Rockaway Pipeline comments to FERC – WEEK ONE: SAFETY

PLEASE COMMENT ON YOUR SAFETY CONCERNS ABOUT THE ROCKAWAY LATERAL PIPELINE!

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 & Regulation facility (M&R Station) to be built in two historic hangars at Floyd Bennett Field.

The impacts and risks are many: local environmental effects from both the construction process and the normal operation of the project, and the risk of catastrophic failure, accidental or intentional. This pipeline will greatly encourage the expansion of fracking with all its attendant environmental ills, and it will bring more fracked (and possibly very radioactive) gas from the Marcellus Shale into our region.

The deadline to fight the Rockaway Pipeline is approaching! The Federal Energy Regulation Commission’s comment period on this project is open until December 9th.

This project is currently under review by the Federal Energy Regulatory Commission (FERC), which has issued a draft Environmental Impact Statement (dEIS) on the project. It’s important that we send as many meaningful comments to FERC as possible.

Inspired by Sandra Steingraber’s “30 Days of Fracking Regs” we’re providing a guideline each week featuring:

  •    Instructions on how to submit your comments
  •    The “Comment topic of the week”
  •    Link to other talking points you may want to use


1.  How to SUBMIT COMMENTS

You can submit a text-only comment of 6000 characters or less by clicking on the COMMENT box here or click on http://www.ferc.gov/docs-filing/ecomment.asp.

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 or click on http://www.carpny.org/how-to-submit-comments-on-the-rockaway-delivery-lateral-project/.

PLEASE SCROLL DOWN !!

2. Featured topic of the week:  FLOODING AND OTHER SAFETY ISSUES

This week we remember what it was like in the Rockaways, South Brooklyn, Staten Island, the Lower East Side, and Long Island and New Jersey’s shores just a year ago. The effects of Superstorm Sandy were still being felt, as they are to this day in some areas, and in many people’s lives they were intensifying. Some were running out of medications, for others the week of cold was beginning to intensify their suffering, and those who could help were climbing 20 flights of stairs to bring blankets, insulin, baby food and other necessities. The homes that stood were dark. The mold was setting in. And countless people were displaced, some permanently.

As we recall how it was then, we now face the task of commenting on the proposed Rockaway Lateral Pipeline.

Hurricanes and Flooding

The Draft Environmental Impact Statement (dEIS) Section 4.1.4.2 (on Hurricanes) states:

“An analysis by the New York State Emergency Management Office (2005) found that the entire Rockaway Peninsula and much of the Brooklyn-Queens area could be flooded due to Category 3, 4 or 5 hurricanes depending on the direction of prevailing winds at landfall, distance from the eye of the storm, eye wall intensity, and tide level, but the risk of flooding during a major hurricane event is difficult to predict. The Intergovernmental Panel on Climate Change considers it likely that hurricanes will become more intense as a result of climate change and sea level rise, but the total number of storms could decline (Pachauri and Renninger, 2007).”

Question: if the total number of storms declines, but the storms are more destructive, how many storms should we consider an acceptable number if any one of them can cause the damage that Superstorm Sandy wreaked on the Rockaways and South Brooklyn, or even worse levels of destruction?

And what is Transco’s response, which FERC considered sufficiently reassuring that they went ahead with their Draft Environmental Impact Statement, the first step along the road to final approval? Let’s look at this quote from the same document:
“Transco states that the ability to forecast hurricanes several days in advance would allow it to ensure the safety and integrity of its system….

During Superstorm Sandy, the water surged to a height of 14 feet. The M&R station is at an elevation of 16 feet, and the equipment is to be raised above floor level by one foot. Are we satisfied that this is a safe remedy? Does anyone notice the year of the ‘recent’ FEMA mapping in this quote from the dEIS in Section 4.1.4.3 (on Flooding)?

According to FERC, “Transco conducted a site-specific land survey of the proposed M&R facility site to determine the elevations of the site relative to FEMA’s designated 100-year floodplain (i.e., the area with a1 percent proposed probability of flooding in a given year). The survey determined that the lowest floor elevation inside the proposed M&R facility is approximately 2.9 feet above the 100-year floodplain delineated in the recent ABE mapping (FEMA, 2012b).”

