njng srl rebuttal testimony of lynch baker and wyckoff

Chiesa ~ Shahinian &. Giantomasi PC

November 11, 2015

Via Federal Express & Electronic Mail

Honorable Irene Kim Asbury Secretary New Jersey Board of Public Utilities 44 South Clinton Avenue, 9th Floor P.O. Box 350 Trenton, NJ 08625-0350

JOHN G. VALERI JR. One Boland Drive

West Orange, NJ 07052 973.530.2030

Fax: 973.530.2230 jvaleri@csg law. com

csglaw.com

Re: In the Matter of the Petition of New Jersey Natural Gas Company for a Determination Concerning the Southern Reliability Link Pursuant to N.J.S.A. 40:550-19 and N.J.S.A. 48:9-25.4; BPU Docket No. G015040403

Dear Secretary Asbury:

On behalf of Petitioner New Jersey Natural Gas Company, please find enclosed an original and ten (1 0) copies of the Rebuttal Testimony of Craig A Lynch, the Rebuttal Testimony of Barry A Baker and the Rebuttal Testimony of John Wyckoff in connection with the above-referenced matter. Petitioner reserves its rights to supplement its testimony in this matter upon receipt of responses to Petitioner's Discovery Requests.

If you have any questions, please do not hesitate to contact me.

JGV:kac Enclosures

Re7~

Cc: Attached Service List (via Federal Express & Electronic Mail)

WEST ORANGE NEW JERSEY TRENTON NEW JERSEY NEW YORK NEW YORK

5600479.1

IN THE MATTER OF THE PETITION OF NEW JERSEY NATURAL GAS COMPANY

FOR A DETERMINATION CONCERNING THE SOUTHERN RELIABILITY LINK

PURSUANT TO N.J.S.A. 40:55D-19

DOCKET NO. GO15040403

SERVICE LIST

5243149.13

* Denotes delivery of a hard copy via Federal Express overnight. All addressees were served via e-mail.

BOARD OF PUBLIC UTILITIES

Irene Kim Asbury *

Secretary

Board of Public Utilities

44 South Clinton Avenue, 9th

Floor

Post Office Box 350

Trenton, NJ 08625-0350

[email protected]

Paul Flanagan, Executive Director



Floor

Post Office Box 350


[email protected]

Cynthia Covie, Chief Counsel



Floor

Post Office Box 350


[email protected]

Jerome May, Director

Division of Energy



Floor

Post Office Box 350


[email protected]

Scott Sumliner

Division of Energy



Floor

Post Office Box 350


[email protected]

Robert Schultheis, Chief

Division of Energy



Floor

Post Office Box 350


[email protected]

John Masiello



Floor

Post Office Box 350


[email protected]

James Giuliano, Director

Division of Reliability and Security



Floor

Post Office Box 350


[email protected]

Michael Stonack



Floor

Post Office Box 350


[email protected]

Eric Weaver



Floor

Post Office Box 350


[email protected]





SERVICE LIST

5243149.13


Rachael Brekke



Floor

Post Office Box 350


[email protected]

Megan C. Lupo, Esq.



floor

Post Office Box 350


[email protected]

Maureen Wagner, Esq.



floor

Post Office Box 350


[email protected]

DIVISION OF RATE COUNSEL

Stefanie A. Brand, Director *

Division of Rate Counsel

140 East Front Street, 4th

Floor

Post Office Box 003


[email protected]

Felicia Thomas-Friel, Esq.



Floor

Post Office Box 003


[email protected]

Maura Caroselli, Esq.



Floor

Post Office Box 003


[email protected]

Shelly Massey



Floor

Post Office Box 003


[email protected]

Brian O. Lipman, Litigation Manager



Floor

Post Office Box 003


[email protected]

Henry M. Ogden, Esq.



Floor

Post Office Box 003


[email protected]

Matthew I. Kahal *

c/o Exeter Associates, Inc.

1108 Pheasant Crossing

Charlottesville, Virginia, 22901

[email protected]

David E. Dismukes, Ph.D. *

Acadian Consulting Group

5800 One Perkins Place Drive

Suite 5-F

Baton Rouge, LA 70808

[email protected]





SERVICE LIST

5243149.13


Kimberly Dismukes *



Suite 5-F


[email protected]

Ed McGee *



Suite 5-F


[email protected]

DEPT. OF LAW & PUBLIC SAFETY –

DIVISON OF LAW

Caroline Vachier, DAG *

Section Chief, Public Utilities Section

State of New Jersey

Department of Law and Public Safety

Division of Law

124 Halsey Street

Post Office Box 45029

Newark, NJ 07101

[email protected]

Babette Tenzer, DAG *

State of New Jersey


Division of Law

124 Halsey Street


Newark, NJ 07101-45029

[email protected]

Geoffrey Gersten, DAG *

State of New Jersey


Division of Law

124 Halsey Street


Newark, NJ 07101-45029

[email protected]

Alex Moreau, DAG *

State of New Jersey

Department of Law & Public Safety

Division of Law

124 Halsey Street


Newark, NJ 07101-45029

[email protected]

Christopher Psihoules, DAG *

State of New Jersey


Division of Law

124 Halsey Street


Newark, NJ 07101-45029

[email protected]

STATE AGRICULTURE

DEVELOPMENT COMMITTEE

Steven Bruder, PP

State Agriculture Development

Committee

369 S. Warren Street.

P.O. Box 330


[email protected]





SERVICE LIST

5243149.13


NJNG

Mark R. Sperduto

New Jersey Natural Gas Company

1415 Wyckoff Road


Wall, NJ 07719

[email protected]

Andrew Dembia, Esq.


1415 Wyckoff Road


Wall, NJ 07719

[email protected]

Craig Lynch


1415 Wyckoff Road


Wall, NJ 07719

[email protected]

Keith Sturn


1415 Wyckoff Road


Wall, NJ 07719

[email protected]

Mariellen Dugan


1415 Wyckoff Road


Wall, NJ 07719

[email protected]

Jeffrey S. Chiesa, Esq.

