COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline

Companies and Or

The commentor’s summary of the project regarding the adequacy of the draft EIS aresponse to comment FA1-1.

CO42-1

S-512
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

S-513
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

The comment regarding the photography the draft EIS is noted. The photos on the taken by the FERC staff during field visitand are generally representative of the pronot preclude the existence of other terrain were not “digitally manipulated.” The prcrossing of and impacts on steep topograpare fully disclosed in the EIS. 

CO42-2

The FERC staff has worked closely with agencies and the other permitting agenciethe EIS. We have considered the informaother agencies and included them in our einformation requests as appropriate. The and considered all substantive comments filing and scoping periods. 

CO42-3

S-514
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

See the response to comment FA1-1 regapending at the time of the draft EIS and dstated in the EIS, our review was completof the NEPA. The FERC’s environmentadirected by New York’s State EnvironmeAct.

CO42-4

Constitution’s Preliminary Migratory BirPlan was filed on May 6, 2014 (http://elibrary.ferc.gov:0/idmws/file_list3683) and the EIS (particularly section 4.accordingly. See the response to commenpending field surveys. 

CO42-5

The construction schedule is discussed in however, the exact start of construction wa final Commission decision, subsequent surveys (see the response to comment FAnecessary federal permits, and a separate FERC confirming completion of any outsConstitution originally proposed to start cquarter of 2014, but has amended this datof 2014. It is anticipated that pipeline conover a period of approximately 9 to 12 mproposed an in-service date of March 201longer appears feasible. We recognize thconditions, and other unforeseen factors cconstruction schedule adjustments or delathat its construction start in July 2014 and continue for approximately 9 months with date of March 31, 2015. This is likewise 

CO42-6

The proposed projects’ purpose and need 1.1 of the EIS, and this section has been uinformation. See the response to commen

CO42-7

The COE and the EPA both participated ain the development of the EIS. The COE agency responsible for implementation of Clean Water Act. This permitting processections 1.5, 4.3, and 4.4 of the EIS. 

CO42-8

Cumulative impacts including developmeShale are discussed in section 4.13 of the updated with new information as indicatecomments FA4-44 and CO26-10. 

CO42-9

Alternatives are discussed in section 3 of updated. Alternative construction method404 of the Clean Water Act are discussed 4.4 of the EIS. See the response to comm

CO42-10

S-515
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

See the response to comment FA1-1. Whappropriate, we have included internet linreferenced in the EIS. Most of the materiplans that were submitted as part of Consapplications, which were filed in the summ

CO42-11

S-516
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

See the response to comment FA1-1. All considered with equal weight, regardless submitting them.

CO42-12

See the response to comment FA1-1. The Counsel’s guidance regarding relevant proutlined in its letter dated January 31, 201

CO42-13

S-517
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

CO42-14 See the responses to comments FA1-1 an

S-518
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

See the response to comment CO42-6. Uwaivers are granted by the agencies, Conthe PFBC and the NYSDEC schedule res(see the response to comment SA4-14) anrestrictions for migratory birds except for circumstances and/or under the condition4.6.1 of the EIS. These circumstances incaccess sensitive waterbodies for crossing construction window. September is the oboth tree clearing and construction within occur. We concluded that with our recommendacomplete all surveys and a mitigation plan blasting) developed in consultation with tprior to construction, would protect the baimpacts.

See the response to comment CO42-6 reg

proposed schedule. The FERC’s compliaprogram (see section 2.5.3 of the EIS) woproject is built in accordance with applicaand all other permits. 

CO42-15

S-519
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

The transportation of supplies, commutinroads that primarily would be used to accwell as Constitution’s traffic managemensection 4.9.4 of the EIS. As stated in sectConstitution would repair any roads damaproject.Access roads are discussed in section 2.2location, description, length, land use, and required (if any) for each of the proposed in appendix E. Constitution included a tyaccess road (Volume 2, Appendix J, see fYork ECP), including a stormwater swaleat http://elibrary.ferc.gov:0/idmws/file_list.a0901.

CO42-16

S-520
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

See the response to comments FA1-1 and not bound by the Applicants’ proposed inFERC staff will take the time necessary to the NEPA review. See the responses to c(permanent fill), CO42-5 (upland forest mCO42-15 (bald eagle). 

CO42-17

S-521
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

The FERC staff (and Constitution) continthe permitting agencies as appropriate. Tupdated to include additional information comments of the permitting agencies. Recomments on the draft EIS, including the NYSDEC, are provided in this appendix. numerous environmental information requcourse of this project, including follow-up responses provided by the Applicants werPermitting agencies may also issue their orequests, and may delay their processing applications depending upon whether they information to proceed. A discussion of athe possible routing the pipeline within thprovided in section 3.4.1.2 of the draft EIcomment FA4-45 regarding high volume 

CO42-18

S-522
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

See the responses to comments FA4-3 anhas indicated that it will require complete route to assess Constitution’s project undWe have included relevant information usand summaries of voluminous materials wexample, wetland delineation reports couto the EIS but are exceedingly voluminousubstantive value to the EIS when they aradministrative record for the project. As significant portion of this information and areas where survey permission has been dobtained only after the Commission issuedenying the projects. 