Leaks and Explosion

The pressure entering that M&R facility will be tremendous. The gas would come into the Rockaway Pipeline from the Lower New York Bay pipeline (running along the coast) at up to 960 pounds per square inch. The regulator’s job is to lower that pressure.

But according to the president of the New England Gas Workers Association: “Water can cause the regulator to be stuck open completely, in the wide open position … If that happens, it dramatically increases the pressure and it can cause serious problems down the line. If gas is coming into a home or a business at a much higher pressure than it’s supposed to, it can cause a fire or even an explosion.  In addition, prolonged exposure to water can contribute to accelerated corrosion of the regulators, causing gas leaks that could trigger an explosion or fire.”

And firemen tell us that in Floyd Bennett Field, many of the hydrants don’t work and others have insufficient water pressure to respond to such a conflagration.

Given the record thus far of this company, how confident do we feel that they can guarantee our safety? Here is a list of some of the 35 reportable accidents they have had since 2006:

  • Appomattox, VA, September 2008 – pipeline fails, blowing a fireball that scorched an area 1,125 feet in diameter, leveling two homes and injuring 5 people and damaging 100 homes.
  • Alabama, 2011 – pipeline ruptures, shooting flames 100 feet into the air for 90 minutes after the pipeline was shut off; the explosion is heard more than 30 miles away.
  • Springfield Township, PA, March 2012 – explosion blows hole in roof of compressor station, shakes homes a half mile away.
  • Ellicott City, MD, July 2013 – Natural gas pipeline explodes, witnesses describe the sound as that of a jet plane landing on the roof. Fortunately nobody was injured.

The Barrier Peninsula

Finally, if the job of the M&R station is to meter and then regulate the enormous pressure in the pipeline, what is being done to protect the people of the Rockaways, where the gas is coming in full force, in a place where the sea floor was upheaved high onto the land and the boardwalk was tossed against buildings like so many sticks? How safe can a high-pressure pipeline be on a barrier peninsula already shown to be so vulnerable to extreme weather?

3. Other TALKING POINTS

Please see the post below for 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, 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.

Public Comments on Rockaway Lateral Pipeline: instructions, talking points

Please take a few moments to make comments on the dEIS (draft environmental impact statement) for the Rockaway Lateral Pipeline. Read on for directions followed by a list of talking points. Feel free to use anything you read here, and of course let it inspire you with your own thoughts and concerns about a high-pressure gas pipeline in an area so hard-hit by a storm just a year ago.

 

Some background information:

The proposed Rockaway Pipeline is a high-pressure natural gas pipeline that would carry fracked gas from the Marcellus Shale into New York City. It would connect to an existing pipeline about 3 miles offshore, be trenched into the ocean floor, enter Gateway National Recreation Area under Riis Beach, continue north through the Rockaway Peninsula, run under Jamaica Bay at the Rockaway Inlet, and then up Flatbush Avenue. Part of the project, a Metering & Regulating Station (M&R Station), would be placed in two historic airplane hangars at Floyd Bennett Field, with the pipeline then returning to Flatbush Avenue as part of National Grid.

This project is currently under review by the Federal Energy Regulatory Commission (FERC), and that agency has issued a draft Environmental Impact Statement (dEIS). We are now in the public comment period for that dEIS.

 

 

 

The full document can be viewed on the FERC website. Note that the deadline for receipt of your comments is DECEMBER 9, 2013.

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 December 9, 2013.

For your convenience, there are three 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

Some talking points:

1. This Project Should Not Be Segmented To Avoid Review

The Rockaway Lateral Delivery Project under FERC review has 2 parts: 1) a 3.2-mile pipeline that would be trenched into the ocean floor and run beneath Riis Beach in Queens, and 2) a Metering & Regulating Facility to be built in historic hangars at Floyd Bennett Field in Brooklyn. But there is a 1.6-mile gap between those 2 pieces of the project.

