Well, the weather outside is frightful . . . But filing is so delightful, especially when our friends at CARP (the Coalition Against the Rockaway Pip

Well, the weather outside is frightful . . .

But filing is so delightful, especially when our friends at CARP (the Coalition Against the Rockaway Pipeline) have made commenting to FERC so much easier. Yeah baby, it's cold outside, so curl up next to the radiator and have at it!

There are three ways you can participate:
1) Sign the pre-written comment letter (time required: 1 minute).
2) Write your own unique comment and CARP will submit your comment to FERC for you (time required: 2 minutes plus however long it takes you to write a comment).
3) Send an e-comment directly to FERC (Time required: 5 minutes plus however long it takes you to write a comment). E-commenting does not require the lengthy registration process that intervening does, just a 2-step process so FERC can verify that your email address is valid.

No matter how you choose to do it, comments are due to FERC by 5pm on Monday, December 9th. Be sure to use docket number CP-13-36-000. FERC's system gets jammed the closer any deadline gets, so we strongly suggest not waiting until 4:45 on Monday.

Talking Points to Include:

sandy map rockaways

CARP has outlined several talking points to inspire you, here, and here. We've been tracking the comments being uploaded to the FERC site, and we find them inspiring. So far, about 225 comments have covered a range of concerns about the pipeline, from flooding hazards (compare the Sandy flood map at right with the project map, below), to damage to the marine environment, misuse of the historic hangars at Floyd Bennett Field, to the terrible track record of the builder, Williams Transco.

rockaway-map-big

Reading any of FERC's reviews can be a maddening experience, and the draft Environmental Impact Statement (dEIS) for the Rockaway Lateral is no different. Despite the obvious risks, FERC determined that "construction and operation of the Projects would result in limited adverse environmental impacts, which would mostly occur during construction." Most of the other reviewing agencies are likewise asleep at the wheel. The EPA rated the dEIS and the proposed alternative as "Lack of Objections—Adequate." Their review did not identify "any potential environmental impacts requiring substantive changes to the proposal." Maybe they just copied and pasted from the Spectra EIS, which said EXACTLY THE SAME THING.

What people have commented on so far:

No one outsmarts a New Yorker. And the comments uploaded prove it. A brief selection of comments filed so far:

Galicia from Ridgewood says, "the metering station is planned for an area prone to flooding, which greatly increases the likelihood of a leak. This will only increase as sea levels rise and the risk of catastrophic storms increases due to climate change."

Laurel from Brooklyn writes, "I find it improbable in the extreme that high-pressure water jets capable of excavating many feet below the ocean floor will have NO significant adverse effect on the surrounding marine ecosystem."

Nicole from Rockaway Beach is adamant: "My neighborhood has already suffered through Sandy and we are not willing to compromise our safety for this pipeline."

Dominick, "speaking from the vantage point of a retired engineer who has overseen the design and construction of high-pressure (2000 psi) equipment; who has participated in various risk assessment and evaluation activities; who understands the mathematics of probabilities and statistics and expected values and outcomes," warns, "The risks to the people are great, and the benefits to the people are negligible."

George from Brooklyn, whose grandfather loaned a suit to Charles Lindbergh upon his landing in France, after the historic transcontinental flight, writes, "Lindbergh's memory is very important to my family and the hangars at Floyd Bennett are like a second home to me."

"No Impact Man," Colin Beavan concurs: "This is not an approprate reuse of our historic heritage area or recreational area."

Afterparty Jones, from Queens, whose comments are mostly unprintable, captures how most of us feel about this pipeline: "OH HELL NO!"

Top Issue of Concern: Radon

By far, the issue that most concerned filers was radon. Here's what FERC had to say about radon in the dEIS: "While the FERC has no regulatory authority to set, monitor, or respond to indoor radon levels, many local, state, and federal entities establish and enforce radon exposure standards for indoor air. It is expected that the combustion of gas transported by the Projects would comply with all applicable air emission standards. In the unlikely event that these standards are exceeded, the necessary modifications would be implemented to ensure public safety."

WE CALL BULLSHIT. NEPA, the National Environmental Policy Act of 1970, demands that FERC take the required "hard look" at radon and make a "good faith analysis" of all environmental issues connected to any federal project. FERC is clearly not acting in good faith here.

Among the questions that must be answered are, what exactly gives FERC the expectation that the gas delivered will comply with standards, when the gas supply being delivered will be different from the gas supply historically delivered? Call on FERC to demand that Williams and National Grid detail the exact source, radioactivity level, and percentage of the gas mix they intend to deliver. Demand that FERC outline WHAT modifications would be implemented if radon levels exceed accepted levels, by what agency and how quickly. Demand to know how and when residents will be notified that their gas supply has exceeded regulated limits. Demand that FERC deny approval of this pipeline until the builder and utilities PROVE the gas delivered will not contain dangerous levels of radon. Call on the EPA to be proactive, and PREVENT a public health crisis AS IS THEIR JOB. These agencies are saying they will wait until a health risk presents itself to respond, when they should be acting in the public interest NOW.

Concerned About Radon?

It makes sense to be. Remember: the only way out of anxiety is action. So take action:
After you file comments to FERC, please contact your local reps and tell THEM your concerns about radon are not being addressed by FERC, and demand they do something about it. Ask them to write to FERC and EPA too. Ask them to support the Rosenthal radon bill. Ask them to listen to citizen demands for energy choices that are sustainable. NYC residents do not need and do not want more shale gas supply or infrastructure. NYC residents are not being adequately informed--almost no one in the Rockaways even knows this pipeline is in the works. Demand more and more timely notification. Demand a more democratic public review. If we could vote on pipelines, this project and many others would not even be under consideration.

Thanks to everyone who has already filed!

NOW IT'S YOUT TURN. Go to it.

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