CO42-19

S-523
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

See the response to CO42-19. Waterbodithe jurisdiction of the COE are discussed 2.3.2.1, 2.3.2.2, 4.3, 4.4, and 4.13 (and otalong with site-specific information proviand L. The COE participated as a cooperdevelopment and review of the draft and have responded to the COE’s formal comwithin this appendix (see the response to have updated the EIS accordingly. The Ccurrent comments and input into the EIS filed in the past. 

CO42-20

S-524
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

S-525
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

S-526
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

See the responses to comments FA1-1 anmust complete all of the remaining field scorridor once survey access is obtained pragency permitting and the FERC’s authorconstruction, if the Commission grants a 

CO42-21

S-527
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

See the response to comment FA4-37. Sediscusses potential impacts on all federallspecies. FERC regulations as well as fedto complete any and all necessary Endangconsultation prior to authorizing construcproject is no exception. Constitution perffederally listed species in consultation widid not require bat surveys in New York a4.7.2. See the response to comment 42-1eagle. 

CO42-22

S-528
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

The EIS has been prepared in accordance implementing regulations and includes a proponents’ purpose and need, alternativeenvironment and environmental consequewill weigh the projects’ environmental imeconomic considerations, and if the projeCommission’s Order will include a rationadditional conditions to avoid or minimizimpacts. As indicated by the commentor, adopt the EIS to fulfill its own requiremenState’s Environmental Quality Review Adetermines it needs additional information presented in the EIS to complete its analyresponsible for obtaining that information additional analysis.

CO42-23

See the responses to comments FA1-1, FAWe conclude that the measures described and appendices K and L of the EIS would groundwater, surface water, and wetlands practicable. The PADEP and the NYSDEdetermining whether the proposed projectmeet the respective states’ implementatioof water quality certificate under Section Act. It has been our experience that FERprojects do not generally violate water qu

CO42-24

S-529
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

S-530
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

S-531
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

See the response to comment CO42-24. Wproposed to be crossed using either dry or methodologies, which would limit the potsedimentation, or turbidity. See the respo34 and section 4.3.3 of the EIS regarding Trenchless Feasibility Study, which can bhttp://elibrary.ferc.gov:0/idmws/file_list.a0901, see volume II appendix N. Given wgeotechnical conditions, constraints, and specifications, we conclude that it is not fuse trenchless methods (conventional borpipe) at all waterbody locations. Proposewaterbody crossing methods and informaappendix K. Endangered species are discthe EIS.

CO42-25

S-532
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

We conclude that with implementation of which include the FERC Plan and Procedimplementation of dry or trenchless crosswaterbodies (see the response to commendesignated water quality uses would not bprojects’ area.

CO42-26

S-533
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

S-534
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

S-535
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

S-536
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

S-537
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

S-538
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

S-539
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

S-540
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

S-541
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

The proposed projects’ purpose and need 1.1 of the EIS, and this section has been uinformation. See the response to commen

CO42-27CO42-28 See the response to comment CO42-23. 

S-542
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

See the response to comment CO42-20. Tresponsible for determining whether to isSection 404 permit. 

CO42-29

S-543
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

S-544
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

S-545
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

See the response to comment CO42-20 andiscussed in the EIS, we conclude that imwould be minimized where possible and w(including locations where PFO wetlands PEM or PSS over the long-term or permawith the COE guidelines where impacts a

CO42-30

S-546
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

CO42-31 See the response to comments CO42-25 a

See the responses to comments CO42-27 CO42-18 (alternatives), and CO42-29 (threview). 

CO42-32

S-547
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

S-548
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

The use of the best management practices and Constitution’s ECPs would serve as tthe prevention of potential impacts, such compliance monitors would document thain accordance with the required environmThe compliance monitoring program woua daily basis. A major goal of the program instances of noncompliance, rather than tfor issues such as inadequate erosion and improper seeding, and rutting. The FERC has various ways to enforce coperforming project sponsor, including, buwork authority, fines, and consideration owithholding project in-service based on wproceeding satisfactorily. The performannecessarily an indicator of the performancthe comments regarding issues with past plocated in the vicinity are noted. See the FA4-53 (karst geology), CO1-5 (floodingrunoff), and CO41-10 (soil compaction). rutting, developed in coordination with thdiscussed in section 4.2.4 of the EIS. 