This summer, National Grid “bridged” that future gap with their Brooklyn-Queens Interconnect (B-QI), Phase I. Because the B-QI has been falsely categorized as a local distribution pipe, National Grid was allowed to construct it under the Rockaway Inlet—through the Special Natural Waterfront Area and Significant Coastal Fish and Wildlife Habitat of Jamaica Bay—without any environmental review.

In 2012 the EPA advised FERC in its review: “A comprehensive evaluation of cumulative, indirect and secondary impacts should be presented. The cumulative impacts analysis should consider the environmental impacts of the National Grid pipeline, without which the Rockaway Delivery Lateral would not be constructed.” And federal case law says a project cannot be segmented so as to avoid review. FERC has ignored the EPA advice and the law. FERC should include a comprehensive evaluation of the cumulative impacts of the entire project—including the National Grid pipeline—in its environmental review.

2. Pipeline Safety 

Since 1986, pipeline accidents have killed more than 500 people, injured over 4,000, and cost nearly seven billion dollars in property damages[1] in the United States alone.

The Rockaway Lateral Pipeline will be vulnerable to leakage during construction, from natural disasters, from terrorism, and from corrosion. Current national inspections  of pipelines are inadequate, with only 7% of natural gas lines inspected each year. The Pipeline and Hazardous Materials Safety Administration (PHMSA) is chronically short of inspectors. It has funding for only 137, but had only 110 inspectors on staff in 2010. Transco plans its own in-person inspections only once every 7 years.

And pipelines DO explode: About 300 per year, on average, causing property damage, injuries — and death.

1. Lena Groeger, Pipelines Explained: How Safe are America’s 2.5 Million Miles of Pipelines? Pro Publica November 15, 2012.

3. Fire and Flood Hazards

The transportation of natural gas by pipeline involves some incremental risk to the public due to the potential for an accidental release of natural gas. The greatest hazard is a fire or major pipeline rupture.” (Draft EIS 4.12)

In Floyd Bennett Field, the Metering & Regulating Facility’s regulator vault will be placed one foot above the floor of an airplane hangar which is at a 16′ elevation above sea level. This is in a flood zone where water crested at 14′ after Hurricane Sandy. The potential mix of seawater and gas is a dangerous one.

When regulator vaults flood, the regulator mechanism’s ability to reduce gas pressure can be significantly impaired. Water can cause the regulator to be stuck in the open position, dramatically increasing the pressure. If gas comes into a home or business at a higher pressure than it’s supposed to, a fire or explosion can result.

Williams Transco claims that the likelihood of flooding is not significantly greater now than in the summer of 2012, just before Hurricane Sandy, despite authoritative findings of the Intergovernmental Panel on Climate Change (IPCC) that sea level rise is inevitable and man-made.

4. Impacts on Protected Species

The project will have negative impacts on endangered and protected species. The dEIS acknowledges that this project “is likely to adversely affect Atlantic Right Whale and Atlantic Sturgeon,” and that it may also have impacts for the Leatherback Sea Turtle, Kemp’s Ridley Sea Turtle, Green Sea Turtle, Loggerhead Sea Turtle, Roseate Tern, Piping Plover, and Seabeach Amaranth. These impacts result from a variety of factors including pile driving noise, dredging, ocean debris, and the potential for collision with vessels.

5. Impacts on Marine Wildlife

Noise in the immediate area of pile driving for pipeline construction would exceed the injury threshold for fish, and the behavioral disturbance threshold for sea turtles; and would exceed the behavioral disturbance for marine mammals for a distance of 2.86 miles. In fact, Williams Transco has applied to the National Ocean and Atmospheric Administration (NOAA) for authorization for “Intermittent Level B Harassment” of six marine mammal species. Construction of the offshore pipeline also would directly disturb approximately 38 acres of seabed due to dredging and jetting. Benthic species in these areas, such as Surfclams, most likely would perish.

