Main Points to Make in Comments to FERC

June 11, 2018

  • The conclusions in FERC’s DEIS were not based on independently verified data that accounted for the entire range of predictable costs and potential impacts.
  • The conclusions in FERC’s DEIS were made with incomplete, misleading and sometimes inaccurate information.
  • The conclusions of FERC in the DEIS are not well-supported.
  • The complete impacts from the NESE Project could not be assessed at the time of the DEIS.
  • There was no presentation of data about current conditions and modeling of potential impacts in the DEIS. 
  • There was no scientific basis provided to support FERC’s assertions that “plans” to minimize or mitigate impacts would be effective since site-specific details and analyses were not provided in the DEIS.  For “mitigation measures”, FERC vaguely references undetailed measures supposedly provided in earlier documents without providing reference to source documents and their own independent evaluation of potential environmental/social impacts and required actions to avoid or minimize these impacts from the NESE Project. 
  • FERC’s DEIS was not based on a complete economic analysis of the entire range of benefits and harms, and it did not fulfill NEPA requirements or FERC’s Policy Statement to fully and fairly consider the economic issues of the Project. 
  • The public was denied the opportunity to use the DEIS to form meaningful comments to participate in the environmental review process since (a) there was a great deal of missing information, (b) FERC wrote about information provided in earlier documents without providing summaries or guides to locate it, (c) a great deal of additional information was provided to FERC on May 11 and again on May 30, 2018 that could not possibly have been reviewed and considered by the public within the timelines imposed by FERC, and (d) all concerns raised by the public during pre-filing and post-application were not all addressed and, when addressed, did not include supporting evidence to justify conclusions. 
  • Given the misleading and deficient components of the DEIS that was published by FERC on March 23, 2018, as well as the vast amount of additional information provided by Williams/Transco on May 11 and May 30, the March 23, 2018 DEIS should be rejected, revised, and re-published by FERC in a supplemental/revised DEIS that addresses (a) all concerns raised by the public with supporting evidence for dismissing or minimizing the concerns, if this is still done by FERC, as well as (b) the added information provided by Williams/Transco on May 11 & May 30, 2018 with FERC’s independent evaluation and analyses.
  • With a revised/supplemental DEIS, FERC should also allow at least another 45 days for the public to fully participate in this environmental review process.

Be sure to send copies of all comments to the NJDEP as an email attachment with a request that the NJDEP deny the Freshwater Wetlands permit application for the Northeast Supply Enhancement (NESE) Project before June 22, 2018.


FERC minimized or disregarded comments and requests from the public, legislators and municipality officials about potential environmental or health danger/damage prior to the issuance of the DEIS and during the DEIS comment period without providing reasons with supportive scientific, data-driven studies.  These include requests for the following:

  • safety analysis of increased velocity of natural gas through Mainlines A and C from the proposed Compressor Station 206
  • require air quality monitoring put in place at the Compressor Station 206 site prior to the issuance of the FEIS and for the lifetime of the CS206 to monitor all chemical emissions identified in the certificate application from CS206 were ignored in the DEIS
  • validate chemical emissions of Compressor Station 206’s ‘estimated’ emissions from existing Solar MARS 100 compressors
  • perform a Heath Impact Assessment (HIA) for those in the area around Compressor Station 206 with measurements of complete emissions including heat, exhaust volume and hazardous air pollutants (highly toxic airborne chemicals)
  • modeling of the impact of year-after-year impacts on the proposed Compressor Station 206 along with all associated buildings and pipeline at the site
  • explore enhanced energy regeneration/efficiencies that could reduce heat emissions from Compressor Station 206


  • In the DEIS, FERC failed to completely analyze the environmental, social and economic adverse impact that will result from disturbances in/by the Raritan & Lower New York Bays on the greater community and habitat.
  • In the DEIS, FERC failed to provide a realistic analysis of specific ecological impacts associated with loss of forest and wetland habitat.
  • In the DEIS, FERC did not consider groundwater mounding at the proposed stormwater basin at the CS206 site and how this might impacts the groundwater contamination plumes at the Higgins Farm Superfund Site.
  • In the DEIS, FERC failed to completely analyze the short- and long-term potential impacts of construction activity on the environment in and around the Raritan & Lower New York Bays from marine vessel traffic, noise, and toxic sediment disturbances.
  • There was no analysis of predicted impacts from increased Greenhouse Gases and methane leaks and emissions as impacts from the NESE Project on the area.
NOTE:  There is still much missing information, and FERC asked for a lot of this to be submitted before construction. 
That is too late for the public to be able to provide meaningful comments as part of the environmental review process.