3-1 Alternatives

3.0 ALTERNATIVES

In accordance with NEPA and our policy, we evaluated alternatives to the projects to determine 

whether an alternative would be technically and economically feasible, and environmentally preferable to 

the proposed action. The purpose of this evaluation was to determine whether there are reasonable 

alternatives that would result in less environmental impact than the projects as proposed while still 

meeting the projects’ objectives. As described in section 1.1, Constitution indicated that the project 

objectives were to: 

• deliver up to 650,000 Dth/d of natural gas supply from Susquehanna County, 

Pennsylvania to the interconnect with the TGP system at the existing Wright Compressor 

Station;

• provide new natural gas service for areas currently without access to natural gas;

• expand access to multiple sources of natural gas supply, thereby increasing supply 

diversity and improving operational performance, system flexibility, and reliability in the 

New York and New England market areas; 

• optimize the existing systems for the benefit of both existing and new customers by 

creating a more competitive market, resulting in enhanced market competition, reduced 

price volatility, and lower prices; and 

• provide opportunities to improve regional air quality by utilizing cleaner-burning natural 

gas in lieu of fuel oil in existing and future residential, commercial, and industrial 

facilities, thereby reducing GHG emissions and other pollutants. 

Iroquois stated that the purpose of its project is to provide 650,000 Dth/d of leased firm capacity 

of natural gas from the terminus of the Constitution’s project in Wright, New York to downstream 

customers in Iroquois’ existing system through the addition of system compression, interconnections with 

TGP, and other necessary infrastructure. According to Iroquois, the interconnection with Constitution’s 

project and the proposed compressor transfer station would provide Iroquois’ existing customers with 

new supply, increased reliability, and lower fuel prices. 

The alternatives to the proposed actions that we address in this section include the no-action 

alternative, system alternatives, route alternatives, minor route variations, and aboveground facility site 

alternatives. 

We established several key criteria to evaluate the potential alternatives identified. Each 

alternative was evaluated in consideration of whether or not it would:

• be technically and economically feasible and practical;

• offer a significant environmental advantage over the proposed action; and

• meet the projects’ objectives, as described above.

With respect to the first criterion, it is important to recognize that not all conceivable alternatives 

are technically feasible and practical. For example, some alternatives may not be possible to implement 

due to technological difficulties or logistics. We do not design natural gas pipeline projects. Rather, 

pipeline companies propose and design pipeline projects in response to market conditions. In turn, we 

analyze these proposals and a reasonable range of alternatives. In conducting this analysis, it is important 

to recognize the environmental advantages and disadvantages of the proposed actions in order to focus the 

analysis on reasonable alternatives that may reduce impacts and offer a significant environmental 
Alternatives 3-2

advantage. A detailed discussion of the environmental consequences of the projects (both positive and 

negative) is included in section 4.0. 

Using the evaluation criteria discussed above and subsequent environmental comparisons, each 

alternative was considered to the point where it was clear that the alternative was either not reasonable, 

would result in substantially greater environmental impacts that could not be readily mitigated, offered no 

potential environmental advantages over the proposed projects, or could not meet the projects’ objectives. 

Alternatives that appeared to result in less than or similar levels of environmental impact were reviewed 

in greater detail. The following sections discuss and analyze each of the alternatives evaluated in 

sufficient detail to explain why they were eliminated from further consideration or are recommended for 

adoption into the respective project.

Where environmental data are presented within this alternatives analysis, it is data collected from 

desktop (e.g., maps, literature, aerial photography, and agency databases) sources. Constitution collected 

field survey data for its proposed route and some (but not all) alternatives. Therefore, to present the most 

consistent comparisons of potential impacts on environmental resources this section presents data 

obtained from desktop sources for both the proposed route and alternative routes, even when field data 

may exist. 

During the preliminary design stage for the projects, Constitution participated in our pre-filing 

process (see section 1.3). This process emphasizes identification of potential stakeholder issues early in 

the development of a project, as well as identification and evaluation of alternatives that may avoid or 

minimize these issues. During this process, Constitution made multiple modifications to its proposed 

pipeline route to address stakeholder concerns. The majority of route changes were made to avoid 

conflicts with existing or planned land uses or to increase the distance of the pipeline route from 

residences and commercial businesses, recreation areas, or other infrastructure. These changes were 

subsequently made part of the Constitution’s proposed route when it filed its FERC application and 

supplements, and are presented in this draft EIS. Iroquois did not participate in our pre-filing process, but 

its proposal is the result of the adoption of an alternative to Constitution’s original proposal (i.e., a new, 

greenfield compressor station) in an effort to reduce overall environmental impact. 

3.1 NO-ACTION ALTERNATIVE

The Commission has two courses of action in processing applications under Section 7 of the 

NGA: 1) deny the requested action (the no-action alternative), or 2) grant the Certificate, with or without 

conditions. If the no-action alternative is selected by the Commission, the proposed facilities would not 

be constructed, and the short- and long-term environmental impacts from the projects would not occur. In 

addition, if the no-action alternative is selected, the stated objectives of Constitution and Iroquois’ 

proposals would not be met. The no-action alternative would eliminate this new natural gas supply for 

New York and New England markets, causing existing and potential users of natural gas to either pursue 

other means of natural gas supply, to rely on other fuels (such as heating oil), or to seek other means to 

meet or curtail their energy needs.

The New York State Energy Planning Board (2009) assessment of natural gas markets in New 

York and in the northeast concluded that most of the interstate transmission pipelines in the region are at 

or near capacity on peak days, and that by 2018 unmet peak day natural gas demand for New York and 

New England could range between an estimated 300,000 to 900,000 Dth/d. Demand for natural gas is 

expected to grow by five percent between 2009 and 2020 for New York alone (New York State Energy 

Planning Board 2009), and production of natural gas is increasing in the northeast region. Other reports 

have also documented increased demand for natural gas in New York and New England and the lack of 
3-3 Alternatives

adequate pipeline capacity to deliver required volumes of natural gas (ISO-New England 2012, ICF 

International 2012). 

The lack of a new pipeline with access to supply sources into the region could prolong the 

existing supply constraints in the proposed delivery areas, which could create winter-premium pricing and 

exacerbate price volatility for all natural gas users in the areas, and could increase the difficulty for others, 

such as the operators of gas-fired electric generating plants, in finding economical gas supplies. This in 

turn could lead to higher gas and electric rates in the region and could lead to energy shortages during 

times of winter peak demand. 

The burning of natural gas at power plants to produce electricity also results in reduced air 

emissions compared to other fossil fuels, such as coal and fuel oil. According to the EPA (2013a), natural 

gas produces at least 50 percent less carbon dioxide (CO2), almost 70 percent less nitrogen oxides (NOx), 

and about 99 percent less sulfur oxides compared to a coal-fired power plant. Since the 1990s, the 

transition to natural gas fueled power plants in New England has substantially decreased dependence 

upon the formerly pre-dominant energy sources of fuel oil, coal, and nuclear energy (ISO-New England 

2012). If the no action alternative were adopted, then air emissions could be increased if other sources of 

energy were used. Other energy alternatives are discussed below in section 3.1.2. 

The no-action alternative would not provide the potential economic benefits associated with the 

proposed projects, including increased jobs, secondary spending, and tax revenues during construction, as 

well as increased property tax revenues to local governments during operations as discussed in section 

4.9. Further, the no-action alternative would not provide natural gas service to municipalities in 

Pennsylvania and New York near the project that do not currently have access to natural gas. The abovementioned transition in energy sources in New England over time has been hastened by the relative lower 

cost of natural gas, which has economic and cost savings benefits that are then passed along to consumers 

of electricity. 

In summary, the no-action alternative would avoid the environmental impacts of the proposed 

projects, but it would result in the need for alternate means to satisfy the demand for natural gas, or other 

sources of energy in New York and New England. The no-action alternative would not meet the 

objectives of the proposed projects. It would likely, however, lead end users to seek energy from other 

sources including other fossil fuels and renewable energy. It could also lead to increased energy 

conservation. Each of these potential options, with respect to the no-action alternative, is discussed 

below.

3.1.1 Energy Conservation and Energy Efficiency

Energy conservation measures have and will continue to play an important role in reducing 

energy demand in the United States. The Energy Policy Act of 2005 includes guidelines to diversify 

America’s energy supply and reduce dependence on foreign sources of energy, increase residential and 

businesses’ energy efficiency and conservation (e.g., EPA Energy Star Program), improve vehicular 

energy efficiency, and modernize domestic energy infrastructure (U.S. Congress 2005). 

New York has strongly promoted energy conservation and has a number of programs in place to 

minimize energy use. One result of these programs is that New York is now the second most energy 

efficient state in the nation on a per capita basis, with about one-third lower energy usage than the

national average. One of New York’s energy goals is to reduce electricity use to 15 percent below 2015 

projected levels, which would provide additional impetus for the state’s electricity efficiency initiatives. 

Data from the New York Independent System Operator (NYISO) demonstrate that although statewide 

energy use dropped a total of 5.1 percent in 2008 and 2009 (primarily due to the downturn in the 
Alternatives 3-4

economy), energy use grew by 3 percent in 2010, and remained near 2010 levels in 2011. Energy use in 

the New York City area in 2010 also exceeded 2008 levels (NYISO 2012). Moreover, projected electrical 

demand in New York is forecast to increase by about 900 gigawatt hours per year between 2011 and 2021 

(NYISO 2012). This projected growth in electrical demand takes into account New York’s 15 percent 

energy efficiency target described above. Con Edison is a major supplier of electricity and natural gas in 

the New York area and operates programs that promote energy efficiency for homes, businesses, and 

industry, including a “Green Team” initiative with opportunities for energy audits, incentives, and rebates 

(Con Edison 2013). 

New England states such as Massachusetts also strongly promote energy efficiency 

(Massachusetts Executive Office of Energy and Environmental Affairs 2013). The State of 

Massachusetts calls energy efficiency its “first fuel” and sponsors programs to promote energy efficiency 

for homes, businesses, cities, new construction projects, and state government operations. Massachusetts 

was ranked as the top state in the American Council for an Energy Efficient Economy’s (ACEEE 2013) 

rankings for 2012 and other New England states such as Connecticut, Rhode Island, and Vermont all also 

ranked in the top ten. Massachusetts has some of the most ambitious energy savings targets in the United 

States with targets of 2.6 percent annual electric savings for 2013-2015 along with state-funding and 

support (ACEEE 2013). Additionally, National Grid is a major supplier of electricity and natural gas in 

the New England area and operates a program called Mass Save which promotes energy efficiency for 

homes, businesses, and industry (National Grid 2013). 

Combined Heat and Power

Combined heat and power (CHP), also known as cogeneration, accounts for almost 12 percent of 

electrical power generation in the U.S. (United States Clean Heat and Power Association 2013). CHP is 

the simultaneous production of electricity and heat from a single fuel source, such as natural gas, biomass, 

biogas, coal, or oil. CHP is not a single technology, but an energy system that can be modified depending 

on the needs of the energy end user. CHP systems consist of a number of individual components 

configured into an integrated whole to recover and use waste heat from production of electricity. These 

components include the prime mover, generator, heat recovery equipment, and electrical interconnection. 

The prime mover drives the overall system and typically includes reciprocating engines, combustion 

turbines, steam turbines, microturbines, and fuel cells (EPA 2011a). In the U.S., CHP decreases energy 

use by about 1.3 trillion British thermal units (Btus) per year and contributes to overall reductions in NOx

and SO2 emissions (United States Clean Heat and Power Association 2013). New York currently has 517 

CHP installations with a generating capacity of about 5,552 megawatts (MW) (ICF International 2013). 

The vast majority (85 percent) of these CHP installations operate using natural gas. 

The State of Massachusetts promotes the use of CHP (Mass.gov 2013). The state offers 

incentives for the use of alternative energy systems such as CHP and stated that CHP was especially 

appropriate for larger commercial, industrial, and institutional facilities. 

Recently, the EPA evaluated the opportunity for the use of CHP at wastewater treatment facilities 

and found that, as of June 2011, wastewater treatment CHP systems were in place at 133 sites in 30 states, 

representing 437 MW of capacity (EPA 2011a). Although 78 percent of the facilities identified rely 

solely on biogas from on-site anaerobic digesters, some facilities employ other fuel sources (e.g., natural 

gas or fuel oil) either because the facility does not use anaerobic digesters or because biogas is not a 

practicable option due to site-specific technical or economic conditions. New York currently has six 

wastewater treatment CHP facilities representing about 3 MW of capacity (EPA 2011a). Wastewater 

CHP systems typically work best when employed at facilities with influent flow rates of 5 million gallons 

per day (mgd) or more (EPA 2011a). This is because waste stream volumes this large are typically 

required to produce sufficient quantities of biogas to make CHP usage economically feasible. The EPA’s 
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2011 study examined the potential for increasing CHP use at wastewater treatment facilities with influent 

rates of at least 1 mgd. Smaller wastewater facilities that employ anaerobic digesters can produce 

sufficient biogas through conventional means (given high enough biosolids loadings) or augment their 

digester process to raise the biogas generation rate (e.g., addition of collected fats, oils, and greases; use 

of microbial stimulants). About 37 percent of the wastewater treatment facilities with influent flows of 1 

to 5 mgd and employing anaerobic digestion processes are candidates for deployment of CHP (EPA 

2011a). If all of these facilities instituted CHP an additional 54 MW per day of electrical generation and 

4,997 million Btu per day of thermal energy could be produced nationally. 

While the Energy Policy Act and these other state and municipal programs promote increased

energy efficiency and conservation by supporting new energy efficient technologies (such as CHP) and 

increasing funds for energy efficiency research, and would no doubt minimize energy use, they are not 

expected to eliminate the increasing demand for energy or natural gas. Additionally, the implementation 

and success of energy conservation in curtailing energy use is a long-term goal, extending well beyond 

the timeframe of the proposed projects. 

Projections by the DOE’s Energy Information Administration (EIA) support this conclusion. 

According to the Annual Energy Outlook 2013 with Projections to 2040 (DOE/EIA 2013a) reference 

case, despite increased efficiency, natural gas consumption (subtotal) in the Mid-Atlantic states, which 

include Pennsylvania and New York, is expected to grow from 2.78 quadrillion Btu per year in 2010 to 

3.45 quadrillion Btu per year in 2040. Natural gas consumption in the New England states is expected to 

grow from 0.90 quadrillion Btu per year in 2010 to 1.12 quadrillion Btu per year in 2040. These natural 

gas estimates comprise about a 24 percent increase in consumption for both regions. Therefore, while 

energy conservation and energy efficiency would undoubtedly reduce the demand for fossil fuels in the 

New York and New England regions to some degree, it would not eliminate the need for additional 

natural gas supply altogether or in the short term. 

While energy conservation reduces demand for energy sources such as natural gas, and may be a 

long-term alternative or partial alternative for the projects, implementation of sufficient energy 

conservation measures to eliminate the need for the proposed projects is not feasible in the short-term. As 

such, we do not consider energy conservation or energy efficiency a practicable alternative to the 

proposed projects and they were eliminated from further analysis.

3.1.2 Non-Gas Energy Alternatives

3.1.2.1 Nuclear Energy

Energy from nuclear power is important nationally and accounted for approximately 9 percent of 

annual energy consumption nationwide in 2011 (DOE/EIA 2013a). In New York, nuclear power 

currently accounts for about 14 percent of statewide generating capacity (NYISO 2012). In New England 

(Massachusetts, Maine, New Hampshire, Vermont, Rhode Island, and Connecticut), nuclear energy 

accounted for approximately 12 percent of total energy consumption in 2012. The projected trends for 

nuclear energy production are relatively flat, with total consumption rising from 0.377 quadrillion Btu in 

2012 to 0.405 quadrillion Btu in 2021 and then decreasing to 0.384 quadrillion Btu by 2033 (DOE/EIA 

2013a). 

Entergy’s Vermont Yankee nuclear plant, which has provided about 4 percent of New England’s 

total electricity supply since 2007, is scheduled to close in 2014 (DOE/EIA 2013b). The reasons cited by 

Entergy for the plant’s closure included low wholesale electricity prices resulting partially from low 

natural gas prices, as well as capital costs associated with maintaining the plant (DOE/EIA 2013b). The 
Alternatives 3-6

same report showed that the portion of total electricity sales in New England attributable to natural gas 

grew from less than 30 percent overall in 2001 to greater than 50 percent in 2012. 

Moreover, increased use of nuclear power is seen by some as a means of reducing GHG 

emissions associated with the burning of fossil fuels. However, environmental and regulatory challenges 

concerning safety and security, the disposal of toxic materials (i.e., spent fuel), and alterations to 

hydrological/biological systems would need to be addressed before any new nuclear power generation 

facilities could be constructed. Nuclear power remains controversial, given these factors. 

Plans for a new nuclear power plant in New York were announced by UniStar Nuclear. UniStar 

Nuclear applied for a Combined License in September 2008 for a new nuclear plant at the Nine Mile 

Point nuclear plant site on Lake Ontario in the town of Scriba, which is approximately 6 miles northeast 

of Oswego, New York. The proposed plant would generate about 1,710 MW of electricity. However, the 

future of the project is unclear. According to the DOE/EIA, UniStar requested that the U.S. Nuclear 

Regulatory Commission suspend its review of the application for the project on May 31, 2010. No other 

proposed new nuclear power reactors have been submitted to the U.S. Nuclear Regulatory Commission in 

New York or New England (NRC 2013). The most recent new nuclear reactor to enter service in the

United States was the Tennessee Valley Authority’s Watts Bar Unit 1 in 1996 (EIA 2013a). 

Because the subject of nuclear power remains controversial, these proposals and any subsequent 

plans that arise to construct new or expand existing plants in the northeast would likely involve prolonged 

review periods that would not meet the objectives of the projects. For these reasons, nuclear power is not 

currently a practicable alternative to the projects and was eliminated from further review.

3.1.2.2 Fossil Fuels

According to the DOE/EIA’s Annual Energy Outlook 2013 with Projections to 2040 reference 

case (DOE/EIA 2013a), fossil fuel consumption as a percentage of total energy consumption is projected 

to drop from 82 percent of total U.S. energy demand in 2011 to 78 percent in 2040. The same DOE/EIA 

source also projected that energy production attributable to the consumption of coal would fall from 19.62 

quadrillion Btu in 2011 to an estimated 18.75 quadrillion Btu in 2040. The projected decline in fossil fuel 

consumption as a percentage of total consumption is due largely to corporate average fuel economy 

standards and state and federal standards for renewable energy sources.

If the proposed projects were not constructed, fossil fuels including coal and fuel oil could be 

used as alternative sources of electricity generation. We are not aware of any plans for major energy 

supply projects that would supply or use petroleum to create electricity in the projects’ area. Coal is used 

for energy generation and would function as an alternative to natural gas. However, relative to natural 

gas, the burning of coal results in greater emissions of pollutants such as NOx, sulfur dioxide (SO2), GHG,

and mercury (EPA 2005). In 2010, coal comprised 46 percent of total U.S. electric power generation 

(DOE/EIA 2011). Due to the greater environmental impacts associated with emissions from coal-burning 

power generation, it is unlikely that coal would displace the need for natural gas in the target market areas 

in the foreseeable future.

Use of fuel oil may result in increased reliance on foreign oil, which could require development 

of additional import, storage, and refining facilities. Fuel oil is commonly transported by pipeline which 

could then require construction of other pipeline systems to transport it which would likely have similar 

impacts as the proposed projects, but in a different location. Reliance on fuel oil as an alternative to 

natural gas would increase the potential for environmental impacts such as oil spills; land development to 

construct or modify import, storage, and refining facilities; and pollution from air emissions. Because 

natural gas burns cleaner than other fossil fuels, is relatively inexpensive compared to other fossil fuels, 
3-7 Alternatives

and is domestically produced, we conclude that it is unlikely that other fossil fuels would displace the 

need for natural gas in the target market areas in the foreseeable future. Therefore, consideration of the 

use of other fossil fuels was eliminated from further review. 

