As part of the FERC process, Transco must get approval from NYS Coastal Management Program before its application can be processed. The deadline for comments is Friday, March 15. Below are comments submitted by CARP. Please use them to formulate comments of your own and submit your comments to: email@example.com.
Coastal Assessment Program Checklist
Williams/Transco has applied to FERC (docket CP12-36) for permission to construct the Rockaway Lateral pipeline project. This project consists of a 26-inch high-pressure gas pipeline to be built in Jamaica Bay and under Jacob Riis Park and a metering and regulating station to be built in Floyd Bennett Field, all located in Gateway National Recreation Area, a national urban park located in the coastal regions of Brooklyn, Queens, and Staten Island.
The Rockaway Lateral pipeline project will be located in and/or contiguous to, and will have a significant impact on:
- The Jamaica Bay Wildlife Refuge: This wetlands area is home to over 300 species of birds and untold numbers of fish, amphibians, insects, and fragile plants. At least 12 of these species are on the nation’s Endangered and Threatened lists.
- The Floyd Bennett Field community garden – the largest community garden on the East Coast, with over 500 plots, is also a major bird flyway and refuge.
- Jacob Riis Park, a public beach that has thousands of visitors every year.
- Gateway National Recreation Area: This urban park is essential to New York City’s 8 million residents. New Yorkers use this coastal park for kayaking, surfing, fishing, birding, swimming, sunbathing, and outdoor beach sports.
The Rockaway Lateral will run by Jamaica Bay Wildlife Refuge, under Jacob Riis beach, and into Floyd Bennett Field, putting all at risk.
The Rockaway Lateral pipeline project will have a significant effect upon:
- Recreational use of fish and wildlife resources: see above and attached document.
- Scenic quality of coastal environment: not only during the construction phase but also at the entry and exit points of the pipeline; the m&r station will emit noise and noxious fumes, which will also impact both users of the park and wildlife, particularly birds.
- Development of future/present water-dependent uses: high-pressure gas pipelines leak: 4% in the first year; 60% within 10 years. Methane is a toxic gas for wildlife, wetlands, swimmers, surfers. It is also explosive.
- Public recreation opportunities: see above.
- Structures of historic or cultural significance: the current Transco plan calls for housing the metering and regulating station in landmarked historic hangars in Floyd Bennett Field, in complete violation of the park’s mandate, and obviating any educational use for those structures now or in the future.
The Rockaway Lateral pipeline project will involve and/or result in:
- Physical alteration of 2 or more acres of land along the shore and under water: trenching for the pipeline itself will cause significant damage to the seabase of Jamaica Bay, with attendant disruption to flora and fauna in the area.
- Excavation of coastal waters: see above.
- Reduction of existing and potential public access along the shore.
- Development within a designated flood zone: This entire area was heavily impacted by Hurricane Sandy and is still suffering the effects and will for some months or years to come. The land on which the proposed m&r station is to be built is a mere 2 feet above the level of Hurricane Sandy’s storm surge.
There are many reasons to be concerned about the Transco pipeline project in Gateway National Recreation Area. Please see the attached document. In addition, please note that this is a national park, and it is a tragedy to watch more and more public land – land that is held in public trust for the people of this country and for future generations – being handed over to energy corporations for private gain.
The Coalition Against the Rockaway Pipeline (CARP) opposes the construction of the Rockaway Lateral pipeline project (FERC document CP13-36), which consists of a 26-inch high-pressure gas pipeline in Jamaica Bay and a metering and regulating station in Floyd Bennett Field, all in Gateway National Recreation Area. This is the precise area that was recently devastated by Hurricane Sandy.
This pipeline project is so wrong in so many ways,
It is a direct threat to the wetlands and wildlife of Jamaica Bay – and particularly the Jamaica Bay Wildlife Refuge. This area is home to over 300 species of birds and untold numbers of fish, amphibians, insects, and fragile plants. At least 12 of these species are on the nation’s Endangered and Threatened lists.
Construction of the Rockaway Lateral would put beachgoers, park users, and area residents at risk. Pipeline leaks and explosions are all too common. Spokespeople for the companies responsible for the Rockaway Lateral say that the pipeline will undergo an internal camera inspection only once every seven years. Even small amounts of methane will have devastating effects on the Jamaica Bay wetlands and the trees, shrubs, and grasses in the Floyd Bennett community garden. Furthermore, the regulating station in Floyd Bennett Field will be unstaffed, monitored remotely by camera from Williams/Transco headquarters in Texas. Fire protection in Floyd Bennett Field is inadequate, with insufficient water pressure and access in an emergency.
The gas carried in the pipeline will be radioactive. Shale gas from the Marcellus has extremely high levels of radon, the second highest cause of lung cancer in the US.
When Hurricane Sandy hit the Rockaways the storm surges reached 14 feet. Climate scientists say that storms of this size and bigger will become a regular occurrence in the near future because of warming oceans and rising sea levels. The place designated for the Rockaway Lateral’s regulating station is 16 feet above sea level – a mere two feet above Sandy’s storm surge. There is no doubt that this regulating station will be hit by the surge of some future storm battering Jamaica Bay. The gas regulator’s function is to reduce gas pressure so the gas can be distributed to customers. When regulator vaults are flooded, the mechanism’s ability to reduce gas pressure can be considerably impaired. The regulator can be stuck in a wide-open position. The fires and explosions that could result would be that much worse because of the area’s inadequate fire protection – access by fire trucks and other emergency vehicles from the outside is limited to a single bridge that could be rendered unusable by a megastorm.
The pipeline itself would come in under the seabed. This makes it vulnerable to damage by hurricanes and other large storms. Hurricanes Andrew, Lili, Ivan, Katrina, and Rita each resulted in hundreds of damaged undersea pipelines – dents, kinks, ruptures, and pipes that were simply pulled apart. And none of them were anywhere near the size of Sandy.
If we are serious about protecting our coastline we cannot allow the Rockaway Lateral Project to go ahead. There is too much at stake.