Chiesa Shahinian & Giantomasi PC

One Boland Drive

West Orange, NJ 07052

[email protected]

John G. Valeri Jr., Esq.


One Boland Drive


[email protected]

Michael K. Plumb, Esq.


One Boland Drive


[email protected]

Matthew J. Korkes, Paralegal


One Boland Drive


[email protected]

JOINT BASE MCGUIRE-DIX-

LAKEHURST

Alice Good

Chief, Environmental and Real Property

Law

2901 Falcon Lane

Joint Base McGuire-Dix-Lakehurst, NJ

08641

[email protected]

COUNTY ADMINISTRATORS

Paul Drayton, Jr.

Burlington County Administrator

49 Rancocas Road, Room 108

Mount Holly, NJ 08060

[email protected]





SERVICE LIST

5243149.13


Carl W. Block

Ocean County Administrator

101 Hooper Avenue

Toms River, NJ 08754-2191

[email protected]

Teri O’Connor

Monmouth County Administrator

Hall of Records

Freehold, NJ 07728

[email protected]

MUNICIPAL CLERKS

Caryn M. Hoyer

Chesterfield Township Clerk

300 Bordentown-Chesterfield Rd.

Chesterfield, NJ 08515

[email protected]

Cindy Dye

North Hanover Township Clerk

41 Schoolhouse Rd.

Jacobstown, NJ 08562

[email protected]

Dana L. Tyler

Upper Freehold Township Clerk

314 Route 539

Cream Ridge, NJ 08514

[email protected]

Dorothy J. Hendrickson, R.M.C.

Plumsted Township Clerk

121 Evergreen Road

New Egypt, NJ 08533

[email protected]

Ann Marie Eden, RMC

Jackson Township Clerk

95 W. Veterans Hwy.

Jackson, NJ 08527

[email protected]

Sabina T. Skibo, RMC, CMR, CPM

Manchester Township Clerk

1 Colonial Drive

Manchester, NJ 08759

[email protected]

ATTORNEYS FOR UPPER

FREEHOLD TWP.

Dennis A. Collins, Esq.

Collins, Vella & Casello, L.L.C.

2317 Highway 34, Suite 1A

Manasquan, NJ 08736

[email protected]

ATTORNEYS FOR INTERVENOR:

BURLINGTON COUNTY BOARD OF

CHOSEN FREEHOLDERS

William R. Burns, Esq. *

Capehart Scatchard, P.A.

142 West State Street

Trenton, NJ 08608

[email protected]

Traci L. Adams, Legal Secretary

Capehart Scatchard, P.A.

142 West State Street

Trenton, NJ 08608

[email protected]





SERVICE LIST

5243149.13



CHESTERFIELD TWP.

Katelyn M. McElmoyl, Esq.

Parker McKay, P.A.

9000 Midlantic Drive

Mount Laurel, NJ 08054-5054

[email protected]

John C. Gillespie, Esq. *

Parker McKay P.A.

9000 Midatlantic Drive

Suite 300

Mount Laurel, NJ 08054-5054

[email protected]


NORTH HANOVER TWP.

Mark Roselli, Esq. *

Roselli Griegel Lozier & Lazzaro, PC

1337 Highway 33

Hamilton, NJ 08690

[email protected]

ATTORNEYS FOR PARTICIPANT:

PLUMSTED TWP.

Denis P. Kelly, Esq. *

Gilmore & Monahan, P.A.

Ten Allen Street

P.O. Box 1540

Toms River, NJ 08754

[email protected]

ATTORNEYS FOR PARTICIPANT:

PINELANDS PRESERVATION

ALLIANCE

Paul Leodori, Esq.

Law Offices of Paul Leodori, P.C.

61 Union Street, 2nd

Floor

Medford, NJ 08055

[email protected]

Todd M. Parisi, Esq. *

Law Offices of Paul Leodori, P.C.

61 Union Street, 2nd

Floor

Medford, NJ 08055

[email protected]

Mr. Carleton Montgomery

Executive Director

Pinelands Preservation Alliance

Bishop Farmstead

17 Pemberton Road

Southampton, NJ 08088

[email protected]

NEW JERSEY NATURAL GAS COMPANY 1

2

PREPARED REBUTTAL TESTIMONY OF 3

CRAIG A LYNCH 4

5

I. INTRODUCTION 6

Q. Please state you name, affiliation and business address. 7

A. My name is Craig A. Lynch and I am Senior Vice-President-Energy Delivery for 8

New Jersey Natural Gas Company (the “Company” or “NJNG”). My business 9

address is 1415 Wyckoff Road, Wall, New Jersey 07719. 10

Q. Did you submit Direct Testimony on behalf of NJNG in this proceeding? 11

Please briefly describe that testimony. 12

A. Yes. I submitted testimony that described NJNG’s delivery system and the 13

proposed Southern Reliability Link Project (“SRL” or “SRL Project”), and 14

explained the need for the Project. I also submitted supplemental direct 15

testimony that described amendments to the SRL Project route and widespread 16

support for the Project. 17

Q. Have you reviewed the direct testimony submitted by James Durr, Mayor, 18

on behalf of the Township of North Hanover, Jeremy I. Liedtka on behalf of 19

the Township of Chesterfield, Joseph T. Brickley, P.E. on behalf of the 20

Burlington County Board of Chosen Freeholders, and Edward A. McGee on 21

behalf of the Division of Rate Counsel? 22

A. Yes. I have reviewed their testimony. 23

24

25

2

Q. Describe the purpose of your testimony. 1

A. I am rebutting or clarifying statements addressing safety and the need for the 2

Project, and addressing further support for the Project. 3

4

II. SAFETY 5

Q. Mayor Liedtka expressed concerns regarding pipeline safety (Liedtka, 6

lines 11 – 73). Could you describe the safety standards that NJNG will 7

adopt in building and operating the SRL Project? 8

A. As stated in my direct testimony, the safe and reliable operation of NJNG’s 9

system is the Company’s primary operational goal. To further that goal, all of 10

