FERC issues Final Environmental Impact Statement on the Rockaway Pipeline

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On February 28 2014, the FERC staff concluded that, “if the proposed Projects are approved, constructed, and operated, the proposed facilities would result in some adverse environmental impacts. However, these impacts would be reduced to less-than-significant levels with the implementation of Transco’s proposed minimization and mitigation measures and the additional measures recommended in the EIS.”

To read the full EIS, go here.

Given the safety record of the Williams Transco and other Williams subsidiaries, CARP wonders whether Transco will indeed implement sufficient measures to protect Gateway National Recreation Area and surrounding communities of the Rockaways and South Brooklyn from these adverse environmental impacts. During the comment period in late 2013, CARP submitted a 40-page document explaining our many objections to the construction of this pipeline. We are continuing our efforts to change the outcome of this project. The most pressing task at hand is to notify users of Riis Beach that construction is expected to begin in May or June of this year, and to mobilize the voices of the community and visitors to alert their representatives in city and state office that this is unacceptable.

We will post outreach opportunities at this site.

We welcome your comments, questions and suggestions at info@carpny.org.

 

The Pipeline Follies

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Concert and Fundraiser for CARP

The Coalition Against the Rockaway Pipeline

is coming your way

FRIDAY FEBRUARY 28, 7-10 P.M.

MUSIC, MAGIC and ART in the beautiful

Park Slope United Methodist Church

6th Avenue at 8th Street, Park Slope, Brooklyn

(F train to 7th Avenue station at 9th Street)

***   $10 admission, or whatever you can afford   ***

http://www.youtube.com/watch?v=sbxWr8EW4oA

For the past two years CARP has been campaigning to stop the Rockaway pipeline. With the able assistance of environmental law firm Meyer Glitzenstein & Crystal, CARP submitted a detailed 40-page document to the Federal Energy Regulatory Commission explaining why this pipeline must not be built. This document will provide the basis for a legal appeal if FERC grants Williams Transco permission to construct the pipeline. Now we are waiting for FERC’s decision

Regardless of the outcome of this struggle, CARP will continue to educate people about climate change and mobilize against Big Energy. But we can’t do this without your help. We need to raise $1,000 to pay our able and generous legal team. And we need money to fund flyers and forums.

So come to our fundraiser on February 28! Performers include:

Jonathan Fluck, thespian and Master of Ceremonies

Pinetree, Floyd Bennett Field gardener, poet, and singer

Anne Bassen voice, with Edith Lettner on sax

folksingers Peter Pasco and Joel Landy

Such as Us, The Lords of Liechtenstein

Kid Ace (master of the magical arts)

Elizabeth Soychak (the Lady in the Green Dress from The Highline Renegade Cabaret)

Ay Mayo! (Afro-Columbian drums of power)

the legendary Rude Mechanical Orchestra

and – direct from the People’s Puppets of Occupy Wall Street – the medieval mixed media known as a Cantastoria.

Video and photography courtesy of Environment TV.

And if you can’t make it but still want to contribute, you can make a tax-deductible donation of any size through our DONATE! page.

Comment Period to FERC has ended; see below for CARP’s submittal

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rockaway-map-big

The comment period on the Rockaway Lateral Pipeline project to the Federal Energy Regulatory Commission has ended. We welcome you to use information from the document CARP Pipeline Comments to FERC December 9 2013 in your efforts on behalf of the environment.

We gratefully acknowledge the work of the Sane Energy Project for the sections on Radon and Lack of Notification, from which we copied verbatim, to Renew New York for the boiler conversion text (also copied verbatim), and to our colleagues at Occupy the Pipeline, New York Climate Action of Brooklyn For Peace, Park Slope United Methodist Church, New York City Friends of Clearwater, United for Action, the Occupy Wall Street Environmental Solidarity Working Group, New York Climate Action Group, C.B. 14 in Rockaway Park, and others. And a heartfelt thank you to everyone who made comments. They poured in over the past days and weeks, especially in the last hours of the workday on Monday, Dec. 9. You responded to over a month’s worth of emails and social networking, used your smartphones to capture CARP’s “Not On The Beach” link from the beautiful posters displayed throughout the Rockaways and parts of Brooklyn and Manhattan, spoke out at hearings, offered support, and spread the word. Your comments were passionate and moving, many stunningly brilliant, speaking for our rights to safely visit OUR National Recreation Area, for the health of the ocean and bay and the protection of the wild creatures who live there or migrate through, breeding and nesting, for the people upstream who would be affected by fracking to feed a gas pipeline imposed upon us by Bloomberg’s administration (and implemented by the National Parks Service) and built by a company with a horrendous safety record, for the children in NYC kitchens who would breathe radioactive gases coming in from Marcellus gas, and for the fragile and unstable climate that is our planet’s life support system.