CO42-33

S-549
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

S-550
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

S-551
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

S-552
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

See the responses to comments CO26-18, and CO42-29. See the response to commthe Leatherstocking Gas Company. The songoing effort to obtain easement agreemIf an easement cannot be negotiated with projects are certificated by the Commissiouse the right of eminent domain to acquirnecessary to construct the projects. The Arequired to compensate the landowner for damages incurred during construction. The potential impacts of the projects upon including our recommendation to ensure mitigated, and mortgages are discussed in 4.9.5 of the EIS, respectively. These sectfor the final EIS.

CO42-34

S-553
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

S-554
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

S-555
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

The FERC staff makes the selection of thnot the applicant. The FERC contractor ithe applicant. In regard to the Keystone XU.S. Department of State (DOS) Office o(OIG) found in February 2012 that there wapplicant improperly influenced the DOS ENTRIX as the third-party contractor and contractual or financial relationships betwand the applicant that would result in a cowould impair the ability of Cardno ENTRperforming the work assigned (DOS 2012comment IND4.U.S. Department of State, Office of the InSpecial Review of the Keystone XL PipeReport Number AUD/SI-12-28, February The photos on the cover of the EIS were tduring field visits to the project area and agricultural, and forested lands that would Section 3 of the EIS examines alternativepipeline routes and configurations, alternacollocation with existing pipelines and I-8and non-renewable energy sources. 

CO42-35

S-556
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

Impacts on forest (section 4.5, appendix Mdue to blasting (section 4.1.3.7 and 4.1.3.as system and collocated alternatives (secare discussed within the EIS. See the resp1 regarding Section 380.15(b) of the Comguidelines. The EIS clearly acknowledgeincluding miles crossed, acres cleared, anThe data are not in any way “hidden.” 

CO42-36

S-557
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

See the response to comments CO26-10, Section 3.1 of the EIS indicates that if the were selected, then other energy sources wto meet customer demand potentially incland renewable energy.” See the response16 and CO32-1. 

CO42-37

S-558
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

The FERC does not prescribe the width oproposed projects; rather the applicant docoordination with resource agencies, in phistoric preservation offices. Typically, tstudy corridor that allows it some flexibiladjustments to the proposed route in orderesource (such as a well) without having tto the field. Otherwise, if the study corridallow such flexibility, then additional, submay be required to assess minor route varcomment regarding the number of parcels surveyed as well adjoining parcels within have not been surveyed is noted. The FEdecisions based on the number of parcels response to comment CO42-15 regarding Typically, field assessments downstream survey corridor are not required. See the LA10-3 regarding the identification of weconstruction and a source reference. 

CO42-38

S-559
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

Information can only be obtained if it is aApplicants typically contact local, state, athe project planning phases to obtain as minformation as available. The backgrounsupplemented or verified through field suprovided. Where access is denied, field scompleted after the issuance of a Certificresponse to comment FA4-3.Threatened and endangered species are diof the EIS. See also the response to commspecies are discussed in section 4.5.4 of thresponse to comment FA4-9. As stated in EIS, Constitution would use a padding mrocks mixed with subsoil do not damage tbe responsible for approving imported sosoil is certified free of noxious weeds and otherwise specified by the landowner) as EIS.

CO42-39

S-560
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

S-561
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

See the responses to comments CO42-23, 29 regarding agency permitting. The defiimpacts is noted. See the response to comthe Leatherstocking Gas Company. See tcomments FA4-45 and CO26-10 regardinMarcellus Shale and our updates to the cusection of the EIS. See the response to coregarding the capacity of the Constitution to serve as a major conduit for natural gas New York. See the response to commentregarding the purpose and need for the pr

CO42-40

S-562
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

S-563
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

S-564
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

S-565
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

S-566
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

S-567
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

A description of unmet need for natural gdiscussed in section 3.1 of the EIS. Sectiindicates that if the no-action alternative wcombination of other energy sources woumeet customer demand potentially includand renewable energy.” Renewable energin section 3.1.2.3 of the EIS. The FERC staff reviews applications for pipeline projects in accordance with an apobjective(s) in order to disclose the enviroproposal to inform the decisionmakers anNEPA, evaluate reasonable alternatives to the FERC as a matter of policy and in accNatural Gas Act and other governing reguthe development of the gas industry’s infron a project-by-project basis. As such, thevaluation of reasonable alternatives does project objectives, determining what an a“should” be, nor does it include redefininProject. This does not mean that the FERrecommend a modification to a project or option; however, the FERC staff’s review that any modifications or alternatives it rewould meet the applicant’s stated objectivCommissioners at the FERC ultimately hevaluate the merits of a project’s objectivproposal, with or without modification, othe Project. Alternative originating or demeet the Project’s objectives would not bCommission decide that a project is not in and necessity, it would deny the project (no-action alternative) versus designing or project with different objectives.A discussion of alternative M, including tpipeline within the median of I-88 was pr3.4.1.2 of the draft EIS. System and collo(sections 3.2, 3.3, and 3.4) are discussed ithe EIS. 

