AIR QUALITY & NOISE

 Deficiencies in the DEIS:

Air Quality

  • The DEIS inaccurately downplays any negative impacts in emissions: “Emissions associated with the Project would contribute to cumulative air quality impacts.”  The DEIS goes on to state that “There is also the potential, however, that the Project would contribute to a cumulative improvement in regional air quality if a portion of the natural gas associated with the Project displaces the use of other more polluting fossil fuels.” (ES-14). It then points to no data to support this supposed benefit.  

  • EPA data (2014) shows that New Jersey CO2 emissions are going up, not down, due to natural gas fired electrical emissions. NJ transitioned from coal years ago and there are no other “more polluting” fossil fuels that PennEast is replacing.

NOISE

  • If changes to the Project construction schedule occur that will materially impact the amount of NOX emissions generated in a calendar year, PennEast shall file with the Secretary, in PennEast’s weekly status report, revised construction emissions estimates prior to implementing the schedule modification demonstrating that the annual NOX emissions resulting from the revised construction schedule do not exceed general conformity applicability thresholds. (Section 4.10.1.3)

  • Prior to construction, PennEast shall file with the Secretary, for review and written approval by the Director of the OEP, a HDD noise mitigation plan to reduce the projected noise level attributable to the proposed drilling operations at the 18 NSAs with predicted noise levels above 55 dBA Ldn. During drilling operations, PennEast shall implement the approved plan, monitor noise levels, include the noise monitoring results in its weekly status reports, and make all reasonable efforts to restrict the noise attributable to the drilling operations to no more than 55 dBA Ldn at the NSAs. (Section 4.10.2.3)

  • PennEast shall file a noise survey with the Secretary no later than 60 days after placing the Kidder Compressor Station in service. If a full load noise condition survey is not possible, PennEast shall provide an interim survey at the maximum horsepower load and provide the full load survey within six months. If the noise attributable to the operation if the compressor station at full load exceeds an Ldn of 55 dBA at any nearby NSA,

  • PennEast shall file a report on what changes are needed and shall install the additional noise controls to meet the level within one year of the in-service date. PennEast shall confirm compliance with the above requirement by filing a second noise survey with the Secretary no later than 60 days after it installs the additional noise controls. (Section4.10.2.3)

  • Prior to the end of the draft EIS comment period, PennEast shall file with the Secretary proposed mitigation measures to minimize noise levels associated with emergency or maintenance MLV blowdown events. Mitigation measures may include but not be limited to use of a silencer, restricting maintenance blowdowns to daytime hours only, and/or notifying landowners in the immediate area of the planned blowdown event. (Section 4.10.2.3)

  • Prior to the end of the draft EIS comment period, PennEast shall file with the Secretary a complete noise analysis of the Project metering (interconnect) stations using the best available typical design or vendor specification with regards to impacts on the closest identified residences/NSA as shown in table 4.10.2-10. (Section 4.10.2.3)

Key Writing Points For Comments


In your comments to FERC, it is important to raise as many different points through multiple letters. You should include detailed notes, specific data and unique stories about how you, your family, your property or business and your community would be impacted by PennEast. 
Following are key facts and figures for your use in your comments, to support your issues and concerns about PennEast. We encourage you to share this information with your friends, family and colleagues, as well.

Cumulative Impacts

  • Six (6) new pipelines: PennEast, Crestwood Marc II, Garden State Expansion Project (GSE), Southern Reliability Link (SRL), William’s Atlantic Sunrise and Northeast Supply Enhancement Project are all segments of an interconnected pipeline system; each segment is dependent upon the others. FERC has not examined the cumulative impacts of these connected actions. Examples:

  • There are contracts and capacity for exactly the same daily capacity of 180,000 dekatherms in firm supply from PennEast as there is for SRL.

  • NJR is an owner of PennEast and has a contract for 180,000 dekatherms of firm supply in PennEast. It is also the owner of the proposed SRL.


The DEIS states that alternatives cannot be considered because PennEast must connect at the top of the Garden State Expansion project - Transco Compressor #205.  Therefore, PennEast itself acknowledges that these projects are connected.  Therefore in-depth cumulative impacts analysis needs to be provided and the DEIS does not accomplish this.

Infrastructure projects are considered “connected” where they are “closely related” and:
  • Automatically trigger other actions which may require environmental impact statements, 

  • Cannot or will not proceed unless other actions are taken previously or simultaneously, and are interdependent parts of a larger action and depend on the larger action for their justification. Id. at § 1508.25(a)(1).