NJNG’s transmission lines are designed, built and operated to the strictest safety 11

standards. 12

In 2009, the BPU changed the New Jersey Administrative Code so that all 13

transmission mains constructed in New Jersey shall meet the design standard for 14

a Class 4 pipeline Location. This was done in recognition that New Jersey is a 15

densely populated state and a Class 4 designation was the appropriate level for 16

the design standards in this atmosphere. As a side note, in keeping with NJNG’s 17

conservative nature towards safety, the Company adopted this position for all 18

their transmission design well over 20 years prior to this rule change. 19

20

Having a service area which is isolated from interstate pipeline suppliers, NJNG 21

has developed an extensive system of transmission infrastructure to feed our 22

customers. In fact, NJNG has more transmission lines than the combined total of 23

3

the three other local distribution companies in New Jersey.1 That fact has 1

required NJNG to develop a separate group of individuals whose only 2

responsibility and focus is the maintenance and safety of that system. Operating 3

a high pressure pipeline system in the most densely populated state in the nation 4

such as NJNG requires constant vigilance. The process involves paying attention 5

to a myriad of details from design, material selection, installation, inspection, 6

testing, and commissioning, followed by controlling the operation and maintaining 7

the pipeline. These factors have been comprehensively managed at NJNG. 8

9

Recent evidence of NJNG’s commitment to safety is the conservative approach 10

taken to comply with the federally mandated Transmission Integrity Management 11

Program (“TIMP”) beginning in 2002. In response to federal requirements 12

mandating baseline inspection of transmission pipelines, NJNG developed a 13

prudent strategy and program based on internal inspection of its natural gas 14

transmission system using “smart-pigs.” Although an inspection program using 15

“smart-pigs” is substantially more capital- and time-intensive, NJNG chose this 16

method because the pigging technique, by actually contacting the pipeline steel, 17

provides a much greater capability to detect potentially hazardous anomalies. 18

This was a critical commitment that defined NJNG’s commitment to pipeline 19

safety. 20

21

1 NJNG has more transmission line than the other local distribution companies because, unlike

the other companies, there are no interstate transmission lines within or abutting the southern portion of NJNG’s service area.

4

As with all newly constructed or upgraded NJNG transmission lines, the SRL is 1

designed and will be operated in conformance with the most conservative 2

(stringent) pipeline integrity standard for a pipeline by designating our 3

transmission pipelines to adhere to the High Consequence Area (“HCA”) 4

standard. The HCA standard applies to transmission lines where buildings with 5

four or more stories are prevalent. The HCA standard is also required where a 6

mile of transmission line passes within 220 yards of 46 or more buildings 7

intended for human occupancy, or passes within 100 yards of a building or small, 8

well-defined outside area occupied by 20 or more persons at least 5 days a week 9

for 10 weeks in any 12-month period.2 An evaluation of the project will show that 10

there are sections of this project which would not qualify for HCA status. Thus, 11

while some limited portions of the SRL require conformance with the HCA 12

standard, a large section of the SRL does not. However, as part of its 13

commitment to safety, NJNG requires all new and replacement transmission 14

lines to be operated to HCA standards 15

16

While periodically assessing the pipe condition and correcting identified 17

anomalies is an important part of the rule addressing HCAs, there are other 18

important requirements. Operators must develop improved management and 19

analysis processes that integrate all available integrity-related data and 20

information and assess the risks associated with pipeline segments in HCAs. 21

2 HCA is defined in 49 CFR 192.903 and also includes the area within a potential impact circle (as

determined by an equation) which includes 20 or more buildings intended for human occupancy or an identified site.

5

Furthermore, operators must enhance damage prevention programs and 1

implement additional risk control measures beyond those already required of 2

other transmission lines. Lastly, NJNG has been ahead of the industry in its 3

extensive use of remotely controlled valves (“RCVs”) on our transmission 4

system, so that segments of the system can be isolated in the unlikely event of a 5

problem. The SRL project will have RCVs installed that will enable us to 6

immediately address any potential issues. 7

8

While Burlington County, Chesterfield and North Hanover have not explicitly 9

commented that NJNG is or has been imprudent in the operation of its natural 10

gas delivery system, the implication is obvious with statements regarding certain 11

unrelated incidents. NJNG’s transmission line safety record speaks for itself. 12

NJNG received over 153,000 one-call requests last year and did not receive any 13

violations involving transmission lines, the subject of this matter. Mayor Liedtka 14

makes repeated references to two recent incidents in Ocean County, neither of 15

which involved transmission lines. The Point Pleasant incident did not involve 16

Company infrastructure or equipment. The Board is aware of and investigating to 17

determine the cause of the Stafford Township incident. 18

NJNG takes seriously the obligation to maintain its transmission system in a safe 19

operating condition. We are proud of the strong safety record that we have built 20

over the years and we strive to maintain our system in a manner that meets or 21

exceeds industry safety standards. As stated above, to that end, NJNG has 22

implemented robust Integrity Management Programs in addition to our long-23

6

standing routine design, safety and maintenance practices. Our integrity 1

management programs have significantly increased the level of preventative and 2

mitigating activities on our pipeline system as part of ongoing assessments (i.e., 3

as in-line inspections, direct assessment, and integrity-related pressure tests). 4

