Cape Atlantic Reliability Project (aka South Jersey Gas pipeline)

The pipeline would be approximately 22 miles from just outside Millville in Maurice River Township, Cumber­land County, through Estell Manor to Beesley’s Point in Upper Township, Cape May County. Pipeline capacity is 125M cf/day.

This 22-mile, 24” natural gas pipeline would traverse the Pinelands Forest Area of Cumberland and Cape May Counties to deliver natural gas for a proposed new elec­tric generating facility at the BL England site on the shore of Great Egg Harbor. It would traverse the Forest Area, a Pinelands planning district where this type of infrastruc­ture is forbidden by the Pinelands CMP, unless it primarily serves the needs of people already in the Pinelands. The SJG pipeline would destroy sensitive ecosystems of the Pinelands and create air and water pollution that threat­ens communities and contaminates drinking water.

RCCM (the owner of the BL England plant) has a 20-year Standard Gas Service Agreement (“SA”) with SJG for 125,000 Mcf (thousand cubic feet) per day. Assuming a 6,500 Btu/KWh heat rate, a 447 MW combined cycle facility will burn approximately 69,700 Dth or approxi­mately 67,224 Mcf of natural gas per day when oper­ating at 100%. This amount is slightly more than just half the 125,000 Mcf per day (“Mcfd”) Daily Contract Quantity of the SA with SJG. Annualizing the 67,224 Mcfd yields an annual quantity of 23,535,391 Mcf per Year. Assuming the plant runs at full capacity, which is likely to be somewhat smaller when taking into ac­count normal maintenance, actual use is estimated at 22,600,000 Mcf. This number is consistent with the Annual Minimum Quantity set forth under the SA of 20,797,397 Mcf per year.

Pinelands Preservation Alliance, New Jersey Sierra Club, and Environment New Jersey challenged the Pinelands Commission approvals in the appeals court, based on the merits of the decision and the way the Commission went about it. Despite being held up in court, the Murphy Administration granted South Jer­sey Gas permit extensions.

The Appellate Division of the Superior Court of New Jer­sey issued a ruling in early November 2016 on the con­solidated appeals of the approvals of the New Jersey Board of Public Utilities and Pinelands Commission staff of the Cape Atlantic Reliability Pipeline. The decision af­firmed the approval issued by the Board of Public Utili­ties regarding the proposed pipeline, and remanded the issue of whether the proposed pipeline conforms to the Pinelands Comprehensive Management Plan to the full Pinelands Commission for decision.

Although the court’s ruling directs that the full Pine­lands Commission must decide whether the pipeline conforms to the Comprehensive Management Plan, it affirmed the BPU’s determination that the pipeline to supply a repowered B.L. England plant is necessary for the service, convenience or welfare of the public.

As of February 24, 2017, South Jersey Gas received final approval from the New Jersey Pinelands Commission to construct its Cape Atlantic Reliability Project.

The proposed pipeline is exactly the kind of infrastructure development which the CMP bars from the Forest Area because, once approved, such developments (1) create pressure for more development along their length (what­ever the project’s proponents may hope or claim today), (2) strike at the integrity of the CMP, (3) create precedents for future violations of the CMP, and (4) risk damage to natural resources in a Pinelands conservation zone. If this project is approved, it will render the long-standing, fun­damental rule of the CMP governing infrastructure in the Forest Area completely meaningless.

In her January 2014 findings regarding the proposed pipe­line, the Executive Director of the Pinelands Commission (Nancy Wittenberg) stated that, “the proposed pipeline is not fully consistent with the permitted use standards for a Forest Area.” The draft MOA, which both the Commis­sion’s Executive Director and SJG urged the Commission to adopt, stated, “Given that the proposed pipeline is in­tended to serve customers located both inside and out­side of the Pinelands, it is evident that the project does not primarily serve only the needs of the Pinelands.”

SJG’s claim that the whole capacity of the pipeline is com­mitted to the power plant is false and misleading. It is not technically defensible on any operating scenario and, given the company’s ability to operate the pipeline at 700 psig, its argument simply represents an attempt to do a bait and switch on the BPU and Pinelands Commission.

The BL England plant itself does not and will not primarily serve the needs of the Pinelands, because the vast major­ity of demands for electricity are outside the Pinelands.

The pipeline will be immersed in the Kirkwood-Co­hansey Aquifer along much, if not most, of its length. Natural gas leaks into the aquifer may cause significant natural resource damage. The route crosses several non-degradation streams designated as “PL” or “FW1” streams under the state surface water quality stan­dards and Clean Water Act. No activity is permitted that may affect the water quality of these streams except towards improved water quality.

A Skipping Stone report from January 201750 stated:

Customers within the Pinelands represent less than 30% of total gas customers benefitted by the “redun­dancy” benefit purported by SJG. The total capacity of the line would be available to SJG to serve non-BL England customers on the highest demand days of the year and primarily serve a redundancy /reliability pur­pose and a potential SJG market growth of as many as 100,000 +/- residential customers (emphasis added). This is due to the excess capacity of the line relative to the use that the (Power) Plant could make of the line.

The report concluded that:

  • the proposed pipeline is designed for a capacity sev­eral times the amount of natural gas that a new 447 KW power plant at the BL England site could consume.
  • the agreement between SJG and the owners of the BL England Plant gives SJG’s other customers first call on the capacity of the new pipeline.
  • the great majority of South Jersey Gas customers who could receive gas through the new pipeline are outside the Pinelands.
  • Accordingly, it is our conclusion that the proposed pipeline will not “primarily serve the needs of the Pinelands.”

The Skipping Stone report clearly shows that a major pur­pose is to allow expansion of SJG business. In the section of this report on the repowering of the BL England plant are statements from the Pinelands Preservation Associa­tion demonstrating that it unnecessary to repower BL Eng­land (see section on BL England power plant below). The conclusion is that neither SJG nor the BL England plant are needed to support current NJ residents.

GHG emissions are based on the portion of the gas that would be available in the pipeline to serve residents after meeting the needs of BL England. Although SJG’s residential customers have priority, for purposes of these computations it is assumed that the pipeline delivers the total amount needed for BL England (the associated GHG emission volumes are shown in the BL England section below).

Based on the assumptions described in Appendix I of our report, the annual volume of GHG’s would be as follows:

  • Emissions from the combustion of the gas the pipe­line would carry = 1.13 MMt (million metric tons) CO2
  • Total emissions from methane leaked across the gas supply chain (extraction to consumption) (Pennsyl­vania and New Jersey) = 0.82 MMt CO2e
  • Emissions from methane leaked during transportation and consumption in New Jersey = 0.14 MMt CO2e
  • Total emissions from pipeline in New Jersey = 1.27 MMt CO2e