CO42-41

S-568
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

S-569
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

Purpose and need are discussed in section description of unmet need for natural gas discussed in section 3.1 of the EIS. The Eevaluation of the probable and cumulative proposed projects, including the 20 factorits 2012 letter where applicable. See the CO42-20. Given that waterbodies would be crossed trenchless construction methods, adverse quality are not anticipated as discussed in conclude that pre-construction testing of necessary. See the responses to comments FA4-45 a

CO42-42

See the response to comments LA7-5,COanalysis of the recoverable reserves of naMarcellus Shale, the holdings of Cabot OSouthwestern Energy, and projected regiogas are beyond the scope of this EIS. 

CO42-43

S-570
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

See the responses to comments CO26-18 disagree that a legal analysis of the use of required to be included in the EIS.

CO42-44

System and collocated alternatives (sectiodiscussed in adequate detail within the EIresponse to comment CO2-1.

CO42-45CO42-46 See the response to comment CO41-29.CO42-47 See the responses to comments FA1-1 an

S-571
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

Groundwater and surface water resources discussed in separate sub-sections for orgbut we recognize the potential for their inassessment of the resources occurs throughow upland erosion control is important twater resources. The discussion regardinBallpark Aquifer in section 4.3.2.1 of the surface water and groundwater interaction

CO42-48

The proposed projects’ impacts on ecosysnetwork between and among living organcomponents of their environment, are disexample includes the relationships of wild(sections 4.5, 4.6, and 4.7 of the EIS). 

CO42-49

Land use is discussed in section 4.8 of the mortgages, and property values are discusEIS, and this section has been updated wiinformation. FERC staff engaged in inderegarding insurance and mortgage issues (see section 4.9 of the EIS). As stated in EIS, Constitution would repair any roads See the response to comment CO41-23 reinduced development of heavy industry. .

CO42-50

Section 4.8 of the EIS describes potential owned or managed by federal, state, or lodevelopments, and compliance with speciprograms such as the Conservation ReserProgram, Clean and Green Program, and 480 and 480a Real Property Tax eligible 

CO42-51

S-572
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

CO42-52 See the response to comments FA4-44 an

Cultural and historical resources are discuthe EIS. Some sensitive cultural resourcedisclosed to the public in order protect thovandalism. This information has been anrecord with the Commission as privileged information. 

CO42-53

Potential visual impacts, including scenic and described in section 4.8.6 of the EIS.

CO42-54CO42-55 See the response to comments LA7-5 and 

See the response CO42-41. The FERC ddevelopment of the gas industry’s infrastrproject-by-project basis, or at the local dithe delivery of natural gas to local users imeans, such as an alternative supply pipedistribution company (other than Leatheror by truck delivery of compressed naturaof any such plans and conclude that such reasonably foreseeable or practical altern

CO42-56

S-573
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

CO42-57 See the responses to comments FA1-1. 

S-574
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

See the responses to comments FA1-1 anEnvironmental Law Litigation Clinic, Incfiled (corrected version) on April 8, 2014supplemental information on February 7, 7, May 6, and June 3 and 19, 2014 that wdraft EIS. We have also developed new iEIS independent of the Applicants. We hincorporated this new information where conclude that we have adequate informatiissuance of the final EIS. 

CO42-58

S-575
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

S-576
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

S-577
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

S-578
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

S-579
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

S-580
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

The need for and types of information thathe course of a project as prior issues may resolved or obsolete and new issues may or state agencies may also request specifineeded for their permitting reviews, but thnecessarily needed for the NEPA review. comment CO42-18. We are in receipt of the NYSDEC, the COE, and other agenciEIS. These current comments are addresresponse to comment CO42-20 regarding in the project and in development of the E

CO42-59

S-581
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

S-582
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

S-583
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

S-584
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

S-585
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

S-586
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

S-587
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

S-588
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

S-589
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

S-590
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

S-591
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

S-592
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

S-593
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

S-594
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

S-595
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

S-596
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

S-597
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

S-598
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

S-599
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

S-600
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

S-601
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

S-602
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

S-603
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

S-604
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

S-605
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

S-606
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

S-607
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

S-608
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

S-609
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

Watersheds that would be crossed by the project are listed and discussed in section table 4.3.3-1 lists the areas of the project be within each watershed. Individual watthat would be crossed are listed by milepoL, respectively. Information regarding waffected by other projects relevant to the canalysis is provided in section 4.13 of the Field data would be used to confirm infordesktop data sources (if the project is certbeen used to identify waterbodies and welocations on a provisional basis pending asurvey access. See section 1.2 of the EIS comment FA4-3. If new waterbodies or wduring subsequent field surveys or during construction methods would be as describ4.4 of the EIS, and the crossings would bconsultation with the permitting agencies and the COE. 