These efforts, along with the investments that we have made enabling the 5

majority of our transmission system to be in-line inspected (piggable), as well as 6

the active participation in industry groups such as the American Gas Association, 7

to advance the state-of-the-art in integrity management, are all part of our 8

comprehensive approach to managing our systems in a safe operating condition. 9

NJNG’ Energy Delivery business unit is an organization, with highly trained and 10

skilled personnel, managing a these transmission assets. During my tenure at 11

NJNG, its commitment to safety and operational excellence remains paramount. 12

NJNG’s culture is not to take risk, but to manage risk by applying state of the art 13

technology, following sound engineering practice, and maintaining the system in 14

accordance with the well-established regulations. 15

16

II. NEED 17

Q. Please respond to Mayor Liedtka’s critique of the SRL Project need 18

(Liedtka, lines 98 – 139). 19

A. I addressed the need for the SRL Project in my direct testimony. The underlying 20

premise of Mayor Liedtka’s critique is that the SRL Project is not necessary 21

because the Company has not experienced a widespread system failure based 22

on the failure or interruption of service from the connection point that provides 23

7

approximately 85% of winter season peak day capacity, all from a single 1

interstate pipeline, the Texas Eastern Transmission System (“TETCO”). While 2

this is true we have noticed a trend in our interstate supplier which we feel needs 3

to be proactively addressed. The Company believes that waiting for a system 4

failure is bad planning and irresponsible. Curtailment has tremendous 5

consequences for customers. The curtailments following Sandy were not related 6

to an interruption in the interstate supply but demonstrated the tremendous cost 7

of widespread curtailment. It also had other implications like making customers’ 8

homes inhabitable due to a lack of heat and hot water. 9

10

The vast majority of winter season peak day natural gas being delivered through 11

a single gate station from a single source creates a very real risk of interruption. 12

Examples include: 13

• An interruption in the firm transportation capacity of TETCO could affect gas 14

supply. During the winter of 2014/2015, two of TETCO’s compressors 15

stations experienced unplanned outages during a winter period which 16

resulted in a force majeure declaration. During the winter of 2013/2014, two of 17

TETCO’s compressor stations experienced an unplanned outage during a 18

peak supply period which resulted in a force majeure declaration and 10% 19

curtailment of supply. We were able to compensate for the short-term 20

decrease in supply by running our LNG facilities. The duration was short 21

enough to ensure our system’s integrity, but the quantity of LNG stored at 22

those facilities is limited. 23

8

• An incident requiring the reduction of pressure or resulting in the failure of 1

part of our transmission system which would require us to close off selected 2

sections of pipe. With all our supply feeding from the north end of our 3

system, Jamesburg citygate, an incident could strain our transmission system 4

to a point where it would be difficult to transport enough gas to our customers 5

downstream of the interruption. A real-life example of this was the event we 6

experienced several years ago, during the December holiday season, where 7

a downed electric line damaged one of our pipelines and required us to 8

significantly lower the operating pressure until repairs were completed. 9

• Equipment failure at one of the gate stations. NJNG maintains its equipment 10

to ensure its availability but unforeseen events remain and are a concern. 11

The loss of a critical piece of equipment during peak supply periods could 12

hamper our ability to supply enough gas to our customers. 13

Q. Please address the direct testimony submitted by Ed McGee of Rate 14

Counsel asserting that the Company only needs a 24-inch pipeline to 15

satisfy its reliability requirements (McGee, p. 5, line 6 through p. 6, line 3). 16

A. Mr. McGee fundamentally misunderstands the purpose of the SRL. The 17

Company stated in its petition that the SRL Project is capable of providing 18

NJNG’s capacity contract volume of 180,000 dekatherms per day (“Dth/day”). 19

Based on that statement, Mr. McGee has run calculations demonstrating that 20

180,000 Dth/day can be delivered with a 24-inch pipe. Mr. McGee then 21

concludes in error that only a 24-inch pipe is necessary. 22

23

9

The error in Mr. McGee’s conclusion arises from his assumption that NJNG’s 1

reliability requirement is 180,000 Dth/day. The 180,000 Dth/day contract was 2

limited by interstate pipeline infrastructure and does not reflect the full reliability 3

requirement. By way of comparison, the Jamesburg station, where TETCO 4

provides 85% of winter season peak day capacity, is connected to three 5

transmission pipes, which are 30-inches, 12-inches, and 10 inches, collectively 6

far exceeding the transmission capacity of either the SRL Project or that of a 24-7

inch pipeline. The Company has a contract at the Jamesburg station for a 8

maximum delivery obligation of 641,590 Dth/day and a total system capacity of 9

771,112 Dth/day, or more than four times the current 180,000 Dth/day contract 10

for the SRL Project. In the event of a 50% reduction in the Company’s 11

transportation contract available from TETCO, a reduction which exceeds the 12

180,000 Dth/day that could be provided by a 24-inch pipeline, the SRL Project as 13

designed would ensure that the NJNG’s system continued to function 14

adequately.3 15

16

While 180,000 Dth/day would mitigate system issues that could arise from certain 17

interruptions, it does not reflect the full quantity that could be required in the 18

event of a large-scale TETCO interruption. Even without Transco upgrades, with 19

a 30-inch pipeline the Company could acquire natural gas in excess of 180,000 20

Dth/day to avoid curtailment by entering into transactions with other firm shippers 21

