“It is horrifying that we have to fight our own government
to save the environment.”
– Ansel adams

Latest Impact Statements from Clean Ocean Action



NJDEP has the ability to “protect, conserve and manage the natural resources of the State, which are by law precious and invaluable public resources held by the State in trust for the benefit of the public; and the rights of the people of the State to enjoy their natural resources free from interference by pollution and contamination.”
~From of the suit filed against E.I. DuPont DeNemours & Co. by the State of New Jersey on 03/27/19 for the Parlin site (#208 on pages 61-62)
Accessed at: https://www.nj.gov/oag/newsreleases19/Parlin_Filed-Complaint_and_Jury-Demand.pdf

Construction of the NESE Project would directly affect wetland soils, vegetation, and wildlife habitats – both onshore and in the waters, and it could affect hydrology characteristics.


Williams/Transco says that construction of NESE would impact the following:

In-water Raritan Bay Loop (NJ & NY waters):

  • 14,165.5 acres surface water’s workspace
  • 87.8 acres direct disturbance of seafloor
  • 947.4 acres spread of unearthed toxins (at least 0.12”) on the seafloor
  • 8.1 miles of the FWS-designated Raritan Bay-Sandy Hook Bay Significant Habitat Complex would be crossed by pipeline installation
  • 7 prime fishing areas crossed in the workspace of the Raritan Bay Loop
  • 1,091,734 cubic yards of sediment (some = toxic) excavated during offshore pipeline installation (not including backfill?)
  • 461 cubic yards of sediment to create a pit to contain the estimated 788 gallons of drilling fluid and cuttings that would be generated during the HDD process for the Long CP Power Cable and Subsea Anode Sled
  • 3,489,482 gallons of seawater used for hydrostatic testing of the Raritan Bay Loop

On land, construction of the Madison Loop & Raritan Bay Loop Pipelines and the Compressor Station 206 site (including access road + pipeline tie-ins) would impact:

  • 65.8 acres of vegetation
  • 37.1 of open vegetation
  • 28.7 of upland forest
  • Approximately 10 acres of 11 wetlands


  • Potential for fires and explosions at compressor station and in pipelines
  • Increased volume of gas through pipelines that are over 50 years old that will be run hotter and faster & possibility of quicker rate of corrosion & unexpected cracks, leaks and explosions
  • soil compaction which causes alterations in natural hydrological patterns and may inhibit regeneration of cleared vegetative species.
  • Noise and emissions during construction
  • Unearthed toxins (onland and from under the seafloor) spread
  • Destruction of habitat for marine life and wildlife
  • Destruction of benthic communities in the water
  • Disruption of migration of fish & marine life
  • Vessel strikes to marine mammals during offshore construction
  • Construction near Superfund Sites
  • Leaking fluid during construction
  • Constant noise & toxic emissions at nearly 850°F at the compressor station


  • marine mammals
  • boating
  • fish
  • fishing
  • shellfish – clams
  • sightseeing
  • horseshoe crabs
  • recreational enjoyment of the outdoors
  • benthic communities
  • whale watching

Threatened or Endangered Species that will be in harm’s way during construction of NESE:

  • Atlantic sturgeon
  • Osprey
  • Humpback whale
  • Bald eagle
  • North Atlantic right whale
  • Barred owl
  • Fin whale
  • Black-crowned night heron

The workspace associated with construction of the Raritan Bay Loop would cross seven recreational fishing grounds including Tin Can, Scallop Ridge, Between the Channels, Gong, Unnamed Fishing Channel, Ambrose Channel, and Sandy Hook Channel. These areas are located in New Jersey and New York state waters between the Sandy Hook and the Rockaway peninsulas and are designated as “prime fishing areas” by New Jersey (NJAC 7:7-9.4).

In the water, construction would unearth toxins that have been buried beneath the seafloor will be unearthed and spread into the water and, possibly, on the shoreline. Some toxins & organic compounds in the seafloor sediment include mercury, copper, lead, zinc, arsenic, PCBs, DDT & dioxins.

