Comments to FERC

Rockaway Pipeline Comments to FERC – WEEK 5: IT’S NOW OR NEVER  12/8/13

Protect the Climate: 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 fight hydrofracking and climate change, which will be exacerbated 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. CP13-36-000) until 5:00pm on December 9th.  (Scroll down for information on how to submit comments to FERC)
 
To help you prepare your comments, we have been featuring various aspects of the many dangers and concerns surrounding this pipeline.  Our final suggested comments focus on the impacts this project will have on hydrofracking and climate change.
 
Talking points on this week’s topic: Hydrofracking and Climate Impacts
Williams Transco has acknowledged that this pipeline will carry fracked gas from the Marcellus Shale.  So it’s not hard to figure out that this will drive production from shale plays upstream and upwind of NYC, will increase the pressure to frack in NY State as well as Pennsylvania, and will help place in jeopardy the water supply and foodshed of millions, creating unacceptable health impacts, stressing local roads and local communities, and potentially turning many more formerly beautiful rural areas into an industrialized zone.  Is this what we want for New York?
 
 
 
Air pollution from the gasfields and emissions from the pipeline and its metering and regulating station (outrageously sited near the Floyd Bennett Community Gardens) will not only cause health effects for humans, plants and animals, but will more than negate the purported “clean burning” advantage of natural gas.
 
At a time when we should be doing everything we can to reduce greenhouse emissions, we will, in fact, be increasing them: as Cornell scientists Howarth, Santoro and Ingraffea document in the May 2011 issue of Climatic Change Letters, 
http://link.springer.com/article/10.1007%2Fs10584-011-0061-5  the carbon footprint of shale gas from extraction through delivery and final use is greater than that of oil or even the dirtiest coal.
 
It’s especially ironic that this pipeline full of greenhouse gas would be going straight through Rockaway, an area which has already been devastated by the effects of climate change in the form of superstorm Sandy. The more we learn about energy production, the more we see that sustainable energy sources like wind, tidal, and solar power are the only way we can hope to mitigate the impending climate catastrophe which is expected to have dramatic impacts on our planet and civilization.
 
Also, far from providing “energy independence,” the use of shale gas will make NYC more, not less, dependent on volatile supplies and prices of fossil fuels.  The massive buildout of natural gas infrastructure currently underway in the Northeast, including facilities for export, encourages sellers to seek the highest bidder, and prices here will rise as gas is exported to markets overseas willing to pay top dollar. Furthermore, despite the industry hype, independent analysis and evidence from older shale plays now indicate that the amount of gas recoverable from the Marcellus will be much less than originally expected.
The only entities that truly need this pipeline are the two principal corporations involved in building it, namely, National Grid and Williams Transco. And their need is not based on providing a service to New Yorkers; rather, it’s based on their need to make a profit, regardless of the consequences.
What New Yorkers truly need is a different approach to energy, one that involves government support for energy efficiency in transit, energy conservation in buildings, a modern energy distribution system, and a rapid conversion to renewable energy. But this can only be achieved if there is the political will – and the public financial support – to bring this about. Continuing to build pipelines and promote the use of shale gas is absolutely going in the wrong direction.  Shale gas is not a “bridge fuel,” it’s a gangplank to disaster.
FERC asserts that it is not their role to consider the effects this pipeline will have on hydrofracking and climate change.  It is our role to tell them that they should, that they must consider these factors in their decisions. Please tell FERC, in your own words, that there are two more reasons not to build this pipeline: on the one end, it will encourage more fracking, and on the other it will insure more climate change.
Please tell FERC, in your own words, that the contribution to catastrophic climate change is 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 hereBE 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.

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Rockaway Pipeline Comments to FERC – WEEK 4: PROTECT THE ECOSYSTEM: NO ROCKAWAY PIPELINE!  12/4/13

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 hereBE 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.

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Rockaway Pipeline Comments to FERC – WEEK 3: PROTECT NEW YORKERS FROM RADON EXPOSURE  11/23/13

An Action Alert from CARP: The Coalition Against the Rockaway Pipeline (www.carpny.org)

This week we enter the holiday season by lighting candles and stringing lights, by bringing our loved ones closer and giving thanks for our blessings over tables laden with food. And for some it begins with a celebration of a miracle – the oil that burned for 8 days when there was barely enough for one night.

As we celebrate the holidays of light and thanksgiving this week, again our thoughts go back just one year to the dark and the cold, to families gathered outdoors on Thanksgiving Day to share food behind a church, to houses ripped apart and people far from home, not sure when they could ever return.
Williams Transco is promising lots of light and heat – but let’s be aware of what may be mingled with that gas coming into our kitchens, our boilers and clothes dryers.
Here’s this week’s subject:
FERC (the Federal Energy Regulatory Commission) is accepting comments on the Rockaway Lateral Delivery Project. Please make a comment, and help us to Keep Radioactive Radon Gas out of our kitchens!
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.
 
