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

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

NEW JERSEY CHAPTER

145 West Hanover St., Trenton, NJ 08618 TEL: [609] 656-7612 FAX: [609] 656-7618 www.SierraClub.org/NJ

Re: OEP/DG2E/Gas 2 Transcontinental Gas Pipe Line Company, LLC Docket No.

CP15-89-000

Dear Ms. Bose,

We do not believe that the Environmental Assessment for Transco’s Garden State Expansion Project does not follow NEPA. It is inaccurate and incomplete because it fails to look at the secondary and cumulative impacts not only from the Garden State Expansion compressor project, but from the Southern Reliability Link pipeline and PennEast Pipeline. The impacts from these other projects need to be included in the EA because they are all one project. We believe that the project should have an Environmental Impact Statement and a full NEPA review that includes a no-build option and examines historic sites. It also needs to be examined for impacts to threatened and endangered species, as well as impacts to groundwater, wetlands and streams and air quality.

The Garden State Expansion project, Southern Reliability Link pipeline and PennEast Pipeline are all one project. NJNG, is a 20% partner in PennEast and is getting their 180,000 dekatherms of natural gas from them. PennEast is putting that gas into a Transco substation in Ewing which is part of the Garden State Expansion. That same amount of gas will then go to compressor station in Chesterfield and into the Southern Reliability Link pipeline. The compressor station, Southern Reliability Link, and PennEast Pipeline would work together as one system and should be evaluated as such. The environmental assessment fails to weigh the secondary and cumulative impacts from this system as a whole by disregarding the effects of the Southern Reliability Link pipeline or PennEast pipeline.

The Environmental Assessment does not examine the cumulative impacts of the two pipelines that are part of the project and instead segments the Garden State Expansion. Federal court ruled that FERC cannot segment these pipelines into multiple projects and that they have to look at secondary and cumulative impacts. The court case Delaware Riverkeeper Network and Sierra Club vs FERC determined that FERC is required by law to examine secondary or cumulative impacts of a project such as this one as a whole and without segmentation. This Environmental Assessment segments the Garden State Expansion project. It fails to evaluate the effects of the project as a whole by leaving out the Southern Reliability Link and PennEast pipelines and this is ultra virus.

We also believe that there will be significant pollution from the compressor station that has not been properly evaluated. The Garden State Expansion compressor station would bring more

Sierra Club: For Our Families, For Our Future

NEW JERSEY CHAPTER 145 West Hanover St., Trenton, NJ 08618 TEL: [609] 656-7612 FAX: [609]

NEW JERSEY CHAPTER

145 West Hanover St., Trenton, NJ 08618 TEL: [609] 656-7612 FAX: [609] 656-7618 www.SierraClub.org/NJ

noise, light, and air pollution, as well as construction and water pollution to the area. We believe there are significant air quality impacts that have not been addressed regarding the compressor station. As such, we do not believe the compressor station would meet the criteria for air quality permits. Compressor stations create air pollution and water pollution by releasing toxic chemicals. These stations experience both scheduled and unscheduled blowdowns which release methane, ethane, MTBEs and other chemicals into the air. Other pollutants that have come from compressor stations include formaldehyde, propane, isobutene, cyclohexane, benzene, toluene, and other greenhouse gasses. High levels of these chemicals that come out of the compressor station via air and water pollution can directly affect public health, especially during construction. There is also concern about “fugitive emissions” which occur from leaks and get worse over time.

The construction and operation of this station would also potentially create water pollution and contaminate drinking water in the region because of the use of hazardous chemicals and runoff from construction that could impact groundwater. This project presents a safety hazard to surrounding communities and environment, especially because of Transco’s history with incidents. Since 2006 Transco’s pipelines have been involved in at least 50 gas transmission incidents. In West Virginia, a pipeline exploded burning down 2 acres of forest. The possibility of safety concerns affecting environmentally sensitive land should be considered in the assessment. An explosion or leak could destroy important habitat and ad pollution to waterways. We believe that the compressor station could potentially create safety hazards for surrounding communities and disrupt environmentally sensitive land and waterways.