6. Impacts on Essential Fish Habitat

The pipeline will be located in a marine area that supports Essential Fish Habitat for 21 species. In addition to noise impacts discussed above, offshore excavations would create turbidity plumes in the water column that could clog fish gills, obscure visual stimuli, and reduce food intake for some fish. It is estimated that up to 402 acres of seabed could be affected by sedimentation.

7. Concerns About The Historic Hangars

Information on the design of the interiors of the airplane hangars is being considered privileged information and not made available to the public, so we have limited information. We do know that, in certain parts of the hangars, fire retardant materials will not be used, due to the “aesthetics” of preserving of the historic look of the hangars, nor will the sprinkler system be activated.

In assessing the potential of vibration from construction activities, Transco states that “the simultaneous operation of multiple pieces of equipment or operation of equipment within 5 to 10 feet from the hanger walls could potentially cause damage.” The EIS suggests that a ‘vibration level threshold’ for the hanger be identified and that a Construction Protection (CPP) plan be created and filed with the Federal Office of Energy Projects (OEP).  However, the Office of Energy Projects’ enforcement division is focused on national gas market oversight and compliance with tariffs, not construction site safety, and is therefore unlikely to be an effective watchdog. What assurance does the public have that such a plan will be credible? Who will enforce the plan?

8. Dredging Of Toxins

The waters off Gateway National Recreation Area are the site of some of the worst dumping along the East Coast. According to an ad hoc committee’s 1970 report, it is part of the largest grossly polluted area in the United States, and contains lead, chromium, copper, gold, selenium, and zinc. These toxins have been buried and kept out of the waters for years, but could be brought up by dredging related to this project, poisoning local fish and ruining commercial fisheries.

9. Mitigation Procedures Inadequate

While “mitigation procedures” such as monitoring protected species are described by Williams Transco, and additional reviews of potential impacts have been recommended by FERC, we have no assurance that these measures will be sufficient to avoid unacceptable environmental harms. Certainly they will not protect us from the “upstream” impacts of fracking and climate change.

10. The Comments Period is too short.

(NOTE: as October 22, the comment period has now been extended another two weeks beyond the initial deadline of November 25, giving the public until Monday December 9 to make comments.)

 

The draft EIS is a dense technical document. The informed layperson who must read this document evenings and weekends needs more time to read and digest the information than given. The comment period, now less than 10 weeks, is too short and should be extended to allow for additional public comment.

11. Do We Need The Gas?

Regarding this project, EPA stated: “The EIS should include a full discussion of the purpose and the need of the proposed project, quantifying energy demand and the need for such facilities in the region.” This has not been adequately discussed in the EIS.

12. The Project Will Encourage Fracking 

The substantial cost of construction of this pipeline puts economic pressure on Williams Transco to continue pumping gas through it as long as possible, and the only new sources of gas available are from fracking shale formations. The more pipelines, the more financial incentive to continue the practice of fracking.

13. It Will Exacerbate Climate Change 

Although “natural gas” burns cleaner than coal or oil, the extraction and transportation of this gas is much more damaging to the atmosphere. Natural gas is methane, which contributes much more to global warming than an equivalent amount of CO2. Any leak in a pipe, or release of gas to mitigate pressure (both of which happen frequently) is very harmful, and the extraction process releases large amounts of methane.

14. Investing Billions In Fossil Fuels Infrastructure Is A Disincentive To Investment In Renewables

Wind, water and solar power can be scaled up in cost-effective ways to meet our energy demands, freeing us from dependence on both fossil fuels and nuclear power.

15. Pipeline company Transco wants to trench the ocean floor this summer.

 
On October 18, 2013–two weeks after the dEIS was published–Transco submitted 543 pages of additional information and the stunning announcement that they plan to lay the pipeline this summer. To do that, Transco would trench the ocean floor off Riis Beach, stirring up sediment—lots of sand for sure & most likely long-buried toxins along with it. All along Williams Transco said this work would be done during winter, when marine populations are low and no one is at the beach. That the project would be done during winter was considered a major aspect of Transco’s mitigation efforts; apparently, Transco now intends to withdraw those mitigations and offers no substitution. All the sampling and counting of marine animals was done during low-count winter months, and those studies were the information on which FERC relied when writing the dEIS. Summer construction has not been considered in the dEIS, and would entail great ecological and economic harm to the area. What will be the risks to swimmers and beach-goers? This cannot be allowed.

