In response to Brian Ham’s May 3 response to our May 2 letter to the editor, clarifications are provided here to ensure that the public is not misled or confused.  Likely, we differ on what constitutes “detailed facility descriptions” since the Application descriptions did not include components like the two 50’ smokestacks or the height of the communication tower, but the more relevant parts for public understanding pertain to (1) the comment period allowed for public review and response to the Application and (2) assertions of safety for a compressor station and the associated pipelines.

First, Mr. Ham noted that the regulatory review process takes 8 to 10 months and that FERC accepts and considers comments at any time during that period.  However, there is a distinction to be made between “accepts” and “considers”.  It is true that FERC accepts comments during this process. However, as seen clearly in the flow chart diagram in the link he provided (FERC’s EIS Pre-Filing Environmental Review Process), that does not mean that FERC provides opportunity for public comment for that entire time.  Public input opportunities are clearly highlighted with turquoise background coloring.  The current opportunity for public comment that must be considered by FERC as they move from reviewing the Application to preparing a draft Environmental Impact Statement (DEIS) ended 30 days after the Application was submitted.  For clarity, the Application was submitted on 3/27/17, and FERC issued a “comment date” of 4/27/17 on their Notice of this Application.  As concerned citizens who recognized that this date was more clearly specified in FERC’s Notices for other projects as the last date for comments to be considered by them, we sought and received confirmation from FERC that 4/27/17 was the cut-off date for comments if we wanted them to be seriously considered but FERC will accept comments at any time.  This is clearly presented in the diagram provided in the letter by Mr. Ham that the time when FERC will be analyzing data and preparing the DEIS is not a time when they consider public comment.  The next turquoise box in the flow chart diagram starts again when FERC issues the DEIS and “opens comment period”.  That being said, people should certainly continue to submit comments to FERC now and until th DEIS is published with the hopeful anticipation that they will be given serious consideration

As a point of reference for the readers, the anticipated dates for aspects of this regulatory process, provided in the correspondence in Williams/Transco’s Application are: 

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Draft Environmental Impact Statement:  10/23/17

Final Environmental Impact Statement:  4/21/18

Certificate of Public Convenience & Necessity from FERC:  6/21/18

Williams/Transco requests a Notice to Proceed with construction from FERC:  8/4/18

Federal Permits (like those from NJDEP):  9/18/18

Mentioning that it is normal for missing data in the Application to be provided in supplemental filings is understood, and the list attached to the 5/2 letter notes what was missing as well as what was anticipated to be provided during the second quarter of 2017.  Disconcerting in the Application were assertions of minimal impact without complete data, supporting studies and analyses.  Additionally, with concerns about safety and the environmental impacts, it was noted that information about the sources for water, sewers and electrical power for Compressor Station 206 were not known when the Application was submitted, but they would be provided in the second quarter of 2017.  Hopefully, that information will be available for public review. 

Mr. Ham noted that the Transco pipeline has been safely operating in Franklin Township for decades, and he also shared that NESE has been designed to increase Transco pipeline deliveries to National Grid [in New York].  However, this does not provide comfort or confidence to people who will be near the compressor station or along the aging pipeline since Williams/Transco has not provided information about a similar-sized gas-powered compressor station near an actively blasting quarry after this was requested.  Without knowing that such a station was built and operated safely for a while elsewhere, people worry.  Those who live near Trap Rock Quarry know the impacts of the blasting on their homes, and they recognize that these impacts compound over time. Additionally, speculation about a contributing factor at a huge pipeline explosion about a year ago in Pennsylvania was that the rate of corrosion on a pipeline was hastened much more quickly than anticipated, and this might have been due to previously increased compressor power since increases in compression raise the temperature and velocity of natural gas traveling through the pipelines.  Knowing that corrosion was detected there but that its amount did not trigger a need for repair before the next planned inspection, and learning about the rapid advance of corrosion that led to an explosion is also worrisome here.  Pipelines associated with Compressor Station 206 are not new, and results of inspection of them are not publicly available information. 

To close, we are pleased to hear that the 4/25/17 NJTV News report that the station would only take up 6 acres was corrected to the 8.92 acres for the compressor station and associated buildings.  The project does, however, involve building of a new access road that will use an additional 7.81 acres unless the planned route for this is changed.  We look forward to seeing the supplemental filings and hope that FERC extends the “comment” period after each of them so that our comments are given serious consideration.

Sincerely,

Franklin Township Task Force on Compressor Station 206 & NESE

Barbara Cuthbert, Kirk Frost, Carol Kuehn, Bernadette Maher & Linda Powell