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

ACTION ALERT: Urge NJ DEP to Withdraw the Air Pollution Control Permit

ACTION ALERT

Urge NJDEP to withdraw the air pollution control permit (Permit Activity Number: PCP170001; PI Number: 36396) and require  Williams/Transco to submit a new air pollution permit application that will need to adhere to the new, more protective thresholds.

Use the attached letter to tell NJDEP that you want them to withdraw the Air Pollution Control Preconstruction Permit and  Certificate to Operate Construction of a New Source that was issued to Williams/Transco on September 2017.

Letter to send to NJDEP:
   –Snail Mail (docx)
–Email (docx)

  • Send it to the list of people at NJDEP provided below.
  • Review the memo that Franklin Township’s Town Manager sent to the NJDEP on August 28, 2018 for more details.

BASIS FOR REQUEST = REGULATIONS OF NJDEP

N.J.A.C. 7:27-8, “Permits and Certificates for Minor Facilities”

  • Section 8.16 – Revocation:
    (b)    The Department may withdraw its approval of a preconstruction permit or permit revision if the permittee:
    1. Does not begin the activities authorized by the permit or permit revision within one year from the date of its approval
  • Section  8.13 – Conditions of approval:
    (b)  The Department may change the conditions of approval of a certificate:
    3. At any time during the period a certificate is in effect, if the Department determines that such change is necessary to protect human health or welfare or the environment.

SEND LETTER VIA EMAIL OR SNAIL MAIL TO:

Catherine R. McCabe, NJDEP Commissioner Commissioner@dep.nj.gov
401 E. State St.
7th Floor, East Wing
P.O. Box 402
Trenton, NJ 08625-0402

Ruth W. Foster, PhD., P.G., Acting Director Ruth.Foster@dep.nj.gov
Office of Permit Coordination and Environmental Review
401 East State Street
PO Box 420
Trenton, NJ 08625

Kenneth Ratzman, Assistant Director – Air Quality Regulation & Planning Kenneth.Ratzman@dep.nj.gov
Bureau of Stationary Sources: Regulation & Planning
401 E. State Street, 2nd Floor;  P.O. Box 420
Mail Code 401-02
Trenton, NJ 08625

Office of Governor Murphy constituent.relations@nj.gov, madeline.urbish@nj.gov
P.O. Box 001
Trenton, NJ  08625

NJDEP’s commitment is to assist in preserving, sustaining, protecting and enhancing the environment to ensure the integration of high environmental quality, public health and economic vitality in partnership with the general public, businesses, environmental communities and government entities through aggressive environmental protection and conservation efforts; and

The proposed Northeast Supply Enhancement (NESE) Project is incompatible with the State’s goal to reduce emissions by 80% from the 2006 baseline by 2050 or Governor Murphy’s Executive Order 28 goal for the State to use 100% clean energy sources by January 1, 2050.

Though the NJDEP issued an air pollution control permit to Williams/Transco for the proposed Compressor Station 206 on September 7, 2017, they have the power to withdraw this permit and require Williams/Transco to submit a new application that will require adherence to stricter (more protective) air pollution standards.

Note that the NJDEP adopted stricter air pollution control standards that went into effect in February 2018 to protect human health, and the anticipated Hazardous Air Pollution (HAPs) emissions from one compressor unit for the NESE Project exceed all of them.  At this facility, there will be two compressor units.  The permit was issued under older standards, and the permitting was for each compressor unit separately.

Emissions of caustic chemicals predicted by Williams/Transco for two (2) Solar MARS 100 turbines

at proposed Compressor Station 206 with the NJDEP Reporting Thresholds (old & new)

EMITTED CHEMICAL

POUNDS PER YEAR

To be emitted

from Compressor Station 206

Reporting Thresholds (NJDEP)

new

old

from one turbine

from two turbines

N.J.A.C. 7:27-17.9

N.J.A.C. 7:27-8

(February 12, 2018)

(February 27, 2015)

Formaldehyde

334

668

3.5

400

Acetaldehyde

44

88

21

1,800

Acrolein 

7.02

14.04

1

8

Benzene

13.18

26.36

6

87.6  (0.01 lbs/hour)

Ethylbenzene

35.2

70.4

19

2,000

Naphthalene

1.428

2.856

1.4

2,000

Propylene Oxide

31.8

63.6

12

1,000

Toluene

142.5

285

2,000

Xylenes

70

140

2,000

Ammonia

14,790 *

29,580 *

* No threshold standards

Though FERC decided that there was no need to complete a Health Impact Assessment for people around the proposed Compressor Station 206 site, they still expect to issue a final Environmental Impact Statement on January 25, 2018 without:

  • Clarifying misrepresentation of emission estimates from Williams/Transco for CS206
  • Assessing toxic impact to nearby environment, human health and water pollution
  • Assessing local air quality impact on MARS 100 combustion efficiency and emissions
  • Validating actual chemical and greenhouse gas emissions using Natural Gas mixtures in Williams/Transco lines in the New Jersey/Pennsylvania area
  • Obtaining actual emissions of MARS 100 turbines in the New Jersey/Pennsylvania area.  Data used is obtained from Solar test runs in lab located in San Diego, California.
  • Revising environmental impacts from toxic chemical emissions recently issued in research studies directly correlating human health impacts and immune disorders with natural gas fired compressor turbines.

THUS, WE ARE RELYING ON THE NJDEP TO ACT TO PROTECT OUR HEALTH.