To paraphrase Margaret Mead, CARP’s 40-page comment.is the result of the work of a small group of committed people.

We’ll keep you informed of next steps, including a fund-raiser to pay the legal fees for the excellent help received from Meyer, Glitzenstein & Crystal, one of the nation’s top environmental law firms. And thanks to Noah at the Center for Biological Diversity for understanding the urgency of the struggle and providing us that connection, and to the small shopkeepers who welcomed us and our posters, and to Genevieve’s class at the New York City College of Technology for creating them with humor and bite.

Five of the posters were seen by much of NYC, but we want you to get a look at everyone’s great work:

bikini in yellow

blue mask

danger

drowning man

not so far

one of these things

red and green

red mask

Rockaway Pipeline Comments to FERC – WEEK 5: IT’S NOW OR NEVER

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Protect the Climate: No Rockaway Pipeline!
 
 
 
An Action Alert from CARP: The Coalition Against the Rockaway Pipeline (www.carpny.org)
 
 
 
The Federal Energy Regulatory Commission (FERC) is accepting comments on the Rockaway Lateral Delivery Project. Please make a comment, and help us to fight hydrofracking and climate change, which will be exacerbated by this project. 
 
 
 
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 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.
 
 
 
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. CP13-36-000) until 5:00pm on December 9th.  (Scroll down for information on how to submit comments to FERC)
 
To help you prepare your comments, we have been featuring various aspects of the many dangers and concerns surrounding this pipeline.  Our final suggested comments focus on the impacts this project will have on hydrofracking and climate change.
 
Talking points on this week’s topic: Hydrofracking and Climate Impacts
 
 
 
 
Williams Transco has acknowledged that this pipeline will carry fracked gas from the Marcellus Shale.  So it’s not hard to figure out that this will drive production from shale plays upstream and upwind of NYC, will increase the pressure to frack in NY State as well as Pennsylvania, and will help place in jeopardy the water supply and foodshed of millions, creating unacceptable health impacts, stressing local roads and local communities, and potentially turning many more formerly beautiful rural areas into an industrialized zone.  Is this what we want for New York?
 
 
 
 
Air pollution from the gasfields and emissions from the pipeline and its metering and regulating station (outrageously sited near the Floyd Bennett Community Gardens) will not only cause health effects for humans, plants and animals, but will more than negate the purported “clean burning” advantage of natural gas.
 
At a time when we should be doing everything we can to reduce greenhouse emissions, we will, in fact, be increasing them: as Cornell scientists Howarth, Santoro and Ingraffea document in the May 2011 issue of Climatic Change Letters, 
 
http://link.springer.com/article/10.1007%2Fs10584-011-0061-5  the carbon footprint of shale gas from extraction through delivery and final use is greater than that of oil or even the dirtiest coal.
 
It’s especially ironic that this pipeline full of greenhouse gas would be going straight through Rockaway, an area which has already been devastated by the effects of climate change in the form of superstorm Sandy. The more we learn about energy production, the more we see that sustainable energy sources like wind, tidal, and solar power are the only way we can hope to mitigate the impending climate catastrophe which is expected to have dramatic impacts on our planet and civilization.
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Also, far from providing “energy independence,” the use of shale gas will make NYC more, not less, dependent on volatile supplies and prices of fossil fuels.  The massive buildout of natural gas infrastructure currently underway in the Northeast, including facilities for export, encourages sellers to seek the highest bidder, and prices here will rise as gas is exported to markets overseas willing to pay top dollar. Furthermore, despite the industry hype, independent analysis and evidence from older shale plays now indicate that the amount of gas recoverable from the Marcellus will be much less than originally expected.
 
 
 
 
 
 
 
 
The only entities that truly need this pipeline are the two principal corporations involved in building it, namely, National Grid and Williams Transco. And their need is not based on providing a service to New Yorkers; rather, it’s based on their need to make a profit, regardless of the consequences.
 
 
 
 
 
What New Yorkers truly need is a different approach to energy, one that involves government support for energy efficiency in transit, energy conservation in buildings, a modern energy distribution system, and a rapid conversion to renewable energy. But this can only be achieved if there is the political will – and the public financial support – to bring this about. Continuing to build pipelines and promote the use of shale gas is absolutely going in the wrong direction.  Shale gas is not a “bridge fuel,” it’s a gangplank to disaster.
 