 
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 fact that the Rockaway Pipeline will bring radioactive radon gas from the Marcellus Shale to our kitchens and boilers.1. Talking points on this week’s topic: Radon Exposure
All gas extracted from shale contains radon, an inert radioactive gas which can cause lung cancer.  Radon mixes with the methane in what we call “natural” gas and travels through delivery pipelines to reach our kitchen stoves, gas dryers and boilers.
Radon is the leading cause of lung cancer in non-smokers.  Lung cancer is the most common cancer for both men and women, and its 5-year survival rate is the lowest among all cancers.  The cancer risk from radon increases when exposure is repeated and more spread out over time, even if the exposure is at very low levels.
Radon decays to equally radioactive and dangerous “progeny,” including polonium and radioactive lead, before decaying to regular, non-radioactive lead.  When radon is breathed in, the radon itself is exhaled, but the radon progeny deposits in the lungs, where it causes cancer.  Because radon is a “heavy” gas, it tends to gravitate towards the floor, making it a particular danger for children and pets.  Radon progeny can also plate out on the sides of gas pipes, creating “hot” radioactive pipes which are an exposure hazard, and a problem for disposal.
In 1986, the EPA set a limit for exposure to radon in air at 4 picocuries per liter.  However, because of increased exposure to many other kinds of radiation in today’s world, both Johns Hopkins University and the World Health Organization have indicated that 2.7 picocuries per liter would be a better standard.  Of course, there is no truly safe level of exposure.
In the past, the natural gas used in this region was sourced from the Gulf Coast.  Such gas has been found to average approximately 5 picocuries of radon per liter at the wellhead.  But the Rockaway Pipeline, according to Williams Transco’s own statements, will also bring us gas from the Marcellus Shale, which lies under Pennsylvania, Ohio and New York.  This gas is much more radioactive.  Studies at wellheads in the Marcellus are very limited, but have shown the potential for as much as 150 picocuries per liter at the wellhead.  Suffice it to say that people within the industry use the radioactivity of the Marcellus Shale as a “marker” to distinguish it from gas from other locations!
Radon levels in NYC apartments will become higher as the proportion of Marcellus gas in our supply increases. Because this source is much physically closer to New York also means that the radon has less time to decay in transit. Radon has a half-life (loses half of its radioactivity) of 3.85 days.  Gas from the Gulf Coast takes 4-8 days to reach New York City, but gas from the Marcellus, which is so much more radioactive to start with, would get here much faster, in less than a day.  So this makes it even more likely that we will be exposed to gas with dangerous levels of radon.
NYC kitchens are particularly vulnerable to radon buildup, since many of these kitchens are small, and may not have windows or hoods venting to the outside.  When internal “passive” wall vents exist in apartments, people often seal them to avoid cooking odors from neighbors.  And during the winter, when windows are most likely to be closed, the demand for gas is highest, and so it is delivered at a faster rate with even less time for radioactivity to decay.  Also, many NYC gas stoves, especially in low-income neighborhoods, still have old fashioned “pilot lights” which result in 24/7 exposure to gas.
Voluntary citizen radon testing over the past two years has shown that NYC kitchens typically have radon levels less than .3 picocuries per liter.  We want to keep it that way!  But with radioactive Marcellus Shale gas coming to NYC from both the Rockaway Pipeline, and the Spectra Pipeline into Manhattan, it has been estimated that an additional 30,000 deaths from lung cancer could result.  Assemblywoman Linda Rosenthal considers this to be such a threat to New Yorkers’ health that she introduced a bill, A6863,
which would require suppliers of natural gas to guarantee that gas delivered to NYC does not contain unacceptable levels of radon.
So what does the FERC draft EIS have to say about radon?  Very little.  Section 4.11.1.5 of the dEIS states as follows:
Radon is a naturally occurring radioactive gas that is odorless and tasteless.  It is formed from the radioactive decay of uranium (Agency for Toxic Substances and Disease Registry, 2011).  Radon can be contained in fossil fuels including natural gas.  Since radon is not destroyed by combustible burning natural gas containing radon can increase the level of radon within a home (Agency for Toxic Substances and Disease Registry, 2010).  Several factors limit the indoor exposure to radon from natural gas.  Radon’s half­­-life, defined as the time it takes for the element to decay to half its initial concentration, is relatively short (3.8 days).  The time needed to gather, process, store and deliver natural gas allows a portion of the entrained radon to decay, which decreases the amount of radon in the gas before it is used in a residence.  The required venting of appliance exhausts from water heaters, furnaces, and other appliances also limits potential exposure pathways to radon emissions.”
 