3 See NJNG Response to RCR-ENG-25b.

10

with rights on the interstate system. Thus the 180,000 Dth/day contract is 1

irrelevant in determining the appropriate size of the SRL Project pipeline. 2

3

Finally, NJNG’s primary existing backbone is 30-inch pipeline. The 30-inch 4

backbone begins at the Texas Eastern supply in Middlesex County and extends 5

south near the northern Ocean County border, as well as other existing 6

segments that have been more recently installed in Ocean County. A 30-inch 7

SRL Project pipeline would facilitate a fully looped 30-inch backbone, an 8

aspirational goal of NJNG’s long term reliability planning.4 While the SRL Project 9

requires a 30-inch pipeline to provide for adequate reliability to the system in its 10

current state, the 30-inch pipeline will also be required to feed the entire system 11

once upgrades are made to backbone to provide for a fully looped system. 12

Q. Please address Rate Counsel’s testimony regarding future growth (McGee, 13

p. 7, lines 10-18). 14

A. Mr. McGee’s statement that future supplies and growth cannot be part of the 15

decision to size and allocate costs is based on a misreading of the Company’s 16

response to one of Rate Counsel’s discovery questions, RCR-ENG-21. In that 17

question, Rate Counsel asked the Company to explain how the pipe size was 18

selected. The Company responded as follows: 19

The diameter of the SRL was selected by performing iterative flow 20

modeling of our existing system with various demand and supply 21

4 Without a looped backbone, the SRL cannot currently provide natural gas to the entire southern

portion of NJNG’s service area. Accordingly, the Jamesburg supply station quantities necessarily exceed the requirements of the SRL.

11

configurations under design day conditions with the SRL in place. 1

This diameter also is equal to NJNG’s existing backbone system 2

beginning at our Texas Eastern supply in Middlesex County and 3

running into northern Ocean County, as well as other existing 4

segments that have been more recently installed. This diameter will 5

also allow greater capacity to be delivered into NJNG’s system from 6

the new Transco supply in the future. 7

As is made clear by the full text of the Company’s response, the SRL Project is 8

not designed to accommodate future growth. Rather, the response addresses the 9

future potential to acquire a firm supply contract in excess of the existing 180,000 10

Dth/day. As stated above, regardless of the availability of interstate capacity to 11

secure firm contracts, additional capacity could flow through the 30-inch SRL in 12

the event of an interruption by diverting contracts with other entities who have 13

contracted for firm supply on that section of Transco’s system. However, 14

additional capacity transacted for in the event of an interruption (e.g., 280,000 15

Dth/day) could not flow through a 24-inch pipe because the smaller pipe diameter 16

would result in unacceptable pressure drop.5 17

18

To ensure reliability, the Project must account for growth during its anticipated 19

lifespan. Assuming, for the sake of argument, that 180,000 Dth/day is an 20

appropriate basis for sizing the SRL Project pipeline (it is not), the current 21

pressure drop associated with that capacity on a 24-inch scenario is only 22


12

marginal and would be rendered inadequate by anticipated future growth over 1

the next 20 years.6 Thus, while the SRL is being built for reliability, a 24-inch 2

pipeline would not keep pace with the anticipated growth of our existing system. 3

4

I believe that the SRL project minimizes overall costs and impacts to customers. 5

Based upon my reading of Mr. McGee’s testimony, he would prefer NJNG to 6

install a 24 inch diameter line, rather than a 30 inch diameter line, solely because 7

he believes that it is the lower cost option. Mr. McGee fails to recognize, 8

however, the impracticality of constructing transmission pipelines on a piece-9

meal approach and the associated burden that this piece-meal approach 10

imposes on customers, the environment and rates. I believe prudent engineering 11

planning and design requires that the utility plan for anticipated customer usage. 12

It is my belief that utilities have an obligation to meet the needs of all of its 13

customers now as well as to prudently plan for the future. Given the obstacles 14

associated with siting natural gas transmission infrastructure in New Jersey, as is 15

evidenced by the proceeding, I believe it would not be prudent for the Company 16

not to design the SRL Project to address customers’ needs in terms of continuity 17

of service if existing system fails, i.e., reliability. Mr. McGee’s recommendation 18

that the Board disallow a portion of the costs, i.e., the cost difference between a 19

24 inch diameter pipe and a 30 inch diameter pipe, based on the existing supply 20


13

contract misses the point of the project and would lead to higher total costs in the 1

future. I believe that the BPU should reject Mr. McGee’s recommendations. 2

3

Q. Would you like to address Rate Counsel’s testimony regarding cost 4

estimates (McGee, p. 4, line 10 through p. 5, line 7)? 5

A. At the outset, let me point out that this proceeding is not a cost recovery 6

proceeding. The purpose of this proceeding is for the Company to obtain a 7

determination from the BPU regarding the route of the SRL project. In an 8

apparent effort to reduce construction costs, Mr. McGee recommends that the 9

Board reject the Company’s cost estimate. First and foremost, the Company 10

disagrees with Rate Counsel’s cost estimates and reserves its right to present 11

testimony objecting to Mr. McGee’s position in the Company’s upcoming base 12

rate case. Mr. McGee also expresses an opinion that insufficient analysis and 13

justification was presented by NJNG to support its cost estimates. As has been 14

repeatedly explained to everyone, these estimates are based upon the best 15

information the Company has to date. The Company is unable to issue an RFP 16

for the engineering construction work until a final route determination has been 17

made by the BPU, Therefore, Mr. McGee’s opinion should be given little, if any, 18

weight. Finally, I believe that this is more appropriate for the Company’s base 19

rate case proceeding when it will seek recover of the SRL project costs. 20

21

III. FURTHER SUPPORT 22

Q. Has the Company received additional support for the SRL Project? 23

14

A. Yes. The Monmouth County Freeholders have withdrawn an earlier objection and 1

now support the SRL Project. See Exhibit 1. 2

3

CONCLUSION 4

Q. Does this conclude your rebuttal testimony at this time? 5

A. Yes, it does. However, I reserve my right to supplement and/or amend my 6

testimony in the future. 7

Exhibit 1


2


BARRY A. BAKER 4

5

I. INTRODUCTION 6

Q. Please state you name and business address and responsibilities with 7

respect to the Southern Reliability Link Project (“SRL” or “SRL Project”). 8

A. My name is Barry A. Baker. My business address is 625 West Ridge Pike, Suite 9

E-100, Conshohocken, PA 19428. I am the Power & Industry Business Unit Lead 10

and Department Manager for Impact Assessment & Permitting department for 11

the Philadelphia Metro Region of AECOM Technology Corp. (“AECOM”). New 12

Jersey Natural Gas (“NJNG” or the “Company”) retained AECOM to assist in the 13

evaluation and development of alternative routes for the Project. I led the team 14

