Talking Points

Talking points for comments to the Federal Energy Regulatory Commission:

1. This Project Should Not Be Segmented To Avoid ReviewThe 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 SafetySince 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.

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