

Failed Extortion by National Grid:

  • National Grid is the gas utility contracted to purchase the capacity from the NESE Project. After both the NY Department of Environmental Conservation and NJ Department of Environmental Protection rejected permits for the proposed project in June 2019, the company issued a moratorium on all new natural gas hook-ups until the project was approved. The company even went so far as to pressure its customers to lobby elected officials to get the project approved.  
  • New York regulators investigated whether the moratorium was necessary and found that there was no justification that National Grid could not meet demand unless the pipeline was approved. National Grid was fined 35 million dollars and forced to connect all new customers.  

Prepared by Clean Ocean Action, June 2021

Action Alert – Williams/Transco submitted new applications for the NESE Project to the NJDEP on January 21, 2020

Click here to review new applications

Previously, on November 26, 2019, Williams/Transco withdrew applications for a section 401 Water Quality Certification and permits pertaining to Freshwater Wetlands, Flood Hazard Area, Coastal Wetlands, and Waterfront Development from the NJDEP.

NJDEP has 20 working days (counting the date of receipt as day #1) to issue their decision that the applications are one of the following, and their decision is expected on or before February 18.

  1. Technically + Administratively Complete (thus, “complete for review” as of the date they were received)
  2. Administratively Complete but Technically Incomplete (NJDEP to specifying additional information required + deadline by which it must be submitted)
  3. Administratively Incomplete (NJDEP to return the applications)
  • If the DEP does not issue their decision within the 20 working day timeframe, the applications are considered to be “complete for review” and this starts a decision timeline for a 90 calendar day review period that can be extended by exactly 30 calendar days with agreement by NJDEP and Williams/Transco.

Typically, there is a 30-day period for (a) comments and (b) requests for fact-finding meetings (a.k.a. public hearings) after the receipt of the applications is published in the DEP Bulletin.  

  • The next publication of the DEP Bulletin is expected on February 5 and, if the applications are listed there, that would mean that we have until March 5 to request hearings and submit comments.


We know that there is no way for Williams/Transco to build NESE’s pipeline and compressor station without threatening our water quality, threatened & endangered species, and wetlands. We will continue to fight this dangerous and unnecessary project to the end.

The NESE Project has been stopped twice in New York and twice in New Jersey when 2017 and 2018 applications for permits were withdrawn and/or denied. Now, following the third applications in June 2019, it’s time for the NJDEP to deny the permit applications with prejudice (a.k.a. “for good”).


Many of the concerns of people in NJ & NY have been heard, and they need to be voiced again about the 2019 permit applications.

NJDEP has issued a comment period for the June 2019 applications that ends on August 2, 2019. We’re asking for an extension but, at this time, we do not know if it will be granted.

Attached are sample written comments/points that are relevant to the NJDEP’s current review of applications as well as political points (such as climate change impacts).

We will be adding additional sample comments to the website as we go, so please check back periodically.


  1. Write separate comments for each topic or point.
    • Using the attached comment statements, you could do a “word search” for a topic or concern of interest to you.
    • On the next page is a list of the attached comment topics with provided information.
  2. Choose points from what is provided on the attached comment ideas/points & use them to create your own individual comments by copying/pasting what you want to use into a Word document. Save it.
  3. Include your full name and address at the end of all comment letters.
  4. Send each comment as an attachment (the Word document or that document saved as a PDF) via one email to all of the following – the 2 NJDEP people reviewing the permit applications (Project Managers) while copying others in the DEP who are involved as well as the Governor. (Emails are listed below so that you can copy & paste them into your email.) You could also copy your local State Senators and Representatives.

Send Emails = To NESE Project Managers at NJDEP:


5. For the Subject of your email, copy & paste this into the space –
Comments on NESE – Program Interest # 0000-01-1001.3; Activity #s: LUP 190001 & LUP190002

6. To identify the comment in the document you will attach, write something like the following as your email message:

Dear Mr. Olivera and Ms. Tamagno:

I would like to thank the DEP for its June 5, 2019 denial of Williams/Transco’s prior set of Land Use permit applications. Transco’s new Land Use permit applications – submitted merely one week after the denial – still fail to satisfy the applicable New Jersey statutes and regulations, including New Jersey’s stringent requirements for issuing a Water Quality Certificate under Section 401 of the federal Clean Water Act.

For accountability, public participation, and use of science-based decision-making, the following comments are provided for consideration during the current comment period for the June 2019 applications by Williams/Transco for the following permits for the proposed Northeast Supply Enhancement Project: Freshwater Wetlands Individual Permit with Section 401 Water Quality Certification, Flood Hazard Area Individual Permit and Verification, Waterfront Development Individual Permit with Section 401 Water Quality Certification, and Coastal Zone Management Act Consistency Determination.

However, this 30-day timeframe is inadequate because the application material is only available for review during business hours in paper format, and this precludes true accessibility for those who cannot spend time at the Municipal Center or NJDEP’s office for reasons that include work, family care and/or disability.