Benthic communities will be killed by dredging, anchoring & redistribution of dredged seafloor sediment. Williams/Transco has proposed to pay 25 cents per clam to New York for destroying these populations, at a total of 3.4 million dollars, to be used for an oyster project at the other end of Long Island rather than something that would improve the water quality in Raritan Bay & Lower New York Harbor.

Hydrostatic testing of the pipeline below the seafloor would use approximately 3,489,482 gallons of seawater, and this process will kill some organisms – Smaller organisms could become trapped (entrained) on the mesh screen that will be used, and larger organisms could be impinged on the screen.

Harassment & Injury of Marine Mammals:

Williams/Transco has applied for permission to cause disruption of behavioral patterns, including, but not limited to, migration, breathing, nursing, breeding, feeding, or sheltering [Level B harassment] for marine mammals that would be caused by pipeline construction sound in the water as well as Level A harassment which has the potential to injure a marine mammal (permanent hearing loss in a portion of the underwater sound frequency spectrum).

According to Williams/Transco’s latest calculations (Draft Incidental Harassment Authorization requests – June 5, 2019 submission to FERC), the request is for “takes” resulting from:

Level A acoustical injury for:

  • 7 gray seals
  • 16 harbor seals

Level B acoustical harassment for:

  • 826 gray seals
  • 1,780 harbor seals
  • 4 harp seals
  • 5 fin whales = endangered (Federal, NJ & NY)
  • 30 humpback whales = endangered (NJ & NY)
  • 1 minke whale
  • 2 North Atlantic right whales = endangered (Federal, NJ & NY)
  • 6,331 bottlenose dolphins
  • 95 common dolphins
  • 11 harbor porpoises = species of concern in New York and New Jersey state waters

NOTE: The 6/5/19 numbers of marine mammals anticipated to be harmed by construction of NESE’s Raritan Bay Loop are much higher than those that were presented to FERC in the 6/6/17 Draft Incidental Harassment Authorization request.

– Two years ago, Williams/Transco did not anticipate any Level A takes.
– Level B harassment authorization requests made on 6/6/17 were:

  • 15 gray seals
  • 32 harbor seals
  • 4 harp seals (no change in # compared to 6/5/19 request)
  • 0 fin whales
  • 0 humpback whales
  • 0 minke whale
  • 0 North Atlantic right whales
  • 46 bottlenose dolphins
  • 20 short-beaked common dolphins
  • 4 harbor porpoises


Compressor Station 206 is proposed to be built next to the Higgins Farm Superfund Site. The Madison Loop is planned to be constructed within ¼ mile of sites with soil and/or groundwater contamination, and two of these sites (*) are also within ¼ mile of the onshore Raritan Bay Loop.

  1. Road Department Garage Area 3-1
  2. Global Sanitary Landfill Superfund Site
  3. Morgan Ordnance Depot
  4. 1788 Route 35 in Sayreville, NJ *
  5. Morgan Fire House*
  6. E.I. DuPont DeNemours and Company site

Additionally, cleanup Areas 7 and 11 (Jetty Sector) of the Raritan Bay Slag NPL site are located within NESE’s proposed construction area in Raritan Bay.

Construction of the Madison Loop is planned to go through acid-producing soils which, when exposed to the air from trenching, the sulfide minerals in the clays oxidize and produce sulfuric acid. Results = poor possibility of re-vegetation in these areas & likely problems with stormwater runoff & erosion.

Construction of the pipeline in the Raritan Bay and Lower NY Harbor would unearth & spread toxins that have been buried beneath the seafloor for years. Levels would exceed standards for mercury & copper. Other toxics that would be disturbed & distributed in the waters include: arsenic, lead, zinc, PCBs, DDT & dioxins.

See Comments by, Clean Ocean Action & National Resources Defense Council about the permit applications to NJDEP which were denied without prejudice on 6/5/19. Of note: Williams/Transco submitted new applications for permits to the NJDEP on 6/10/19.