Northeast Supply Enhancement aka NESE (Somerset and Middlesex Counties and the Raritan Bay)

(FERC docket number CP17-101)

Grassroots opposition to this project is lead by SCRAP-NESE (Stop Compressor and Resist Added Pipeline – Northeast Supply Enhancement Project) https://www. scrap-nese.org with support from many environmental organizations.

Williams is in the application review stage of the Northeast Supply Enhancement Project, also called NESE. The project is being designed to add 400,000 dekatherms (400M cubic feet) per day of additional natural gas transmission capacity and is targeted to start construction in the fall/winter of 2019 and be in service for the winter heating season of 2020. The project design includes:

Greenfield Compressor Station 206, Somerset County, New Jersey – a new 32,000 HP compressor station near Transco’s mainline consisting of two natural gas-fired compressor units and associated facilities.

  • Approximately 10 mile, 42 inch loop (pipeline laid parallel to existing lines) in Lancaster County, Penn­sylvania,
  • Compressor Station 200, Chester County, Penn­sylvania – add 21,902 HP by installing one electric motor-driven compressor unit,
  • Approximately 3.4 mile, 26-inch loop of Transco’s existing Lower NY Bay Lateral from Transco’s Sta­tion 207 downstream to the Morgan meter and Regulating station, Middlesex County, New Jersey (onshore)
  • Approximately 23 mile, 26-inch loop of the existing Lower NY Bay Lateral from the Morgan Meter and Regulating station in Middlesex County, New Jersey to the Rockaway Transfer Point, New York State wa­ters (offshore) which would trench 23 miles of ocean floor and churn up toxins that will land on beaches.

The Northeast Supply Enhancement project will in­crease Transco pipeline deliveries to National Grid (dis­tributor) by 400 million cubic feet per day.

Williams withdrew and resubmitted applications for the following permits in June 2018:

  • Waterfront Development Individual Permit
  • Water Quality Certificate under Section 401 of the Clean Water Act
  • Flood Hazard Area Individual Permit and Verification
  • Freshwater Wetlands Individual Permit and accom­panying Transition Area Waiver
  • Concurrence with Applicant’s Coastal Zone Manage­ment Act (CZMA) Consistency Assessment.

A report commissioned by the EELC and written by Mi­chael Aucott48, which reviewed documents associated with the project including Transco’s Resource Report 9 on Air Quality & Noise, and FERC’s Draft Environmental Impact Statement dated March 2018, stated:

(1) Transco’s emissions of nitrogen oxides (NOx) will exacerbate the region’s ozone pollution problem. The project will be built in an area that is in a Clean Air Act “non-attainment area for ozone pollution. Construction of the pipeline will emit a precursor for ozone, nitrogen oxides (NOx), in a quantity that is well above accept­able levels (100 tons per year). Transco’s proposal to mitigate these emissions is faulty.

(2) Transco’s statements on New York City’s demand for natural gas rely on outdated City documents that have been revised and updated numerous times. The up-to-date City documents do not support Transco’s posi­tion. The proposed pipeline’s supply of 400,000 deka­therms per day is more than twice as much additional natural gas as NYC would need even if it achieved the highly unlikely goal of converting all of its residential and commercial buildings’ fuel oil use to natural gas. Given the City’s current emphasis on implementation of efficiency measures designed to reduce demand for natural gas, and the possibility that increasingly cost-effective non-fossil fuel energy sources including solar and wind will displace natural gas for some uses, there appears to be no realistic possibility that the bulk of the proposed project’s natural gas supply increase will ac­tually be needed to convert the City’s buildings’ fuel oil use to natural gas. Implementing a pipeline construc­tion project that would more than double the supply of natural gas that the City would be likely to need in the extremely unlikely possibility that it could convert all its buildings’ fuel oil use to natural gas is inimical to the expressed goal of the City to actually reduce its de­pendence on natural gas and to make major reductions in its emissions of greenhouse gases.

(3) Hazardous Air Pollutant emissions from the Project will significantly exceed NJDEP’s new HAP reporting thresholds. Transco’s Resource Report 9, published March 2017, asserted that Transco’s Hazardous Air Pollutant emissions would be below NJDEP’s report­ing thresholds. That is no longer accurate. New NJDEP thresholds became effective in February 2018. These current HAP reporting thresholds appear in N.J.A.C. 7:27-17.9. According to these thresholds, HAP emissions from each of the two Mars 100 turbines exceed reporting thresholds for formaldehyde, acetaldehyde, acrolein, benzene, ethylbenzene, napththalene, and propylene oxide. Transco’s position on the health impact of Haz­ardous Air Pollutants was based on compliance with the old NJDEP thresholds: that position must be revisited.

Even if it can be demonstrated that the NESE project can provide an overall benefit to New York City (and this may be unlikely), no benefits are projected to accrue to New Jersey. And the people and the environment of that state will bear the impacts of the excess emissions of NOx and the associated threat of exacerbation of ozone pollution.