3.1.2.3 Renewable Energy

The DOE/EIA (2013a) projects rapid growth in renewable fuel consumption due primarily to the 

implementation of the federal Renewable Fuels Standard for transportation fuels and state renewable 

portfolio standard (RPS) programs for electric generation. Nationally, the consumption of renewable 

energy is projected to increase between 2011 and 2040 from about 9 percent in 2011 to approximately 13 

percent in 2040 as a result of state standards, federal tax credits for renewable electricity generation and 

the federal renewable fuels standard (DOE/EIA 2013a). A summary of potential renewable energy use in 

the projects’ area is included below.

Wind

Wind power technology that has experienced advancements over the last 20 years including 

reductions in installation costs, improved turbine performance, and reduced maintenance costs. Although 

wind projects have no operational emissions, such developments can negatively affect wildlife 

(particularly birds and bats), visual resources, and other environmental resources. In the projects’ general 

area, the sites with the highest wind velocities tend to be located along ridgelines in areas of steep slopes 

(National Renewable Energy Laboratory [NREL] 2010) which are challenging to access and generally 

highly visible.

To date, most of the large-scale renewable projects participating in the New York RPS program 

are wind projects in northern and western New York where wind resources are greatest. As of March 

2012, currently operating wind generation capacity in New York is about 1,414 MW, or approximately 3 

percent of statewide generating capacity (NYISO 2012). Interconnect requests into NYISO’s queue as of 

March 2012, representing proposed power projects, would add another 4,000 MW of wind capacity 

(NYISO 2012). Since the wind farm areas are typically located far from major downstate load areas, 

major infrastructure improvements would be necessary for these projects to serve the New York City 

area. 

To address this concern, proposals are being evaluated to develop wind resources closer to or in 

the vicinity of major load areas. The New York Power Authority (NYPA), Long Island Power Authority,

and Con Edison, in collaboration with other public agencies, are currently conducting technical and 

environmental studies to determine the feasibility of siting a wind farm about 13 to 15 miles offshore of 

the western end of the Rockaway Peninsula to generate 350 MW of electricity by 2015 (with the potential 

to expand to 700 MW in later phases) to serve the New York City and Long Island market. According to 

the Joint Con Edison - Long Island Power Authority Offshore Wind Power Integration Project Feasibility 

Assessment (March 20, 2009), a 350-MW wind facility operating at a 30 percent capacity factor would 

generate about 920,000 MW hours per year, half of which would serve New York City. In June 2010, the 

NYPA Board of Trustees authorized the NYPA to apply for a lease for approximately 64,500 acres of 

underwater land from the Federal Bureau of Ocean Energy Management, Regulation and Enforcement, 

formerly known as the Minerals Management Service. In September 2011, the NYPA submitted a 

request to that agency to lease approximately 81,500 acres offshore of the Rockaway Peninsula for 

construction of up to 700 MW of wind power. The New York State Energy Research and Development 

Authority completed an initial environmental feasibility study (NYSERDA 2010). These actions indicate 

a continuing interest in the project; however, the development of the offshore wind project is still in its 

early phase and its future is still uncertain. However, additional site-specific engineering and 

environmental studies need to be completed, the agencies need to release a request for proposal to select a 
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private project developer to build and operate the wind farm, the filing of permit applications would need 

to be made, and environmental reviews would need to be conducted. The Cape Wind Project, another 

proposed wind power project with 130 turbines producing up to 454 MW, would be located in Nantucket 

Sound off shore of Massachusetts (Cape Wind 2013). Cape Wind has received applicable permit 

approvals and is pending as its project financing phase is completed and legal challenges are resolved. 

Total consumption of renewable energy sources such as wind (and combined with other 

renewable energy sources such as conventional hydroelectric, geothermal, and solar) is projected to rise 

from 0.219 quadrillion Btu in 2010 to an estimated 0.270 quadrillion Btu in 2020 and ultimately to 0.378 

quadrillion Btu by 2040 in the New England region (DOE/EIA 2013a). It appears likely that wind 

projects will continue to be pursued depending on tax credits and/or other financial incentives, state 

programs, technology improvements, transmission availability, and the public interest. In June 2010, the 

governor of New York, along with the governors of nine other east coast states, signed a memorandum of 

understanding with the U.S. Department of the Interior to establish the Atlantic Offshore Wind Energy 

Consortium to promote the development of wind resources on the Outer Continental Shelf. In February 

2011, the DOE and U.S. Department of the Interior published A National Offshore Wind Strategy, a 

guidance document for developing an offshore wind energy industry in the United States. This document 

calls for development of 10 gigawatts (GW) of deployed wind generation capacity by 2020, at a cost of 

$0.10 per kilowatt hour; and a longer term goal of 54 GW of generating capacity by 2030, at a cost of 

$0.07 per kilowatt hour. However, the authors note that, to achieve the called-for generation goals, two 

critical objectives must be met: reducing the cost of offshore wind energy and reducing the timeline for 

deploying offshore wind energy (i.e., streamlining regulatory review and permitting). It is also 

speculative at this point to say which individual project(s) may be approved and economically supported 

to provide power to the New York markets, or what effect these projects might have on the local natural 

gas market.

In the near-term, sufficient wind energy is not available in the projects’ vicinity that would 

provide the 650,000 Dth/d (190,496.4 megawatt hours or 15,874.7 MW per 12-hour day) of energy that 

would be provided by the proposed projects. Constitution estimated that 5,292 new wind turbines would 

be required to provide the same energy generation capacity as the natural gas to be transported by the 

proposed projects. The amount of land that would be directly impacted by operation of that number of 

wind turbines was estimated to be approximately 1,323 acres including access roads and support 

structures, but excluding the turbine spacing buffer that would be necessary between turbines (NREL 

2012). Assuming an average of 2.5 acres per MW of wind power, the total land requirements for a 

theoretical wind project with the power generation capacity of the proposed projects could be greater than 

39,000 acres (NREL 2009). This estimated amount of land is far greater than the permanent impact on

lands of the proposed projects, which would be approximately 744 acres for the proposed pipeline and 2.4 

acres for the Iroquois compression transfer station. 

The largest wind farm currently operating in New York has a 320-MW capacity; approximately 

50 wind farms of the same size would be required to replace the proposed projects. No wind projects are 

operational in the counties crossed by the proposed pipeline (NYSDEC 2012a). The Moresville Wind 

Farm project is proposed and under review in Delaware County; however, that project would produce 66 

MW of energy, a mere 0.4 percent of the energy capacity that would be provided by the proposed 

projects, which is clearly insufficient in meeting their objectives (NYSDEC 2012b). 

Onshore wind power generation requires large, permanent turbines and supporting facilities, as 

well as construction of electric transmission lines to connect wind facilities to transport the wind energy 

to consumers. These facilities would have an impact on visual resources, since onshore wind turbines are 

constructed to capture wind high above the natural topography and could be constructed along highly 

visible ridge lines. Additionally, wind turbines may have direct impacts on resident and migratory birds, 
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bats, and other wildlife from collision mortality or indirect impacts from habitat disturbance. 

Construction of offshore wind power generation facilities may result in impacts on marine species. In 

contrast, the permanent right-of-way of the proposed pipeline area would be restored to pre-construction 

contours and maintained as herbaceous cover. Potential impacts on wildlife from the proposed projects 

are expected to be largely short-term and temporary, with the exception of habitat conversion in forested 

areas and the establishment of some aboveground facilities. Therefore, theoretical onshore wind 

generation facilities would result in greater impacts upon visual, vegetation, and wildlife resources than 

the proposed projects. 

Because of the greater potential for negative environmental impacts on lands, visual resources,

and wildlife from a wind energy project, as well as limitations including the short-term unavailability of 

sufficient wind energy to meet the projects’ objectives, we have determined that wind energy is not a 

suitable alternative for the proposed projects and it was eliminated from further consideration. 

Geothermal Power

Geothermal energy is dependent upon proximity to hotspots of volcanic activity or tectonic plate 

boundaries. The project area is not conducive to development of geothermal power generation projects. 

Therefore, geothermal energy was eliminated from further consideration.

Fuel Cells

Fuel cells use hydrogen or fossil fuels to generate electricity more cleanly than traditional 

electrical generation methods; however, fuel cell technology is in the early phases of development. 

Because fuel cell technology is not sufficiently developed to provide a cost-effective, substantial source 

of energy, fuel cells were eliminated from further consideration. 

Hydroelectric Generation

Hydroelectric generation is fully commercialized, including both run-of-river and large 

impoundment-type projects ranging in capacity from less than one MW to hundreds of MW. The 

DOE/EIA (2013a) has projected that little new hydroelectric capacity will be developed through 2040. 

Although hydroelectric power does not result in emissions of air pollutants, it can alter flow conditions 

within streams, thereby affecting habitats for fish and other aquatic organisms. Additionally, new 

hydroelectric facilities may require the construction of electric power transmission lines and their 

associated environmental impacts. 

One new project that has applied for a license from the FERC is the Thompson Hydroelectric 

Project (P-12741) on the Hudson River in Saratoga and Washington Counties, New York (FERC 2013). 

This proposed project would consist of a dam, a generating unit with a capacity of approximately 24 MW, 

a transmission line, and other facilities that, if licensed and constructed, would have an estimated annual 

generation of approximately 69 gigawatt hours. The applicant for the Thompson Hydroelectric Project 

filed an application for a successive preliminary permit on August 20, 2013 proposing to study the 

feasibility of the hydropower project. 

Currently, there are two proposed transmission projects to import hydroelectric and wind power 

into New York and New England: the Champlain Hudson Power Express Project and the Northern Pass 

Project. The DOE (2013) issued a notice of availability for a draft EIS for the Champlain Hudson Power 

Express Project on October 21, 2013. Both proposed projects require a Presidential Permit since the 

transmission line would involve a border crossing. The Champlain Hudson Power Express Project 

involves construction of a 1,000-MW high voltage direct current transmission system from a converter 
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station southeast of Montreal in Quebec, Canada to the New York City area. The proposed transmission 

cables would be buried in Lake Champlain, the Hudson River, and under adjacent existing railroad rightsof-way. According to the project sponsors, the transmission line is expected to be used primarily by 

hydroelectric and wind generators in Canada. A projected energy market and emissions impact analysis, 

prepared by Champlain Hudson Power Express, Inc., states that the project would facilitate the import of 

more than 7,647 gigawatt hours of renewable energy per year, which would expand the renewable energy 

base within New York by 13 percent. The project is ongoing, and the public comment period for the draft 

EIS ended in December 2013. 

The proposed Northern Pass Project would bring 1,200 MW of hydroelectric energy from Quebec 

to New Hampshire and New England (Northern Pass 2013). The Northern Pass Project transmission line 

would be largely collocated with existing rights-of-way and would extend approximately 187 miles. 

Northern Pass submitted an application to the DOE in October 2010, and filed an amended application in 

June 2013. Regulatory review of the project is ongoing. 

The proposed projects’ area is generally not conducive to development of major new 

hydroelectric power generation projects. The importation of hydroelectric power from Canada via the 

proposed construction of new electric transmission lines appears to be an emerging option for some of the 

energy needs in both New York and New England. However, these potential sources of hydroelectric 

power are not sufficient to displace the need for increased natural gas supplies in the region. Therefore, 

hydroelectric energy generation was eliminated from further consideration.

Biomass

Combustion of biomass is a proven technology using biomass feedstock, which, if properly 

grown, represents a renewable resource (EPA 2013b). Biomass can be derived from organic materials 

such as crops, wood, and municipal wastes. These products can then be turned in to heat and electricity.

In New York, biomass (e.g., wood) has been the leading in-state renewable resource consumed in 

the residential, commercial, and industrial sectors as measured by primary energy input. According to the 

New York State Energy Plan, New York uses 99 trillion Btu of wood and 13 trillion Btu of biogenic 

waste annually and has the technical and practical potential to develop 350 trillion and 14 trillion Btu 

annually by 2018, respectively (New York State Energy Planning Board 2009). Current biomass 

generating capacity participating in New York’s RPS was 26.0 MW as of December 31, 2012 

(NYSERDA 2013). An additional 43.3 MW of biomass generation capacity is in development or under 

construction. The mix of feedstock for these facilities includes wood, tire-derived fuel, coal, and landfillderived methane. Information from the NYISO indicates that biomass accounts for less than 2 percent of 

current generation capacity in the New York Control Area (NYISO 2013). 

The State of Massachusetts limited incentives associated with some biomass facilities in 2012 

(Mass.gov 2012). The limitations involved the status of certain wood-burning (and similar organic 

material burning) power plants as renewable energy sources due to concerns based on carbon emissions 

and GHG concerns. New air quality efficiency standards would be required at biomass facilities to 

maintain state-mandated incentives.

Biomass is not considered a viable alternative to the increased natural gas supplies that would be 

provided by the proposed projects based on its limited capacity, and it was eliminated from further 

consideration. 
3-11 Alternatives

Photovoltaic (Solar Power)

Photovoltaic power systems convert sunlight directly into electricity. These systems generally 

are not well-suited for use as large-scale generation in the proposed projects’ area due to relatively low 

direct insolation, higher capital costs, potential reliability issues, and lower efficiencies. 

To promote photovoltaic power systems in New York State, including providing clean energy 

jobs and promoting the diversity of the state’s energy sources, on January 27, 2010, the NYPA released a 

request for proposals seeking a public-private partnership for the installation of up to 100 MW of 

photovoltaic systems across the state (NYPA 2010). The NYPA is reviewing numerous proposals 

received and, once proposals are selected, the NYPA expects the installations to occur through 2014. A 

recent assessment of solar domestic hot water systems within New York indicated that solar thermal 

energy could potentially provide over half of the energy required for water heating in a typical home that 

has adequate access to sunlight. Solar energy systems can be more easily deployed in densely populated 

areas than other renewables and where their output closely matches with peak demand; however, solar 

systems are among the highest cost renewable technologies (New York State Energy Planning Board 

2009).

Solar energy also is used and promoted in New England. For example, the City of Boston has a 

program called Renew Boston Solar with a goal of increasing solar energy system capacity in Boston to 

25 MW by 2015 (CityofBoston.gov 2013). This program encourages installation of solar technology in 

homes and businesses, as well as within City government. 

Solar power generation on an industrial scale requires large, permanent facilities with impervious 

cover and no shading to allow for photovoltaic panels to gather energy. In contrast, the permanent rightof-way of the proposed project area would be restored to pre-construction contours and maintained as 

herbaceous cover. Therefore, a large, industrial scale, solar power generation facility would result in 

greater visual, vegetation, and habitat impacts than the proposed projects. Impacts of new electric 

transmission lines associated with solar power generation facilities would be similar to impacts from the 

proposed projects. Additionally, the operational land requirements for solar power generation would far 

exceed those required for the proposed projects as at least an estimated 1,176 acres of permanent 

aboveground solar facilities would be required to produce the equivalent 15,875 MW of power. In 

addition to the construction of a solar power generation facility, construction of access roads and electric 

transmission lines also would be required to transport the generated solar energy to consumers, resulting 

in additional environmental impacts. Because of the far greater land use required for a solar power 

generation project, as well as limitations including potential reliability issues, higher costs, and the 

unsuitability of the proposed project area (due to low direct insolation), solar power generation as an 

alternative to the increased natural gas supplies that would be delivered by the proposed projects was 

eliminated from further consideration.

Tidal and Wave Power

New York is committed to continued research and marketing of the development of tidal, current, 

and other hydrokinetic resources in the projects’ area (New York State Energy Planning Board 2009). 

Wave and tidal energy technologies are still in the early stages of development. The limiting factors in 

the development of these new technologies include the high cost of construction and environmental 

monitoring, as well as the management of potential impacts on competing uses. From the Commission’s 
Alternatives 3-12

experience in reviewing projects that involve requests for preliminary permits,1 the interest in developing 

wave energy projects has been limited to the west coast of the United States, due to the resource 

availability and its proximity to shore. While the Commission has issued a number of preliminary 

permits, and currently has several active licensing proceedings for the development of tidal energy 

projects in New York, these proposals are for small-scale demonstration projects that are seeking, or plan 

to seek, short-term pilot licenses that would allow them to gather the field data necessary for a full-scale 

commercial deployment. For instance, in January 2012, the Commission issued a pilot project license for 

the Roosevelt Island Tidal Energy Project, a 1,050-kilowatt pilot-scale hydrokinetic generation facility 

that would be located in the East River in New York City (FERC 2012). The project would be 

constructed in three phases and operate for 10 years. When fully built, the facility would generate about 

2.4 gigawatt hours annually.

Tidal energy is also being explored in New England. The Town of Edgartown has partnered with 

governmental agencies and academic institutions to evaluate using tidal power to produce electricity for 

the Muskeget Tidal Energy Project (New England Marine Renewable Energy Center 2013). This tidal

project would produce 5 MW of energy. Demonstration tests were conducted in August 2011. The 

Muskeget Tidal Energy Project would be subject to multiple agency regulatory reviews, including by the 

Commission.

Given its preliminary nature of tidal and wave energy in the United States and relatively small 

scale, tidal and wave energy is not a viable alternative to the increased natural gas supplies that would be 

delivered by the proposed projects, and it was eliminated from further consideration 

Summary of Renewable Energies

The renewable energy projects planned or proposed in both New York and New England would 

help to diversify the electricity market in the both regions, thus helping to protect consumers from volatile 

fossil fuel prices and assisting both regions with achieving their respective RPS goals. Accordingly, 

while these renewable energy projects would benefit the energy market by diversifying the array of fuels 

used to generate electricity, they are not expected to meet consumers’ overall electricity needs. 

Moreover, renewable energy is not completely interchangeable with natural gas. Most renewable energy 

sources are used to generate electricity. While natural gas is used for this purpose, it is also used for 

space heating and cooking. Although these uses could be served by electricity instead of natural gas, 

existing natural gas-based heating and cooking systems would have to be converted to electric-based 

systems, which may be prohibitively expensive for many consumers. Finally, moving electricity from the 

point of generation to consumers may require major investment in electric transmission lines as well as 

other additional infrastructure costs. Additionally, the development of the transmission lines associated 

with renewable projects would have potentially adverse effects on air, water, ecological values, and other 

resources. Therefore, renewable energy alternatives were eliminated from further consideration.

3.2 SYSTEM ALTERNATIVES

3.2.1 Existing Transportation System Alternatives

System alternatives would make use of other existing, modified, or proposed pipeline systems (or 

other transportation systems) to meet the stated objectives of the projects. A system alternative would 

 1 The Commission’s preliminary permits carry a term of 3 years and do not authorize project construction or 

operation. The purpose of a preliminary permit is to maintain priority of a potential future license application 

for a site while a developer gathers the information necessary for developing a license application.
3-13 Alternatives

make it unnecessary to construct all or part of the proposed projects, although some modifications or 

additions to another existing pipeline system may be required to increase its capacity, or another entirely 

new system may need to be constructed to meet the projects’ purpose and need. Such modifications or 

additions would result in environmental impact that could be less than, similar to, or greater than those 

associated with construction of the proposed projects. The purpose of identifying and evaluating system 

alternatives is to determine whether potential environmental impacts associated with the construction and 

operation of the proposed facilities could be avoided or reduced while still meeting the basic objectives of 

the projects. 

To be practicable system alternatives to the proposed projects, other systems, or modified systems 

would need to meet the Applicants’ stated objectives (sections 1.1 and 3.0) and be both technically 

feasible and practicable. Two of the Applicants’ objectives that are crucial to the evaluation of system 

alternatives would be their ability to: 

• deliver up to 650,000 Dth/d of natural gas supply from Susquehanna County, 

Pennsylvania to the interconnects with the Iroquois and TGP systems at the existing 

Wright Compressor Station (or otherwise delivery of the same amount of natural gas to 

the destination markets through other means); and

• expand access to new sources of natural gas supply, thereby increasing supply diversity 

and improving operational performance, system flexibility, and reliability in the New 

York and New England market areas. 

