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

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 Countdown — 90 Days to Comment on Draft EIS

FERC has just released the draft environmental impact statement (dEIS) for the Rockaway Pipeline, with the following information. The full document can be viewed on the FERC website.

The FERC staff mailed copies of the draft EIS to federal, state, and local government representatives and agencies; elected officials; environmental and public interest groups; Native American tribes; potentially affected landowners and other interested individuals and groups; newspapers and libraries in the project area; and parties to this proceeding. Paper copy versions of this EIS were mailed to those specifically requesting them; all others received a CD version. In addition, the draft EIS is available for public viewing on the FERCs website (www.ferc.gov) using the eLibrary link. A limited number of copies are available for distribution and public inspection at:

Federal Energy Regulatory Commission
Public Reference Room
888 First Street NE, Room 2A
Washington, DC 20426
(202) 502-8371

Comment Procedures and Public Meetings

Any person wishing to comment on the draft EIS may do so. To ensure consideration of your comments on the proposal in the final EIS, it is important that the Commission receive your comments before November 25, 2013.
For your convenience, there are four methods you can use to submit your comments to the Commission. In all instances, please reference the appropriate docket number (CP13-36-000 for the Rockaway Project and CP13-132-000 for the Northeast Connector Project) with your submission. The Commission encourages electronic filing of comments and has dedicated eFiling expert staff available to assist you at (202) 502-8258 or efiling@ferc.gov. Please carefully follow these instructions so that your comments are properly recorded.

1. You may file your comments electronically by using the eComment feature, which is located on the Commission’s website at www.ferc.gov under the link to Documents and Filings. An eComment is an easy method for interested persons to submit brief, text-only comments on a project.

2. You may file your comments electronically by using the eFiling feature, which is located on the Commission’s website at www.ferc.gov under the link to Documents and Filings. With eFiling, you can provide comments in a variety of formats by attaching them as a file with your submission. New eFiling users must first create an account by clicking on eRegister. You will be asked to select the type of filing you are making. A comment on a particular project is considered a Comment on a Filing.

3. You may file a paper copy of your comments at the following address:
Kimberly D. Bose, Secretary
Federal Energy Regulatory Commission
888 First Street NE, Room 1A

4. In addition to or in lieu of sending electronic or written comments, the Commission invites you to attend one of the public comment meetings its staff will conduct in the Rockaway Project area to receive comments on the draft EIS. Interested groups and individuals are encouraged to attend and present oral comments on the draft EIS. Transcripts of the meetings will be available for review in eLibrary under the project docket numbers. All meetings will begin at 7:00 p.m., and are scheduled as follows:

October 22, 2013

Knights of Columbus Rockaway Council 2672
333 Beach 90th Street
Rockaway Beach, NY 11693

October 23, 2013

Aviator Sports & Events Center
3159 Flatbush Avenue
Brooklyn, NY 11234

Great News!

The NYS Department of State, which has responsibility for determining whether the Rockaway Lateral is “consistent” with the federal Coastal Zone Management Act, was scheduled to release its report on September 3. Instead, it has requested a second stay, until December 5, 2013, in making its determination.

This almost certainly means that NYS Department of State has concerns about the project and wants additional time to review the matter before making a final determination. The NYS Department of State has the power to kill the pipeline if it feels it is inconsistent with the Coastal Zone Management Program.

Catch an Interview with CARP on “The Many Shades of Green”

Today, Wednesday, July 24, host Maxine Margo Rubin interviews CARP’s Maureen Healy about the Rockaway Pipeline and the Liberty Port Ambrose LNG terminal.

To Listen Live

The interview will air today, Wednesday, July 24th at 2 p.m. To listen live, go to BBox Radio and click “Listen.”

To Listen Later

The interview will be archived at BBox Radio and at Many Shades of Green.

The show will re-stream on July 25 at 9:30 a.m., July 27 at 8:00 a.m., and July 29 at 10:30 a.m.