CO42-60

S-610
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

CO42-61 See the responses to comments CO26-10 

Waterbodies and wetlands would be restosections 4.3 and 4.4 of the EIS, including breakers that would reduce the possibility subsurface groundwater flow patterns in tthe responses to comments CO41-15 and response to comment CO41-54 for impacproject. 

CO42-62

Erosion and sedimentation, as well as eroare discussed throughout the draft EIS, pa4.2, 4.3, and 4.4. No waterbodies are curcrossed under “wet” open-cut trenching m2.3.2.2 of the EIS. Constitution could reqcut methods only if dry open-cut methods infeasible such as an inability to maintain diversion structures due to stream geomojustification and proposal for any alternatwould require additional review and apprPADEP, the NYSDEC, and the Commissimplemented.Precipitation is fairly evenly distributed obasis (2.3 inches in February to 4.1 incheNew York) within the project vicinity (wwinter months (December through Februathan the other months. This information hEIS. The potential for flash flooding is d4.1.3.5 of the EIS, where we also noted thTropical Storm Lee occurred in the monthSeptember, 2011. Appropriate erosion ancontrols would be installed to prevent sedcleared or disturbed areas during storms iConstitution’s Plan and Procedures, whicFERC’s standard, and the ECPs. Sedimentation caused by the removal of wcontained within the dewatered zones of tcrossings and the stream channel would bpipeline installation. See the response to regarding equipment bridges. These meaadequately minimize the mobilization of areas. Climate data accessed at website: http://www.weather.com/weather/wxclim12222 on May 5, 2014.

CO42-63

S-611
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

Constitution would ensure that base flowsource streams during the water withdrawtesting process as stated in section 4.3.3.5 maintenance of flow should prevent advechanges in stream temperatures and diel tHydrostatic testing typically lasts several Constitution stated that water would be h14 days. The month that hydrostatic testichange because it would depend on the raoccurs, as well as the dates upon which alissue final approvals. Constitution intendwithdrawal permit applications to the SusCommission, the Delaware River Basin CNYSDEC; the withdrawals would also be conditions of those permits. Further, our Constitution maintain adequate flow rates provide for all waterbody uses, and proviwithdrawals of water by existing users.

CO42-65

The soils in cleared riparian areas would restoration with permanent grasses, tempotemporary mulch depending on the seasonmatting made of jute, wood excelsior, or used to anchor mulch where needed. FolConstitution would allow a 25-foot-wide waterbody bank to revegetate with native stabilize banks, reduce erosion impacts, acover for fisheries resources; however, a may be permanently maintained in an herabove the pipeline to facilitate pipeline in

CO42-64

S-612
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

See the response to comment CO41-12. Tplans for monitoring of water quality, biopost-construction recovery at stream crositems could be the subject of other permitminimum, the status of revegetation at ripassessed after the first two growing seasowould be taken if needed. The right-of-wand mowed about once every three years maintenance; any longer term revegetatioaddressed as necessary. Constitution wouat least 25 feet wide to permanently revegright-of-way at each waterbody crossing (wide corridor centered over the pipeline) stabilization, stream shading, and to provstated in section 4.6.1.4 of the EIS. See tFA4-12 regarding the FERC’s complianc

CO42-67

See the response to comment FA4-24. Astated that the hydrostatic discharge locatdetermined, it is likely that discharge wousource or test segment locations identified 4.3.3-6 of the EIS. The use of dewatering minimize erosion and sedimentation. Teswater discharges is typically not required Constitution would be required to dispose accordance with section III.E of its Plan, disposal facility such as a landfill or possupland location where there may be a bensoil amendment. If drilling fluids were plocation, then landowner approval, surveyincluding sediment and erosion control, w

CO42-66

S-613
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

No fill is proposed for waterbodies. See tcomment FA4-26 regarding permanent fi

CO42-69

Impact durations are defined in section 4.on streams and aquatic life resulting from are expected to be minor and generally ochour crossing period. Most aquatic specimacroinvertebrates, typically re-colonize weeks to months. Temporary constructioassociated with the use of dry crossing mprimarily to short periods of increased turinstallation of the pipeline during the asseand downstream dams and following instwhen the dams are removed and flow acrarea is re-established.

CO42-68

See the response to comment FA4-23 regon waterbodies located within the construnot directly crossed by the pipeline.

CO42-70

See the response to comment FA4-33 regconstruction windows.

CO42-71CO42-72 See the response to comment CO42-65.

Constitution would offer to landowners aconstruction test and at least one post-conwells for the parameters as stated in sectioSee the response to comment FA4-3 regasurveys. 