Another important consideration is whether a system alternative is economically practical. Two 

shippers (Cabot and Southwestern) have signed precedent agreements with Constitution for the proposed 

natural gas volumes. The shippers would deliver gas from existing sources in Pennsylvania to the New 

York and New England markets. To be economically practicable, a system alternative must be capable of 

meeting these two shippers’ requirements. 

Figure 3.2.1-1 provides a geographic overview of the proposed project area, as well as the relative 

location of other existing interstate natural gas pipelines in the area that were evaluated as system 

alternatives. The status of existing systems is described below in section 3.2.2. 

Another potential system alternative could involve the transportation of the required volume of 

liquefied natural gas (LNG) to the delivery point by truck via existing roadways. We asked Constitution 

to evaluate a natural gas shipping alternative involving the potential use of LNG transport trucks to 

deliver the same amount of natural gas from the supply area in Susquehanna County, Pennsylvania to the 

delivery area near the existing Wright Compressor Station, along with any other infrastructure that may 

be required. This alternative would require the construction of a new liquefaction facility near the supply 

area, a vaporization plant at the delivery point, and an estimated 302,345 LNG tanker truck one-way trips 

per year, or approximately 828 trips per day each day of the year. Given the requirement for the new 

liquefaction and vaporization facilities that would have to be constructed as well as the number of truck 

trips that would be required on a continuous basis, we conclude that the use of LNG trucks to deliver the 

required amounts of natural gas is not preferable to the proposed projects. 
Existing Wright

Compressor Station

Transco (Leidy)

Tennessee (TGP 300)

Tennessee (TGP 200)

Iroquois (IQT)

Millennium

Dominion

PENNSYLVANIA NEW

JERSEY

CONNECTICUT

R. I.

MASSACHUSETTS

NEW HAMPSHIRE

VERMONT

NEW YORK

Algonquin

Susquehanna

Supply Area

Proposed Pipeline

Susquehanna Supply Area

p

0 20 40 60 80

Miles

Figure 3.2.1-1

Constitution Pipeline Project

Relative Location to Other Projects Overview Map

3-14
3-15 Alternatives

3.2.2 Status of Existing Pipeline Systems

Constitution’s joint owners, Williams Partners Operating, LLC, Cabot Pipeline Holdings, LLC, 

and Piedmont Constitution Pipeline Company, LLC do not own or operate existing pipeline systems 

capable of meeting the natural gas delivery capacity that the proposed pipeline project would provide to 

service downstream markets in New York and New England. However, there are four other existing 

pipeline systems operating in the vicinity of the proposed pipeline project area in addition to the Iroquois 

and TGP 200 pipeline systems operating in the New York and New England market areas. These other 

pipelines include:

• Transco Leidy;

• TGP 300 Line; 

• Millennium Pipeline Company, LLC (Millennium); and

• Dominion Transmission, Inc. (Dominion).

Constitution obtained data for each pipeline system and determined that all of these systems are 

currently operating at or near full capacity. We have reviewed this information and conclude that these 

pipelines do not have the available capacity to transport the required volumes of natural gas to the 

delivery point in Wright, New York in their current configuration. Moreover, none of the existing 

pipeline systems are connected to the proposed pipeline project’s gas supply area in Susquehanna County, 

Pennsylvania except for TGP’s 300 Line. However, TGP’s 300 Line proceeds in an east-west direction, 

not northeast towards the existing Wright Compressor Station and proposed delivery area. TGP’s 200 

Line is the only pipeline that connects to the existing Wright Compressor Station and proposed natural 

gas delivery area, (Transco Leidy, Millennium, and Dominion do not). Even if additional pipeline was 

constructed for the purposes of connecting any of these system alternatives to the supply area and the 

delivery area, there still is not sufficient available capacity on any of these existing pipeline systems to 

meet the proposed pipeline projects’ required delivery of natural gas. Therefore, we do not consider use 

of existing pipeline systems as feasible alternatives for the proposed projects. 

3.2.3 Modification of Existing Pipeline Systems

Because none of the existing pipeline systems in the project area have the capacity to meet the 

projects’ objectives in their current state, they would require substantial modifications to meet the 

projects’ objectives. These modifications could include greenfield pipeline construction to connect to the 

supply area, delivery area, or both; the use of existing pipeline where possible along with looped pipeline 

(i.e., new pipeline construction generally adjacent to an existing pipeline); additional compression; or 

some combination of these options. 

We dismissed major system alternatives from further consideration if it were considered to have 

environmental impacts greater than the proposed pipeline project. These cases at a minimum involved 

routes that were partially looped with an existing pipeline and had a new greenfield segment that 

exceeded the length of the proposed project (124 miles). This eliminated system alternatives involving 

greenfield and looping options of the Millennium and Transco Leidy from further analysis. The 

Millennium and Transco Leidy systems are discussed further below in relation to other possible system 

alternatives in configurations that would not require a greenfield pipeline exceeding the length of the 

pipeline proposed by Constitution. 

Two other system alternatives, for TGP and Dominion, would have greenfield pipeline lengths 

less than the proposed pipeline, but would have to be combined with looped pipeline segments to provide 
Alternatives 3-16

the same service delivery capacity as the proposed pipeline. An evaluation of the potential for these two 

interstate pipelines to provide the same service as the proposed projects is also presented below.

3.2.3.1 Tennessee Gas Pipeline

The TGP pipeline system carries natural gas from the Gulf of Mexico, Louisiana, and Texas to 

the northeastern United States. As shown in Figure 3.2.1-1, the TGP system in the projects’ area includes 

both the TGP 200 Line and 300 Line. The TGP 200 Line extends from western New York State through 

the Wright Compressor Station and into New England. The TGP 300 Line transverses across northern 

Pennsylvania, south of the proposed pipeline project area, and transports gas through New Jersey to New 

York City and New England markets. 

The existing TGP system does not have available capacity in the relevant locations and could not 

meet the proposed projects’ delivery capacity of up to 650,000 Dth/d of natural gas. To meet the required 

capacity, looping along portions of approximately 354 miles of the existing TGP system and additional

compression (between 160,000 and 256,000 horsepower) would be required. Additionally, to connect to 

the supply area in Susquehanna County, Pennsylvania, expansion of the TGP system would require 

construction of approximately 25 miles of greenfield pipeline. The TGP system alternative would 

proceed south from the supply area via the 25-mile-long greenfield pipeline, proceed west along TGP’s 

300 Line to TGP’s Compressor Station 319 in Bradford County, Pennsylvania, head north to TGP’s 

Compressor Station 237 in Ontario County, New York, and then, finally, east along TGP’s 200 Line 

ending at the Wright Compressor Station (figure 3.2.3-1). 

Constitution estimated that installation of between 142 and 260 miles of mostly looped 30-inchdiameter pipeline and substantial new compression would be required for the TGP system alternative. 

We have reviewed this information and conclude that the required new facilities would likely result in 

land disturbance and environmental impacts greater than the impacts of the proposed projects due to the 

greater total length of new pipeline facilities and the need for additional new or modified compressor 

station facilities with at least 8 times the amount of compression required for the proposed project. 

Therefore, we do not consider use of the TGP system alternative as preferable to the proposed projects.

3.2.3.2 Dominion

The Dominion pipeline system transports gas to markets in the Northeast, Mid-Atlantic, and 

Midwest via its pipeline system in Virginia, Maryland, Pennsylvania, New York, West Virginia, and 

Ohio. Dominion does not have available capacity in the proposed project area and therefore could not 

meet the required projects’ capacity of up to 650,000 Dth/d of natural gas. Looping would be required to 

accommodate the proposed pipeline capacity along approximately 135 miles of Dominion’s existing 

pipeline system. Additionally, construction of approximately 92 miles of greenfield pipeline would be 

required to connect the existing Dominion pipeline facility to Constitution’s receipt area in Susquehanna 

County, Pennsylvania and to the delivery area at the Wright Compressor Station (figure 3.2.3-2). 

Additional compression between 96,000 and 128,000 horsepower would also be required. The required 

new facilities would result in environmental impacts that likely would be greater than the impacts of the 

proposed projects due to the greater total length of new pipeline facilities (about 100 more miles) and the 

need for new or modified compressor station facilities (an increase of over 400 percent). Therefore, we 

do not consider modification of the Dominion pipeline system to be preferable to the proposed projects.
Existing Wright

Compressor Station

Transco (Leidy)

Tennessee (TGP 300)

Tennessee (TGP 200)

Iroquois (IQT)

Millennium

Dominion

PENNSYLVANIA NEW

JERSEY

CONNECTICUT

R. I.

MASSACHUSETTS

NEW HAMPSHIRE

VERMONT

NEW YORK

Algonquin

Susquehanna

Supply Area

TGP 300 - TGP 200 Alternative

Proposed Route

Susquehanna Supply Area

p

0 20 40 60 80

Miles

Figure 3.2.3-1

Constitution Pipeline Project

Tennessee (TGP 300) - Tennessee (TGP 200)

3-17
Existing Wright

Compressor Station

Transco (Leidy)

Tennessee (TGP 300)

Tennessee (TGP 200)

Iroquois (IQT)

Millennium

Dominion

PENNSYLVANIA NEW

JERSEY

CONNECTICUT

R. I.

MASSACHUSETTS

NEW HAMPSHIRE

VERMONT

NEW YORK

Algonquin

Susquehanna

Supply Area

Dominion Alternative

Proposed Route

Susquehanna Supply Area

p

0 20 40 60 80

Miles

Figure 3.2.3-2

Constitution Pipeline Project

Dominion Alternative

3-18
3-19 Alternatives

3.2.3.3 Other System Alternative Configurations

In addition to the TGP and Dominion system alternatives discussed above that were originally 

envisioned by Constitution in its application and which would generally proceed west initially, then north, 

and then east; we also considered system alternatives that would first proceed east along either the TGP 

300 Line, Transco Leidy, or Millennium pipelines more directly towards New York City. In theory, 

natural gas delivered in a more direct pathway to the vicinity of New York City could supply that market 

demand assuming that the appropriate interconnections for transportation and distribution could be 

maintained. Furthermore, depending upon the amount of natural gas destined for delivery in New 

England and existing infrastructure servicing the New England area, other options may exist to deliver the 

required amount of natural gas to that market area as well. 

As noted above, there is not sufficient available capacity to transport natural gas along the 

existing the TGP 300 Line, Transco Leidy, or Millennium pipelines in the direction of New York City to 

supply natural gas needs in that area. Further, the connection of a new pipeline proceeding east towards 

New York City to another existing or new pipeline extending northeast from New York City towards 

New England would be constrained by the high level of development within New York City and the 

surrounding area. Given these considerations, we conclude that system (or collocated) alternatives along 

the existing TGP 300 Line, Transco Leidy, or Millennium pipelines proceeding east directly toward New 

York City and then connecting with existing or new pipelines and proceeding towards New England, are 

not feasible and would not be preferable to the proposed projects. 

3.3 COLLOCATION WITH EXISTING PIPELINE SYSTEMS

We reviewed the potential for collocation of the proposed pipeline project almost completely 

along the route of existing pipeline systems either alone or in tandem with other existing systems, or a 

combination of existing and proposed pipeline systems. In addition, we evaluated the potential for partial 

collocation with an existing pipeline system. Two existing pipeline systems or combinations of existing 

systems were evaluated: TGP and a Millennium-Dominion-TGP system combination. We also assessed 

collocation using a combination of a proposed EmKey pipeline, an existing EmKey pipeline, the 

Dominion Pipeline, and TGP 200 Line. Finally, we reviewed the potential for an alternative with partial 

collocation along the existing Bluestone pipeline. These existing and proposed pipeline systems are 

depicted in figures 3.2.1-1 and 3.3-1.

We received comments about potential collocation of the proposed pipeline with the Laser 

Northeast Gathering System (Laser System). The Laser System consists of a 16-inch-diameter pipeline 

and gas gathering system located in Susquehanna County, Pennsylvania (approximately 33 miles) and 

Broome County, New York (approximately 10 miles). Laser is owned by Williams Partners LP, a 

company affiliated with the Constitution Pipeline. The Laser System is located approximately 10 miles to 

the northwest of Constitution’s proposed route, is designed for proximity to gas wells as a meandering 

gathering pipeline, and is not located near Constitution’s proposed natural gas receipt points. For these 

reasons, we do not consider collocation of the pipeline project with the Laser System to be viable and it 

was not evaluated further. The Laser System is also depicted in figure 3.3-1. 
Existing Wright

Compressor Station

Tennessee (TGP 300)

Tennessee (TGP 200)

Iroquois (IQT)

Millennium

Dominion

NEW YORK

Susquehanna

Supply Area

EmKey

Bluestone

EmKey - 

Proposed

Laser

Chemung

Bradford

Lycoming Sullivan

Tioga

Wyoming

Cortland

Tioga

Cayuga

Onondaga

Schuyler

Seneca

Tompkins

Wayne

Yates

Broome

Chenango

Herkimer

Madison

Oneida

Otsego Albany

Fulton

Greene

Montgomery

Saratoga

Schoharie

Columbia

Rensselaer

Delaware

Sullivan

Lackawanna

Pike

Susquehanna

Wayne

Dutchess

Orange

Putnam

Ulster

Proposed Route

Susquehanna Supply Area

p

0 20 40

Miles

Figure 3.3-1

Constitution Pipeline Project

EmKey, Bluestone, and Laser Pipeline Systems Emkey and Bluestone Alignment Sources:

http://emkeycompanies.com/emkey-resources/

http://www.dtepipeline.com/pdfs/bluestoneGatheringMap.pdf

3-20
3-21 Alternatives

3.3.1 TGP Collocated Alternative

As generally described above for the TGP system alternative (figure 3.2.3-1), the TGP collocated 

alternative would proceed south from the Susquehanna County, Pennsylvania supply area via a 25-milelong greenfield pipeline, proceed west along TGP 300 to TGP Compressor Station 319 in Bradford 

County, Pennsylvania, head north to TGP Compressor Station 237 in Ontario County, New York, then 

east along TGP 200 ending at the Wright Compressor Station. Collocation with the TGP system could 

allow for transportation of natural gas from the vicinity of the supply area in Susquehanna County to the 

Wright Compressor Station. 

This largely collocated TGP route would require installation of approximately 362 miles of new, 

collocated pipeline, approximately 25 miles of greenfield pipeline, and construction of two new 

compressor stations (one in Tioga County, Pennsylvania and one in Schoharie County, New York). The 

total length of this pipeline, approximately 387 miles, is more than three times the length of the proposed 

pipeline, and although it would be collocated with existing rights-of-way for approximately 94 percent of 

its length, it would also result in much greater total land disturbance, impacts on more landowners, and 

greater total environmental impacts relative to the proposed projects. Therefore, we do not consider 

collocation with the TGP pipeline system to be preferable to the proposed projects. 

3.3.2 Millennium-Dominion-TGP Collocated Alternative

We also considered collocation with a combination of three different pipeline systems: 

Millennium to Dominion to TGP 200. This collocated alternative would involve an approximately 10-

mile-long greenfield pipeline connecting the supply area in Susquehanna County, Pennsylvania to the 

north to the Millennium Pipeline, then west to the Dominion Pipeline, then northeast to the TGP 200 

Pipeline proceeding east to the Wright Compressor Station (figure 3.3.2-1). Collocation with the 

Millennium-Dominion-TGP systems could allow for transportation of natural gas from the vicinity of the 

supply area in Susquehanna County to the Wright Compressor Station. 

This largely collocated Millennium-Dominion-TGP route would require installation of 

approximately 222 miles of new, collocated pipeline, approximately 10 miles of greenfield pipeline, and 

construction of at least one new compressor station. The total length of this pipeline, approximately 232 

miles, is almost twice the length of the proposed pipeline, and although it would be collocated with 

existing rights-of-way for approximately 96 percent of its length, it would also result in greater total land 

disturbance, impacts on more landowners, and greater total environmental impacts relative to the 

proposed pipeline. Therefore, we do not consider collocation with the Millennium-Dominion-TGP 

pipeline system to be preferable to the proposed projects. 

3.3.3 EmKey-Dominion-TGP 200 Collocated Alternative

The existing EmKey pipeline is comprised of approximately 35 miles of 16- to 24-inch-diameter 

mainline pipeline and smaller laterals in Chenango and Madison Counties, New York. The EmKey 

pipeline is essentially a gathering line designed to collect and transport natural gas from wells in those 

two counties. EmKey has also proposed to expand its gathering line system with approximately 40 miles 

of new pipeline in Broome, Chenango, and Madison Counties, New York (EmKey 2013). 
Existing Wright

Compressor Station

Transco (Leidy)

Tennessee (TGP 300)

Tennessee (TGP 200)

Iroquois (IQT)

Millennium

Dominion

PENNSYLVANIA NEW

JERSEY

CONNECTICUT

R. I.

MASSACHUSETTS

NEW HAMPSHIRE

VERMONT

NEW YORK

Algonquin

Susquehanna

Supply Area

Millennium - Dominion - TGP 200 Alternative

Proposed Route

Susquehanna Supply Area

p

0 20 40 60 80

Miles

Figure 3.3.2-1

Constitution Pipeline Project

Millennium - Dominion - Tennessee (TGP 200)

3-22
3-23 Alternatives

The collocated EmKey-Dominion-TGP 200 alternative would proceed north from the 

Susquehanna County, Pennsylvania supply area via new, greenfield pipeline; begin collocation with the 

proposed EmKey pipeline route in Broome County, New York; proceed north to the existing EmKey 

pipeline in Chenango County, New York; then north to the Dominion Pipeline; northeast for a short 

distance along the Dominion Pipeline; then east via TGP 200 to the Wright Compressor Station (figure 

3.3.3-1). In addition, construction of at least one new compressor station would also be required. The 

total length of this EmKey-Dominion-TGP 200 collocated alternative, approximately 147 miles, is almost 

23 miles longer than the proposed pipeline. 

The existing and proposed EmKey pipelines would include meandering pathways and laterals 

designed for collecting gas from wells, not for the direct transportation of natural gas northeast to the 

Wright Compressor Station. Gathering lines typically have smaller diameters (due to lower volumes) and 

have more frequent bends and turns, which generally cannot be achieved with 30-inch-diameter pipe. 

Therefore, collocation is unlikely for the entirety of its length and would require many pipeline crossovers 

that would require substantially more and larger workspaces for construction. 

Further, Constitution’s proposed receipt points would be located approximately 20 to 25 miles 

away from the start of the EmKey pipeline. Although it would be collocated with existing rights-of-way 

for approximately 95 percent of its length, it would also result in greater total land disturbance, impacts 

on more landowners, greater total environmental impacts relative to the proposed pipeline project 

(including a crossing of the Susquehanna River), and reliance upon collocation with a proposed pipeline 

route for which ultimate approval and construction is uncertain. Because EmKey’s project status and its 

likelihood of construction is unknown, if it were not built, the maximum extent of collocation would be 

decreased to about 67 percent. While the use of some overlapping workspaces may be possible, it is 

likely that implementation of this alternative would require extensive use of abutting or adjacent rights-ofway, resulting in new impacts on previously undisturbed areas. Therefore, we do not consider collocation 

with the EmKey-Dominion-TGP 200 pipeline systems to be preferable to the proposed projects. 

