Tell the Pinelands Commission to STOP the South Jersey Gas pipeline

Send a letter (below) to tell the Pinelands Commission to reject the South Jersey Gas pipeline that is proposed to cut through the Pinelands.

Learn why the SJG pipeline should be rejected.

Fill in the letter to the Pinelands Commission below* (Deadline: EXTENDED to 5 p.m. on Feb. 8 due to overwhelming response so far – keep it going!)

stopGSESRL

First Name *

Last Name *

Email Address *

Town

State

The Letter

Dear Ms. Arnett,

As a concerned member of the community, I am writing to express my strong opposition to the Southern Reliability Link (File No. 0000-15-0007.1) and to the Garden State Expansion (File No. 0300-15-0002.2 FWW15000). Below I have detailed the many reasons that the NJDEP should reject these projects:

SRL is inappropriately segmented, and SRL and GSE are inextricably linked. SRL does not meet the definition of an “independent utility” under Section 404 of the Clean Water Act. Therefore, SRL must be reviewed with GSE as a “single and complete” project. GSE and SRL must be combined under the same wetland permit application to accurately assess the impact of the installation.

There is NO public need for SRL. Profit is the only justification. According to Skipping Stone, a national firm with expertise in energy market services, NJNG’s SRL is not needed for reliable gas supply and NJNG already has a resilient system with built-in redundancy. SRL would increase consumer’s costs while boosting NJNG’s profits. Ratepayers would pay the $170 million to build an unnecessary pipeline — plus additional annual costs from Williams’ Transco Garden State Expansion (GSE).

In filings with the Board of Public Utilities and the Pinelands Commission, NJNG conceded that its existing system is sufficient to serve all its current and anticipated future customers, and that the existing system is already highly redundant and resilient.

SRL’s applications are not complete, especially its Freshwater Wetlands permit and its plans to use Horizontal Direction Drilling (HDD). NJNG has failed to submit plans concerning:
•	Complete HDD drawings with thorough “geotechnical assessments” (which determine the physical properties of soil and rock around a site) 
•	Bore designs (plans for digging horizontal holes under streambeds)
•	Additional workspace required for HDD
•	HDD failure plans, including containment and cleanup of accidental discharges 
•	NJNG also doesn't have permission to work in the roads owned by Burlington County and the townships. It is seeking to bypass this fact, despite the rules.

HDD is not a panacea — it poses serious issues. The U.S. Fish & Wildlife Service and PennEast (NJNG is a partner in PennEast) warn of the risks of “inadvertent return” (IR) during HDD. IRs can spoil waterways and damage sensitive aquatic communities. HDD problems such as IR can occur from: Rock fractures or unconsolidated geology; Low-density soils; Inadequate bore design. HDD mud discharge can include: Excessive volume of mud released, up to 10,000 gallons; Up to several acres of wetland impacted, and up to a mile of stream destroyed.

NJDEP should not allow NJNG to use HDD without submitting detailed geotechnical studies, a drilling plan and an IR contingency plan that includes a drilling mud containment, response and notification plan. Without this information, NJDEP is gambling with sensitive natural resources — including those of the New Jersey Pinelands.

In high-quality waters such as those that SRL would cross, HDD failures and/or IRs may impair pristine waterways that are supposed to be protected. SRL’s use of HDD must be evaluated by individual permit, waterway by waterway.

It is not appropriate for NJDEP to use “Permit by Rule” for SRL. NJDEP’s guidelines state that a pipeline should not cause any “disruption to streams,” yet using HDD to construct SRL could cause significant disruption. SRL has dozens of stream crossings. NJDEP must consider each one to evaluate HDD’s potential impact. It cannot assume no impacts. Also, “Permit by Rule” should not apply to a project that has no “independent utility” such as SRL.

Finally, I take the below issues with the GSE project for failing to meet NJDEP standards for obtaining a Freshwater Wetlands Individual Permit.

Williams’ Impact Analysis was incomplete. Williams’ application fails to provide a comprehensive analysis of wetland impacts. GSE, as proposed, would cause an excessive amount of destructive impacts to 4.7 acres of wetlands. Williams’ selection of this particular wetlands site causes impacts to regulated resources, including wetlands and waters, which are avoidable. Williams indicated yet superficially considered and dismissed less harmful alternative sites with no wetland impacts.  The clean water act presumes that less harmful alternatives exist. NJDEP should reject this freshwater wetlands permit due to Williams’ failure to even attempt to comply with the regulations.
	
Water Quality Standards were ignored. Williams did not even mention compliance with New Jersey’s water quality standards in their compliance statement. Williams’ failure to discuss dewatering and other impacts to the existing use of Sucker Run in its Individual Permit application does not satisfy the requirements of the Freshwater Wetlands Protection Act (FWPA).

NJDEP is required to determine ‘public interest’ independently. NJDEP cannot substitute FERC’s Certificate of Public Convenience and Necessity for its own determination of ‘public interest’ as required under the FWPA. FWPA defines “the public interest” very differently than FERC’s regulations.

The GSE and SRL projects are about private gain, not public interest, and should be rejected.

Thank you for considering my views.

Thank you for making your voice heard. Together, we can STOP South Jersey Gas pipeline!

Want to do more? Attend a public meeting about the pipeline at the Pinelands Commission, on January 24. You can also submit another letter to the Commissioners, via this online Public Comment form.

*Your letter will automatically be sent to the Pinelands Commission.

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Tell the Pinelands Commission to STOP the South Jersey Gas pipeline

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