Thus, in addition to considering my comments, I am asking for (a) an extension of the comment period for an additional 45 days beyond August 2 for sending you comments as well as (b) posting of the application material in a web-accessible format on the DEP website. This should not be difficult since Williams/Transco provided the DEP with all application material on a DVD in late June/early July.

7. Then, attach your comment as a Word document or PDF.

Comment Topics – Elaborated Points are in the attached dociments.

(1) Construction of the NESE Project threatens water quality, increased stormwater flooding, and threatened & endangered species.


A. Construction of a stormwater basin at the proposed Compressor Station 206 site does not include complete plans that account for the specific soil type that exists there.

B. Impacts to the habitat for the State threatened barred owl as well as protected vernal pool habitats at the proposed Compressor Station 206 site were not adequately assessed or avoided.

C. Construction Schedule of the Raritan Bay Loop was reduced from 12 months to 7 months

D. A shortened timeline increases the intensity of work, so the overall impacts will be magnified.

E. Noise Impacts from Pile Drivings – It is not clear if the construction schedule for these activities has changed with the compressed construction schedule for the Raritan Bay Loop, but the requests for harassment have increased.

F. Dredging up toxics has not been avoided by construction of the Raritan Bay Loop, and this will likely cause long-term harm that was not accounted for in the applications.

G. To reach a conclusion that the impacts on water quality would be short-lived, temporary and localized neglects to consider the unusual tidal flows in Raritan Bay, the chain-reactions from destroyed habitat and food sources for marine life, and the contamination of food sources for marine life and people.

H. NESE’s Raritan Bay Loop’s Undisputed, Devastating Impact on Shellfish Beds and Benthic Communities

I. Williams/Transco has not sufficiently identified permanent, temporary, and secondary/indirect impacts from onland construction, and they have not shown plans to avoid and/or mitigate these impacts.

  • Acid Producing Soils
  • Construction through or near Superfund Sites & other toxic sites

(2) Williams/Transco did not demonstrate that there are no practicable alternatives to avoid impacting exceptional resource value wetlands and their transition areas.


(3)  Williams/Transco did not demonstrate a “compelling public need” for the NESE Project that meets requirements of NJ’s Freshwater Wetlands Protection Act Rules at N.J.A.C. 7:7A-10.4 or, alternatively, demonstrate an extraordinary hardship from denial of a permit.


The NESE Project does not serve an essential health or safety need of the municipality in which it would be constructed, and its proposed use does not serve existing needs of residents of the State.

  • Air Quality & Health Impacts
  • Safety Risks – Fires or Explosions

Additionally, the “need” for the NESE Project has been refuted by reports, and the needs of the State that are currently focused on fighting climate change impacts would be harmed by the NESE Project despite claims by Williams/Transco about “benefits” to New Jersey.

(4)  NESE is not in the Public Interest.


  • need to preserve natural resources
  • relative extent of the public and private need for the regulated activity
  • practicability of using reasonable alternative locations and methods
  • economic value
  • ecological value of the freshwater wetlands and probable impact on public health and fish and wildlife.

(5)  Contaminants that would be unearthed, suspended and redistributed in the Raritan Bay exceed “acceptable” levels. Exceedances were found by the NYSDEC for heavy metals (copper & mercury) in New York waters, too. Thus, construction of the Raritan Bay Loop of the NESE Project would (a) negatively impact surface water quality, and (b) harm threatened and endangered species and their habitat. Additionally, the shortening of the in-water construction schedule raises serious concerns about impacts from increased vessel traffic and noise as well as adhering to time-of-year restrictions to protect threatened and endangered species if the schedule needs to be altered due to unforeseen circumstances. Furthermore, the unique tidal flows in the Raritan Bay do not seem to have been given appropriate consideration.


(6)  Other Concerns about In-Water Construction

  • Time of Year Restrictions
  • Thermal Discharges


(7)  There is a Questionable “Need” for additional natural gas in National Grid’s NY area.


(8)  There is no real consideration of climate crisis-mitigating renewable alternatives by the Federal or State agencies. Additionally, the impact of the NESE Project on climate change effects should be considered in light of the threats facing New Jersey as well as the State’s goals to reduce greenhouse gases.


(9) Misleading and incomplete information in the Factsheets provided by Williams/Transco



On June 10, 2019, five days after NJDEP denied permits for the NESE Project, Williams/Transco submitted new applications to NJDEP for a Freshwater Wetlands permit with 401 Water Quality Certification, Flood Hazard Area individual permit and verification, and Waterfront Development permit with Section 401 Water Quality Certification.

Attachments about the June 10, 2019 applications:  


Once these new applications are published in the DEP Bulletin, we have a 30-day period to send comments & request hearings.  

Comment talking points will be posted soon.