CO42-73

S-614
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

Section 4.3.3.3 actually stated “None of taboveground facilities, including Iroquoiswithin a FEMA flood hazard zone.” The chance flood (Zones A, AE) is also called year-flood by the FEMA (http://www.femmanagement/flood-zones, website accessThe 0.2-percent chance flood is the 500-ymoderate flood hazard with a risk betweeand the 500-year flood. The EIS has been information. The information presented iprovided by the Federal Emergency Mana

CO42-75

At waterbodies that would be crossed by those affected by access roads or bridges, stream banks or channels would be restorconstruction equipment, to either match pcontours or to a stable angle of repose if tnecessary for bank stability. This process section V.C.3 of Constitution’s Procedurethe FERC standard. 

CO42-74

Potential impacts on fish and wildlife (secspecies (section 4.7), and cumulative impdiscussed in the EIS. Other species such invertebrates may also be affected by the population level impacts are not anticipatspecies may be able to re-colonize the res

CO42-76

S-615
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

Potential impacts on bats are discussed in 

of the EIS. Given the localized nature of crossings, it is unlikely that impacts on mimpacts would affect bat foraging behavionot identified as of concern for the projecnot request that this species be added to o4.7. Given the measures that would be usminimize impacts on aquatic habitats as d4.6, and 4.7 of the EIS, we conclude that river otter would be mostly temporary anSee the response to comment FA4-31. 

CO42-77

Potential impacts on birds (including bald habitats are discussed in section 4.5, 4.6.1sections have been updated for the final EConstitution’s Preliminary Migratory BirPlan which was filed on May 6, 2014 (http://elibrary.ferc.gov:0/idmws/file_list

3683). 

CO42-78

S-616
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

General impacts on general wildlife are d4.6.1. See the response to comment FA4

CO42-79

S-617
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

General impacts on general wildlife are d4.6.1. See the response to comment FA4

CO42-80

General impacts on general wildlife, inclufisheries are discussed in section 4.6. See comments FA4-32 and FA4-35. Discussibeen added to section 4.7 of the EIS. 

CO42-81

S-618
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

General impacts on fisheries (including trsection 4.6.2 of the EIS. Impacts on streaavoided or minimized through the use of crossing methods. As described in sectioConstitution would attempt to capture and be in the sections to be dewatered for dry of the American eel has been added to sec

CO42-82

S-619
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

S-620
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

Potential impacts on freshwater mussels a4.6 and 4.7 of the EIS.

CO42-83

Section 4.6 of the EIS has been updated rimpacts on aquatic macroinvertebrates.

CO42-84

S-621
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

As discussed in section 4.7.3 of the EIS, Clist of special-status species, including placonsultation with federal and state agencirecommendation in section 4.7 of the EIS complete field studies for all applicable stincluding rare plants, and develop mitigatconsultation with the state agencies prior construction. 

CO42-85

S-622
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

Constitution indicated that its consultationthe New York Natural Heritage Program 1 of the EIS. These additional contacts wConstitution assesses and adopts route vacontractor yards. We have included a rec4.7 of the EIS that Constitution complete applicable state-listed species and develop consultation with the state agencies prior construction. See the response to commethe list of special-status species and our readditional consultations. 

CO42-86CO42-87 See the response to comment FA4-3.

S-623
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

CO42-88 See the response to comment CO42-63.

Constitution performed biological surveythe relevant agencies and using qualified to comment FA4-3. 

CO42-89

S-624
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

Constitution stated that it did not anticipain waterbodies. However, the EIS containrecommendation that prior to any in-streaConstitution develop with the state agencspecific blasting plan for the FERC’s revi

CO42-90

The comments indicating that some rare sfrom utility corridors are noted.

CO42-91

Invasive species and the didymo are discuthe EIS. See also the response to comme

CO42-92

S-625
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

In general, Constitution would only use htreatment of invasive species, while mowmaintain the right-of-way. Constitution’s the FERC standard, would allow routine vmowing over the full width of the permanuplands no more frequently than every 3 VII.A.5 of the Plan, New York ECP (Volalso be found at http://elibrary.ferc.gov/idmws/file_list.asp01). However, to facilitate periodic corrocorridor not exceeding 10 feet in width cemay be mowed at a frequency necessary tcorridor in an herbaceous state. See the rFA6-10 regarding long-term monitoring oway for invasive species. We have updatEIS regarding vegetation maintenance whduring the migratory bird nesting season August 1) of any year unless specifically the responsible land management agency control of unauthorized vehicle access to discussed in section 4.8.3 of the EIS.

CO42-93

See the responses to comments CO1-5 anflooding. Climate change is discussed in EIS. 

CO42-94

S-626
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

CO42-95 See the responses to comments FA4-45 aCO42-96 The commentor’s comments are noted.

