WEEK TWO Action Alert: Keep the Gas Industry out of our National Park
FERC (the Federal Energy Regulatory Commission) is accepting comments on the Rockaway Lateral Delivery Project. Please make a comment, and help us to Keep the Gas Industry out of our National Park!
The gas industry intends to surround us with an expanding network of shale gas pipelines to bring fracked gas to markets here and overseas. One of these is the Rockaway Pipeline, a 26-inch high-pressure pipeline to be built by Williams Transco (also known as Transcontinental) and National Grid. It will be trenched into the ocean floor, run under the sand of Riis Park Beach, cross below the Rockaway Inlet adjacent to Jamaica Bay, and continue up Flatbush Avenue to a metering & regulating facility (M&R station) to be built in two historic hangars at Floyd Bennett Field. Part of this project has not been deemed subject to federal review and has already been built, but the crucial part still has to pass state and federal review.
Plans for this pipeline are currently under review by FERC, which has issued a draft Environmental Impact Statement (dEIS) on the project.
The public can make comments on the Rockaway Lateral Delivery Project (Docket No. CP-13-36-000) until 5:00pm on December 9th.
This week we are focusing comments on the fact that much of this project is taking placed within NYC’s only national park, Gateway National Recreation Area (GNRA).
- The proposed pipeline would cross over 1/2 mile of land within GNRA boundaries. Much of this would be located onshore within Jacob Riis Park (see draft EIS page 4-109).
- The M&R Station would be constructed within a 1.1-acre historic hangar complex (i.e., Hangars 1 and 2). Approximately 5.5 acres would be directly affected by construction of the M&R facility (draft EIS page 4-111).
Please read below for:
1. Talking points on this week’s topic: Our National Park
2. Instructions on how to submit your comments
1. This week’s talking points.
A. Floyd Bennett Field has national historic significance
As part of the Rockaway Project, Transco plans to build a metering and regulating station inside historic hangars 1 and 2 in Floyd Bennett Field, located within GNRA. Although Transco will restore the facades, for the duration of this company’s use, the interiors of hangars 1 and 2 will be off limits to the public.
Why are Floyd Bennett Field and these hangers historically significant?
- Floyd Bennett Field was the first municipal airport in New York City
- Because of its unusually long runways and fair weather conditions, Floyd Bennett Field became noted as a prime airport for the experimental fliers establishing speed and distance records. Pioneers aviators Charles Lindbergh and Amelia Earhart frequented the field.
- During World War II it was the busiest Naval Air Station in the United States.
- Floyd Bennett Field still retains the architectural design and historic integrity of an early municipal airport.
http://www.cr.nps.gov/nr/travel/aviation/flo.htm “Floyd Bennett Field Historic District.”
Two years ago, the federally-convened Floyd Bennett Field Blue Ribbon Panel recommended that Gateway “preserve and herald the site’s aviation history,” advising that “the remaining derelict hangars should be rehabilitated and repurposed as flexible and multi-purpose spaces, possibly as space for historic aircraft storage or viewing or other commercial uses” and that “in the long-term, aviation activity should be relocated [from elsewhere in the field] to Hangar Row”. The panel believed the concentration of aviation-related and cultural activities in Hangar Row would serve “as a visible draw to the site.”
Additionally, the panel asked Gateway to “remove inappropriate uses”, citing the NYC Police Department driver training as an example, and recommended establishment of a “moratorium preventing any inappropriate uses.”
Now Transco proposes to build a metering & regulating station within two of these historic hangars. To understand what that might look like, we turned to a federal agency that knows a lot about these matters—Pipeline & Hazardous Materials Safety Administration (P&HMSA). In layman’s terms, they advise local governments and developers to think twice before building near pipeline appurtenances (m&r facilities, for example) because they likely will be the source of noise, odor, emissions and the occasional accident.
So, if one might be wise to forgo development near the source of such annoyance and/or hazards, why would one invite the source of such annoyance/hazards to an area that had already been developed?
Given the historic nature of this airfield and these buildings, and the vision so recently set forth by the Blue Ribbon Panel, does the Transcontinental plan (and what we know of metering & regulating facilities) measure up to the vision?