ACTION ALERT: New York State Department of Environmental Conservation (NYS DEC) extended the comment period on Williams/Transco’s 5/17/19 reapplication for a Water Quality Certification to July 13, 2019.

ACTION ALERT: New York State Department of Environmental Conservation (NYS DEC) extended the comment period on Williams/Transco’s 5/17/19 reapplication for a Water Quality Certification to July 13, 2019.

Williams/Transco’s application for a Water Quality Certification (WQC) was rejected by NYS DEC on May 15, 2019, because: Williams/Transco re-applied on May 17.
*the pipeline “would result in greenhouse gas (“GHG”) emissions, which cause climate change and thus indirectly impact water and coastal resources.” When Williams re-applied on May 17, 2019, it responded that, “without agreeing that this comment is relevant to the Water Quality Certification,” building the NESE would reduce GHG emissions. To make this claim, Williams hypothesized that if all 400,000 dekatherms of the gas delivered through the pipeline in an entire year were burned in boilers that would otherwise burn #2 fuel oil, 2.80 million metric tons less carbon dioxide equivalents would be emitted in a year.
*construction would cause “mortality, injury, or temporary displacement of the organisms living on, in, or near the 87.8 acres of seafloor directly affected by the Project”

*construction of the NESE “would have major impacts to habitats due to the disturbance of shellfish beds and other benthic resources.”
In Williams’ re-application submitted on May 17, 2019 (“WQC Application”), it responded that, while indeed, construction of the proposed pipeline would indeed destroy whatever shellfish beds lay in its path, it would offer “compensatory mitigation.” Williams would give $3.4 million to the Long Island Shellfish Restoration Project, a NYS project that seeks to restore native shellfish to Long Island.
*the construction schedule did not provide any buffers that would keep it from impinging on “time-of-year” restrictions to protect threatened & endangered species should Williams encounter any delays. These restrictions ensure that vulnerable species can migrate and spawn without impediment. In New York State, the time-of-year restriction runs from January 1 through the end of April. Construction delays could result from an extreme weather event, equipment failure, an unexpected difficulty with seafloor geology, etc. In its re-application on May 17, 2019, Williams responded that it had made the construction plan shorter to ensure that it wouldn’t impinge on the migration and spawning of sensitive marine species. It did so by hiring more construction equipment that would operate simultaneously along the length of the planned route. Williams now says it would complete the offshore portion of the NESE project in seven months, with an extra month available if there are delays. Yet at the same time, Williams is promising to slow down the dredging process in some areas to address DEC’s concern that toxic contaminants will be released at levels that exceed the state’s water quality standards. In short, the construction schedule is not credibly designed to ensure that the project meets water quality standards.
* “most notably . . . water quality standards for both mercury and copper are projected to be exceeded in certain areas in New York State waters.” The DEC also noted “significant water quality impacts from the resuspension of sediments.” When Williams re-applied on May 17, 2019, it responded that at points along the construction path where mercury and copper would be particularly prevalent, it would slow the dredging and, with regards to mercury, also halt it completely for 1 hour at each ‘slack-tide’ period (i.e, the high tide and low tide intervals). Williams claimed that this would resolve the DEC’s concerns about mercury and copper. Williams also offered new information that asserted that the total suspended solids generated by filling in the trench at certain spots would be significant only close to the sea floor.


Here are four-sample comment prompts that have background information to make it easy to submit a comment to the DEC:

**Keep an eye out for more comment prompts over the next month**

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


Information About FERC’s Incomplete and Misleading DEIS

Click to open PDF documents containing the following information:

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


Montgomery Resolution #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.


2018-03-23 FERC Issues DEIS

The Federal Energy Regulatory Commission issued the Draft Environmental Impact Statement today, March 23, 2018.

The link below is a read only share of the DEIS which has two parts (Part 1 and Part 2).  Additionally, we have several sections extracted from the main DEIS document such as the table of contents.  Extracted files being with Part1-extract-description.

FTTF March 2018 update to Franklin Township Residents

Proposed Compressor Station 206
Franklin Township Task Force March 2018 Update

— Without Franklin Township resident involvement,
this project could soon become a reality.  —



  • Groups from New Jersey and New York City are having weekly meetings to coordinate for the Draft Environmental Impact Statement (DEIS) release from the Federal Energy Regulatory Commission (FERC).
  • FERC indicated it will release the DEIS in March 2018.
  • Franklin Township Task Force (FTTF) published compilation of chemicals released by CS206 on a yearly basis and the health impacts. (See link

How you can make a difference for Franklin Township

  • Register as an intervenor on FERC & comment. (For instructions & sample comments, see link
  • Coordinate with FTTF to contribute analysis of DEIS (assist in reading and interpreting sections).  Email stopftcompressor (at) yahoo (dot) come
  • Learn and spread the word of the dangers from the project.
  • Outreach to neighbors, friends and organizations
  • Attend workshops and public hearings.  Talking points will be provided.


Countdown to Compressor station being built