that conducted the siting study. I also coordinate the overall environmental 15

permitting and approval efforts on behalf of NJNG, including surveys, 16

investigations, and permit preparation and submittals to federal, state, and local 17

agencies. 18

Q. Did you submit Direct Testimony on behalf of NJNJ in this proceeding? 19


A. Yes. I submitted testimony that described the alternatives analysis, including the 21

methodology used to review alternative routes and how NJNG identified the 22

selected route. 23



2

the Township of Chesterfield, and Joseph T. Brickley, P.E. on behalf of the 1

Burlington County Board of Chosen Freeholders? 2



A. I am rebutting or clarifying certain statements made in the intervenors’ direct 5

testimony addressing historic impacts and alternative route analysis. 6

II. HISTORIC IMPACTS 7

Q. Mayor Durr raises his concerns regarding proper consideration of impacts 8

on historic structures (Durr, Par. 11 – 17). Please explain how AECOM 9

considered historic structures along the route, including the Arneytown 10

Historic District. 11

A. The alternatives analysis involved consideration of potential impacts from three 12

perspectives, including (1) the Built Environment, which addresses human and 13

cultural resources including residential neighborhoods, other community-valued 14

buildings, and historic sites; (2) the Natural Environment; and (3) Engineering 15

Considerations. All three perspectives are considered in evaluating the routes to 16

determine the preferred route. Historic structures are one element of the Built 17

Environment perspective. Based on past experience and public feedback, the 18

Built Environment perspective was given the greatest weight of the three 19

perspectives (37.5%), and proximity to residences was given the greatest weight 20

(30%) within that perspective. Historic properties within 150 feet of the centerline 21

were assigned a 14% weight within the Built Environment perspective. Thus, 22

3

historic properties were identified and weighted in determining the preferred 1

route. 2

3

Regarding the specific historic properties identified in Mayor Durr’s testimony, 4

Route C passed within 150 feet of 84 historic properties. Route B was within 150 5

feet of 15 properties, Route A was within 150 feet of 8 historic properties, and 6

Route D and Route E each passed within 150 feet of just 1 historic property. The 7

project study area contains a dense concentration of historic resources as 8

illustrated in Table 2-8 and our route counts. Impacts to historic resources have 9

been evaluated and a route selected that minimizes impacts to these as well 10

other resources of value in the project area. 11

12

Identifying the number of historic properties along a proposed route is a factor for 13

selecting the preferred route considering all potential impacts. However, once the 14

preferred route is selected, the analysis of impacts on historic resources does not 15

end. The Petitioner must complete a Historic Architectural Survey Report and a 16

Phase I Archaeological Survey, and submit them to the New Jersey Historic 17

Preservation Office. Both of these reports have been submitted to the New 18

Jersey Historic Preservation Office and both address the Arneytown Historic 19

District. 20

21

The New Jersey Historic Preservation Office recently reviewed and commented 22

on the Architectural Survey, stating that 23

4

“HPO concurs that the choice to locate the pipeline right-of-way 1

(ROW) within existing roadway at most locations will avoid direct 2

adverse effects to historic properties eligible for or listed on the 3

National Register of Historic Places. In addition, the locations of 4

valves and laydown areas will avoid indirect visual effects. The 5

report concludes that fencing should be erected during construction 6

in the Arneytown Historic District, in order to avoid unforeseen 7

damage by construction equipment. The HPO concurs with this 8

recommendation.” 9

However, to further ensure the SRL Project avoids vibration impacts, the HPO 10

has requested monitoring of vibration impacts of construction activity within the 11

Arneytown Historic District. HPO further recommends a three phase vibration 12

avoidance control process in keeping with applicable federal standards. Thus, 13

the regulatory review process is functioning properly and has already fully 14

addressed the concerns raised by Mayor Durr. 15

16

Regarding the buttonwood trees addressed by Mayor Durr (Par. 17), the 17

alignment runs on the side of the road opposite of the identified trees in order to 18

specifically avoid any potential impacts on those trees. 19

20

21

22

23

5

III. ALTERNATIVE ROUTES 1

Q. Please address the alternative routes through the Joint Base or through the 2

JCP&L ROW advanced by the intervenors (Durr, Par. 20; Brickley, Lines 3

148-210, 231-247; Liedtka, Lines 70-73). 4

A. Neither of those routes is feasible. As indicated in my prior analyses, the JCP&L 5

ROW alternative cannot be built because it passes through parcels designated 6

as Preserved Farmland through the State Agriculture Development Commission. 7

Only farming activities are permitted to occur on those lands. The preserved 8

farmland represents a fatal flaw in the proposed route because building a 9

pipeline across it is prohibited by law. Notwithstanding that fatal flaw, AECOM 10

analyzed the JCP&L route and determined that the cumulative quantitative value 11

of impacts from the JCP&L ROW alternative would be higher than the impacts for 12

the selected route and higher than any other evaluated alternative. 13

14

The Company has advised AECOM that the Joint Base route is not feasible 15

based on the operational requirements of the base, as communicated to the 16

Company by the Joint Base leadership. See Rebuttal Testimony of John 17

Wyckoff. Attached is a figure depicting operational areas of the base that are 18

referred to in the Joint Base correspondence dated November 6, 2015, attached 19

hereto as Exhibit 1. 20

21

Q. Does this conclude your rebuttal testimony? 22

A. Yes, it does. However, I reserve my right to supplement and/or amend my 23 testimony in the future. 24

Exhibit 1

!.

!.

!.

