ACTION ALERT: Comment Period Extended to August 23

The fight against Compressor Station 206 and the pipeline in the Raritan Bay is not over! 

Williams/Transco still needs permits from NJDEP and the NY State Department of Environmental Conservation (NYSDEC) to receive FERC’s permission to begin construction. 

  • The earlier permit applications to NJDEP were withdrawn or rejected – 6/23 & 7/10/17 applications withdrawn on 6/15/18 > new applications submitted 6/20/18 > denied by NJDEP on 6/5/19 > new applications submitted on 6/12/19. 

It has been over 3 years since the opposition to the NESE Project began, and there’s still hope that the NJDEP will do the right thing and reject the third set of applications from Williams/Transco for permits since they fail to meet State requirements for the permits

  • The June 12, 2019 applications to NJDEP still do not meet NJ regulations by showing a “compelling public need” for the NESE Project. 
  • They still include harms from construction of the pipeline to our surface water quality, marine life, and threatened & endangered species and their habitats. 
  • The proposed infiltration basin for the compressor station site still does not meet required regulations. 
  • Operations would guarantee decades of toxic air pollution from the compressor station. 

See attachments: NJDEP’s deficiency letters

Now is the time to make it known that you expect the NJDEP to deny the water permit applications that they received on June 12, 2019 for the NESE Project. 

YOUR COMMENTS ARE NEEDED!  Click the button below to submit your comments through the Action Network by the extended deadline of August 23.

SUBMIT COMMENTS

ACTION ALERT – SEND COMMENTS TO NJDEP BY AUGUST 2, 2019

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Project has been stopped twice in New York and twice in New Jersey when 2017 and 2018 applications for permits were withdrawn and/or denied.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”).

YOUR COMMENTS ARE NEEDED!

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.

Recommendations:

  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:

Stephen.Olivera@dep.nj.gov
Joslin.Tamagno@dep.nj.gov

cc:

Commissioner@dep.nj.gov
Ruth.Foster@dep.nj.gov
Christopher.Jones@dep.nj.gov
Diane.Dow@dep.nj.gov
Ginger.Kopkash@dep.nj.gov
Constituent.relations@nj.gov

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.

OPEN PDF OF COMMENT 1

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.

OPEN PDF OF COMMENT 2

(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.

OPEN PDF OF COMMENT 3

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.

OPEN PDF OF COMMENT 4

  • 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.

OPEN PDF OF COMMENT 5

(6)  Other Concerns about In-Water Construction

  • Time of Year Restrictions
  • Thermal Discharges

OPEN PDF OF COMMENT 6

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

OPEN PDF OF COMMENT 7

(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.

OPEN PDF OF COMMENT 8

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

OPEN PDF OF COMMENT 9

ACTION ALERT: Stop NESE – 3 Quick Actions You Can Take Today!

Call to Action: Stop NESE last quick action to FERC prior to FEIS issuance scheduled for 1/25/2019

As we rapidly approach the scheduled release of the FEIS for CP17-101, the question arises, “What can people do to make any impact for stopping this atrocity project from occurring?”

We are calling for the coalition to please take action and reach out to others to take action in the next 20 days leading up to the scheduled FERC FEIS (Final Environmental Impact Statement).  This is the last time where the public will have any meaningful impact on the FERC process. 

We developed 3 quick actions with sample messages that will have impact, especially with more people doing the actions.  Even New York and Pennsylvania people can voice in on these issues.  This might be NJ focused on impact, but the reality is, the more people voicing in, the more force we raise to FERC.

If NY folks have quick bullets of major FERC omissions at this point, please send them on.

Quick 5 minute actions

  1. Call and email Senator Smith (senbsmith@njleg.org, (732) 752-0770, @SenatorBobSmith).
    Bill SR94 sitting in Env & Energy committee that he chairs for more than 5 months.
    Sample message: https://drive.google.com/open?id=1dE1ROHaj94R1YK9rG3a0_XHS_mcJ1GfYSkypkBx4hv0
  2. Call and email Assemblyman Wayne DeAngelo (asmdeangelo@njleg.org, (609) 631-7501; @DeAngeloLD14).
    Bill AR164 sitting in Telecommunications & Utilities that he chairs for more than 5 months.
    Sample message: https://drive.google.com/open?id=17ZGOTMOd6GHNOwWXWJ0NCxFwqvzpFb9n7flgjnGQnII
  3. Send comment to FERC and copy your legislators urging FERC to heed impacted residents and municipalities.
    1. Reference Franklin Township 12/20/2018 FERC Submission including FTTF Memo:
      FERC: https://elibrary.ferc.gov/idmws/search/intermediate.asp?link_file=yes&doclist=14731233
      Also available on our GoogleDrive: https://drive.google.com/open?id=1FVbdYd9S_iwliWl85fjInFBKt7g_ChRV
    2. Sample Letter: 
      https://drive.google.com/open?id=1rALfYAamSenn73q1FmN8_jrBC1ZpsIUzwRtTUiypmtg

In addition to Franklin Township sending the FTTF Memo to FERC, South Brunswick sent the attached memo to FERC right at the end of 2018.  Waiting for Montgomery and Princeton to do the same, if you live in those areas, please encourage them to do so.

We have come 2 years fighting this project and we have delayed FERC twice.  That is significant.  It is from this coalition and all the actions from the public that the coalition has influenced that enabled the delays.  Let’s capitalize on that and go out with a bang prior to the issuance of the FEIS scheduled for 1/25/2019!

A number of us on FTTF have continued through the last half of 2018 sending comments to FERC, calling elected officials and actively pressing back on Transco even in Twitter.

We urge all the communities engaged to please help residents take this last set of actions prior to the FEIS (including Princeton Manor, Princeton Highlands, Princeton Walk and Princeton University teams)

The FTTF steering committee team would like to wish you Happy New Year and with your help, maybe free of the threat of NESE.

Action Alert – NJDEP Update

NJDEP has heard from us about issues with the Freshwater Wetlands Permit Application. 

  • See the attached transcript of the comments (PDF) at the November 5, 2018 hearing at Franklin High School.
  • By November 20 (the deadline to send comments to NJDEP about this permit), over 1,000 comments were sent. 

NJDEP is still reviewing the permit applications and asking Williams/Transco for more information.  Permits are needed from NJDEP for Freshwater Wetlands, Flood Hazard Area, Coastal Wetlands and Waterfront Development.

  • None of the applications have been deemed to be “technically complete”.
  • Applications were received by the NJDEP on June 20, 2018, and they have one calendar year to either grant or deny each permit.

NJDEP stated that there will be another hearing, but the details have not been publicized.  We suspect that the next hearing will be in Old Bridge or Sayreville.

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: 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

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.

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.