NEW JERSEY CHAPTER

145 West Hanover St., Trenton, NJ 08618

TEL: [609] 656-7612 FAX: [609] 656-7618
www.SierraClub.org/NJ

Kimberly D. Bose, Secretary

Federal Energy Regulatory Commission
888 First Street NE, Room 1A
Washington, DC 20426
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 Transcos 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] 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 Transcos history with
incidents. Since 2006 Transcos 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] 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 Jerseys 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,

Jeff Tittel

Sierra Club: For Our Families, For Our Future