3.3.4 Bluestone Pipeline Partially Collocated Alternative

The existing Bluestone pipeline is comprised of approximately 40 miles of trunk line located in 

Susquehanna County, Pennsylvania and Broome County, New York (figure 3.3-1). The Bluestone 

pipeline is essentially a gathering line designed to collect and transport natural gas from wells in those 

two counties; it connects to the TGP 300 Line in the south and the Millennium system to the north. It 

does not follow a direct path typical of natural gas transmission pipelines, as its route is dependent upon 

linkage and proximity to existing natural gas wells. Constitution’s proposed pipeline would be collocated 

with the Bluestone pipeline at MP 22.0 to 22.3 for a distance of approximately 1,901 feet, would cross 

over the Bluestone pipeline in multiple locations, and would make use of at least four access roads 

operated by Bluestone. Given the meandering nature of the Bluestone pipeline, its overall short length 

compared to the entire proposed pipeline route, and since Constitution has already proposed partial 

collocation and to make use of at least some other areas already disturbed by Bluestone, we conclude that 

additional collocation with the Bluestone pipeline is not preferable to the proposed project.
Existing Wright

Compressor Station

Tennessee (TGP 300)

Tennessee (TGP 200)

Iroquois (IQT)

Millennium

Dominion

NEW YORK

Susquehanna

Supply Area

EmKey

Bluestone

EmKey - 

Proposed

Chemung

Bradford

Lycoming Sullivan

Tioga

Wyoming

Cortland

Tioga

Cayuga

Onondaga

Schuyler

Seneca

Tompkins

Wayne

Yates

Broome

Chenango

Herkimer

Madison

Oneida

Otsego Albany

Fulton

Greene

Montgomery

Saratoga

Schoharie

Columbia

Rensselaer

Delaware

Sullivan

Lackawanna

Pike

Susquehanna

Wayne

Dutchess

Orange

Putnam

Ulster

EmKey - Dominion - TGP 200 Alternative

Proposed Route

Susquehanna Supply Area

p

0 20 40

Miles

Figure 3.3.3-1

Constitution Pipeline Project

EmKey - Dominion - Tennessee (TGP 200) Emkey and Bluestone Alignment Sources:

http://emkeycompanies.com/emkey-resources/

http://www.dtepipeline.com/pdfs/bluestoneGatheringMap.pdf

3-24
3-25 Alternatives

3.4 ROUTE ALTERNATIVES AND MINOR ROUTE VARIATIONS 

Major route alternatives include those that deviate from the proposed route for a significant 

distance, often a majority or more of the proposed route’s length, and which provide a substantially 

different pathway from the source area to the delivery area. Minor route alternatives deviate from the 

proposed route less substantially than major route alternatives, are often designed to avoid large 

environmental resources or engineering constraints, and typically remain within the same general area as 

the proposed route. Minor route variations are typically site-specific and may allow for avoidance of 

certain localized features such as a home, wetland, or orchard. 

This assessment includes route alternatives and variations identified by Constitution, FERC staff, 

landowners, municipalities, and other stakeholders. Many of the alternatives identified below are the 

result of Constitution adopting changes to reduce impacts on specific resources; therefore, some of the 

alternatives presented are those that were originally identified by Constitution as part of its planned route 

in May 2012. Subsequently, our assessment of the environmental consequences of the alternatives and 

variations already incorporated by Constitution into its proposed route is included as part of our 

environmental analysis of the proposed projects in section 4.0.

3.4.1 Major Route Alternatives

We evaluated two major route alternatives, alternatives K and M. These two alternatives, along 

with a comparison of potential environmental impacts and other relevant factors, are described below and 

depicted in figure 3.4.1-1. 

3.4.1.1 Alternative K

Alternative K was developed by Constitution to maximize collocation with existing rights-ofway. As with the proposed route, alternative K begins at the Williams Central Compressor Station in 

Susquehanna County, Pennsylvania, and ends at the existing Wright Compressor Station in Schoharie 

County, New York. This alternative is approximately 118 miles long, which is about 6 miles shorter than 

the proposed route. Alternative K is collocated with existing rights-of-way, primarily electric 

transmission lines, for approximately 90 miles or about 76 percent of its total length. A comparative 

analysis of environmental impacts of the proposed route and alternative K is presented in table 3.4.1-1.

Alternative K crosses the New York City Water Supply Watershed (NYCWSW) in Delaware and 

Schoharie Counties, New York for approximately 33 miles. The NYCWSW provides unfiltered drinking 

water supply to approximately eight million consumers, almost one-half the population of New York 

State (New York City Department of Environmental Protection [NYCDEP] 2012). The proposed 

pipeline route would also cross public water supply watersheds (i.e., Cobleskill Reservoir watershed, Pine 

Hill Reservoir watershed, and the Barton Hill Natural Resource Protection Overlay watershed), but these 

three watersheds would be crossed for a combined length of approximately 4 miles. Additionally, 

potential impacts on the Pine Hill Reservoir watershed would be minimized through the use of an HDD 

for much of the proposed crossing length in that area. In addition, Constitution’s proposed pipeline route 

is located at least 1 mile away from springs supplying the Barton Hill Natural Resource Protection 

Overlay watershed.
ALTERNATIVE K

ALTERNATIVE M

SEGMENT 1

ALTERNATIVE M

SEGMENT 3

ALTERNATIVE M

SEGMENTS 5 & 6

WRIGHT 

COMPRESSOR 

STATION

NEW YORK

PENNSYLVANIA

NEW YORK CITY

WATERSHED

SUB-ALTERNATIVE K

Cortland

County

Broome

County

Chenango

County

Madison County

Otsego

County

Albany

County

Greene

County

Schoharie

County

Delaware

County

Sullivan

County

Susquehanna

County

Wayne

County

Ulster

County

§ ̈¦88

§ ̈¦88

Proposed Constitution Pipeline Route

Alternative K

Sub-Alternative K

Alternative M

Susquehanna Source Area

New York City Watershed

p

0 10 20

Miles

Figure 3.4.1-1

Constitution Pipeline Project

Major Route Alternatives

NEW YORK

PENNSYLVANIA

NJ

MA

MD

CT

NH

VA

VT

DE

RI

3-26
3-27 Alternatives

TABLE 3.4.1-1 

Comparison of Proposed Route to Alternative K

Factor

Proposed

Route

Alternative

Route

Difference

(if Applicable)a

Length of Corresponding Segments (miles) 124.4 118.0 -6.5

Type of Right-of-Way

Length Adjacent to Existing Utility Right-of-Way (electric/pipeline) 

(miles)

11.2 82.1 70.9

Length Adjacent to Existing Roadways Paralleling and within an 

Existing Right-of-Way or Easement (miles)

0.0 0.0 0.0

Length Adjacent to Existing Roadway Paralleling and Abutting an 

Existing Right-of-Way or Easement (miles)

0.5 0.5 0.0

Length Adjacent to Existing Roadways Paralleling an Existing Rightof-Way or Easement within 300 feet (miles)7.5 7.7 0.2

Right-of-Way Requirements

Pipeline Construction Requirements (acres) 1,659.2 1,572.7 -86.5

Pipeline Operation Requirements (acres) 754.2 714.9 -39.3

Wetlands

Total Wetland Complexes Crossed (number) 33 36 3

Total Wetland Crossed (linear feet) 8,148 8,470 322

Total Wetland Impacts (construction/operation) (acres) 14.0/9.4 14.6/9.7 0.6/0.4

Palustrine Forest Wetland Complexes Crossed 

(construction/operation) (acres)

2.0/1.3 2.2/1.5 0.2/0.2

Palustrine Scrub-Shrub Wetland Complexes Crossed 

(construction/operation) (acres)

5.5/3.7 3.4/2.3 -2.2/-1.4

Palustrine Emergent Wetland Impacts (construction/operation) 

(acres)

6.6/4.4 9.0/6.0 2.5/1.6

Waterbodies

Waterbodies Crossed (number) 98 134 36

Major River Crossings (number greater than 100 feet) 2 3 1

Streams with Drinking Water Use Designation (number) 1 5 4

Cultural Resources

National Historic Landmarks (number) 0 0 0

National Register of Historic Places Eligible or Potentially Eligible 

Cultural Resources Sites Crossed (number) 

0 1 1

Land Use

Forested Land Crossed (miles) 79.0 80.4 1.4

Forested Land Impacts (construction/operation) (acres) 1,053.9/479.0 1,072.5/487.5 18.7/8.5

Forest Edge Crossed (miles) 43.1 69.9 26.9

Forested Edge Impacts (construction/operation) (acres) 574.3/261.0 932.4/423.8 358.1/162.8

Forest Interior Crossed (miles) 36.0 10.5 -25.5

Forested Interior Impacts (construction/operation) (acres) 436.0/218.7 127.4/63.7 -308.6/-154.3

Important Bird Area Crossed (miles) 2.4 19.1 16.7

Audubon Forest Blocks of Importance (miles) 6.1 47.8 41.7
Alternatives 3-28

TABLE 3.4.1-1 (continued)

Comparison of Proposed Route to Alternative K

Factor

Proposed

Route

Alternative

Route

Difference

(if Applicable)a

Agricultural Land Crossed (miles) 36.0 22.2 -13.8

Agricultural Land Impacts (construction/operation) (acres) 545.6/218.2 336.5/134.6 -209.1/-83.6

Landfills, Quarries, Material Storage and Processing (number) 6 0 -6

Property Owners

Property Owners Affected (number of parcels crossed) 655 623 -32

Residences Located within 50 feet of the Pipe Centerline (number) 7 1 -6

Residences Located within 125 feet (number) 7 14 7

Residences Located within 250 feet (number) 79 72 -7

Federal and State Land

Federal Lands Crossed (number/miles) 0 0 0

State Forest/Parks (number/miles) 2/0.1 1/0.6 -1/0.5

Trails

Trails (number) 2 1 -1

Other Physical Features

Road Crossings (number) 129 134 5

Railroads Crossed (number) 4 5 1

Other Environmental Features

Shallow Depth to Bedrock Crossed (miles) 43.7 34.9 -8.8

Steep Slopes Crossed (30 degrees or greater) (miles) 8.1 14.7 6.6

Side Slope Construction greater than 30 Percent Slope (miles) 2.3 0 -2.3

Environmental Hazards and/or Concerns (within 0.5 mile) (number) 8 9 1

Landslides / Unstable Lands Crossed (miles) 0.0 0.0 0.0

___________________

a Totals may not sum correctly due to rounding

Alternative K also crosses and collocates with the West Delaware Tunnel of the New York City 

Water Supply Aqueduct System for approximately 4 miles (NYCDEP 2012). This aqueduct carries water 

supplies from the NYCWSW to New York City. If alternative K was pursued, drilling and blasting 

would be prohibited in the vicinity of the aqueduct, and other special permitting requirements would 

apply. Other energy infrastructure crossed and/or collocated with alternative K include electric utility 

lines operated by Penelec, New York State Electric and Gas, the NYPA, and National Grid, as well as 

pipelines operated by Enterprise and Millennium. 

The NYCDEP administers several programs designed to protect the NYCWSW. These programs 

include stormwater permitting and regulation, land acquisition, agricultural partnerships, forestry 

initiatives, stream management and restoration plans, riparian buffer protection regulations, and wetland 

protection. Land use permits are required for certain activities occurring within the watershed as 

described in NYCDEP’s Watershed Rules and Regulations (NYCDEP 2006).

The NYCDEP, in its scoping comments, noted the sensitivity of the water supply watershed, its 

importance to millions of water consumers in New York, and potential impacts on the watershed and 

ultimately the water supply resulting from stormwater discharges and polluted runoff that could occur 
3-29 Alternatives

during construction of the pipeline. It is likely that major additional permitting efforts and impact 

avoidance, minimization, and mitigation measures would be required by the NYCDEP if alternative K 

was adopted. The NYCDEP supported Constitution’s decision to deem alternative K as non-viable and 

requested that Constitution’s project not be sited within the NYCWSW. The NYCDEP further noted that 

if Constitution’s project were subsequently routed through the NYCWSW, then the route would be 

subject to their permitting requirements and regulations and that the NYCDEP would have additional 

scoping and environmental review comments. 

Both the proposed route and alternative K have certain advantages environmentally. Alternative 

K is shorter in length, thereby affecting less land (i.e., smaller overall footprint). It is also collocated with 

more existing rights-of-way than the proposed route resulting in less greenfield construction. 

Consequently, it would have fewer impacts on forest interiors, property owners, nearby residences, and 

shallow bedrock. 

However, the proposed route crosses much fewer waterbodies, streams designated as drinking 

water supplies, areas within public water supply watersheds (as discussed above), and important bird 

areas and forest blocks of importance for birds as designated by the National Audubon Society. In 

particular, alternative K crosses an additional 19 miles of Audubon Society-designated Important Bird 

Areas, and 48 miles of Audubon Forest Blocks of Importance. Important Bird Areas vary in size, but are 

typically discrete habitats that provide essential habitat for bird species including sites for breeding, 

migrating, and overwintering (Audubon New York 2013). These areas also typically focus on habitats for 

birds that are under regulatory protection, those birds that are considered at risk or especially vulnerable 

to habitat loss, or at places where large numbers of birds may congregate. Forest Blocks of Importance 

are contiguous blocks of forested areas providing habitat for many wildlife species, including birds. In 

addition to the total miles of blocks crossed, the blocks crossed by alternative K are larger, more 

contiguous blocks than those crossed by the proposed route.

The utility lines that alternative K would collocate with have variable right-of-way widths 

(depending on its operator) of between 150 and 200 feet wide. Factoring in areas of extra workspace that 

would be needed for crossovers of existing subsurface utilities, roads, staging areas for wetland and 

waterbody crossings, and avoidance of transmission towers and guide wires, the long-term impacts of

construction could result in a corridor ranging between 200 and 325 feet. 

Although there can be environmental benefits to collocation of linear projects and expansion of 

existing rights-of-way, impacts on certain wildlife species also may occur. Forest interior species, such as 

some migratory birds, mammals, and other fauna, may be isolated or have movements restricted by the 

occurrence of extensive cleared gaps or corridors through otherwise forested areas (FERC 2008, USDA

and U.S. Forest Service 2002, Bourque and Desrochers 2003). Certain species may be more sensitive to 

wider gaps than others. In some cases, forest gaps of approximately 250 feet may inhibit bird movement 

or affect behavior (U.S. Department of Agriculture 2002). Increased nest predation and parasitism may 

also occur along expanded corridors. Generalist, forest edge, or disturbance-tolerant avian and other 

wildlife species could benefit from the expansion of open corridors, but the forest interior and 

disturbance-intolerant species may not. 

The proposed route avoids the NYCWSW, which supplies unfiltered drinking water to 

approximately one-half of the State of New York. Potential impacts on rare or protected species such as 

the bald eagle, Indiana bat, bog turtles, timber rattlesnake, and dwarf wedgemussel also would have to be 

fully evaluated if alternative K was selected over the proposed route. The proposed pipeline route’s 

impacts on rare and protected species are discussed in section 4.7. According to Constitution, the full 

assessment and possible adoption of alternative K would add extensive time for study, stakeholder input, 

agency review and permitting, and construction, potentially adding over 2 years to the project schedule. 
Alternatives 3-30

Constitution also stated that such a delay would likely render the project non-viable from a market 

perspective. Given all of these factors, we do not consider that alternative K offers a significant 

environmental advantage over the proposed pipeline project. 

We also considered a sub-alternative K (figure 3.4.1-1) which diverges from the proposed 

pipeline route north of the NYCWSW thereby avoiding it, connects to alternative K, and then proceeds

north to the existing Wright Compressor Station. The addition of sub-alternative K adds approximately 6 

miles to the proposed pipeline’s overall length and would require the construction of a greenfield 

compressor station in order to meet the expanded compression requirements necessitated by the increased 

length. For these two reasons, we do not consider adoption of sub-alternative K to be preferable to the 

proposed projects and it is not further evaluated. 

3.4.1.2 Alternative M

Alternative M was developed to evaluate the possibility of collocating the proposed pipeline with 

Interstate 88 (I-88). Numerous commenters requested that an alternative route be evaluated which would 

place a portion of the pipeline route within or adjacent to the I-88 corridor, thereby reducing the need for 

disturbance in greenfield areas. I-88 originates near Binghamton, New York, which is just north of the 

Susquehanna County, Pennsylvania supply area, and proceeds approximately 118 miles to the northeast to 

the vicinity of Schenectady, New York. The proposed pipeline route and I-88 occur in the same general 

vicinity as each other, both trending northeast-southwest. Near the northeast end of the proposed pipeline 

route at MP 121, I-88 and the proposed pipeline route would be located about 300 feet apart, before the 

route proceeds approximately 3 miles east ending at the Wright Compressor Station, the pipeline project’s 

delivery point.

The I-88 corridor is managed by the New York State Department of Transportation (NYSDOT), 

with funding and oversight provided by the FHWA. Constitution consulted with the NYSDOT and 

FHWA regarding the possibility of locating alternative M within or along the right-of-way for I-88. We 

also have coordinated with the NYSDOT and FHWA regarding alternative M. 

As a result of this coordination several potential construction or engineering issues have been 

identified regarding alternative M:

• blasting near the roadway; 

• use of two-tone construction techniques on side slopes; 

• disruption of interstate traffic flow during blasting;

• delays caused by slow moving, heavy construction equipment operating near the 

roadway; and

• limited areas where the pipeline could be safely installed relative to the roadway. 

For the safety of both motorists and construction workers, Constitution would not be allowed to 

access the construction workspace directly from I-88; rather, access would have to be obtained from 

adjacent private properties. Constitution also would not be allowed to access the permanent right-of-way 

from I-88 during operations. Placement of the pipeline within the controlled access area2 managed by the 

NYSDOT would obstruct pipeline construction as well as inspections and maintenance during pipeline 

 2 A controlled access area is a highway with limited ingress and egress to facilitate traffic flow, and which the 

owners of abutting lands are typically denied access to or from the highway.
3-31 Alternatives

operations. The NYSDOT stated that the proposed pipeline would be required to comply with FHWA 

policy, (23 CFR 645, Subpart B) which states that Constitution would be required to show that no feasible 

alternative routes exist to obtain approval of the alternative M route from the NYSDOT and FHWA. As 

demonstrated in this analysis, multiple alternative routes do exist including the route proposed by 

Constitution. Further, because the easements are federally managed, Constitution would be required to 

successfully negotiate an easement for any portion of its project located within or crossing these access 

areas. If the NYSDOT refused the granting of an easement or if a mutually agreeable easement could not 

otherwise be negotiated in these areas, and the Commission were to grant an approving Certificate, it 

would essentially be approving a non-buildable project, as federally managed lands cannot be acquired

through the power of eminent domain. In some cases, projects are built on federally managed lands; 

however, the appropriate land managing agency was receptive to the granting of an easement.

Constitution used a tiered approach in developing a technically feasible and constructible route 

for alternative M. First, placement of the pipeline within the median of I-88 was evaluated. Given that 

the median width ranges from 60 to 100 feet, and Constitution’s project would generally require at least a 

100 foot construction right-of-way, there is not sufficient width for construction workspace within the 

median. The limited space within the median would also not be sufficient for specialized construction 

techniques such as the HDD method. Additionally, side slopes occurring within the median would 

require even more workspace, and existing stormwater management structures would present obstacles to 

construction. Additionally, ingress and egress to project workspaces would only be accessible directly 

from the left-hand lanes of I-88. This would likely require shifts of traffic to accommodate ingress and 

egress resulting in safety concerns, potential damage to motorists and vehicles, and delays in traffic for 

the duration of construction associated with reduced lane width and shifts. Given these factors, we concur 

that placement of the pipeline within the I-88 median is not technically feasible.

Second, placement of the pipeline adjacent to I-88 within or along the controlled access under 

jurisdiction of the NYSDOT was evaluated. When I-88 was constructed, the highway was placed along 

steep side slopes in many locations, and was often installed along rocky cliffs or bluffs via use of blasting. 

This roadway configuration leaves little or in some cases no room for construction workspaces adjacent to 

the roadway, which is further exacerbated by the lack of safe construction or operational access from I-88. 