 ____________________________________________________________________
Public hearings on the Rockaway Lateral Pipeline project were held on October 22 and 23. Transcripts of the oral comments on the draft EIS presented at these meetings will be available for review in eLibrary under the project docket number.The draft EIS itself 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

Thank you for your commitment to our health and our planet.
You can see more about the FERC process here: http://elibrary.ferc.gov/idmws/file_list.asp?accession_num=20131004-3002
You can also visit us on Facebook at CARP.

The deadline to fight the Rockaway Pipeline is approaching

The deadline to fight the Rockaway Pipeline is approaching 
and we need your help!


BREAKING NEWS
Williams Transco says it must trench the ocean this coming summer! 

Throughout the FERC process Williams Transco maintained they were going to do their ocean trenching during winter when marine populations are low. Now, after all the delays in the FERC process were caused by Transco and 2 weeks after the dEIS is published, comes this announcement:

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, and continue up Flatbush Avenue to a Metering & Regulation facility (M&R Station) to be built in two historic hangars at Floyd Bennett Field.

Almost the entire project falls within Gateway National Recreation Area, our National Park. The Rockaway Pipeline will transgress the waters of the Rockaway Inlet, adjacent to the protected environment of the Jamaica Bay Wildlife Refuge, and its M&R Station is to be sited within feet of the Floyd Bennett Community Garden, Aviator Sports, and camping grounds.

The impacts and risks are many. There will be local environmental effects from both the construction process and the normal operation of the project. There is also the risk of catastrophic failure, accidental or intentional. This pipeline will greatly encourage the expansion of fracking with all its attendant environmental ills, and it will bring more fracked (and possibly very radioactive) gas from the Marcellus Shale into our region.

Even worse, instead of freeing us to develop renewable energy, building this pipeline commits us to additional decades of shale gas use, which exacerbates climate change. This is a sad irony for all of us who are so freshly aware of climate change destruction, and especially for residents of Rockaway and the communities in and surrounding Jamaica Bay where many are still recovering from Superstorm Sandy.
 

  
Do you want to stop this? 

 
Please join us at the Public Hearings this week! 

The Federal Energy Regulatory Commission (FERC) has recently released its draft Environmental Impact Statement (dEIS) for this project.  There will be two public hearings for the dEIS, and we need you to come and express your concerns and opposition to the pipeline.

Tuesday,      October 22, 2013
Knights of Columbus Rockaway Council 267, 333 Beach 90th Street, Rockaway Beach, NY 11693
Wednesday, October 23, 2013
Aviator Sports & Events Center, 3159 Flatbush Avenue, Brooklyn, NY 11234
Both hearings start at 7:00 p.m. 

Getting there by public transportation: 

To get to 333 Beach 90th Street: A train to Broad Channel (make sure you take the Far Rockaway train, NOT the Lefferts Avenue train), transfer to the S train (same platform), take it one stop to Beach 90th Street, walk north on Beach 90th Street.
To get to Aviator Sports Center: #2 or #5 train to Flatbush/Nostrand Avenues (Brooklyn College stop), then Q35 bus south (stops across the street from Aviator). Ask the driver to announce the stop.

Some talking points for comment at the hearings follow. 

1. Why Is This Project Divided Into Two Segments? 

The Rockaway Lateral Delivery Project under FERC review has 2 parts: 1) a 3.2-mile pipeline that would be trenched into the ocean floor and run beneath Riis Beach in Queens, and 2) a Metering& Regulating Station to be built in historic hangars at Floyd Bennett Field in Brooklyn. But there is a 1.6-mile gap between those 2 pieces of the project.
This summer, National Grid “bridged” that future gap with their Brooklyn-Queens Interconnect (B-QI), Phase I. Because the B-QI has been falsely categorized as a local distribution pipe, National Grid was allowed to construct it under the Rockaway Inlet—through the Special Natural Waterfront Area and Significant Coastal Fish and Wildlife Habitat of Jamaica Bay—without any environmental review. 