 
 
 
 
FERC asserts that it is not their role to consider the effects this pipeline will have on hydrofracking and climate change.  It is our role to tell them that they should, that they must consider these factors in their decisions. Please tell FERC, in your own words, that there are two more reasons not to build this pipeline: on the one end, it will encourage more fracking, and on the other it will insure more climate change.
 
 
 
 
 
Please tell FERC, in your own words, that the contribution to catastrophic climate change is one more reason why the Rockaway Pipeline should not be approved, and should not be built.
 
 

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.

Other Talking Points

Please see our suggested talking points concerning the likelihood of construction at the beach this spring and summer, the segmentation of parts of this project to avoid federal review, the inappropriateness of siting this project in a national park, the dredging up of long-buried toxins, the possibility of radon exposure, the dangers of explosion and flooding, whether we actually 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.

Rockaway Pipeline Comments to FERC – WEEK 4: PROTECT THE ECOSYSTEM: NO ROCKAWAY PIPELINE!

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Protect the Ecosystem: No Rockaway Pipeline!

An Action Alert from CARP: The Coalition Against the Rockaway Pipeline (www.carpny.org)

The Federal Energy Regulatory Commission (FERC) is accepting comments on the Rockaway Lateral Delivery Project. Please make a comment, and help us to Protect Marine Wildlife, including endangered species, which will be impacted by this project.

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 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.

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. (Scroll down for information on how to submit comments to FERC)

To help you prepare your comments, we are featuring each week a different aspect of the many dangers and concerns surrounding this pipeline. This week’s suggested comments focus on the impacts this project will have on endangered species, essential fish habitat, and other aspects of marine biology.

Talking points on this week’s topic: Ecosystem Impacts

We already know that humans have many concerns about this pipeline, including the potential for leaks and explosions, inappropriate use of national parkland, exposure to radon, accelerating climate change, encouraging fracking, disrupting beach use, etc.

But what about all the other living beings that will be impacted by this project and are not able to speak up for themselves or write comment letters? For example, did you know that in connection with the project’s construction Williams Transco has applied to the National Marine Fisheries Service for “Incidental Harassment Authorization” for seven marine mammals? These include gray seals, harbor seals, harp seals, the North Atlantic right whale, bottlenose dolphins, harbor porpoises, and short-beaked common dolphins.

A number of endangered and protected species may be affected, as well. Williams Transco has acknowledged that the project “is likely to adversely affect” the Atlantic sturgeon, and “may affect” the North Atlantic right whale, leatherback sea turtle, Kemp’s ridley sea turtle, green sea turtle, and loggerhead sea turtle. One of the most serious possible impacts is exposure to underwater noise resulting from pile driving in the construction process. But the dEIS also mentions a host of other concerns, including possible injuries from collisions with construction vessels or equipment, possible loss of feeding habitat as fish populations and organisms that dwell on the ocean bottom are disturbed, exposure to floating debris, exposure to toxic sediments, etc. (The dEIS states that 38 acres of seabed will be directly impacted by construction, and another 402 acres will be affected by sediment stirred up in the construction process. Some of this sediment is likely to include unidentified or proprietary substances that are toxic to marine life.)

The Atlantic sturgeon is far from the only fish that may be affected. In fact, within the project construction area, Essential Fish Habitat has been identified for 39 fish species, including flounder, monkfish, bluefish, black sea bass, and the Atlantic, Spanish and king mackerel. Williams Transco states that, “Overall, impacts on managed species identified as having EFH in the Project area will vary depending on the species.” In addition to the noise effects mentioned above, these impacts may include increased water turbidity from construction operations, direct loss of eggs and larvae during construction trenching operations, and reduction in available forage due to reduction of benthic (bottom dwelling) community densities.

While Williams Transco states that benthic communities will re-establish over a short period of time, the timeline for this to happen is not at all certain. It will likely take several years for pre-construction levels to be established, and since maintenance will disrupt the trenched area again every seven years, the cumulative impacts may result in permanent ecosystem damage. Transco Williams has also acknowledged that their new plans to perform construction during the spring and summer, rather than during the winter as originally intended, may have a greater impact on benthic organisms.

And what about birds? Well, there are plenty of them in the project construction area, as well as Jamaica Bay and Floyd Bennett Field, including protected species like the roseate tern, and the piping plover. Williams Transco does not expect birds to suffer any impacts directly related to construction. But do we really think negative environmental impacts will completely cease after the construction phase? We know that shale gas pipelines continually leak methane. How will that affect the birds and the surrounding ecosystem?