B. The project jeopardizes the historic airplane hangers.
The “construction and operation of the Projects could potentially affect historic properties. Direct effects could include destruction or damage to all or a portion of an archaeological site or alteration or removal of a historic property. Indirect effects could include the introduction of visual, atmospheric, or audible elements that affect the setting or character of a historic property.”
(From section 4.10.4, page 4-132 of the Draft EIS submitted by FERC.)
In Section 4.11, page 4-130 Transco writes that “the simultaneous operation of multiple pieces of equipment or equipment operating at distances closer than 5 to 10 feet (from the Hangers) could potentially cause damage.” The study recommends that the engineering design for the Rockaway Project identify vibration level thresholds for the structures, that Transco prepare and implement a Construction Protection Plan (CPP) to protect the integrity of the hangar complex during construction, and that the plan include vibration monitoring.
Transco further writes that if the FERC, in consultation with the National Parks Service “determines that a historic property would be adversely affected by the Projects and (the damage) could not be avoided, Transco would be required to prepare a treatment plan in consultation with the appropriate parties to mitigate adverse effects.”
In other words, Williams Transco knows that construction may damage the existing historic hangers, and that they will very likely need to create a plan to mitigate damage, but only if the National Parks Service and FERC require them to do so.
C. Floyd Bennett Field is an important recreational and educational destination for New York City residents.
In December 21, 2010 the Floyd Bennett Field Blue Ribbon Panel’s recommendations stated “Floyd Bennett Field (FBF) should be an iconic urban National Park, simultaneously preserving significant natural and cultural resources, serving as a “gateway” to the National Park experience for New York City’s residents and visitors of all ages, and helping to address the open space deficit of southern Brooklyn and Queens. . . The historical and habitat assets of FBF should be restored and made accessible. Incompatible uses should be moved out or scaled back.”
Current activities at Floyd Bennett Field include
- Youth camping
- Nature trails
- A model airplane flying field
- Sports fields used by the Public School Athletic League
- An archery range
- Aviator Sports (uncomfortably close to Hangers 1 and 2)
- The Floyd Bennett Garden Association of over 400 gardeners (merely 200 feet from Hangers 1 and 2)
- A cricket club
- The Historic Aircraft Restoration Project, and
- The Gateway Environmental Education Center run by the NYC Department of Education and NYU.
Rather than place an industrial project in Floyd Bennett field, the activities described above should be protected and enhanced. This pipeline project constitutes an ‘incompatible use’, as discussed by the Floyd Bennett Field Blue Ribbon Panel, above.
D. This project does not belong in our National Park.
Gateway National Recreation Area sees approximately 9.5 million visitors a year. The enabling legislation for Gateway states that:
“In order to preserve and protect for the use and enjoyment of present and future generations an area possessing outstanding natural and recreational features, the Gateway National Recreation Area (hereinafter referred to as the “recreation area”) is hereby established.”
(16 USC Chapter 1, Subchapter LXXXVII – GATEWAY NATIONAL RECREATION AREA)
Finally, but critical to your understanding of the risks inherent in allowing this project into our park, here are some links to information about Williams Transco’s safety record and how the company has addressed problem elsewhere:
The use of a National Park for industrial purposes is incompatible with the purpose and intent of the National Parks.
Such use will also jeopardize the health and safety of those who use Floyd Bennett Field for recreation, as well as that of beachgoers at Jacob Riis Park. The impacts will be most severe for those New Yorkers in the lower socioeconomic brackets who are unable to afford summer homes or vacation travel, and who therefore rely more heavily on the public parks.
2. How to Submit Comments
You can submit a short text-only comment of 6000 letters or less by clicking on the COMMENT box here.
BE SURE TO INCLUDE THE DOCKET NUMBER, CP13-36-000.
If you want to submit with attachments, or are commenting on behalf of an organization or sending a paper copy, go here for instructions.
3. Other Talking Points
Other talking points are available concerning the likelihood of construction at the beach this spring and summer, the segmentation of parts of this project to avoid federal review, potential impacts on protected species and commercial fisheries, the dredging up of long-buried toxins, whether we need this gas, the effects of more fossil fuel development on our climate, and how this pipeline and others will lock us in to more fracking rather than helping us transition to renewable energy. Thank you.