In 2012 the EPA advised FERC in its review: “A comprehensive evaluation of cumulative, indirect and secondary impacts should be presented. The cumulative impacts analysis should consider the environmental impacts of the National Grid pipeline, without which the Rockaway Delivery Lateral would not be constructed.” And federal case law says a project cannot be segmented so as to avoid review. FERC has ignored the EPA advice and the law. FERC should include a comprehensive evaluation of the cumulative impacts of the entire project—including the National Grid pipeline—in its environmental review.

2. Pipeline Safety 

Since 1986, pipeline accidents have killed more than 500 people, injured over 4,000, and cost nearly seven billion dollars in property damages” in the United States alone.1 The Rockaway Lateral Pipeline will be vulnerable to leakage during construction, from natural disasters, from terrorism, and from corrosion. Current national inspections  of pipelines are inadequate, with only 7% of natural gas lines inspected each year. The Pipeline and Hazardous Materials Safety Administration (PHMSA) is chronically short of inspectors. It has funding for only 137, but had only 110 inspectors on staff in 2010. Transco plans its own in-person inspections only once every 7 years.
And pipelines DO explode: About 300 per year, on average, causing property damage, injuries — and death. 

1. Lena Groeger, Pipelines Explained: How Safe are America’s 2.5 Million Miles of Pipelines? Pro Publica November 15, 2012.
 

3. Fire and Flood Hazards
 

The transportation of natural gas by pipeline involves some incremental risk to the public due to the potential for an accidental release of natural gas. The greatest hazard is a fire or major pipeline rupture.” (Draft EIS 4.12)

In Floyd Bennett Field, the Metering & Regulating Facility’s regulator vault will be placed one foot above the floor of an airplane hangar which is at a 16′ elevation above sea level. This is in a flood zone where water crested at 14′ after Hurricane Sandy. The potential mix of seawater and gas is a dangerous one.

When regulator vaults flood, the regulator mechanism’s ability to reduce gas pressure can be significantly impaired. Water can cause the regulator to be stuck in the open position, dramatically increasing the pressure. If gas comes into a home or business at a higher pressure than it’s supposed to, a fire or explosion can result.

Williams Transco claims that the likelihood of flooding is not significantly greater now than in the summer of 2012, just before Hurricane Sandy, despite authoritative findings of the Intergovernmental Panel on Climate Change (IPCC) that sea level rise is inevitable and man-made.

4. Impacts on Protected Species

 

The project will have negative impacts on endangered and protected species. The dEIS acknowledges that this project “is likely to adversely affect Atlantic Right Whale and Atlantic Sturgeon,” and that it may also have impacts for the Leatherback Sea Turtle, Kemp’s Ridley Sea Turtle, Green Sea Turtle, Loggerhead Sea Turtle, Roseate Tern, Piping Plover, and Seabeach Amaranth. These impacts result from a variety of factors including pile driving noise, dredging, ocean debris, and the potential for collision with vessels.

5. Impacts on Marine Wildlife

 

Noise in the immediate area of pile driving for pipeline construction would exceed the injury threshold for fish, and the behavioral disturbance threshold for sea turtles; and would exceed the behavioral disturbance for marine mammals for a distance of 2.86 miles. In fact, Williams Transco has applied to the National Ocean and Atmospheric Administration (NOAA) for authorization for “Intermittent Level B Harassment” of six marine mammal species. Construction of the offshore pipeline also would directly disturb approximately 38 acres of seabed due to dredging and jetting. Benthic species in these areas, such as Surfclams, most likely would perish.

