Vegetation & Wildlife

 Deficiencies in the DEIS:

Missing and Faulty Analysis

  • Prior to construction, PennEast shall modify its proposal to exclude the use of forested areas as pipe storage-yards. (Section 4.5.1.2)

  • Prior to construction, PennEast shall develop a New Jersey No-Net Loss Reforestation Act Plan for the parcels identified in table 4.5.1-2 of the EIS, in coordination with NJDEP and file the plan with the Secretary. (Section 4.5.1.2)

  • Prior to the construction, PennEast shall develop an Invasive Species Management Plan in consultation with appropriate state agencies that includes measures it will implement during construction and operation to minimize the spread of invasive and noxious plant species along with documentation of consultation with the relevant agencies. (Section4.5.1.2)

  • Prior to construction, PennEast shall file with the Secretary a Migratory Bird Conservation Plan developed in consultation with the FWS, along with documentation of consultation with the FWS. (Section 4.5.2.3)

Key Writing Points For Comments

 
Vegetation and Threatened & Endangered Species

  • PennEast has not completed surveys for a range of threatened and endangered species, including long-tailed salamanders.  If you have spotted long-tailed salamanders or other sensitive wildlife species on your property, please submit a comment to FERC about this, and also contact alix@njconservation.org so that we can help you document these species on your property.

  • The DEIS has yet to provide mitigation measures for bog turtles or any of the state-listed species or state species of concern. It also has yet to ensure the project doesn’t come within at least 0.25 mile of bat shelter (“hibernacula”).

  • The DEIS fails to list, document, or provide any survey information about New Jersey plant species of special concern. Impacts to these plants cannot be mitigated. There is an extensive list of these species in the pipeline’s route, and the DEIS completely ignores them, despite many comments on the docket from agencies and biologists asking for data and avoidance plans.

  • “FERC requests that the FWS consider this EIS as the Biological Assessment,” (ES-9) yet the DEIS is missing survey information for 70% of the properties along the route.

  • The DEIS’s premature publication prevents the public from commenting on the missing mitigation plans such as:
              ​- A NJ No-Net Loss Reforestation Act Plan for the parcels identified in table 4.5.1-2
              An Invasive Species Management Plan
              A Migratory Bird Conservation Plan

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)

The PennEast Draft Environmental Impact Statement (DEIS) is deficient and should be withdrawn.  I am concerned about the following issues:
I am shocked that this DEIS could be released at the stage it is currently in. The DEIS has yet to provide mitigation measures for bog turtles or any of the state-listed species or state species of concern. It also has yet to ensure the Project doesn’t come within at least 0.25 mile of bat hibernacula.


The DEIS fails to list or document or provide any survey information about New Jersey Plants of Special Concern.  There is a very, very long list of these species in the pipelines route, and the DEIS completely ignores them, despite many comments on the docket from agencies and biologists asking for data and avoidance plans.  Impacts to these plants cannot be mitigated.


“FERC requests that the FWS consider this EIS as the Biological Assessment,” (ES-9) yet how can that be if this DEIS is missing survey information for 70% of the properties the pipeline will cross?


It is not fair that the DEIS was published prematurely because it prevents the public from commenting on the missing mitigation plans such as: 

        a NJ No-Net Loss Reforestation Act Plan for the parcels identified in table 4.5.1-2,
        an Invasive Species Management Plan
        a Migratory Bird Conservation Plan

How can we be given a September 12th deadline for comments when we don’t have all the information we need to be reviewing?  I urge FERC to withdraw this DEIS and to give the public at least 90 days for commenting after the DEIS is complete.

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 VEGETATION & WILDLIFE.