“While the FERC has no regulatory authority to set, monitor, or respond to indoor radon levels, many local, state, and federal entities establish and enforce radon exposure standards for indoor air.  It is expected that the combustion of gas transported by the Projects would comply with all applicable air emission standards.  In the unlikely event that these standards are exceeded, the necessary modification would be implemented to ensure public safety.”
They seem to be saying that: (1) the radon will decay (even though we know that it will arrive from the Marcellus in less than a day, less than the 3.8 day half-life); (2) venting will reduce exposure (even though many kitchens have neither windows nor functioning vents); and (3) if there is a problem, it will somehow be dealt with. This does not seem very reassuring.
Another thing to consider is that methane pipelines are subject to enormous amounts of leakage, so even if you do not have natural gas in your own kitchen, you may still be exposed to this radioactive gas as you walk the streets of the five boros.  For example, take a look at natural gas leaks in Manhattan: http://blog.visual.ly/data-art-and-environmentalism-collide-at-cooper-union/
 
Please tell FERC, in your own words, why you do not want the Rockaway Pipeline to expose us to dangerous levels of radon that will cause cancer. Some additional materials that may be helpful are given below.
To learn more about radon in our natural gas supply: http://saneenergyproject.org/radon/
A complete panel discussion on this topic that was held at Cooper Union:http://www.youtube.com/playlist?list=PL5ZIvUpU2rlFyetf942AHLVpq-w5YMfda

2. 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.”

3. Other Talking Points

Other talking points are available 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.

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Rockaway Pipeline Comments to FERC – WEEK 2: KEEP THE GAS INDUSTRY OUT OF OUR NATIONAL PARK  11/15/13

WEEK TWO Action Alert: Keep the Gas Industry out of our National Park

FERC (the Federal Energy Regulatory Commission) is accepting comments on the Rockaway Lateral Delivery Project. Please make a comment, and help us to Keep the Gas Industry out of our National Park!

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 (also known as Transcontinental) 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. Part of this project has not been deemed subject to federal review and has already been built, but the crucial part still has to pass state and federal review.

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.

 

This week we are focusing comments on the fact that much of this project is taking placed within NYC’s only national park, Gateway National Recreation Area (GNRA).

 

  • The proposed pipeline would cross over 1/2 mile of land within GNRA boundaries. Much of this would be located onshore within Jacob Riis Park (see draft EIS page 4-109).
  • The M&R Station would be constructed within a 1.1-acre historic hangar complex (i.e., Hangars 1 and 2). Approximately 5.5 acres would be directly affected by construction of the M&R facility (draft EIS page 4-111).

Please read below for:

 

1.      Talking points on this week’s topic: Our National Park

2.      Instructions on how to submit your comments

 

1. This week’s talking points.

A. Floyd Bennett Field has national historic significance

As part of the Rockaway Project, Transco plans to build a metering and regulating station inside historic hangars 1 and 2 in Floyd Bennett Field, located within GNRA. Although Transco will restore the facades, for the duration of this company’s use, the interiors of hangars 1 and 2 will be off limits to the public.

Why are Floyd Bennett Field and these hangers historically significant?

  • Floyd Bennett Field was the first municipal airport in New York City
  • Because of its unusually long runways and fair weather conditions, Floyd Bennett Field became noted as a prime airport for the experimental fliers establishing speed and distance records. Pioneers aviators Charles Lindbergh and Amelia Earhart frequented the field.
  • During World War II it was the busiest Naval Air Station in the United States.
  • Floyd Bennett Field still retains the architectural design and historic integrity of an early municipal airport.

http://www.cr.nps.gov/nr/travel/aviation/flo.htm “Floyd Bennett Field Historic District.”

Two years ago, the federally-convened Floyd Bennett Field Blue Ribbon Panel recommended that Gateway “preserve and herald the site’s aviation history,” advising that “the remaining derelict hangars should be rehabilitated and repurposed as flexible and multi-purpose spaces, possibly as space for historic aircraft storage or viewing or other commercial uses” and that “in the long-term, aviation activity should be relocated [from elsewhere in the field] to Hangar Row”. The panel believed the concentration of aviation-related and cultural activities in Hangar Row would serve “as a visible draw to the site.”

Additionally, the panel asked Gateway to “remove inappropriate uses”, citing the NYC Police Department driver training as an example, and recommended establishment of a “moratorium preventing any inappropriate uses.”

                                                                                                                                                                                                     http://www.rpa.org/pdf/FBF_Report_Final.pdf

Now Transco proposes to build a metering & regulating station within two of these historic hangars. To understand what that might look like, we turned to a federal agency that knows a lot about these matters—Pipeline & Hazardous Materials Safety Administration (P&HMSA). In layman’s terms, they advise local governments and developers to think twice before building near pipeline appurtenances (m&r facilities, for example) because they likely will be the source of noise, odor, emissions and the occasional accident.

https://primis.phmsa.dot.gov/comm/pipa/pipa_practice_ND18.htm

So, if one might be wise to forgo development near the source of such annoyance and/or hazards, why would one invite the source of such annoyance/hazards to an area that had  already been developed?