6. Impacts on Essential Fish Habitat 

The pipeline will be located in a marine area that supports Essential Fish Habitat for 21 species. In addition to noise impacts discussed above, offshore excavations would create turbidity plumes in the water column that could clog fish gills, obscure visual stimuli, and reduce food intake for some fish. It is estimated that up to 402 acres of seabed could be affected by sedimentation.

7. Concerns About The Historic Hangars 

Information on the design of the interiors of the airplane hangars is being considered privileged information and not made available to the public, so we have limited information. We do know that, in certain parts of the hangars, fire retardant materials will not be used, due to the “aesthetics” of preserving of the historic look of the hangars, nor will the sprinkler system be activated.
In assessing the potential of vibration from construction activities, Transco states that “the simultaneous operation of multiple pieces of equipment or operation of equipment within 5 to 10 feet from the hanger walls could potentially cause damage.” The EIS suggests that a ‘vibration level threshold’ for the hanger be identified and that a Construction Protection (CPP) plan be created and filed with the Federal Office of Energy Projects (OEP).  However, the Office of Energy Projects’ enforcement division is focused on national gas market oversight and compliance with tariffs, not construction site safety, and is therefore unlikely to be an effective watchdog. What assurance does the public have that such a plan will be credible? Who will enforce the plan?

8. Dredging Of Toxins 

The waters off Gateway National Recreation Area are the site of some of the worst dumping along the East Coast. According to an ad hoc committee’s 1970 report, it is part of the largest grossly polluted area in the United States, and contains lead, chromium, copper, gold, selenium, and zinc. These toxins have been buried and kept out of the waters for years, but could be brought up by dredging related to this project, poisoning local fish and ruining commercial fisheries.

9. Mitigation Procedures Inadequate 

While “mitigation procedures” such as monitoring protected species are described by Williams Transco, and additional reviews of potential impacts have been recommended by FERC, we have no assurance that these measures will be sufficient to avoid unacceptable environmental harms. Certainly they will not protect us from the “upstream” impacts of fracking and climate change.

.

10. The Comments Period is too short. 

(NOTE: as October 22, the comment period has now been extended another two weeks beyond the initial deadline of November 25, giving the public until Monday December 9 to make comments.) 

At over 300 pages of text, 64 tables, 45 figures and 17 appendices the draft EIS is a dense technical document. The informed layperson who must read this document evenings and weekends needs more time to read and digest the information than given. The comment period, now less than 10 weeks, is too short and should be extended to allow for additional public comment.

11. Do We Need The Gas? 

Regarding this project, EPA stated: “The EIS should include a full discussion of the purpose and the need of the proposed project, quantifying energy demand and the need for such facilities in the region.” This has not been adequately discussed in the EIS.

12. The Project Will Encourage Fracking 

The substantial cost of construction of this pipeline puts economic pressure on Williams Transco to continue pumping gas through it as long as possible, and the only new sources of gas available are from fracking shale formations. The more pipelines, the more financial incentive to continue the practice of fracking.

13. It Will Exacerbate Climate Change 

Although “natural gas” burns cleaner than coal or oil, the extraction and transportation of this gas is much more damaging to the atmosphere. Natural gas is methane, which contributes much more to global warming than an equivalent amount of CO2. Any leak in a pipe, or release of gas to mitigate pressure (both of which happen frequently) is very harmful, and the extraction process releases large amounts of methane.

14. Investing Billions In Fossil Fuels Infrastructure Is A Disincentive To Investment In Renewables
Wind, water and solar power can be scaled up in cost-effective ways to meet our energy demands, freeing us from dependence on both fossil fuels and nuclear power.

 ____________________________________________________________________

Shortly after the hearings we will be in touch with information on how to make written comments on this draft EIS at the FERC website.
Thank you for your commitment to our health and our planet.

You can also visit us on Facebook at CARP.

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.

What’s with the Signs?

Some of you may have seen a Human Pipeline along Flatbush Avenue — people holding up signs on the road to Floyd Bennett Field.

Here’s what it’s about: National Grid and Williams Transco are building a  high-pressure gas pipeline through Gateway and up Flatbush. Here’s why this is a really bad idea. [read more]