Additionally, blasting would likely be required in many locations in close proximity to the highway, 

thereby potentially affecting highway use during construction. As noted above, construction within side 

slopes would also require expanded workspaces. Given these factors, we concur that placement of the 

pipeline immediately adjacent to I-88 within the NYSDOT’s controlled access area is not feasible.

Finally, we evaluated placement of the pipeline adjacent to I-88 where feasible (outside of the 

NYSDOT’s controlled access area) with deviations away from the I-88 corridor as necessary to avoid 

constraints such as side slopes, cliffs, stormwater management structures, known cultural resources, 

environmentally sensitive areas; as well as population centers, homes, and businesses. The result of these 

evaluations is the route discussed here as alternative M.

If alternative M were subsequently proposed as the preferred route, the FHWA, along with 

NYSDOT, stated that they would need to complete additional review of the plan sheets (with I-88 access 

control lines) of the segments where the pipeline could approach and ultimately impact the I-88 control of 

access area. 

For purposes of our comparative analysis, alternative M was divided into six segments. This 

allows us to evaluate incorporating potentially one or more segments of alternative M into the proposed 

route. However, due to the proximity of I-88 to the Susquehanna supply area and delivery point in 

Wright, New York, three segments of alternative M are identical to the proposed pipeline route; therefore, 

they are not assessed as part of the analysis. The remaining three segments are evaluated where 
Alternatives 3-32

alternative M and the proposed route do not follow an identical path. This process allows for a 

comparison not just for alternative M relative to the proposed route, but also for a more detailed 

assessment of various segments of alternative M compared to corresponding segments of the proposed 

route. The alternative M route segments are depicted in figure 3.4.1-2 and are evaluated below.

Three paired comparison segments are straightforward comparisons of the proposed route to 

corresponding alternative M segments. These comparison segments include (noting that segments 2, 4, 

and 7 are identical to the proposed route and are not compared):

• proposed route segment 1 compared to alternative M segment 1;

• proposed route segment 3 compared to alternative M segment 3; and

• proposed route segment 5/6 compared to alternative M segment 5/6.

In addition to these three straightforward segment comparisons, two other possible combinations 

of proposed route segments 5/6 with alternative M segments 5/6 were evaluated. We discuss these 

additional route combinations in order to obtain the maximum number of possible comparisons. In order 

to facilitate this process, and because alternative M segment 5/6 was relatively lengthy at approximately 

46 miles long, Constitution developed a “bridge” connecting the proposed route segment 5 to alternative 

M segment 6 and also a “bridge” connecting alternative M segment 5 to the proposed route segment 6. 

These bridges were located near Richmondville, in Schoharie County, New York and they are depicted in 

figure 3.4.1-2. These alternative M combination alternatives included:

• proposed route segment 5/6 compared to alternative M segment 5 to bridge 1 to the 

proposed route segment 6; and

• proposed route segment 5/6 compared to proposed route segment 5 to bridge 2 to 

alternative M segment 5/6.

Each of these five comparisons for various alternative M scenarios are evaluated and discussed 

below. 
BRIDGE 2

BRIDGE 1

PROPOSED ROUTE

SEGMENT 5

PROPOSED ROUTE

SEGMENT 6

ALTERNATIVE M

SEGMENT 6

ALTERNATIVE M

SEGMENT 5

SEGMENT 2

ALTERNATIVE M

SEGMENT 1

ALTERNATIVE M

SEGMENT 3

SEGMENT 4

SEGMENT 7

Chenango

County

Madison

County

Otsego

County

Greene

County

Schoharie

County

Delaware

County

Alternative M Seg1

Alternative M Seg 3

Alternative M Seg 5+6

Alternative M Seg 5 to Bridge 1

to Proposed Route Seg 6

Proposed Route Seg 5 to Bridge

2 to Alternative M Seg 6

Proposed Route

p

0 5 10 15

Miles

Figure 3.4.1-2

Constitution Pipeline Project

Alternative M Segments

NEW YORK

PENNSYLVANIA

NJ

MA

MD

CT

NH

VA

VT

DE

RI

3-33
Alternatives 3-34

Proposed Route Segment 1 Compared to Alternative M Segment 1

Alternative M segment 1 diverges from the proposed route at MP 49.1 in Chenango County, New 

York and rejoins the proposed route at MP 57.6 in Delaware County, New York. This segment is 0.5 

mile longer than the proposed pipeline route. Alternative M segment 1 parallels the I-88 corridor for 28 

percent of its length in the southwestern portion of the project area and diverges from the I-88 corridor to 

avoid features such as a rock quarry, steep rocky bluffs, a residential area, and a waterbody. The 

locations of the Towns of Sidney and Unadilla, large wetland complexes, and the Susquehanna River 

precluded the feasibility of crossing under I-88 and proceeding along the northern side of the corridor. A 

comparison of the environmental and other routing considerations associated with proposed route 

segment 1 compared to alternative M segment 1 is presented in table 3.4.1-2. 

TABLE 3.4.1-2 

Comparison of Proposed Route Segment 1 to Alternative M Segment 1

Factor

Proposed

Route

Alternative

Route

Difference

(if Applicable)a

Length of Corresponding Segments (miles) 8.3 8.8 0.5

Type of Right-of-Way

Length Adjacent to Existing Utility Right-of-Way (electric/pipeline) 

(miles)

2.5 0.0 -2.5

Length Adjacent to Existing Roadways Paralleling and within an 

Existing Right-of-Way or Easement (miles)

0.0 0.0 0.0

Length Adjacent to Existing Roadway Paralleling and Abutting an 

Existing Right-of-Way or Easement (miles)

0.0 0.0 0.0

Length Adjacent to Existing Roadways Paralleling an Existing Rightof-Way or Easement within 300 feet (miles)0.2 2.5 2.3

Right-of-Way Requirements

Pipeline Construction Requirements (acres) 111.1 117.1 6.0

Pipeline Operation Requirements (acres) 50.5 53.2 2.7

Wetlands

Total Wetland Complexes Crossed (number) 2 0 -2

Total Wetland Crossed (linear feet) 81 0 -81

Total Wetland Impacts (construction/operation) (acres) 0.1/0.1 0.0/0.0 -0.1-/0.1

Palustrine Forest Wetland Complexes Crossed 

(construction/operation) (acres)

0.0/0.0 0.0/0.0 0.0/0.0

Palustrine Scrub-Shrub Wetland Complexes Crossed 

(construction/operation) (acres)

0.1/0.1 0.0/0.0 -0.1/-0.1

Palustrine Emergent Wetland Impacts (construction/operation) 

(acres)

0.0/0.0 0.0/0.0 0.0/0.0

Waterbodies

Waterbodies Crossed (number) 6 6 0

Major River Crossings (number greater than 100 feet) 0 0 0

Streams with Drinking Water Use Designation (number) 1 0 -1

Cultural Resources

National Historic Landmarks (number) 0 0 0

National Register of Historic Places Eligible or Potentially Eligible 

Cultural Resources Sites Crossed (number) 0 0 0
3-35 Alternatives

TABLE 3.4.1-2 (continued)

Comparison of Proposed Route Segment 1 to Alternative M Segment 1

Factor

Proposed

Route

Alternative

Route

Difference

(if Applicable)a

Land Use

Forested Land Crossed (miles) 5.1 6.8 1.7

Forested Land Impacts (construction/operation) (acres) 67.9/30.8 90.0/41.9 22.1/10.1

Forest Edge Crossed (miles) 4.1 3.1 -1.0

Forested Edge Impacts (construction/operation) (acres) 54.8/24.9 41.1/18.7 -13.7/-6.2

Forest Interior Crossed (miles) 1.0 3.7 2.7

Forested Interior Impacts (construction/operation) (acres) 11.9/5.9 44.5/22.2 32.6/16.3

Important Bird Area Crossed (miles) 0.0 0.0 0.0

Audubon Forest Blocks of Importance (miles) 0.0 0.0 0.0

Agricultural Land Crossed (miles) 2.0 1.0 -1.0

Agricultural Land Impacts (construction/operation) (acres) 30.6/12.2 15.4/6.2 -15.2-/6.1

Landfills, Quarries, Material Storage and Processing (number) 0 0 0

Property Owners

Property Owners Affected (number of parcels crossed) 36 41 5

Residences Located within 50 feet of the Pipe Centerline (number) 0 0 0

Residences Located within 125 feet (number) 0 0 0

Residences Located within 250 feet (number) 6 10 4

Federal and State Land

Federal Lands Crossed (number/miles) 0/0.0 0/0.0 0/0.0

State Forest/Parks (number/miles) 0/0.0 0/0.0 0/0.0

Trails

Trails (number) 1 1 0

Other Physical Features

Road Crossings (number) 8 8 0

Railroads Crossed (number) 0 0 0

Other Environmental Features

Shallow Depth to Bedrock Crossed (miles) 3.9 3.6 -0.3

Steep Slopes Crossed (30 degrees or greater) (miles) 0.1 1.0 0.9

Side Slope Construction (miles) 0.2 0.8 0.6

Environmental Hazards and/or Concerns (within 0.5 mile) (number) 0 3 3

Landslides / Unstable Lands Crossed (miles) 0.0 0.0 0.0

___________________

a Totals may not sum correctly due to rounding

Many of the routing factors considered above are similar between the two alternatives. Although 

alternative M segment 1 is collocated with the I-88 corridor or other existing corridors for 2.5 miles, the 

corresponding proposed route segment is collocated with existing corridors for 2.7 miles. Notably, the 

proposed route would affect fewer forested lands, interior forested lands, landowners, residences within 
Alternatives 3-36

250 feet, and side slopes. Therefore, we do not consider adoption of alternative M segment 1 to be 

preferable to the proposed project. 

Proposed Route Segment 3 Compared to Alternative M Segment 3

Alternate M segment 3 diverges from the proposed route at MP 61.2 in Delaware County, New 

York, crosses a short portion of Otsego County, New York, and then re-enters Delaware County before 

rejoining the proposed route at MP 76.9. Alternate M segment 3 is collocated with the southern side of I88 for a portion of its length and deviates to avoid a cemetery, residential areas, and a commercial area 

adjacent to the Susquehanna River. The possibility of crossing under I-88 and proceeding along the 

northern side of the roadway corridor was not considered practical for this segment due to the locations of 

the Towns of Otego and Oneonta, New York. A comparison of the environmental and other routing 

considerations associated with proposed route segment 3 compared to alternative M segment 3 is 

presented in table 3.4.1-3. 

TABLE 3.4.1-3 

Comparison of Proposed Route Segment 3 to Alternative M Segment 3

Factor

Proposed

Route

Alternative

Route

Difference

(if Applicable)a

Length of Corresponding Segments (miles) 15.7 18.0 2.3

Type of Right-of-Way 

Length Adjacent to Existing Utility Right-of-Way (electric/pipeline) 

(miles)

0.0 0.0 0.0

Length Adjacent to Existing Roadways Paralleling and within an 

Existing Right-of-Way or Easement (miles)

0.0 0.0 0.0

Length Adjacent to Existing Roadway Paralleling and Abutting an 

Existing Right-of-Way or Easement (miles)

0.0 0.1 0.0

Length Adjacent to Existing Roadways Paralleling an Existing Rightof-Way or Easement within 300 feet (miles)0.5 6.3 5.9

Right-of-Way Requirements

Pipeline Construction Requirements (acres) 208.9 239.6 30.7

Pipeline Operation Requirements (acres) 95.0 108.9 13.9

Wetlands

Total Wetland Complexes Crossed (number) 5 1 -4

Total Wetland Crossed (linear feet) 1,074 350 -724

Total Wetland Impacts (construction/operation) (acres) 1.8/1.2 0.6/0.4 -0.2/-0.8

Palustrine Forest Wetland Complexes Crossed 

(construction/operation) (acres)

0.3/0.2 0.6/0.4 0.3/0.2

Palustrine Scrub-Shrub Wetland Complexes Crossed 

(construction/operation) (acres)

0.2/0.1 0.0/0.0 -0.2/-0.1

Palustrine Emergent Wetland Impacts (construction/operation) 

(acres)

1.4/1.0 0.0/0.0 -1.4/-1.0

Waterbodies

Waterbodies Crossed (number) 11 17 6

Major River Crossings (number greater than 100 feet) 0 0 0

Streams with Drinking Water Use Designation (number) 0 0 0
3-37 Alternatives

TABLE 3.4.1-3 (continued)

Comparison of Proposed Route Segment 3 to Alternative M Segment 3

Factor

Proposed

Route

Alternative

Route

Difference

(if Applicable)a

Cultural Resources

National Historic Landmarks (number) 0 0 0

National Register of Historic Places Eligible or Potentially Eligible 

Cultural Resources Sites Crossed (number)

0 0 0

Land Use

Forested Land Crossed (miles) 11.6 14.5 2.9

Forested Land Impacts (construction/operation) (acres) 154.9/70.4 193.6/88.0 38.7/17.6

Forest Edge Crossed (miles) 5.0 11.0 6.1

Forested Edge Impacts (construction/operation) (acres) 66.5/30.2 147.2/66.9 80.7/36.7

Forest Interior Crossed (miles) 6.6 3.5 -3.2

Forested Interior Impacts (construction/operation) (acres) 80.4/40.2 42.2/21.1 -38.2/-19.1

Important Bird Area Crossed (miles) 0.0 0.0 0.0

Audubon Forest Blocks of Importance (miles) 0.0 0.0 0.0

Agricultural Land Crossed (miles) 3.3 1.5 -1.8

Agricultural Land Impacts (construction/operation) (acres) 44.0/20.0 19.6/8.9 -24.4/-11.1

Landfills, Quarries, Material Storage and Processing (number) 0 0 0

Property Owners

Property Owners Affected (number of parcels crossed) 78 88 10

Residences Located within 50 feet of the Pipe Centerline (number) 0 0 0

Residences Located within 125 feet (number) 0 0 0

Residences Located within 250 feet (number) 7 14 7

Federal and State Land

Federal Lands Crossed (number/miles) 0/0.0 0/0.0 0/0.0

State Forest/Parks (number/miles) 0/0.0 0/0.0 0/0.0

Trails

Trails (number) 0 0 0

Other Physical Features

Road Crossings (number) 13 12 -1

Railroads Crossed (number) 0 0 0

Other Environmental Features

Shallow Depth to Bedrock Crossed (miles) 5.9 4.7 -1.3

Steep Slopes Crossed (30 degrees or greater) (miles) 0.4 2.3 2.0

Side Slope Construction (miles) 0.2 6.5 6.4

Environmental Hazards and/or Concerns (within 0.5 mile) (number) 0 13 13

Landslides / Unstable Lands Crossed (miles) 0.0 0.0 0.0

___________________

a Totals may not sum correctly due to rounding
Alternatives 3-38

Many of the routing factors considered above are similar between the two alternatives. Although 

alternative M segment 3 is collocated with the I-88 corridor or other existing corridors for 6.4 miles, the 

proposed route is 2.3 miles shorter overall. Alternative M segment 3 crosses fewer wetlands, forest 

interiors, and shallow bedrock areas. However, the proposed route segment 3 crosses fewer waterbodies, 

forested wetlands, forested lands overall, property owners, and side slopes. Therefore, we do not consider 

adoption of alternative M segment 3 to be preferable to the proposed pipeline. 

Proposed Route Segment 5/6 Compared to Alternative M Segment 5/6

Alternative M segment 5/6 diverges from the proposed route at MP 77.4 in Delaware County, 

New York, and re-connects with the proposed route at MP 121.3. Alternative M segment 5/6 is 

collocated for about 27 miles but diverges from I-88 to avoid side slopes and the Town of Richmondville, 

New York. The collocation could be increased with a potential crossing of I-88 and then proceeding 

generally along the northern side of the roadway but this was not considered practical due to the presence 

of the Towns of Maryland, Schenevus, and Worcester, New York. However, alternative M segment 5/6 

crosses under I-88 near the Town of Bramanville, New York and then proceeds along the northern side of 

the I-88 corridor for approximately 7 miles before crossing back under I-88 and re-connecting with the 

proposed route. A comparison of the environmental and other routing considerations associated with 

proposed route segment 5/6 compared to alternative M segment 5/6 is presented in table 3.4.1-4. 

TABLE 3.4.1-4 

Comparison of Proposed Route Segment 5/6 to Alternative M Segment 5/6

Factor

Proposed

Route

Alternative

Route

Difference

(if Applicable)a

Length of Corresponding Segments (miles) 43.9 47.5 3.6

Type of Right-of-Way 

Length Adjacent to Existing Utility Right-of-Way (electric/pipeline) 

(miles)

0.0 0.0 0.0

Length Adjacent to Existing Roadways Paralleling and within an 

Existing Right-of-Way or Easement (miles)

0.0 0.0 0.0

Length Adjacent to Existing Roadway Paralleling and Abutting an 

Existing Right-of-Way or Easement (miles)

0.1 0.3 0.2

Length Adjacent to Existing Roadways Paralleling an Existing Rightof-Way or Easement within 300 feet (miles)2.2 26.7 24.5

Right-of-Way Requirements

Pipeline Construction Requirements (acres) 585.5 633.9 48.4

Pipeline Operation Requirements (acres) 266.1 288.1 22.0

Wetlands

Total Wetland Complexes Crossed (number) 8 6 -2

Total Wetland Crossed (linear feet) 2,272 2,281 9

Total Wetland Impacts (construction/operation) (acres) 3.9/2.6 3.9/2.6 0.0/0.0

Palustrine Forest Wetland Complexes Crossed 

(construction/operation) (acres)

0.4/0.2 3.1/2.1 2.7/1.8

Palustrine Scrub-Shrub Wetland Complexes Crossed 

(construction/operation) (acres)

1.3/0.8 0.4/0.3 -0.8/-0.6

Palustrine Emergent Wetland Impacts (construction/operation) 

(acres)

2.3/1.5 0.4/0.3 -1.9/-1.3
3-39 Alternatives

TABLE 3.4.1-4 (continued)

Comparison of Proposed Route Segment 5/6 to Alternative M Segment 5/6

Factor

Proposed

Route

Alternative

Route

Difference

(if Applicable)a

Waterbodies

Waterbodies Crossed (number) 35 45 10

Major River Crossings (number greater than 100 feet) 1 2 1

Streams with Drinking Water Use Designation (number) 0 5 5

Cultural Resources

National Historic Landmarks (number) 0 0 0

National Register of Historic Places Eligible or Potentially Eligible 

Cultural Resources Sites Crossed (number)

0 0 0

Land Use

Forested Land Crossed (miles) 29.2 29.7 0.5

Forested Land Impacts (construction/operation) (acres) 389.5/177.0 395.9/179.9 6.4/2.9

Forest Edge Crossed (miles) 13.7 25.8 12.1

Forested Edge Impacts (construction/operation) (acres) 182.3/82.9 343.3/156.1 161.1/73.2

Forest Interior Crossed (miles) 15.5 3.9 -11.6

Forested Interior Impacts (construction/operation) (acres) 188.4/94.2 47.8/23.9 -140.6/-70.3

Important Bird Area Crossed (miles) 0.0 0.0 0.0

Audubon Forest Blocks of Importance (miles) 2.4 0.0 2.4

Agricultural Land Crossed (miles) 10.4 6.5 -3.9

Agricultural Land Impacts (construction/operation) (acres) 157.1/62.9 98.5/39.4 -58.6/-23.5

Landfills, Quarries, Material Storage and Processing (number) 3 1 -2

Property Owners

Property Owners Affected (number of parcels crossed) 253 140 -113

Residences Located within 50 feet of the Pipe Centerline (number) 0 2 2

Residences Located within 125 feet (number) 1 12 11

Residences Located within 250 feet (number) 18 56 38

Federal and State land

Federal Lands Crossed (number/miles) 0/0.0 0/0.0 0/0.0

State Forest/Parks (number/miles) 1/0.1 0/0.0 -1/-0.1

Trails

Trails (number) 1 0 -1

Other Physical Features

Road Crossings (number) 43 42 -1

Railroads Crossed (number) 0 0 0

Other Environmental Features

Shallow Depth to Bedrock Crossed (miles) 19.5 7.6 -11.9

Steep Slopes Crossed (30 degrees or greater) (miles) 3.6 10.1 6.6

Side Slope Construction (miles) 0.8 2.7 1.9
Alternatives 3-40

TABLE 3.4.1-4 (continued)

Comparison of Proposed Route Segment 5/6 to Alternative M Segment 5/6

Factor

Proposed

Route

Alternative

Route

Difference

(if Applicable)a

Environmental Hazards and/or Concerns (within 0.5 mile) (number) 1 6 5

___________________

a Totals may not sum correctly due to rounding

Many of the routing factors considered above are similar between the two alternatives. Although 

alternative M segment 5/6 is collocated with the I-88 corridor or other existing corridors for 

approximately 27 miles, the proposed route segment is 3.6 miles shorter overall. Alternative M segment 

5/6 also crosses fewer forest interiors, Audubon-designated forest blocks of importance, property owners, 

and shallow bedrock areas. However, the proposed route segment 5/6 crosses fewer waterbodies, forested 

wetlands, and much fewer nearby residences and steep side slopes. Therefore, we do not consider 

adoption of alternative M segment 5/6 to be preferable to the proposed pipeline. 