Reasons for withdrawing the air pollution control permit:

  • Transco applied for the NJDEP CS206 air compressor emissions air permit on January 6, 2017.   NJDEP approved Transco’s air permit application on September 7, 2017, based on Williams/Transco’s wording in dialogue with NJDEP with misleading emission estimates and no actual emission data.  NJDEP permit application correspondence with Williams/Transco indicates that NJDEP did not evaluate or cross reference estimates and NJDEP did not detect the emission reporting irregularities in the data provided by Williams/Transco.
  • Williams/Transco received their air pollution permit before stricter air quality standards in N.J.A.C. 7:27-17.9 were operative in February 2018.  These new, lower reporting thresholds for Hazardous Air Pollutants (HAPs) were adopted due to the rapid decrease in air quality and the urgent need to tighten air emissions in New Jersey. 
  • In the NJDEP permit application and also included in Williams/Transco’s application to FERC were test results provided by Solar for two (2) test runs on Solar Mar 100 units.  Testing was performed in Solar’s labs located in San Diego, CA.  Test run results indicate a high dependency with temperature producing a highly variable emission output.  Tests did not account for the impact of environmental factors such as relative humidity, air quality and elevation at the actual proposed site on the natural gas combustion despite having significant impact and consequential emissions of chemicals and greenhouse gasses.  Additionally, data was missing in the emissions reporting of each test run.  Additionally, Solar, FERC, and Williams/Transco did not consider or assess the difference between the location where test runs were performed (San Diego, CA) versus the target location where the Compressor Station 206 is proposed to be installed (Franklin Township, NJ).  Neglecting the factors of installation location air quality, relative humidity, temperature patterns and elevation at the proposed CS206 site means that to date, there is no legitimate estimate of emissions or chemical and greenhouse emissions for MARS 100 turbines installed at the proposed location.
  • NJDEP did not receive any actual data of existing MARS 100 turbines (CS206 proposes 2 MARS 100 turbines) from existing MARS 100 turbines deployed along Williams/Transco’s pipelines throughout Pennsylvania, which would have a much more accurate representation of emissions for the CS206 proposed location.
  • Without current air quality measures at the proposed location, the emissions estimates have no bearing or accuracy for actual emissions at the proposed location.
  • Humidity and ambient air quality directly impact combustion, yet data was only provided for 60% humidity, and the ambient air quality measures were not taken at the immediate site that is next to an air polluting facility (Trap Rock Quarry).
  • In the FERC application, Williams/Transco provided emission estimates on one table claiming estimates were for both turbines and on a table one (1) page later showing emissions represented a single turbine.  The emissions for VOCs turned out to be for one (1) turbine.  Additionally, some of the emissions were inconsistent with emission estimates provided by manufacturer emissions. 
  • Test run data and Specification Sheets provided by Solar, show that both RPM and HP are lower at higher (average: 59°F) temperatures which suggests that combustion is converting less fuel to energy.  This indicates there is a possibility that increased unburned fuel, primarily Methane, would be released as exhaust.
  • Solar does not warranty emissions for SO2, PM10, PM2.5, VOC and formaldehyde according to their Predicted Emission Performance pages.  This means that the Solar MARS 100 emissions of SO2, PM10, PM2.5, VOC and formaldehyde are highly variable and subject to environmental and variability of older combustion technology used in MARS 100 turbines.
  • Williams/Transco referenced air quality monitors used for the ambient air quality readings that were not the closest monitors to the proposed Compressor Station 206 site, and wind direction is a relevant factor.  For example, there are monitoring stations at Edison’s EPA building and at the Rutgers station at Cook College which are closer than Elizabeth, NJ or Philadelphia, PA.
  • NJDEP did not indicate any validation or analyses of the Ammonia emissions, which is estimated under San Diego generated test runs to be 29,580 pounds per year.
  • If Volatile Organic Compounds (VOCs) are higher, or other contaminants such as Particulate Matter (PM2.5 and PM10) are higher in New Jersey than where the testing occurred and the efficiency of combustion conversion to energy is reduced; then it is very likely that the MARS 100 turbines will emit more pollutants and unburned fuel in the exhaust on an ongoing basis for the expected lifetime operation of the Compressor Station 206.
  • Over the past seven years, Williams/Transco has frequently upgraded and expanded turbines at existing compressor stations throughout New Jersey.  This indicates that there is a high likelihood that Williams/Transco will attempt add more MARS 100 turbines to the CS206 location.

Attachments:

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)

Status of Applications to NJDEP for water permits

Approximately 2,000 mailed and emailed letters were sent to the NJDEP requesting fact-finding meetings (“hearings”) on the water quality permit applications submitted by Williams/Transco on June 20, 2018.  THANK YOU!

NJDEP has started their review of the applications and, on July 18, 2018, they sent a letter to Williams/Transco and FERC identifying deficiencies with the applications.  

NJDEP has one calendar year to grant or deny the permit applications that they received on June 20, 2018, and Williams/Transco now expects to hear the decision in April 2019.

Since NJDEP has 90 days after holding fact-finding meetings to issue their decision, we are anticipating that the fact-finding meetings will be scheduled in the winter of 2018 once they have adequate information for the application reviews.  However, the meeting could be sooner. We’ll let you know when we learn more. Stay tuned!

Fact-Finding Meetings:

  • NJDEP staff will facilitate the meeting at a place that can hold many people.
  • 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.
  • It’ll probably start around 5:30 PM.  However, you can come later. If you want to speak, you will need to sign-up at the meeting to do this.

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

 

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.