Section 1 Route FRoute 68 PotentialConnection Point

Potential ConnectionArea Along CR 539(Pinehurst Road)

Section 1 & Section 2Connection Point

Recreation/Park Area

MilitaryHousing Units



DenseResidential Areas

Military Range &Live Fire Range Areas

ActiveMilitaryAirport

Golf Course &Athletic Fields

OperationalMilitaryBuildings

Scott St

Monmouth Rd

CR 537

Juliustown Rd

E Main St

CR 545

CR 539

Trenton Rd

CR 630

Pemberton By Pass

CR 670

Lakehurst Rd

Pointville Rd

RT 539

Pemberton Browns Mills Rd CR 530

Fort Dix Rd

RT 68

Pemberto

n Wrightstown Rd

Maple Ave Front St

CR 616W Main St

Archertown Rd

Texas Ave

ST68

ST68

ST70

Archertown

BrownsMills

CedarGlen

Lakes

ColliersMills

Cookstown

Fort DIX

HanoverFurnace

Hockamik

Juliustown

McGuireAFB

NewEgypt

NewLisbon

PembertonHeights

Pointville

SykesvilleTilghmansCorner

Whitesbog

Wrightstown

Prepared By: DFJob: 60416786

Checked By: BABDate: 11/11/2015

JB MDL Existing Features

BurlingtonCounty

MercerCounty

MonmouthCounty

OceanCounty

LEGEND:!. Infrastructure Connection Point

Southern Reliability Link Project Proposed Centerline(Section 1 - Route B, Section 2 - Route D)

Alternatives Analysis RoutesSection 1 - Route ASection 1 - Route CSection 1 - Route DSection 1 - Route ESection 1 - Route FSection 2 - Route ASection 2 - Route B

JB MDL Installation AreaMilitary Housing and QuartersAirfield Surface AreaAthletic Field AreaGolf Course AreaRecreation/Park AreaLive Fire Military Range AreaMilitary Range AreaRoads Prepared For: New Jersey Natural Gas, Wall Township, New Jersey

Coordinate System: NAD 1983 StatePlane New Jersey FIPS 2900 FeetProjection: Transverse Mercator: Units: Foot US

NOTES:1. Please reference the Alternatives Analysis Report prepared by AECOM for additional informationregarding Alternatives Analysis Routes.2. JD MDL (Joint Base McGuire-Dix-Lakehurst) Installation Area, Military Housing and Quarters, AirfieldSurface Area, Recreation Park Area, Live Fire Military Range, Military Range, Golf Course Area, andAthletic Field Area data was provided by JB MDL in September 2014.

REFERENCES:ESRI Streetmap Data2012 - 2013 High Resolution Orthophotography (NJOGIS via ArcGIS Online)

O0 1 2

Miles

Burlington & OceanCounties, New Jersey

NJPA


2


JOHN B. WYCKOFF 4

5

I. INTRODUCTION 6

Q. Please state your name, affiliation and business address. 7

A. My name is John B. Wyckoff, P.E., and I am the Director of Engineering for New 8

Jersey Natural Gas Company (the “Company” or “NJNG”). My business address 9

is 1415 Wyckoff Road, Wall, New Jersey 07719. 10

Q. Did you submit Direct Testimony on behalf of NJNG in this proceeding? 11


A. Yes. I submitted testimony that described the proposed construction and design 13

of NJNG’s Southern Reliability Link Project (the “SRL Project” or “Project”). 14



the Township of Chesterfield, and Joseph T. Brickley, P.E. on behalf of the 17

Burlington County Board of Chosen Freeholders? 18



A. I am rebutting or clarifying statements addressing the proposed construction and 21

design of the SRL Project, traffic impacts, and the alternative route through Joint 22

Base McGuire-Dix-Lakehurst. 23

24

25

2

II. CONSTRUCTION AND DESIGN 1

Q. Please address the future roadway construction issues raised by Joseph 2

T. Brickley, P.E., on behalf of Burlington County (Brickley, Lines 25-73). 3

A. The SRL Project is aligned within roadway rights-of-way, primarily below the 4

existing road bed. Burlington County has raised concerns relating to locating the 5

Project within the traveled portion of the roadway rights-of-way. As designed, 6

those concerns do not materialize into significant future complications for road 7

upgrades or utility expansion beyond those possible on any other proposed utility 8

project. 9

10

For example, Mr. Brickley states that the SRL Project will require Burlington 11

County to acquire additional ROW for roadway drainage improvements. 12

(Brickley, Line 43-46.) As designed, the SRL Project will have minimal impact on 13

roadway reconstruction or drainage improvements, as is typical for projects of 14

this nature. If Burlington County requires additional ROW width to improve 15

roadway drainage, that requirement is independent of the existence of the SRL 16

Project. In fact, locating the SRL within the roadbed may significantly reduce 17

potential conflicts with drainage that is typically installed near the edge of the 18

right-of-way to accommodate future road widening. We have asked the County to 19

share their Master Plan with us so we have a better understanding of their 20

concerns, but to date, they have not done so. 21

22

3

Likewise, Mr. Brickley states that the SRL Project will complicate future 1

expansion of other utilities in Burlington County. (Brickley, Lines 47 -73.) That is 2

incorrect. The SRL Project will have minimal impact on most utilities due to its 3

four foot depth. In our experience, water and sanitary sewer projects can be 4

effectively designed to avoid most, if not all, conflicts with other utilities. 5

Specifically, water can be installed without conflict, as it operates under pressure. 6

7

Regarding precautions arising from working on other utilities in the vicinity of the 8

SRL Pipeline, those precautions are identical to the precautions that would be 9

taken for any and all existing utilities currently within the roadways for portions of 10

the identified route.1 No special equipment is required and NJNG typically 11

supplies trained personnel at no charge to be on site of projects working around 12

transmission facilities to monitor the activities and assure safety. 13

14

NJNG does not require or know of any special qualifications that a responsible 15

contractor would need to possess to work around our facility and has never 16

encountered any agency requiring special insurance on projects around our 17

existing transmission facilities. 18

19

Regarding Mr. Brickley’s concerns about the narrowness of County Routes 528 20

and 664, both of which have at least 50 feet of right-of-way, it is important to 21

1 I am not familiar with the basis for Mr. Brickley’s statements concerning a limited pool of

contractors and extremely high limits of insurance coverage. The Company requested documents from Burlington County relating to those statements and did not receive any responsive documents.