Given the historic nature of this airfield and these buildings, and the vision so recently set forth by the Blue Ribbon Panel, does the Transcontinental plan (and what we know of metering & regulating facilities) measure up to the vision?   

 

B. The project jeopardizes the historic airplane hangers.

The “construction and operation of the Projects could potentially affect historic properties. Direct effects could include destruction or damage to all or a portion of an archaeological site or alteration or removal of a historic property. Indirect effects could include the introduction of visual, atmospheric, or audible elements that affect the setting or character of a historic property.”

(From section 4.10.4, page 4-132 of the Draft EIS submitted by FERC.)

In Section 4.11, page 4-130 Transco writes that “the simultaneous operation of multiple pieces of equipment or equipment operating at distances closer than 5 to 10 feet (from the Hangers) could potentially cause damage.” The study recommends that the engineering design for the Rockaway Project identify vibration level thresholds for the structures, that Transco prepare and implement a Construction Protection Plan (CPP) to protect the integrity of the hangar complex during construction, and that the plan include vibration monitoring.

Transco further writes that if the FERC, in consultation with the National Parks Service “determines that a historic property would be adversely affected by the Projects and (the damage) could not be avoided, Transco would be required to prepare a treatment plan in consultation with the appropriate parties to mitigate adverse effects.”

In other words, Williams Transco knows that construction may damage the existing historic hangers, and that they will very likely need to create a plan to mitigate damage, but only if the National Parks Service and FERC require them to do so.  

 

C. Floyd Bennett Field is an important recreational and educational destination for New York City residents.

In December 21, 2010 the Floyd Bennett Field Blue Ribbon Panel’s recommendations stated “Floyd Bennett Field (FBF) should be an iconic urban National Park, simultaneously preserving significant natural and cultural resources, serving as a “gateway” to the National Park experience for New York City’s residents and visitors of all ages, and helping to address the open space deficit of southern Brooklyn and Queens. . . The historical and habitat assets of FBF should be restored and made accessible. Incompatible uses should be moved out or scaled back.”

(http://www.rpa.org/floydbennett/FBF-Task-Force-Recommendations.pdf)

Current activities at Floyd Bennett Field include

  • Youth camping
  • Nature trails
  • A model airplane flying field
  • Sports fields used by the Public School Athletic League
  • An archery range
  • Aviator Sports (uncomfortably close to Hangers 1 and 2)
  • The Floyd Bennett Garden Association of over 400 gardeners (merely 200 feet from Hangers 1 and 2)
  • A cricket club
  • The Historic Aircraft Restoration Project, and
  • The Gateway Environmental Education Center run by the NYC Department of Education and NYU.

Rather than place an industrial project in Floyd Bennett field, the activities described above should be protected and enhanced.  This pipeline  project constitutes an ‘incompatible use’, as discussed by the Floyd Bennett Field Blue Ribbon Panel, above.

D. This project does not belong in our National Park.

Gateway National Recreation Area sees approximately 9.5 million visitors a year. The enabling legislation for Gateway states that:

“In order to preserve and protect for the use and enjoyment of present and future generations an area possessing outstanding natural and recreational features, the Gateway National Recreation Area (hereinafter referred to as the “recreation area”) is hereby established.”

(16 USC Chapter 1, Subchapter LXXXVII – GATEWAY NATIONAL RECREATION AREA)

Finally, but critical to your understanding of the risks inherent in allowing this project into our park, here are some links to information about Williams Transco’s safety record and how the company has addressed problem elsewhere:

http://www.naturalgaswatch.org/?p=1305

http://www.youtube.com/watch?v=uPeh8RZGZmA&list=PLo1TDxDrIRYoOSND7uKrDMeK8RD46Ks8T

http://new.livestream.com/accounts/2274717/events/2185305/videos/21874206

The use of a National Park for industrial purposes is incompatible with the purpose and intent of the National Parks.

 

Such use will also jeopardize the health and safety of those who use Floyd Bennett Field for recreation, as well as that of beachgoers at Jacob Riis Park.  The impacts will be most severe for those New Yorkers in the lower socioeconomic brackets who are unable to afford summer homes or vacation travel, and who therefore rely more heavily on the public parks.

2. 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.

3. Other Talking Points

Other talking points are available 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.

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Rockaway Pipeline comments to FERC – WEEK ONE: SAFETY  11/9/13

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.

 

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Public Comments on Rockaway Lateral Pipeline: instructions, talking points 10/24/13

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 HabitatThe 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 ToxinsThe 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 InadequateWhile “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.
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Rockaway Countdown — 90 Days to Comment on Draft EIS  10/05/2013

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 http://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 http://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

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