Williams Transco has proposed a variety of “mitigation” measures aimed at reducing or limiting the environmental impacts of the pipeline’s construction, such as keeping a watch out for whales and sea turtles and holding off on construction operations when they are sighted. But do we really know how effective these measures will be? In many instances, Williams Transco asserts that possible negative impacts will be “minimal,” they will be temporary, or they will only affect “individuals,” not “populations.” Does that mean it’s acceptable if only a few sea turtles or dolphins are injured by construction equipment? And for a project that shouldn’t be happening in the first place? We really don’t need methane gas for our energy future. It will only encourage fracking and climate change, and we should be going to renewables instead.

Please tell FERC, in your own words, that the impacts on the surrounding ecosystem are one more reason why the Rockaway Pipeline should not be approved, and should not be built.

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.

Other Talking Points

Please see our suggested talking points concerning the likelihood of construction at the beach this spring and summer, the segmentation of parts of this project to avoid federal review, the inappropriateness of siting this project in a national park, the dredging up of long-buried toxins, the possibility of radon exposure, the dangers of explosion and flooding, whether we actually 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.

Rockaway Pipeline Comments to FERC – WEEK 3: PROTECT NEW YORKERS FROM RADON EXPOSURE

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Protect New Yorkers from Radon Exposure

An Action Alert from CARP: The Coalition Against the Rockaway Pipeline (www.carpny.org)

This week we enter the holiday season by lighting candles and stringing lights, by bringing our loved ones closer and giving thanks for our blessings over tables laden with food. And for some it begins with a celebration of a miracle – the oil that burned for 8 days when there was barely enough for one night.

As we celebrate the holidays of light and thanksgiving this week, again our thoughts go back just one year to the dark and the cold, to families gathered outdoors on Thanksgiving Day to share food behind a church, to houses ripped apart and people far from home, not sure when they could ever return.
Williams Transco is promising lots of light and heat – but let’s be aware of what may be mingled with that gas coming into our kitchens, our boilers and clothes dryers.

Here’s this week’s subject:

FERC (the Federal Energy Regulatory Commission) is accepting comments on the Rockaway Lateral Delivery Project. Please make a comment, and help us to Keep Radioactive Radon Gas out of our kitchens!

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 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.

Plans for this pipeline are currently under review by FERC, which has issued a draft Environmental Impact Statement (dEIS) on the project.

 
 
To help you prepare your comments, we are featuring each week a different aspect of the many dangers and concerns surrounding this pipeline.  This week’s suggested comments focus on the fact that the Rockaway Pipeline will bring radioactive radon gas from the Marcellus Shale to our kitchens and boilers.

1. Talking points on this week’s topic: Radon Exposure

All gas extracted from shale contains radon, an inert radioactive gas which can cause lung cancer.  Radon mixes with the methane in what we call “natural” gas and travels through delivery pipelines to reach our kitchen stoves, gas dryers and boilers.

Radon is the leading cause of lung cancer in non-smokers.  Lung cancer is the most common cancer for both men and women, and its 5-year survival rate is the lowest among all cancers.  The cancer risk from radon increases when exposure is repeated and more spread out over time, even if the exposure is at very low levels.

Radon decays to equally radioactive and dangerous “progeny,” including polonium and radioactive lead, before decaying to regular, non-radioactive lead.  When radon is breathed in, the radon itself is exhaled, but the radon progeny deposits in the lungs, where it causes cancer.  Because radon is a “heavy” gas, it tends to gravitate towards the floor, making it a particular danger for children and pets.  Radon progeny can also plate out on the sides of gas pipes, creating “hot” radioactive pipes which are an exposure hazard, and a problem for disposal.

In 1986, the EPA set a limit for exposure to radon in air at 4 picocuries per liter.  However, because of increased exposure to many other kinds of radiation in today’s world, both Johns Hopkins University and the World Health Organization have indicated that 2.7 picocuries per liter would be a better standard.  Of course, there is no truly safe level of exposure.

In the past, the natural gas used in this region was sourced from the Gulf Coast.  Such gas has been found to average approximately 5 picocuries of radon per liter at the wellhead.  But the Rockaway Pipeline, according to Williams Transco’s own statements, will also bring us gas from the Marcellus Shale, which lies under Pennsylvania, Ohio and New York.  This gas is much more radioactive.  Studies at wellheads in the Marcellus are very limited, but have shown the potential for as much as 150 picocuries per liter at the wellhead.  Suffice it to say that people within the industry use the radioactivity of the Marcellus Shale as a “marker” to distinguish it from gas from other locations!