4

remember that the SRL pipeline will be 30 inches wide. With a minimum 1

clearance of twelve inches around the pipeline, that leaves at least 45.5 feet of 2

right-of-way width for installation of other utilities. 3

4

In the unlikely and unforeseen event that Burlington County’s future plans 5

become incompatible with the SRL Project, NJNG will work with the County to 6

resolve conflicts, propose alternatives, or relocate the SRL Project as necessary 7

and with Board approval. Proper planning will avoid any delays associated with 8

such relocation and all costs will be incurred by the Company, as I outlined in 9

NJNG’s response to CHES-NJSRL-28. 10

II. TRAFFIC 11

Q. Please address the traffic impacts raised by Joseph T. Brickley, P.E., on 12

behalf of Burlington County (Brickley, Lines 76-119). 13

A. The Petition does not address traffic because the Petition is not the appropriate 14

document for addressing traffic. Early in the outreach process, NJNG met with 15

Burlington County officials to discuss traffic planning and were told that the 16

Townships would control coordination of traffic impacts to minimize 17

inconvenience to the public and ensure the safety of all involved. This is the 18

typical approach to traffic planning with local police involved in development of 19

traffic control plans, as well as modifications on a day-to-day basis based on 20

construction progress. NJNG has attempted to coordinate traffic plans with the 21

Townships but those efforts have been rebuffed to date. When the intervenors 22

5

agree to participate in necessary discussions for developing a traffic plan, a 1

traffic plan will be mutually developed. 2

3

Mr. Brickley has also stated that construction will take 2.5 years in Burlington 4

County, a duration calculated by adopting all of the most conservative, or “worst 5

case”, estimates based on the most extreme and restrictive working conditions 6

that could be envisioned. A more reasonable estimate of the duration of 7

construction for the portion of the SRL within Burlington County would be 8

approximately six months. This estimate is based on typical working conditions 9

for large scale construction projects such as realistic work hours, appropriate 10

traffic detours, and multiple crews working simultaneously within the County 11

portion. The temporary impacts would also be localized to defined work areas, 12

not the entire road system, and only during assigned working hours as we 13

typically backfill and open the construction zones during non-working hours. The 14

Company has no incentive to needlessly extend the duration of construction. It is 15

our experience that longer daily impacts are more acceptable to the public than 16

having longer overall project durations. 17

Q. Please address the traffic impacts raised by Mayor Durr regarding the 18

General William C. Doyle Memorial Cemetery (Durr, Par. 9). 19

A. First, the cemetery has three separate public entrances on three separate roads 20

(Arneytown-Chesterfield Road (CR 664), Province Line Road, and Jacobstown-21

Chesterfield Road), so accommodating traffic impacts is feasible through 22

coordination of our construction activities with the facility. The existence of an 23

6

entrance located on a road that is not part of the project makes this coordination 1

more realistic. Second, the SRL route abuts the cemetery for approximately 1 2

mile, and more than sixty percent of that distance is separated from the 3

developed portion of the cemetery by over 150 yards of wooded, vacant land. 4

The short length of roadwork associated with the cemetery also weighs in favor 5

of reaching an acceptable traffic plan. Third, working in a manner that does not 6

interrupt burial services is precisely the type of issue that the Company would 7

address if North Hanover would agree to meet with the Company to address 8

traffic control. At that meeting, the Company would suggest either coordinating 9

schedules to work around burial services, or if such work-arounds proved 10

infeasible, working at night along that short stretch of road. It has always been 11

the Company’s desire and intent to provide the proper respect and dignity that is 12

due this important facility. 13

III. ALTERNATIVE ROUTE THROUGH JOINT BASE MCGUIRE-DIX-14

LAKEHURST. 15

Q. Please address the alternative route through Joint Base McGuire-Dix-16

Lakehurst proposed by Assemblyman Dancer and referenced in the 17

intervenors’ testimony (Brickley, Lines 148-210; Durr, Par. 20; Liedtka, 18

Lines 72-73). 19

A. Discussions with the Joint Base leadership included considerations regarding the 20

general alignment through the Joint Base later proposed by Assemblyman 21

Dancer. At that time, the Joint Base advised that the alignment was not suitable 22

because it passed through the operational areas of the Base, including 23

7 5600602.1

commercial/office areas and active artillery/firing ranges, as well as 1

environmentally sensitive areas. Accordingly, that route did not advance to a full 2

alternatives analysis. On October 29, I met with the Joint Base leadership and 3

others, including Assemblyman Dancer. At that meeting the Joint Base 4

leadership again made it clear that the Company’s preferred route remains the 5

Joint Base’s preference, and any other route similar to that proposed by the 6

Assemblyman and others would negatively impact the Base’s mission. Joint 7

Base leadership also explained the reasons why Assemblyman Dancer’s route is 8

not a preferable route including, among other things, those I just noted. I have 9

attached a copy of the correspondence from the Joint Base commander dated 10

November 6, 2015 which memorializes in writing the Joint Base’s preference of 11

the Company’s preferred route for its location on Base property, attached hereto 12

as Exhibit 1. 13

CONCLUSION 14

Q. Does this conclude your rebuttal testimony at this time? 15

A. Yes, it does. However, I reserve my right to supplement and/or amend my 16

testimony in the future. 17

Exhibit 1

njng srl rebuttal testimony of lynch baker and wyckoff

Documents