There are two pipelines that make up the entirety of the project along with the Garden State Expansion. The Southern Reliability Link (SRL) that would attach to the compressor station in Chesterfield and run through Burlington, Monmouth, and Ocean counties. The 30-mile, 30 inch pipeline would begin in Chesterfield, Burlington County and run through the Pinelands to the shore to connect to the utility system in Manchester Township, Ocean County. Since this pipeline would be a direct result of the compressor station and is part of the project as a whole, we believe that the impacts of the pipeline must be considered as part of the assessment.

The Southern Reliability Link pipeline would go through the Pinelands National Reserve. The Pinelands is a UN biosphere reserve and one of the largest sources of fresh drinking water on the east coast. This project would put the environmentally sensitive lands, as well as drinking water for thousands of people, at risk. It may also impact the Bomarc Superfund Site and federally recognized endangered species such as Swamp Pink. Both of these issues need to be evaluated as part of the Environmental Assessment as well. We need to look at the cumulative impact environmentally of all these pipelines cutting through the Pinelands and threatening our drinking water as well as impacts under the Clean Water Act and Clean Air Act.

Since the Southern Reliability Link pipeline will be a direct result of the compressor station, FERC should not take any action until a 401 permit is granted for it. It also needs to be evaluated for impact to wetlands and 303 permit. We believe that the SRL line would violate the Clean

Sierra Club: For Our Families, For Our Future

NEW JERSEY CHAPTER 145 West Hanover St., Trenton, NJ 08618 TEL: [609] 656-7612 FAX: [609]

NEW JERSEY CHAPTER

145 West Hanover St., Trenton, NJ 08618 TEL: [609] 656-7612 FAX: [609] 656-7618 www.SierraClub.org/NJ

Water Act Also and cannot meet the requirement for a 401 water quality permit. We also believe that it violates the 404 section of the Clean Water Act and cannot meet the criteria for 404 permits. The reason is because of the amount of high quality streams, wetlands, and rivers it is crossing through. Many of these streams are C-1, meaning it will be impacting some of the highest water quality waterways in the state. We are seriously concerned that the pipeline crosses New Jersey’s C-1 designated waters and associated wetlands and habitats. Many of these streams carry anti-degradation criteria.

Despite claims from the company, the Southern Reliability Link would bring five times as much natural gas into Ocean County than necessary for resiliency. The purpose of this pipeline is for growth in the coastal region, not for reliability along the route. It would do so by transporting gas from PennEast. Therefore, PennEast Pipeline should also be included in the evaluation of environmental impacts of this system as a whole. PennEast pipeline is proposed to go from Pennsylvania to New Jersey and cut through open space and important waterways. We believe that this pipeline violates the Clean Water Act and does not meet criteria for 404 permits or 401 water quality permits. Since the gas from PennEast pipeline would be transported via the Southern Reliability Pipeline that would connect to the compressor station, the environmental impacts of both pipelines need to also be considered when evaluating those of the compressor station.

The Sierra Club believes that this Environmental Assessment is inadequate because it fails to include a meaningful cumulative environmental analysis that includes “the impact on the environment which results from the incremental impact of the action when added to other past, present and reasonably foreseeable future actions” regardless of who undertakes them. Cumulative impacts can result from individually minor but collectively significant actions taking place over a period of time.” The Garden State Expansion Project needs to be evaluated for not only the environmental impacts of the proposed compressor station in Chesterfield, but those of the Southern Reliability Link and PennEast pipelines that would make up the entire system and project as a whole. The Southern Reliability Link and PennEast pipeline are part of the whole project and need to be included in the Environmental Assessment.

Very truly yours,

be included in the Environmental Assessment. Very truly yours, Jeff Tittel Sierra Club: For Our Families,

Jeff Tittel

Sierra Club: For Our Families, For Our Future