Radon levels in NYC apartments will become higher as the proportion of Marcellus gas in our supply increases. Because this source is much physically closer to New York also means that the radon has less time to decay in transit. Radon has a half-life (loses half of its radioactivity) of 3.85 days.  Gas from the Gulf Coast takes 4-8 days to reach New York City, but gas from the Marcellus, which is so much more radioactive to start with, would get here much faster, in less than a day.  So this makes it even more likely that we will be exposed to gas with dangerous levels of radon.

NYC kitchens are particularly vulnerable to radon buildup, since many of these kitchens are small, and may not have windows or hoods venting to the outside.  When internal “passive” wall vents exist in apartments, people often seal them to avoid cooking odors from neighbors.  And during the winter, when windows are most likely to be closed, the demand for gas is highest, and so it is delivered at a faster rate with even less time for radioactivity to decay.  Also, many NYC gas stoves, especially in low-income neighborhoods, still have old fashioned “pilot lights” which result in 24/7 exposure to gas.

Voluntary citizen radon testing over the past two years has shown that NYC kitchens typically have radon levels less than .3 picocuries per liter.  We want to keep it that way!  But with radioactive Marcellus Shale gas coming to NYC from both the Rockaway Pipeline, and the Spectra Pipeline into Manhattan, it has been estimated that an additional 30,000 deaths from lung cancer could result.  Assemblywoman Linda Rosenthal considers this to be such a threat to New Yorkers’ health that she introduced a bill, A6863,

which would require suppliers of natural gas to guarantee that gas delivered to NYC does not contain unacceptable levels of radon.

So what does the FERC draft EIS have to say about radon?  Very little.  Section 4.11.1.5 of the dEIS states as follows:

“Radon is a naturally occurring radioactive gas that is odorless and tasteless.  It is formed from the radioactive decay of uranium (Agency for Toxic Substances and Disease Registry, 2011).  Radon can be contained in fossil fuels including natural gas.  Since radon is not destroyed by combustible burning natural gas containing radon can increase the level of radon within a home (Agency for Toxic Substances and Disease Registry, 2010).  Several factors limit the indoor exposure to radon from natural gas.  Radon’s half­­-life, defined as the time it takes for the element to decay to half its initial concentration, is relatively short (3.8 days).  The time needed to gather, process, store and deliver natural gas allows a portion of the entrained radon to decay, which decreases the amount of radon in the gas before it is used in a residence.  The required venting of appliance exhausts from water heaters, furnaces, and other appliances also limits potential exposure pathways to radon emissions.”

 
“While the FERC has no regulatory authority to set, monitor, or respond to indoor radon levels, many local, state, and federal entities establish and enforce radon exposure standards for indoor air.  It is expected that the combustion of gas transported by the Projects would comply with all applicable air emission standards.  In the unlikely event that these standards are exceeded, the necessary modification would be implemented to ensure public safety.”

They seem to be saying that: (1) the radon will decay (even though we know that it will arrive from the Marcellus in less than a day, less than the 3.8 day half-life); (2) venting will reduce exposure (even though many kitchens have neither windows nor functioning vents); and (3) if there is a problem, it will somehow be dealt with. This does not seem very reassuring.

Another thing to consider is that methane pipelines are subject to enormous amounts of leakage, so even if you do not have natural gas in your own kitchen, you may still be exposed to this radioactive gas as you walk the streets of the five boros.  For example, take a look at natural gas leaks in Manhattan: http://blog.visual.ly/data-art-and-environmentalism-collide-at-cooper-union/

 
Please tell FERC, in your own words, why you do not want the Rockaway Pipeline to expose us to dangerous levels of radon that will cause cancer. Some additional materials that may be helpful are given below.

To learn more about radon in our natural gas supply: http://saneenergyproject.org/radon/

A complete panel discussion on this topic that was held at Cooper Union:http://www.youtube.com/playlist?list=PL5ZIvUpU2rlFyetf942AHLVpq-w5YMfda

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.

Rockaway Pipeline Comments to FERC – WEEK TWO: IN OUR NATIONAL PARK?

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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.”

                                                                                                                                                                                                     http://www.rpa.org/pdf/FBF_Report_Final.pdf

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.

https://primis.phmsa.dot.gov/comm/pipa/pipa_practice_ND18.htm

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.”

(http://www.rpa.org/floydbennett/FBF-Task-Force-Recommendations.pdf)

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:

http://www.naturalgaswatch.org/?p=1305

http://www.youtube.com/watch?v=uPeh8RZGZmA&list=PLo1TDxDrIRYoOSND7uKrDMeK8RD46Ks8T

http://new.livestream.com/accounts/2274717/events/2185305/videos/21874206

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.