S-627
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

S-628
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

S-629
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

S-630
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

S-631
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

S-632
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

S-633
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

S-634
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

S-635
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

S-636
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

S-637
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

S-638
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

S-639
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

S-640
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

S-641
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

S-642
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

S-643
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

S-644
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

S-645
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

S-646
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

S-647
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

S-648
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

S-649
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

S-650
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

S-651
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

S-652
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

S-653
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

S-654
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

S-655
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

S-656
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

S-657
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

S-658
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

S-659
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

S-660
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

S-661
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

S-662
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

S-663
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

S-664
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

S-665
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

S-666
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

S-667
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

S-668
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

S-669
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

S-670
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

S-671
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

S-672
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

S-673
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

S-674
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

S-675
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

S-676
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

S-677
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

S-678
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

S-679
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

S-680
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

S-681
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

S-682
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

S-683
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

S-684
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

S-685
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

S-686
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

S-687
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

S-688
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

S-689
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

S-690
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

S-691
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

S-692
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

S-693
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

S-694
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

S-695
COMPANIES AND ORGANIZATIONS

CO42 – Stop the Pipeline (cont’d)

Companies and Or

S-696
The commentor’s statements regarding th

COMPANIES AND ORGANIZATIONSCO43 – Hudson Highlands Environmental Consulting 

Companies and Or

CO43-1

See the response to comment FA1-1 regainformation.

CO43-2

S-697
The FERC invited both the PADEP and t

participate in the development of the EIS in August 2012 (http://elibrary.ferc.gov:0/idmws/file_list8039 and http://elibrary.ferc.gov:0/idmws/file_list.a8033). Neither agency opted to participatcooperating agency; however, both particconference calls between the FERC, reguApplicants during the pre-filing period. 

COMPANIES AND ORGANIZATIONSCO43 – Hudson Highlands Environmental Consulting (cont’d) 

Companies and Or

CO43-3

See the response to comment LA7-5. Furneed approach for agencies will vary for a example, a resource or land managing ageown projects, or oversee projects sponsorThis is very different from a regulatory agproposals for private sector project sponsresponse to comment LA7-5, a FERC EIS applicant’s stated purpose for a project bujustify or defend it. Only the FERC Comdecide whether a project is needed (e.g., iconvenience and necessity).

CO43-4

S-698
COMPANIES AND ORGANIZATIONS

CO43 – Hudson Highlands Environmental Consulting (cont’d) 

Companies and Or

See the response to comments LA7-5, COregarding the need of the proposed projeccomment CO26-11 regarding induced devresponse to comment FA4-46 regarding tproject.

CO43-5

S-699
COMPANIES AND ORGANIZATIONS

CO43 – Hudson Highlands Environmental Consulting (cont’d) 

Companies and Or

See the response to comment CO2-1. As 3.2 and 3.3 of the EIS, we evaluated multand major collocated alternatives that woneed for greenfield construction. 

CO43-6

See the response to comment CO41-38. A4.2.4 of the EIS, Constitution would emptechniques and prevent the mixing of topsrock in agricultural areas. Soil identified would be mitigated in two phases. In the contractor would deep rip and rock pick ttillage device. Stones that are larger than removed from the subsoil area being rippfollowing topsoil replacement would empthe soil to a depth of 20 to 22 inches. Adwould conduct compaction tests and till csoils in agricultural and residential areas tparatills or similar equipment as identifieaddition, Constitution would employ agrimonitor each part of construction within aConstitution would monitor restoration of years following the initial in-service date 

CO43-7

See the response to comment CO2-1. We of pipelines with existing utilities where pthe value of collocation in regard to envirHowever, it is not always practical or feaan existing utility. In addition, our generadoes not necessarily mean that another utcollocated with the proposed projects. No other applicant has entered the FERCa different project that would be collocatepipeline. However, we are aware that TGof evaluating a separate project that if procollocated with the Constitution pipeline. discussion of this project in sections 3 and 

CO43-8

S-700
COMPANIES AND ORGANIZATIONS

CO43 – Hudson Highlands Environmental Consulting (cont’d) 

Companies and Or

The FERC issued an environmental inforConstitution on May 14, 2014 regarding tHDD at the subject property. See section additional assessment and updated informWe note that the Kernan Trust has denied property, which includes geotechnical inv

CO43-9CO43-10 See the response to comments LA7-5 and 

S-701
COMPANIES AND ORGANIZATIONS

CO43 – Hudson Highlands Environmental Consulting (cont’d) 

Companies and Or

CO43-11 See the response to comment CO4-2.

The commentor’s statements regarding thof alternative routes is noted. Typically, conducted for alternative routes unless thexhibiting a strong potential to be preferaroute based on desktop information.

S-702

CO43-12
COMPANIES AND ORGANIZATIONS

CO43 – Hudson Highlands Environmental Consulting (cont’d) 

Companies and Or

CO43-13 See the response to comment CO42-41. 

The NYSDOT regulations indicate that phighway at a depth of 60 inches below thconclude that due to traffic disruption and issues, it is not feasible to install the pipelalong the length of or along extended segthe response to comment CO37-15. 