The cumulative impacts of PennEast on greenhouse gases should be evaluated.

  • The DEIS concludes that there are ‘no significant cumulative impacts’ but it omits much of the data necessary to reach an accurate finding. This is a violation of NEPA and Council on Environmental Quality (CEQ) regulation mandating that agencies ensure "environmental information is available to public officials and citizens before decisions are made and before actions are taken.” 40 C.F.R. § 1500.l(b) (emphasis added)

  • The DEIS cites the “implementation of specialized construction techniques” as a way to prevent cumulative impacts. However, FERC has requested details about these techniques but PennEast has still not provided it.

  • Species cumulative impacts are incomplete. This shows that the DEIS is not ready to be released and no conclusions should be made.

Noise cumulative impacts are only measured for HDD but no measurements are given for increased construction noise or increased noise from the additional operation of the GSE compressor station #205 that PennEast’s gas will require.

The DEIS inaccurately downplays any negative impacts in emissions: “Emissions associated with the Project would contribute to cumulative air quality impacts.”  The DEIS goes on to state that “There is also the potential, however, that the Project would contribute to a cumulative improvement in regional air quality if a portion of the natural gas associated with the Project displaces the use of other more polluting fossil fuels.” (ES-14). It then points to no data to support this supposed benefit.  EPA data (2014) shows that New Jersey CO2 emissions are going up, not down, due to natural gas fired electrical emissions. NJ transitioned from coal years ago and there are no other “more polluting” fossil fuels that PennEast is replacing.
 

Sample Letter  

Kimberly D. Bose, Secretary
Federal Energy Regulatory Commission
888 First Street NE, Room 1A
Washington, DC  20426

RE: PennEast Pipeline (CP15-558-000) 

Dear Secretary Bose,
I am (enter your name and state how you are affected - directly impacted landowner?  Intervener?  Business  Owner?) in this proceeding who lives in (enter your address or Twsp).  I am concerned about the impact the pipeline will have on noise.

The DEIS says that, “based on the analyses conducted, the proposed mitigation measures, and our recommendations, we concluded that
construction and operation of the Project would not result in significant noise impacts on residents and the surrounding environment.” However, FERC is still missing a lot of information from PennEast such as,
    -“a HDD noise mitigation plan to reduce the projected noise level attributable to the proposed drilling operations at the 18 NSAs with predicted noise levels above 55 dBA Ldn.”
    -“mitigation measures to minimize noise levels associated with emergency or maintenance MLV blowdown events.”
    -“a complete noise analysis of the Project metering (interconnect) stations using the best available typical design or vendor specification with regards to impacts on the closest identified residences/NSA.”

How can FERC make an informed decision without any of this data? How can they just say that with FERC’s recommendations and mitigation measures, there will be no significant impact even though FERC has yet to receive any complete document from PennEast which outlines mitigation measures for noise levels?

FERC says, “PennEast shall file a noise survey with the Secretary no later than 60 days after placing the Kidder Compressor Station in service.” It then goes on to says that if the noise levels from the Kidder Compressor Station do not meet the correct standards, PennEast shall report and implement mitigation measures within one year of the in-service date and then PennEast also then is given another 60 days to show FERC that it has in fact corrected the noise levels! How can FERC conclude that there will be no significant impacts when people may have to endure noise levels above 55 dBA Ldn for a whole year? This timeline seems awfully lengthy, especially when considered in conjunction with other time limits, such as the short 45-day period that the public has to comment on the DEIS.

Why won’t PennEast know the noise levels of the Kidder Compressor Station before it is in service? Why would FERC allow the Kidder Compressor Station to be built with the potential to have noise levels above above 55 dBA Ldn and still claim that the pipeline will have no significant noise impacts?

With so many information gaps, I don’t see how FERC can conclude that this pipeline won’t have any significant noise or air quality impacts. 
I respectfully call upon FERC to respond to my comments, and to suspend the review of this fraudulent DEIS.

Sincerely,

You will have a FERC ID, if
you filed as an intervener or have filed previously.

  Forgot your FERC ID?
If you have intervened or commented before you should have recieved a FERC ID #.
If you do not have it you can enter your email address you used to file.
Ready to
File?
CLICK HERE
CLICK HERE

You will need to know the Docket # CP15-558 when you file.

Comments to FERC on the Docket

Below are some of the teriffic comments from citizens they have already filed on the docket.

You can use these as a tool to help you build your comments. Some of these comments are from specialist in their field so your comment does not have to be as detailed. You can write about your concerns about NOISE.