Proposed Route Segment 5/6 Compared to Alternative M Segment 5, Bridge 1, Proposed Route 

Segment 6

This section describes the comparative analysis of incorporating alternative M segment 5 into the 

project without alternative M segment 6. Because the division of these two segments is about 2 miles 

from the proposed route, a “bridge” was developed to connect the routes in a more direct fashion. This 

was therefore termed alternative M segment 5, bridge 1, proposed route segment 6. It diverges from the 

proposed route at MP 77.4 in Delaware County, New York and re-connects with the proposed route at 

MP 121.3. A comparison of the environmental and other routing considerations associated with proposed 

route segment 5/6 compared to alternative M segment 5, bridge 1, proposed route segment 6 is presented 

in table 3.4.1-5. Note that both routes being compared include segment 6 of the proposed route due to the 

location of the bridge.

TABLE 3.4.1-5

Comparison of Proposed Route to Alternative Route M Segment 5, Bridge 1, Proposed Route Segment 6

Factor

Proposed

Route

Alternative

Route

Difference

(if Applicable)a

Length of Corresponding Segments (miles) 43.9 48.0 4.1

Type of Right-of-Way 

Length Adjacent to Existing Utility Right-of-Way (electric/pipeline) 

(miles) 0.0 3.9 3.9

Length Adjacent to Existing Roadways Paralleling and within an 

Existing Right-of-Way or Easement (miles) 0.0 0.0 0.0

Length Adjacent to Existing Roadway paralleling and abutting an 

existing Right-of-Way or easement (miles) 0.1 0.3 0.2

Length Adjacent to Existing Roadways paralleling an existing Rightof-Way or easement within 300 feet (miles) 2.2 14.9 12.7

Right-of-Way Requirements

Pipeline Construction Requirements (acres) 585.5 639.6 54.1

Pipeline Operation Requirements (acres) 266.1 290.7 24.6
3-41 Alternatives

TABLE 3.4.1-5 (continued)

Comparison of Proposed Route to Alternative Route M Segment 5, Bridge 1, Proposed Route Segment 6

Factor

Proposed

Route

Alternative

Route

Difference

(if Applicable)a

Wetlands

Total Wetland Complexes Crossed (number) 8 7 -1

Total Wetland Crossed (linear feet) 2,272 2,377 105

Total Wetland Impacts (construction/operation) (acres) 3.9/2.6 4.1/2.7 0.2/0.1

Palustrine Forest Wetland Complexes Crossed 

(construction/operation) (acres) 0.4/0.2 3.1/2.1 2.8/1.8

Palustrine Scrub-Shrub Wetland Complexes Crossed 

(construction/operation) (acres) 1.3/0.8 0.4/0.3 -0.9/-0.6

Palustrine Emergent Wetland Impacts (construction/operation) 

(acres) 2.3/1.5 0.6/0.4 -1.7/-1.2

Waterbodies

Waterbodies Crossed (number) 35 40 5

Major River Crossings (number >100 feet) 1 2 1

Streams with Drinking Water Use Designation (number) 0 0 0

Cultural Resources

National Historic Landmarks (number) 0 0 0

National Register of Historic Places Eligible or Potentially Eligible 

Cultural Resources Sites crossed (Number) 0 0 0

Land Use

Forested Land Crossed (miles) 29.2 33.9 4.7

Forested Land Impacts (construction/operation) (acres) 389.5/177.0 451.6/205.3 62.1/28.2

Forest Edge Crossed (miles) 13.7 25.1 11.4

Forested Edge Impacts (construction/operation) (acres) 182.3/82.9 334.7/152.1 152.1/69.3

Forest Interior Crossed (miles) 15.5 8.8 -6.8

Forested Interior Impacts (construction/operation) (acres) 188.4/94.2 106.3/53.2 -82.1/-41.0

Important Bird Area Crossed (miles) 0 0 0

Audubon Forest Blocks of Importance (miles) 2.4 0 -2.4

Agricultural Land Crossed (miles) 10.4 8.8 -1.5

Agricultural Land Impacts (construction/operation) (acres) 159.1/63.7 132.4/53.0 -26.7/-10.7

Landfills, Quarries, Material Storage and processing (number) 3 1 -2

Property Owners

Property Owners Affected (number of parcels crossed) 253 167 -86

Residences located within 50 feet of the pipe Centerline (number) 0 2 2

Residences located within 125 feet (number) 1 6 5

Residences located within 250 feet (number) 18 34 16

Federal & State Land

Federal Lands Crossed (number/miles) 0/0.0 0/0.0 0/0.0

State Forest/Parks (number/miles) 1/0.1 0/0.0 -1/-0.1

Trails

Trails (number) 0 1 1
Alternatives 3-42

TABLE 3.4.1-5 (continued)

Comparison of Proposed Route to Alternative Route M Segment 5, Bridge 1, Proposed Route Segment 6

Factor

Proposed

Route

Alternative

Route

Difference

(if Applicable)a

Other Physical Features

Road Crossings (number) 43 38 -5

Railroads Crossed (number) 0 0 0

Other Environmental Features

Shallow Depth to Bedrock Crossed (miles) 19.5 13.8 -5.7

Steep Slopes Crossed (30 degrees or greater) (miles) 3.6 10.5 6.9

Side Slope Construction (miles) 0.8 5.4 4.6

Environmental Hazards and/or Concerns (within 0.5 mile) (number) 1 1 0

Landslides / Unstable lands crossed (Length) 0.0 0.0 0.0

___________________

a Totals may not sum correctly due to rounding

Many of the routing factors considered above are similar between the two alternatives. Although 

alternative M segment 5 to bridge 1 to proposed route segment 6 is collocated with the I-88 corridor or 

other existing corridors for approximately 19 miles, the corresponding segment of the proposed route is

4.1 miles shorter overall. Alternative M segment 5 to bridge 1 to proposed route segment 6 also would 

cross fewer forest interiors, property owners, and shallow bedrock areas. However, the proposed route 

segment 5/6 crosses fewer forested wetlands, (and less forested land overall), nearby residences, and side 

slopes. Therefore, we do not consider adoption of alternative M segment 5, bridge 1, proposed route 

segment 6 to be preferable to the proposed pipeline route (proposed route segments 5/6). 

Proposed Route Segment 5/6 Compared to Proposed Route Segment 5, Bridge 2, Alternative M 

Segment 6

Similar to the discussion of preceding section, here we discuss the comparative analysis of 

incorporating alternative M segment 6 into the project without alternative M segment 5. Because the 

division of these two segments is about 2 miles from the proposed route, a “bridge” was developed to 

connect the routes in a more direct fashion. This was therefore termed proposed route segment 5, bridge 

2, alternative M segment 6. This segment diverges from the proposed route at MP 77.4 in Delaware 

County, New York, and re-connects with the proposed route at MP 121.3 in Schoharie County, New 

York. A comparison of the environmental and other routing considerations associated with proposed 

route segment 5/6 compared to proposed route segment 5, bridge 2, alternative M segment 6 is presented 

in table 3.4.1-6. 
3-43 Alternatives

TABLE 3.4.1-6 

Comparison of Proposed Route to Proposed Route Segment 5, Bridge 2, Alternative Route M Segment 6

Factor

Proposed

Route

Alternative

Route

Difference

(if Applicable)a

Length of Corresponding Segments (miles) 43.9 44.2 0.3

Type of Right-of-Way 

Length Adjacent to Existing Utility Right-of-Way (electric/pipeline) 

(miles)

0.0 0.0 0.0

Length Adjacent to Existing Roadways Paralleling and within an 

Existing Right-of-Way or Easement (miles)

0.0 0.0 0.0

Length Adjacent to Existing Roadway Paralleling and Abutting an 

Existing Right-of-Way or Easement (miles)

0.1 0.2 0.0

Length Adjacent to Existing Roadways Paralleling an Existing Rightof-Way or Easement within 300 feet (miles)2.2 13.5 11.3

Right-of-Way Requirements

Pipeline Construction Requirements (acres) 585.5 589.9 4.4

Pipeline Operation Requirements (acres) 266.1 268.1 2.0

Wetlands

Total Wetland Complexes Crossed (number) 8 5 -3

Total Wetland Crossed (linear feet) 2,272 2,181 -91

Total Wetland Impacts (construction/operation) (acres) 3.9/2.6 3.8/2.5 -0.2/-0.1

Palustrine Forest Wetland Complexes Crossed 

(construction/operation) (acres)

0.4/0.2 0.4/0.2 0.0/-0.1

Palustrine Scrub-Shrub Wetland Complexes Crossed 

(construction/operation) (acres)

1.3/0.8 1.4/1.0 0.2/0.1

Palustrine Emergent Wetland Impacts (construction/operation) 

(acres)

2.3/1.5 2.0/1.3 --0.3/-0.2

Waterbodies

Waterbodies Crossed (number) 35 42 7

Major River Crossings (number greater than 100 feet) 1 1 0

Streams with Drinking Water Use Designation (number) 0 3 3

Cultural Resources

National Historic Landmarks (number) 0 0 0

National Register of Historic Places Eligible or Potentially Eligible 

Cultural Resources Sites Crossed (number)

0 0 0

Land Use

Forested Land Crossed (miles) 29.2 24.3 -4.9

Forested Land Impacts (construction/operation) (acres) 389.5/177.0 323.6/147.1 -65.9/-29.9

Forest Edge Crossed (miles) 13.7 13.7 0.0

Forested Edge Impacts (construction/operation) (acres) 182.3/82.9 182.1/82.8 -0.1/-0.1

Forest Interior Crossed (miles) 15.5 10.6 -4.9

Forested Interior Impacts (construction/operation) (acres) 188.4/94.2 128.6/64.3 -59.8/-29.9

Important Bird Area Crossed (miles) 0.0 0.0 0.0

Audubon Forest Blocks of Importance (miles) 2.4 2.4 0.0

Agricultural Land Crossed (miles) 10.4 9.5 -0.8
Alternatives 3-44

TABLE 3.4.1-6 (continued)

Comparison of Proposed Route to Proposed Route Segment 5, Bridge 2, Alternative Route M Segment 6

Factor

Proposed

Route

Alternative

Route

Difference

(if Applicable)a

Agricultural Land Impacts (construction/operation) (acres) 157.1/62.8 144.4/57.8 -12.7/-5.1

Landfills, Quarries, Material Storage and Processing (number) 3 1 -2

Property Owners

Property Owners Affected (number of parcels crossed) 253 220 -33

Residences Located within 50 feet of the Pipe Centerline (number) 0 0 0

Residences Located within 125 feet (number) 1 7 6

Residences Located within 250 feet (number) 18 39 21

Federal and State Land

Federal Lands Crossed (number/miles) 0/0.0 0/0.0 0/0.0

State Forest/Parks (number/miles) 1/0.1 1/0.1 0/0.0

Trails

Trails (number) 1 1 0

Other Physical Features

Road Crossings (number) 44 49 5

Railroads Crossed (number) 0 0 0

Other Environmental Features

Shallow Depth to Bedrock Crossed (miles) 19.5 13.8 -5.7

Steep Slopes Crossed (30 degrees or greater) (miles) 3.6 2.3 -1.3

Side Slope Construction (miles) 0.8 3.6 2.8

Environmental Hazards and/or Concerns (within 0.5 mile) (number) 1 6 5

Landslides / Unstable Lands Crossed (miles) 0.0 0.0 0.0

___________________

a Totals may not sum correctly due to rounding

Many of the routing factors considered above are similar between the two alternatives. Although 

proposed route segment 5, bridge 2, alternative M segment 6 is collocated with the I-88 corridor or other 

existing corridors for approximately 14 miles, the proposed route segment is 0.3 mile shorter overall. 

Proposed route segment 5, bridge 2, alternative M segment 6 crosses less forested land overall, and fewer

forest interiors, property owners, and shallow bedrock areas. However, the proposed route segment 5/6 

crosses fewer waterbodies, nearby residences, and side slopes. Therefore, we do not consider adoption of 

proposed route segment 5, bridge 2, alternative M segment 6 to be preferable to the proposed pipeline 

route. 

3.4.2 Minor Route Alternatives

Although they can extend for several miles, minor route alternatives deviate from the proposed 

route less substantially than major route alternatives. Minor route alternatives are often designed to avoid 

large environmental resources or engineering constraints, and typically remain within the same general 

area as the proposed route.
3-45 Alternatives

3.4.2.1 Minor Route Alternatives Adopted into the Proposed Route 

Based on consultations with landowners, resource agencies, municipal governments, field review, 

and impact assessment, Constitution fully incorporated nine minor route alternatives and partially 

incorporated two additional minor route alternatives into the proposed route during the pre-filing and 

post-filing review stages of its project. As such, they are now part of the proposed action and are 

included in our impacts assessment in section 4.0. These changes were adopted primarily to increase 

collocation, avoid or minimize impacts on natural resources, reduce or eliminate safety and 

constructability concerns, and/or avoid or minimize conflicts with existing or proposed residential land 

uses. Minor route alternatives adopted into the proposed pipeline route are described in table 3.4.2-1 and 

depicted in figure 3.4.2-1. 

TABLE 3.4.2-1 

Minor Route Alternatives Adopted into the Proposed Pipeline Route

Alternative

Start 

Milepost

End 

Milepost

County, 

State

Adopted/ 

Partially 

Adopted Description

Alternative A 0.0 9.8 Susquehanna 

County, PA

Adopted The original route (A1) was designed to 

increase collocation with utility rights-ofway. However, alternative A was 

adopted to reduce impacts on wetlands, 

waterbodies, and property owners

compared to route A1. Alternative T was 

subsequently adopted into alternative A 

(see below). 

Alternative T Sub-Part of 

alternative A

Sub-Part of 

alternative A

Susquehanna 

County, PA 

Adopted Alternative T was adopted in association 

with alternative A (see above) at the 

crossing of Martins Creek adjacent to 

State Route 11 to avoid steep slope

construction, thereby resolving an issue 

with Alternative A. 

Brushville Road 

Minimization 

Route

11.6 14.1 Susquehanna 

County, PA

Adopted The Brushville Road Minimization Route 

alternative was adopted to avoid a 

sensitive palustrine forested wetland 

hemlock forest and rare plants compared 

to the original route in this area 

(Brushville Road Route 1). This routing

also fulfills landowner requests to move 

the proposed pipeline away from 

residences and toward the rear property 

boundaries. This route results in 

reduced impacts on wetlands and 

waterbodies compared to alternative 

Brushville Road Route 1. 

Alternative S 18.8 23.6 Susquehanna 

County, PA 

Adopted Alternative S was adopted based upon 

the results of geotechnical analysis and 

field surveys to avoid potential landslide 

areas along a hillside north of Starrucca 

Creek. It also allows for safer 

construction, operation and maintenance 

of the pipeline compared to alternative 

S1. Although alternative S would 

increase impacts on forested lands, 

waterbodies, and property owners, it is

still preferable to routing through the 

landslide area for constructability, longterm pipeline integrity, and safety 

reasons. 
Alternatives 3-46

TABLE 3.4.2-1 (continued)

Minor Route Alternatives Adopted into the Proposed Pipeline Route

Alternative

Start 

Milepost

End 

Milepost

County, 

State

Adopted/ 

Partially 

Adopted Description

Alternative B 25.2 44.7 Susquehanna 

County, PA, 

Broome and 

Chenango 

Counties, NY

Adopted Alternative B was adopted to increase 

collocation with existing utility corridors, 

thereby reducing impacts on forested 

lands, including interior forest compared 

to Alternative B2. It also avoids springs 

used as potable water supply for the 

town of Afton in Chenango County, NY. 

Although this route is slightly longer and 

would increase impacts on waterbodies

compared to route B2, it is still preferable 

for the favorable reasons identified 

above.

Melondy Hill 

State Forest 

Minimization 

Route

41.5 44.7 Broome and 

Chenango 

Counties, NY 

Adopted The Melondy Hill State Forest 

Minimization route was adopted into the 

proposed project route, and minimizes 

impacts by being shorter overall, 

reducing impacts on forested lands, 

forested wetlands, having fewer side 

slopes, and limiting the crossing length to 

0.1 mile within the Melondy Hill State 

Forest compared to the Melondy Hill 

State Forest Avoidance Reroute (see 

below). 

A route that would avoid Melondy Hill 

State Forest completely was also 

evaluated; however, that route would 

have been longer, and had more side 

slopes, forest impacts, and wetland 

crossings. 

Clapper Hollow 

State Forest 

Minimization 

Route

96.9 97.4 Schoharie 

County, NY 

Adopted The Clapper Hollow State Forest 

Minimization Route was adopted to 

reduce the crossing length of the state 

forest from the originally considered

route. The current proposed route limits

the crossing of Clapper Hollow State 

Forest to approximately 411 feet.

A route that completely avoids Clapper 

Hollow State Forest was also evaluated

(Clapper Hollow State Forest Avoidance 

Reroute); however, that route crosses an 

existing spring-fed trout pond that was 

the subject of landowner concern. 

Alternative R 105.0 116.8 Schoharie 

County, NY 

Adopted Alternative R was adopted in response to 

comments from the town of 

Richmondville, NY to reduce the number 

of affected landowners, minimize 

crossing of agricultural land, and move 

the route away from the Cobleskill 

Reservoir to the maximum extent 

possible. This route is shorter and 

substantially reduces the number of 

waterbody crossings compared to 

Alternative R1. Although alternative R 

would increase impacts on forested 

lands, including forest interiors, it is

preferable for the favorable reasons 

identified above. Alternative R 

incorporates components of alternatives 

L and O (see below). 
3-47 Alternatives

TABLE 3.4.2-1 (continued)

Minor Route Alternatives Adopted into the Proposed Pipeline Route

Alternative

Start 

Milepost

End 

Milepost

County, 

State

Adopted/ 

Partially 

Adopted Description

Alternative L Part of 

alternative R

Part of 

alternative R

Schoharie 

County, NY 

Partially 

Adopted

A portion of alternative L was adopted in 

association with alternative R (see 

above) to minimize crossing of 

agricultural land (compared to the 

original route of Alternative R) at the 

request of the Schoharie County 

Planning Commission. By adopting 

alternative R, portions of alternative L are 

no longer connected to the proposed 

project route and were therefore not 

adopted. 