New York City Comptroller Scott Stringer provided the following statement on 9/5/18 opposing the Williams pipeline:

“New York City is on the path to a greener, more sus­tainable future and the construction of the proposed Williams Northeast Supply Enhancement pipeline in the Rockaways is simply a monumental step backwards from that vision.”

“The 23-mile pipeline would extend from New Jersey, along the Staten Island coast, past Coney Island and into the Rockaways. Allowing the construction of the pipe­line risks damage to many of New York’s most precious habitats and natural assets, including New York Harbor, Jamaica Bay, and the Rockaway’s many beaches.”

“I urge the Federal Energy Regulatory Commission to reject plans for the Williams pipeline and to deliver an Environmental Impact Statement that truly accounts for the harm that climate change and rising sea levels pose to New Yorkers and our environment.”

“Our goal of cutting 80 percent of emissions by 2050 makes the construction of this pipeline wholly unnec­essary. Rather than enhance the energy infrastructure of yesterday, our City must instead do all that it can to transition to renewable energy sources and promote greater energy efficiency.”

Other environmental dangers besides climate change include:

  • Air pollution
  • High heat exhaust and volume from smokestacks at CS206 (unstudied effects on wildlife or the en­vironment)
  • Spread of toxic groundwater & toxic soil
  • Destruction of habitat for threatened & endangered species
  • Trenching 23 miles of ocean floor, which will churn up toxins that will endanger sea life and land on beaches.
  • Transco’s NESE Project will impact a significant amount of wetland in New Jersey — over 41 acres, including approximately 20 acres of forested wet­land. In addition, the NESE Project will remove 35.3 acres of upland forest, and the impacts will be long term or permanent. The trees would take up to 50 years (or longer) to become reestablished, and can­not be reestablished directly over the pipeline.
  • Noise & toxin impacts on marine life as well as habi­tats for wildlife in/by the Bay
  • Damage to wetlands, removal of trees, constructing in soils that produce sulfuric acid when exposed to the air (and create very difficult re-vegetation conditions)
  • Increased velocity of gas leading to increased chanc­es of more rapid corrosion leading to increased chances of unexpected cracks, leaks or explosions (thus, more methane released and potential to spread toxins from nearby Superfund and toxic sites)
  • Potential economic damage to the fishing and rec­reation industry by the bay.

Under the Murphy Administration, the NJDEP’s Air Qual­ity Division denied a request to withdraw the 9/7/17 Air Pollution Control Preconstruction Permit and Certifi­cate to Operate Construction of a New Source (10/17/18 letter from Ken Ratzman) even though they are allowed to do so since there has not been any activity at the CS206 site for one year after issuance of this permit.

The Murphy administration can stop the NESE project under the following rules:

  1. NJDEP can deny permit applications for the following (received by NJDEP on 6/20/18)
  • Waterfront Development Individual Permit
  • Water Quality Certificate under Section 401 of the Clean Water Act
  • Flood Hazard Area Individual Permit and Verification
  • Freshwater Wetlands Individual Permit and accom­panying Transition Area Waiver
  • Concurrence with Applicant’s Coastal Zone Manage­ment Act (CZMA) Consistency Assessment.
  1. NJDEP can withdraw the Air Pollution Control Precon­struction Permit and Certificate to Operate Construc­tion of a New Source and require Williams/Transco to submit a new application that would need to address the new HAP reporting thresholds in N.J.A.C. 7:27-17.9.
  2. Demand a Health Impact Assessment be conducted around the proposed CS206 site before, during and af­ter construction (if approved).

According to the Freshwater Wetlands Protection Act Rules, N.J.A.C. 7:7A, “compelling public need” means that “based on specific facts, the proposed regulated ac­tivity will serve an essential health or safety need of the municipality in which the proposed regulated activity is located, that the public health and safety benefit from the proposed use and that the proposed use is required to serve existing needs of the residents of the State, and that there is no other means available to meet the estab­lished public need.” Clearly this is not the situation with the NESE compressor station and pipeline.

The Williams DEIS stated the annual potential to emit for Compressor Station 206 in New Jersey as being 130,863 tons of CO2 per year and 33.4 tons of methane per year. Based on the assumptions described in Ap­pendix I it is estimated that total annual GHG emissions in the region (all of the gas is expected to be consumed in New York) would be as follows:

  • Emissions from the combustion of the gas the pipe­line would carry = 7.85 MMt (million metric tons) CO2
  • Total emissions from methane leaked across the gas supply chain (extraction to consumption) (Pennsyl­vania and New Jersey) = 5.86 MMt CO2e
  • Emissions from methane leaked during transporta­tion and consumption in New Jersey and New York = 0.96 MMt CO2e
  • Total emissions from pipeline in New Jersey and New York = 15.42 MMt CO2e

The Somerset compressor would emit 0.14 MMt of CO2 per year.