Alternative O Part of 

alternative R

Part of 

alternative R

Schoharie 

County, NY 

Partially 

Adopted

A 5.4 mile portion of alternative O was 

adopted in association with alternative R 

(see above) to move the pipeline away 

from the Cobleskill Reservoirs to the 

maximum extent possible (compared to 

the original route of Alternative R) at the 

request of the Town of Cobleskill. 

Alternative Q 116.6 124.1 Schoharie 

County, NY 

Adopted Alternative Q was adopted to collocate 

with the existing TGP right-of-way, to 

minimize potential impacts on Schoharie 

Creek, and to decrease potential impacts 

on the Barton Hill watershed compared 

to Alternative Q1. Although this segment 

is longer and would affect more forested 

land overall, forest interior, and property 

owners compared to Alternative Q1, it 

would reduce impacts on waterbodies 

and nearby residences. 
WRIGHT

COMPRESSOR

STATION

ALTERNATIVE Q1

ALTERNATIVE R1 (L1, O1)

ALTERNATIVE A-T (ADOPTED)

Chenango 

County

BRUSHVILLE ROAD

MINIMIZATION ROUTE

(ADOPTED)

ALTERNATIVE B2

ALTERNATIVE S1

ALTERNATIVE A1 (T1) BRUSHVILLE ROAD 1

ALTERNATIVE S (ADOPTED)

ALTERNATIVE B

(ADOPTED)

ALTERNATIVE R-L-O

(ADOPTED)

ALTERNATIVE Q (ADOPTED)

Cortland

County

Broome

County

Chenango

County

Otsego

County

Albany

County

Greene

County

Schoharie

County

Delaware

County

Sullivan

County

Susquehanna County

Wayne

County

Ulster

County

Brushville Road 1

Clapper Hollow State Forest

Avoidance Reroute

Melondy Hill State Forest

Avoidance Reroute

Alternative A1 (T)

Alternative B2

Alternative Q1

Alternative R1 (L, O)

Alternative S1

p

0 5 10 15 20

Miles

Figure 3.4.2-1

Constitution Pipeline Project

Adopted Minor Route Alternatives and Corresponding Non-adopted Segments

NEW YORK

PENNSYLVANIA

NJ

MA

MD

CT

NH

VA

VT

DE

RI

Proposed Constitution Pipeline Route

Susquehanna Supply Area

Melondy 

Hill State

Forest

MHSF

AVOIDANCE

ROUTE

MHSF

MINIMIZATION

ROUTE

MELONDY HILL STATE FOREST 

AVOIDANCE/MINIMIZATION ROUTE

Clapper Hollow

State Forest

CHSF

AVOIDANCE

ROUTE

CHSF

MINIMIZATION

ROUTE

CLAPPER HOLLOW STATE FOREST 

AVOIDANCE/MINIMIZATION ROUTE

3-48
3-49 Alternatives

3.4.2.2 Minor Route Alternatives Not Adopted into the Proposed Route

We evaluated five additional alternatives based on review of environmental and other routing 

factors. Minor route alternatives, alternatives C, D, E1, G, and P are discussed below and comparative 

analyses relative to the proposed route are provided. These alternatives are depicted in figure 3.4.2-2. 

Alternatives C and D

Alternative C begins at MP 90.3 in Delaware County, New York and extends 38.2 miles into 

Schoharie County, New York, terminating at the proposed Westfall Road M&R Station. Constitution 

identified alternative C in an effort to increase collocation with existing utility rights-of-way, to avoid 

crossing several landowner tracts, and to locate the pipeline predominantly agricultural land within the 

Schoharie Creek floodplain. A comparison of the environmental and other routing considerations 

associated with alternative C to the proposed route is presented in table 3.4.2-2. 

Alternative D is a sub-alternative of alternative C, and was developed to avoid the floodplain 

valley along Schoharie Creek. Alternative D would minimize construction and operational concerns 

associated with siting the pipeline along Schoharie Creek. Alternative D is 1.3 miles west of Schoharie 

Creek, parallels the boundary of the Burnt-Rossman State Forest, and crosses mountain ridges before 

connecting back to alternative C.

Elected representatives in Schoharie County expressed interest in avoiding impacts on ridgelines 

for aesthetic reasons, as well as concerns about routing the pipeline through agricultural areas. 

Alternative C involves seven crossings of Schoharie Creek (a major waterbody); workspace constraints at 

many of these crossing locations would limit Constitution’s ability to implement HDDs. Because 

Schoharie Creek is subject to flash flooding, safe construction, operation, and maintenance of the pipeline 

within the floodplain would be of concern. Also, alternative C crosses a portion of Burt-Rossman Hills 

State Reforestation Area (where it would be adjacent to an existing utility right-of-way). Adoption of 

alternative D into alternative C would decrease impacts on agricultural lands, but would increase impacts 

on forested habitat and crossings of land with shallow depth to bedrock. 

Therefore, inclusion of alternative D into alternative C is not preferable due to the increase in 

forested impacts and amount of shallow bedrock crossed. Compared to the proposed route, alternative C 

is approximately 4 miles longer, crosses Schoharie Creek six more times, and would have increased 

impacts on wetlands, forested wetlands, waterbodies, property owners, and nearby residences. Therefore, 

we do not consider adoption of alternative C (or D) to be preferable to the proposed project. 
WRIGHT

COMPRESSOR

STATION

ALTERNATIVE C (D)

ALTERNATIVE E1

ALTERNATIVE G

ALTERNATIVE P

Chenango

County

SUSQUEHANNA 

SUPPLY AREA

Cortland

County

Broome

County

Chenango

County

Otsego

County

Albany

County

Greene

County

Schoharie

County

Delaware

County

Sullivan

County

Susquehanna

County

Wayne

County

Ulster

County

Alternative C (D)

Alternative E1

Alternative G

Alternative P

p

0 5 10 15 20

Miles

Figure 3.4.2-2

Constitution Pipeline Project

Minor Route Alternatives Not Adopted

NEW YORK

PENNSYLVANIA

NJ

MA

MD

CT

NH

VA

VT

DE

RI

Proposed Project Route with Adopted

Alternatives

Susquehanna Supply Area

3-50
3-51 Alternatives

TABLE 3.4.2-2

Comparison of the Proposed Pipeline Route to Alternative C (and D)

Factor

Proposed

Route

Alternative

Route

Difference 

(if Applicable)a

Length of Corresponding Segments (miles) 34.2 38.2 4.0

Type of Right-of-Way 

Length Adjacent to Existing Utility Right-of-Way (electric/pipeline) 

(miles)

1.0 12.8 11.8

Length Adjacent to Existing Roadways Paralleling and within an 

Existing Right-of-Way or Easement (miles)

0.0 0.0 0.0

Length Adjacent to Existing Roadway Paralleling and Abutting an 

Existing Right-of-Way or Easement (miles)

0.1 0.1 -0.1

Length Adjacent to Existing Roadways Paralleling an Existing Rightof-Way or Easement within 300 feet (miles)2.2 1.9 -0.3

Right-of-Way Requirements

Pipeline Construction Requirements (acres) 455.9 509.3 53.5

Pipeline Operation Requirements (acres) 207.2 231.5 24.3

Wetlands

Total Wetland Complexes Crossed (number) 4 16 12

Total Wetland Crossed (linear feet) 925 4,822 3,897

Total Wetland Impacts (construction/operation) (acres) 1.6/1.1 8.3/5.5 6.7/4.5

Palustrine Forest Wetland Complexes Crossed 

(construction/operation) (acres)

0.0/0.0 3.3/2.2 3.3/2.2

Palustrine Scrub-Shrub Wetland Complexes Crossed 

(construction/operation) (acres)

1.2/0.8 0.9/0.6 -0.3/-0.2

Palustrine Emergent Wetland Impacts (construction/operation) 

(acres)

0.4/0.3 4.1/2.7 3.7/2.5

Waterbodies

Waterbodies Crossed (number) 23 35 12

Major River Crossings (number greater than 100 feet) 0 7 7

Streams with Drinking Water Use Designation (number) 0 0 0

Cultural Resources

National Historic Landmarks (number) 0 0 0

Number of National Register of Historic Places Eligible or Potentially 

Eligible Cultural Resources Sites Crossed (number) 0 2 2

Land Use

Forested Land Crossed (miles) 20.8 16.9 -3.9

Forested Land Impacts (construction/operation) (acres) 277.3/126.1 225.6/102.6 -51.7/-23.5

Forest Edge Crossed (miles) 9.7 16.0 6.3

Forested Edge Impacts (construction/operation) (acres) 129.6/58.9 213.7/97.2 84.1/38.2

Forest Interior Crossed (miles) 11.1 0.9 10.2

Forested Interior Impacts (construction/operation) (acres) 134.3/67.2 10.8/5.4 -123.5/-61.8

Important Bird Area Crossed (miles) 0 0 0

Audubon Forest Blocks of Importance (miles) 2.4 4.4 1.9
Alternatives 3-52

TABLE 3.4.2-2 (continued)

Comparison of the Proposed Pipeline Route to Alternative C (and D)

Factor

Proposed

Route

Alternative

Route

Difference 

(if Applicable)a

Agricultural Land Crossed (miles) 10.1 17.0 6.9

Agricultural Land Impacts (construction/operation) (acres) 153.0/61.2 257.1/102.9 104.1/41.6

Landfills, Quarries, Material Storage and Processing (number) 3 0 -3

Property Owners

Property Owners Affected (number of parcels crossed) 191 207 16

Residences Located within 50 feet of the Pipe Centerline (number) 0 0 0

Residences Located within 125 feet (number) 0 5 5

Residences Located within 250 feet (number) 18 36 18

Federal and State Land

Federal Lands Crossed (number/miles) 0 0 0

State Forest/Parks (number/miles) 1/0.1 1/0.3 0/0.2

Trails

Trails (number) 1 0 -1

Other Physical Features

Road Crossings (number) 34 35 1

Railroads Crossed (number) 0 0 0

Other Environmental Features

Shallow Depth to Bedrock Crossed (miles) 15.2 8.2 -7.0

Steep Slopes Crossed (30 degrees or greater) (miles) 3.0 2.3 -0.8

Side Slope Construction (miles) 0.8 1.1 0.3

Environmental Hazards and/or Concerns (within 0.5 mile) (number) 1 1 0

Landslides / Unstable Lands Crossed (miles) 0.0 0.0 0.0

___________________

a Totals may not sum correctly due to rounding

Alternative E1

Alternative E was considered in response to comments from the Schoharie County Planning 

Commission regarding the potential to reduce the length of the route and to site the pipeline away from 

ridgelines. Alternative E evolved into alternative E1 based on six minor route deviations included at the 

request of landowners. Alternative E1 begins at MP 93.6 and re-connects to the proposed route at MP 

95.3. A comparison of the environmental and other routing considerations associated with alternative E1 

to the proposed route is presented in table 3.4.2-3. 
3-53 Alternatives

TABLE 3.4.2-3

Comparison of the Proposed Pipeline Route to Alternative E1

Factor

Proposed

Route

Alternative

Route

Difference

(if Applicable)a

Length of Corresponding Segments (miles) 1.7 1.7 0.0

Type of Right-of-Way 

Length Adjacent to Existing Utility Right-of-Way (electric/pipeline) 

(miles)

0.0 0.0 0.0

Length Adjacent to Existing Roadways Paralleling and within an 

Existing Right-of-Way or Easement (miles)

0.0 0.0 0.0

Length Adjacent to Existing Roadway Paralleling and Abutting an 

Existing Right-of-Way or Easement (miles)

0.0 0.1 0.0

Length Adjacent to Existing Roadways Paralleling an Existing Rightof-Way or Easement within 300 feet (miles)0.2 0.2 0.0

Right-of-Way Requirements

Pipeline Construction Requirements (acres) 23.2 23.2 0.0

Pipeline Operation Requirements (acres) 10.6 10.6 0.0

Wetlands

Total Wetland Complexes Crossed (number) 0 1 1

Total Wetland Crossed (linear feet) 0 221 221

Total Wetland Impacts (construction/operation) (acres) 0 0.4/0.3 0.4/0.3

Palustrine Forest Wetland Complexes Crossed 

(construction/operation) (acres)

0.0 0.0 0.0

Palustrine Scrub-Shrub Wetland Complexes Crossed 

(construction/operation) (acres)

0.0 0.0 0.0

Palustrine Emergent Wetland Impacts (construction/operation) 

(acres)

0 0.4/0.3 0.4/0.3

Waterbodies

Waterbodies Crossed (number) 2 2 0

Major River Crossings (number greater than 100 feet) 0 0 0

Streams with Drinking Water Use Designation (number) 0 0 0

Cultural Resources

National Historic Landmarks (number) 0 0 0

Number of National Register of Historic Places Eligible or Potentially 

Eligible Cultural Resources Sites Crossed (number)

0 0 0

Land Use

Forested Land Crossed (miles) 1.3 1.3 0.0

Forested Land Impacts (construction/operation) (acres) 17.9/8.1 17.9/8.1 0.0/0.0

Forest Edge Crossed (miles) 1.1 1.2 0.1

Forested Edge Impacts (construction/operation) (acres) 14.3/6.5 15.6/7.1 1.3/0.6

Forest Interior Crossed (miles) 0.3 0.2 -0.1

Forested Interior Impacts (construction/operation) (acres) 3.3/1.6 2.1/1.0 -1.2/-0.6

Important Bird Area Crossed (miles) 0.0 0.0 0.0

Audubon Forest Blocks of Importance (miles) 1.5 1.3 -0.2
Alternatives 3-54

TABLE 3.4.2-3 (continued)

Comparison of the Proposed Pipeline Route to Alternative E1

Factor

Proposed

Route

Alternative

Route

Difference

(if Applicable)a

Agricultural Land Crossed (miles) 0.2 0.1 -0.1

Agricultural Land Impacts (construction/operation) (acres) 2.9/1.2 1.8/0.7 -1.1/-0.4

Landfills, Quarries, Material Storage and Processing (number) 0 0 0

Property Owners

Property Owners Affected (number of parcels crossed) 15 11 -4

Residences Located within 50 feet of the Pipe Centerline (number) 0 0 0

Residences Located within 125 feet (number) 0 0 0

Residences Located within 250 feet (number) 0 2 2

Federal and State Land

Federal Lands Crossed (number/miles) 0/0.0 0/0.0 0/0.0

State Forest/Parks (number/miles) 0/0.0 0/0.0 0/0.0

Trails

Trails (number) 0 0 0

Other Physical Features

Road Crossings (number) 3 3 0

Railroads Crossed (number) 0 0 0

Other Environmental Features

Shallow Depth to Bedrock Crossed (miles) 0.4 0.5 0.1

Steep Slopes Crossed (30 degrees or greater) (miles) 0.2 0.2 0.0

Side Slope Construction (miles) 0.1 0.0 -0.1

Environmental Hazards and/or Concerns (within 0.5 mile) (number) 0 0 0

Landslides / Unstable Lands Crossed (miles) 0.0 0.0 0.0

___________________

a Totals may not sum correctly due to rounding

The proposed route and alternative E1 are about the same length and would have similar impacts 

on waterbodies, wetlands, forested land, nearby residences, and side slopes. Further, the proposed route 

was already developed to satisfy both landowner concerns and the Schoharie County Planning 

Commission’s request to move the pipeline away from ridges and into lower lying areas. For these 

reasons, we do not consider adoption of alternative E1 to be preferable to the proposed project. 

Alternative G

Alternative G was considered in response to comments from the Schoharie County Planning 

Commission and Wright Township to locate the pipeline within predominantly agricultural land in the 

Schoharie Creek floodplain and to avoid karst geology. Alternative G starts at MP 101.8 and ends at the 

proposed Westfall Road M&R Station. Alternative G follows along the ridge of Towpath Mountain and 

parallels portions of alternatives C and D. A comparison of the environmental and other routing 

considerations associated with alternative G to the proposed route is presented in table 3.4.2-4. 
3-55 Alternatives

TABLE 3.4.2-4

Comparison of the Proposed Pipeline Route to Alternative G

Factor

Proposed

Route

Alternative

Route

Difference

(if Applicable)a

Length of Corresponding Segments (miles) 22.7 25.3 2.6

Type of Right-of-Way 

Length Adjacent to Existing Utility Right-of-Way (electric/pipeline) 

(miles)

1.0 0.6 0.4

Length Adjacent to Existing Roadways Paralleling and within an 

Existing Right-of-Way or Easement (miles)

0.0 0.0 0.0

Length Adjacent to Existing Roadway Paralleling and Abutting an 

Existing Right-of-Way or Easement (miles)

0.1 0.1 0.0

Length Adjacent to Existing Roadways Paralleling an Existing Rightof-Way or Easement within 300 feet (miles)1.8 2.6 0.8

Right-of-Way Requirements

Pipeline Construction Requirements (acres) 302.4 337.3 34.9

Pipeline Operation Requirements (acres) 137.5 153.3 15.9

Wetlands

Total Wetland Complexes Crossed (number) 3 5 2

Total Wetland Crossed (linear feet) 735 2,505 1,770

Total Wetland Impacts (construction/operation) (acres) 1.3/0.8 4.3/2.9 3.0/2.0

Palustrine Forest Wetland Complexes Crossed 

(construction/operation) (acres)

0.0/0.0 1.4/1.0 1.4/1.0

Palustrine Scrub-Shrub Wetland Complexes Crossed 

(construction/operation) (acres)

0.9/0.6 1.1/0.7 0.2/0.1

Palustrine Emergent Wetland Impacts (construction/operation) 

(acres)

0.4/0.3 1.8/1.2 1.4/1.0

Waterbodies

Waterbodies Crossed (number) 13 22 9

Major River Crossings (number greater than 100 feet) 1 0 -1

Streams with Drinking Water Use Designation (number) 0 1 1

Cultural Resources

National Historic Landmarks (number) 0 0 0

Number of National Register of Historic Places Eligible or Potentially 

Eligible Cultural Resources Sites Crossed (number)

0 1 1

Land Use

Forested Land Crossed (miles) 13.4 9.7 3.7

Forested Land Impacts (construction/operation) (acres) 178.8/81.3 129.2/58.7 -49.6/-22.5

Forest Edge Crossed (miles) 6.8 8.3 1.4

Forested Edge Impacts (construction/operation) (acres) 91.1/41.4 110.0/41.4 18.9/8.6

Forest Interior Crossed (miles) 6.6 1.4 5.1

Forested Interior Impacts (construction/operation) (acres) 79.8/39.9 17.5/8.7 -62.3/-31.2

Important Bird Area Crossed (miles) 0.0 0.0 0.0

Audubon Forest Blocks of Importance (miles) 2.4 6.2 3.8
Alternatives 3-56

TABLE 3.4.2-4 (continued)

Comparison of the Proposed Pipeline Route to Alternative G

Factor

Proposed

Route

Alternative

Route

Difference

(if Applicable)a

Agricultural Land Crossed (miles) 7.6 13.4 5.8

Agricultural Land Impacts (construction/operation) (acres) 115.0/46.0 202.3/80.9 87.3/34.9

Landfills, Quarries, Material Storage and Processing (number) 2 0 -2

Property Owners

Property Owners Affected (number of parcels crossed) 110 142 32

Residences Located within 50 feet of the Pipe Centerline (number) 0 0 0

Residences Located within 125 feet (number) 0 2 2

Residences Located within 250 feet (number) 10 21 11

Federal and State Land

Federal Lands Crossed (number/miles) 0/0.0 0/0.0 0/0.0

State Forest/Parks (number/miles) 0 1/2.4 1/2.4

Trails

Trails (number) 0 2 2

Other Physical Features

Road Crossings (number) 19 26 7

Railroads Crossed (number) 0 0 0

Other Environmental Features

Shallow Depth to Bedrock Crossed (miles) 9.3 5.8 -3.5

Steep Slopes Crossed (30 degrees or greater) (miles) 2.7 1.2 -1.5

Side Slope Construction (miles) 0.7 0.9 0.2

Environmental Hazards and/or Concerns (within 0.5 mile) (number) 1 3 2

___________________

a Totals may not sum correctly due to rounding

Alternative G would be subject to the same construction, operation, and maintenance safety 

concerns as alternative C due to its location within the Schoharie Creek floodplain, as discussed above. 

Alternative G is longer than the proposed route and would result in additional impacts on Audubon Forest 

Blocks of Importance, trail crossings, wetlands, waterbodies, property owners, and nearby residences. It 

also crosses 2.4 miles of the Burt-Rossman Hills State Forest, which would be the largest state forest 

crossing associated with the project. This state forest is fully avoided by the proposed pipeline project 

route. Therefore, we do not consider adoption of alternative G to be preferable to the proposed project. 

Alternative P

Alternative P was considered to minimize potential impacts on the Barton Hill public water 

supply watershed at the request of the Town of Wright. Alternative P begins at MP 121.5 and end at the 

proposed Westfall Road M&R Station. A comparison of the environmental and other routing 

considerations associated with alternative P to the proposed route is presented in table 3.4.2-5. 
3-57 Alternatives

TABLE 3.4.2-5

Comparison of the Proposed Pipeline Route to Alternative P

Factor

Proposed

Route

Alternative

Route

Difference

(if Applicable)a

Length of Corresponding Segments (miles) 2.9 3.3 0.3

Type of Right-of-Way 

Length Adjacent to Existing Utility Right-of-Way (electric/pipeline) 

(miles)

1.0 0.2 -0.8

Length Adjacent to Existing Roadways Paralleling and within an 

Existing Right-of-Way or Easement (miles)

0.0 0.0 0.0

Length Adjacent to Existing Roadway Paralleling and Abutting an 

Existing Right-of-Way or Easement (miles)

0.0 0.0 0.0

Length Adjacent to Existing Roadways Paralleling an Existing Rightof-Way or Easement within 300 feet (miles)0.0 1.0 1.0

Right-of-Way Requirements

Pipeline Construction Requirements (acres) 38.9 43.3 4.4

Pipeline Operation Requirements (acres) 17.7 19.7 2.0

Wetlands

Total Wetland Complexes Crossed (number) 0 0 0

Total Wetland Crossed (linear feet) 0 0 0

Total Wetland Impacts (construction/operation) (acres) 0.0/0.0 0.0/0.0 0.0/0.0

Palustrine Forest Wetland Complexes Crossed 

(construction/operation) (acres)

0.0/0.0 0.0/0.0 0.0/0.0

Palustrine Scrub-Shrub Wetland Complexes Crossed 

(construction/operation) (acres)

0.0/0.0 0.0/0.0 0.0/0.0

Palustrine Emergent Wetland Impacts (construction/operation) 

(acres)

0.0/0.0 0.0/0.0 0.0/0.0

Waterbodies

Waterbodies Crossed (number) 1 1 0

Major River Crossings (number greater than 100 feet) 0 0 0

Streams with Drinking Water Use Designation (number) 0 0 0

Cultural Resources

National Historic Landmarks (number) 0 0 0

National Register of Historic Places Eligible or Potentially Eligible 

Cultural Resources Sites Crossed (number)

0 0 0

Land Use

Forested Land Crossed (miles) 0.4 0.7 0.3

Forested Land Impacts (construction/operation) (acres) 5.2/2.4 9.5/4.3 4.3/1.9

Forest Edge Crossed (miles) 0.4 0.7 0.3

Forested Edge Impacts (construction/operation) (acres) 5.2/2.4 9.5/4.3 4.3/1.9

Forest Interior Crossed (miles) 0.0 0.0 0.0

Forested Interior Impacts (construction/operation) (acres) 0.0 0.0 0.0

Important Bird Area Crossed (miles) 0.0 0.0 0.0

Audubon Forest Blocks of Importance (miles) 0.0 0.0 0.0
Alternatives 3-58

TABLE 3.4.2-5 (continued)

Comparison of the Proposed Pipeline Route to Alternative P

Factor

Proposed

Route

Alternative

Route

Difference

(if Applicable)a

Agricultural Land Crossed (miles) 2.4 2.4 0.0

Agricultural Land Impacts (construction/operation) (acres) 36.9/14.7 36.7/14.7 -0.2/-0.1

Landfills, Quarries, Material Storage and Processing (number) 0 0 0

Property Owners

Property Owners Affected (number of parcels crossed) 13 11 -2

Residences Located within 50 feet of the Pipe Centerline (number) 0 1 1

Residences Located within 125 feet (number) 0 2 2

Residences Located within 250 feet (number) 1 4 3

Federal and State Land

Federal Lands Crossed (number/miles) 0/0.0 0/0.0 0/0.0

State Forest/Parks (number/miles) 0/0.0 0/0.0 0/0.0

Trails

Trails (number) 0 0 0

Other Physical Features

Road Crossings (number) 3 3 0

Railroads Crossed (number) 0 0 0

Other Environmental Features

Shallow Depth to Bedrock Crossed (miles) 0.2 0.1 -0.1

Steep Slopes Crossed (30 degrees or greater) (miles) 0.0 0.0 0.0

Side Slope Construction (miles) 0.0 0.0 0.0

Environmental Hazards and/or Concerns (within 0.5 mile) (number) 0 0 0

Landslides / Unstable Lands Crossed (miles) 0.0 0.0 0.0

___________________

a Totals may not sum correctly due to rounding

The proposed route is 0.3 mile shorter and slightly less collocated than alternative P. The 

proposed route and alternative P would have roughly equal impacts on wetlands and waterbodies. The 

proposed route would have fewer impacts upon forested land and nearby residences, while alternative P 

would have fewer impacts on the number of property owners. Both the TGP and Iroquois gas pipeline 

systems have operated within the Barton Hill watershed for many years without any known impact on the 

water supply. For these reasons, we do not consider adoption of alternative P to be preferable to the 

proposed project. 

3.4.3 Minor Route Variations

In addition to the major and minor route alternatives described above, we evaluated minor route 

variations which are much smaller in scale. Typically, they are shorter in length and involve minor shifts 

in the pipeline alignment to avoid a site-specific resource issue or concern. These site-specific issues 

included proximity to homes and property boundaries, avoidance of forested land, waterbodies, wetlands, 

side slopes, special agricultural areas, and addressing impacts on other construction-related, 

environmental, or landowner concerns. While many of these minor variations were incorporated, a 

smaller number were reviewed and rejected for environmental or construction engineering reasons, or 
3-59 Alternatives

because some of them subsequently became isolated and obsolete due to the incorporation of other 

alternatives. A brief description of each variation, the reasons why it was adopted or rejected, and our 

assessments are presented below. 

Constitution indicated that it had evaluated 371 minor route variations over the course of project 

development and that over 50 percent of its originally considered pipeline route had changed due to 

incorporation of alternatives and smaller realignments since its original filing in May 2012. During our 

pre-filing process 200 of these minor route variations were evaluated by Constitution during the course of 

preliminary route review, engineering design, and field assessments. These 200 variations were part of 

the early phase, original route design process and are not discussed further below as the concerns for 

which they were developed have been addressed. 

We assessed 20 minor route variations to avoid or minimize potential impacts on wetlands and 

waterbodies. In many cases, the landowners, staff from the NYSDEC, and staff from the COE met with 

Constitution in the field to develop these potential minor route variations. All 20 minor route variations 

were incorporated into its proposed route. Appendix H (Status of Minor Route Variations Assessed for 

Impacts on Water Resources) details the parcel number, location, assessment, status of the alternative 

relative to the proposed route, and landowner resolution status for each minor route variation identified by 

the NYSDEC and COE staff. We determined that these minor route variations, as incorporated in the 

proposed route, would reduce impacts on the water resources, and have no reason to recommend further 

analysis along the segments of the proposed route.

Other minor route variations were identified by landowner or stakeholder input. The status of 

these minor route variations, 151 in total, is discussed in the following three sections below. These were 

identified based on input to Constitution directly from landowners, input to Constitution from our staff 

based on landowner comments supplied to us, as well as Constitution’s coordination with the NYSDAM, 

NYSDEC, and the COE. 

3.4.3.1 Minor Route Variations Reported to Constitution 

Constitution reported 96 minor route variations based on requests from potentially affected 

landowners (appendix H-1) that cross 257 individual tracts. Constitution adopted 81 of these 96 minor 

route variations into its proposed route or otherwise resolved the landowners’ concerns. Constitution 

stated that the remaining 15 minor route deviations were not adopted for reasons such as:

• rendering the route variation as obsolete or replacement by another route; 

• routing conflicts with other infrastructure; 

• substantial increases in pipeline length; 

• substantial increases in the number of affected landowners; and 

• increases in environmental impacts. 

Appendix H-1 details the parcel number, location, assessment, status of the alternative relative to 

the proposed route, and landowner resolution status for each minor route variation identified by 

Constitution. We concur with Constitution’s assessment for its identified minor route variations with one 

exception. In this case a variation was developed (but not adopted) that would increase the distance 

between the pipeline and a water well on tract ALT-B-NY-BR-082.003. We determined that this 

deviation or possibly other minor pipeline realignment could reduce potential impacts on this well;

therefore, we recommend that:
Alternatives 3-60

• Constitution should further assess a minor route deviation for parcel ALT-B-NYBR-082.003 and either incorporate a route that avoids the water well or otherwise 

explain how potential impacts on the well have been effectively avoided, minimized, 

or mitigated, and file this information with the Secretary prior to the end of the 

draft EIS comment period. 

3.4.3.2 Minor Route Variations Reported By Stakeholders

We assessed 48 minor route variations that would affect 102 individual tracts as a result of 

comments we received from potentially affected landowners (appendix H-2). We developed potential 

minor route variations based on our field visits, landowner input, and our review of desktop data; and 

supplied those variations to Constitution for assessment. Constitution adopted 41 of these 48 minor route 

variations into its proposed route or otherwise resolved the landowners’ concerns. Constitution stated that 

the seven remaining minor route deviations were not adopted for reasons such as the route variation was 

unnecessary or there were routing conflicts with other infrastructure. 

Appendix H-2 details the parcel number, location, assessment, status of the variation relative to 

the proposed route, and landowner resolution status for each minor route variation we identified. We 

generally concur with Constitution’s assessment and conclusions for these stakeholder-identified minor 

route variations listed in appendix H-2 and found that these variations result in fewer impacts. However, 

we received comments that landowner resolution for one of the parcels is not yet complete, and we have 

received comments about ten other parcels where issues remain. These tracts are listed below in table 

3.4.3-1. Based on the unresolved status of several landowner comments regarding the proposed crossings 

of eleven individual tracts, we recommend that:

• Constitution should further assess minor route deviations for the tracts identified in 

table 3.4.3-1 of the EIS in coordination with the landowners and either incorporate 

a route that avoids the resources of concern or otherwise explain how potential 

impacts on resources have been effectively avoided, minimized, or mitigated. 

Constitution should file the assessments with the Secretary prior to the end of the 

draft EIS comment period. 
3-61 Alternatives

TABLE 3.4.3-1

Status of Minor Route Variations Reported to Stakeholders

Land Parcel ID MP

Requested Minor Route

Deviation Description

ALT-S-PA-SU-007.002 21.1 Landowner concerned with proximity of alignment to future house site.

NY-BR-077.000 40.6 Landowner concerned current alignment would prohibit future development of the 

land.

ALT-B-NY-BR-082.000 41.4 Landowner was concerned about rights to build a house, removal of trees and berry 

bushes, and ability to cross the pipeline.

NY-CH-001.007 42.5 Landowner requested the pipeline be moved to the back of their property so as to 

not impact a future gas well or home site.

NY-DE-111.000 72.9 Landowner concerned about damage to a woodlot, wetlands, and stream on the 

property.

NY-DE-137.000 77.2 Landowner concerned with proximity of pipeline to home (100 feet) and because the 

alignment cuts the property in half.

NY-DE-199.000 86.6 Landowner concerned with proximity of pipeline to home (25-50 feet).

NY-DE-226.000 90.8 This deviation was developed to avoid forested land.

ALT-O-NY-SC-015.000

ALT-O-NY-SC-017.000

ALT-O-NY-SC-022.000

114.1, 

115.0, and 

115.6

The route could disrupt farming operations and make the landowner out of 

compliance with their agricultural permits.

____________________

For parcels listed above, we are requesting that Constitution provide additional information as described above.

3.4.3.3 Minor Route Variations Assessed for Impacts on Agricultural Land

We assessed seven minor route variations based on requests to reduce construction or operational 

impacts on agricultural areas affecting 26 tracts of land (appendix H-3). We evaluated these tracts with 

assistance from the NYSDAM. In many cases, the NYSDAM staff visited the sites of these potential 

variations in the field with both the landowner and Constitution. Constitution indicated that it had 

adopted all seven of the variations into its proposed route or otherwise resolved the landowners’ concerns. 

However, the NYSDAM indicated that issues remained unresolved for six tracts where construction 

activity may result in limited access to other farmable fields during construction or conflict with terms of 

agricultural conservation agreements. Therefore, we recommend that:

• Constitution should further assess minor route deviations for the tracts identified in 

table 3.4.3-2 of the EIS in coordination with the landowners and the NYSDAM. 

Constitution should either incorporate a route that avoids the agricultural resources 

of concern or otherwise explain how potential impacts on resources have been 

effectively avoided, minimized, or mitigated. Constitution should file the 

assessments with the Secretary prior to the end of the draft EIS comment period.

Table 3.4.3-2 details the parcel number, location, assessment, status of the alternative relative to 

the proposed route, and landowner resolution status for each tract where concerns are unresolved. With 

the exception of the above, we determined that impacts on the remaining tracts listed in appendix H-3 

were adequately minimized and did not require further assessment. 
Alternatives 3-62

TABLE 3.4.3-2

Status of Minor Route Variations Assessed for Impacts on Agricultural Lands

Affected Parcel Numbers MP

Reason for Minor

Deviation

NY-CH-011.000

NY-CH-013.000

NY-CH-012.000

NY-CH-014.000

UA-NY-CH-015.001

NY-CH-017.000

45.9 Deviation to minimize impact on farmland.

NY-CH-011.000

NY-CH-013.000

NY-CH-012.000

NY-CH-014.000

NY-CH-015.000

UA-NY-CH-015.001

NY-CH-016.000

NY-CH-017.000

46.5 Deviation to minimize impact on farmland.

NY-SC-156.000

NY-SC-152.000

NY-SC-160.000

ALT-Q-NY-SC-001.000

ALT-Q-NY-SC-002.000

ALT-Q-UA-NY-SC-004.000

ALT-Q-NY-SC-005.000

ALT-Q-NY-SC-006.000

116.4 Deviation to minimize impact on farmland;

a re-route was already considered and approved for this landowner.

____________________

For parcels noted in bold we are requesting that Constitution provide additional information as described above.

3.5 ABOVEGROUND FACILITY SITE ALTERNATIVES

We evaluated the locations of the proposed aboveground facilities to determine whether 

environmental impacts would be reduced or mitigated by the use of alternative facility sites. Our 

evaluation involved inspection of aerial photography and mapping, as well as our own field work along 

the proposed projects’ corridor and location. The aboveground facilities for the proposed projects include 

Constitution’s Turnpike Road M&R Station (including one MLV site and pig launcher), the White Road 

Tie-in, the Sutton Road Tie-in, 10 MLVs, the Westfall Road M&R Station (which would include one 

MLV site and a pig receiver) and Iroquois’ new compressor transfer station at the terminus of 

Constitution’s pipeline.

Because the locations of the two proposed meter stations would be linked to the general location 

of the associated natural gas receipt and delivery points near the proposed Constitution project origin and 

at the pipeline terminus, the search for alternatives was constrained to sites adjacent to the existing 

Central Compressor Station and the existing Wright Compressor Station, respectively. We did not 

identify any reasonable alternative sites for the proposed meter stations that would offer a major 

environmental advantage to the proposed sites for these facilities. 

The proposed locations of MLVs along the proposed pipeline route were partly determined based 

on DOT safety regulations that specify the maximum distance between sectionalizing block valves, and 

require that these facilities be located in readily accessible areas. The location for the White Road Tie-in 

was determined by the location of the proposed non-jurisdictional White Road M&R Station and Miller 

Compressor Station facilities. Similarly, the location for the Sutton Road Tie-in was determined by the 

location of the proposed non-jurisdictional Sutton Road M&R Station. In addition, the proposed White 

Road Tie-in, Sutton Road Tie-in, and MLVs would all be located wholly within Constitution’s proposed 

pipeline operational right-of-way. No additional land disturbance beyond that already accounted for 
3-63 Alternatives

within the proposed pipeline’s permanent right-of-way would be required for the White Road Tie-in, 

Sutton Tie-in, or proposed MLVs, and we did not identify any site alternatives for these facilities that 

would be preferable to the proposed locations. Furthermore, as discussed above, the tie-ins and MLVs 

would only have minimal operational impacts on visual aesthetics, which did not necessitate the need for 

additional analysis.

Early in the pre-filing process in May 2012, Constitution proposed to construct a new greenfield 

compressor station on an undeveloped parcel near the existing Wright Compressor Station. Constitution 

identified six potential locations for a new compressor station (figure 3.5-1). In February 2013, 

Constitution re-evaluated hydraulic modeling estimates and determined that the compression needed to 

deliver natural gas from the proposed pipeline into Iroquois’ system could be met by modifying the 

existing Wright Compressor Station owned by Iroquois. These modifications eliminated the need for a 

new, greenfield compressor station. As such, Iroquois has proposed a new compressor transfer station 

adjacent to its existing compressor station and wholly on its own property that would provide Constitution 

with the needed compression. Furthermore, adding compression on Iroquois’ property would allow it to 

optimize the new compressors in tandem with the existing facilities. Therefore, this resulted in a decrease 

in the total amount of compression needed to complete the project. Iroquois has proposed to construct 

20,500 horsepower of compression, while Constitution would have been required to construct 32,000 

horsepower of compression without Iroquois’ optimizations.

Alternative locations for the proposed Iroquois compressor transfer station included six parcels in 

the vicinity of the existing Wright Compressor Station along Westfall Road or Barton Hill Road. While 

these parcels were potentially viable alternative sites, siting the compressor transfer station within the 

existing parcel owned by Iroquois would have several advantages. These advantages include: 

• use of an existing industrially developed parcel;

• elimination of the need for survey permission and right-of-way acquisition from other 

private landowners;

• making use of existing compressor facilities where possible instead of construction of 

completely new facilities;

• reduced air emissions from reductions in total compression needed;

• use of existing access roads; and

• lack of impacts on environmental resources such as waterbodies, wetlands, agricultural 

land, residences, or cultural resources.

For these reasons, we concluded that construction of the compressor transfer station on the 

existing Iroquois parcel was preferable to construction on a previously non-industrial site. 
SCHOHARIE COUNTY

A

B

C

D E

F

Existing Wright

Compressor Station/

Proposed Compressor 

Transfer Station

MP 124.4

MP 122

MP 123

MP 124

Kimmy Rd

Co Rd 54

Sheldon Rd

Fox Creek

Farm Rd

Blanchard Rd Westfall Rd

Warner Rd

Wilber Rd

Sever Rd

Co Rd 25

Barton

Hill Rd

State Rte 146

Kump Rd

Dugan Hill Rd

Cook Rd

State Rte 443

Westfall Rd

Co Rd 25

Barton

Hill Rd

Co Rd 26

Larry Hill Rd

Proposed 30-inch Diameter Natural

Gas Pipeline Alignment

Compressor Station Alternatives

p

0 1,000 2,000 3,000

Feet

Figure 3.5-1

Compressor Station Site Alternatives

NEW YORK

PENNSYLVANIA

NJ

MA

MD

CT

NH

VA

VT

DE

RI

3-64