CO43-15

Section 3.0 of the EIS evaluated alternativthe projects’ objectives. One of the objecfrom Susquehanna County, Pennsylvania Compressor Station. Therefore, all alternrequired to end at the Wright Compressor 

CO43-14

The citation for the statement in section 3been corrected. As stated in the NYSDONon-Communication Utilities on New YoControl of Access Right-of-Way, “all excshow that alternate locations are not feasiimplemented from a standpoint of providservices in a manner conducive to safety, of maintenance and operations.” Therefoalternative M is still applicable.

CO43-16

S-703
COMPANIES AND ORGANIZATIONS

CO43 – Hudson Highlands Environmental Consulting (cont’d) 

Companies and Or

CO43-17 The commentor’s statements regarding al

The statements made in section 3.4.1.2 of safety apply to both construction crews anusing the roadway during construction. Tof the reasons, not the sole reason, that alrejected.

CO43-18

S-704
COMPANIES AND ORGANIZATIONS

CO43 – Hudson Highlands Environmental Consulting (cont’d) 

Companies and Or

CO43-19 See the response to comment CO5-6.

The FERC does not necessarily require an survey alternative routes. Therefore, deskused so as to compare similar data. It is einherent discrepancies in the desktop data data would apply to both the proposed rouroute equally. In addition, as noted in appcrossed by the proposed projects), tables mixture of field delineated wetlands (whibeen verified by the COE) and desktop daConstitution did not have survey permissicertificated, then Constitution must survesurveyed parcels (access might have to be cases), and those new field data would be to supplant and refine the data originally sources. 

CO43-20

S-705
COMPANIES AND ORGANIZATIONS

CO43 – Hudson Highlands Environmental Consulting (cont’d) 

Companies and Or

See the response to comment CO5-6 regaquantitative data. As stated in section 3.0 alternatives data comparison was obtaineWhere environmental data was presented analysis, it was data collected from desktoliterature, aerial photography, and agency Each alternative was considered to the pothat the alternative was either not reasonasubstantially greater environmental impacreadily mitigated, offered no significant padvantages over the proposed projects, or projects’ objectives. Alternatives that appthan or similar levels of environmental imgreater detail. Section 3.0 of the EIS disceach of the alternatives evaluated in suffiwhy they were eliminated from further corecommended for adoption into the respe3.0 of the EIS presented a table of factors route. Subjective assessments are used in evaluadisparate parameters that are difficult or ia simple decision-making formula for an These parameters do not always have equassessment with factors such as overall dilength, amount of acreage to be disturbed(forest impacts), impacts on state or feder(streams, wetlands-particularly PFO wetlsafety or constructability (side slope consmore weight than factors with short-term row crops or hayfields), non-regulated resor other factors (number of roads and railslopes are typically more problematic for than steep slopes. We have updated sectithe general process of our assessment and considerations.

CO43-21

S-706
COMPANIES AND ORGANIZATIONS

CO43 – Hudson Highlands Environmental Consulting (cont’d) 

Companies and Or

As acknowledged in the draft EIS on pagof alternative M segment 5/6, there are beassociated with both options. The proposconsiderably shorter, thereby disturbing lwould affect less PFO wetlands, waterbodwith drinking water designations), nearby slopes. Alternative M segment 5/6 would collocated with adjacent rights-of-way anforest interior, Audubon forest blocks of iowners, and shallow bedrock. Overall forelatively similar. Given the relative beneassociated with the two options on a comconcluded that alternative M segment 5/6 the proposed route segment. 

CO43-21 (cont’d)

See the response to comment FA1-1. Anprior to the end of the draft EIS comment incorporated into this EIS. Any informatconstruction will be filed on our e-Library available to the public. Therefore, all infoavailable for public review. Constitutionrequest was filed on our e-Library system (http://elibrary.ferc.gov:0/idmws/file_list2518).

CO43-22

S-707
COMPANIES AND ORGANIZATIONS

CO43 – Hudson Highlands Environmental Consulting (cont’d) 

Companies and Or

S-708
COMPANIES AND ORGANIZATIONS

CO43 – Hudson Highlands Environmental Consulting (cont’d) 

Companies and Or

S-709
COMPANIES AND ORGANIZATIONS

CO43 – Hudson Highlands Environmental Consulting (cont’d) 

Companies and Or

CO43-23 See the response to comment CO4-2.

As stated in section 3.4.3.1, appendix H-1 number, location, assessment, status of ththe proposed route, and landowner resoluminor route variation identified to Constisection 3.4.3.2, appendix H-2 details the passessment, status of the alternative relatiroute, and landowner resolution status for variation as a result of comments we receaffected landowners. See the response to 

CO43-24CO43-25 See the response to comment CO12-3.

S-710
COMPANIES AND ORGANIZATIONS

CO43 – Hudson Highlands Environmental Consulting (cont’d) 

Companies and Or

See the response to comment FA1-1. We recommendation in section 5.2 of the EIS written authorization from the Director of construction of their respective project fashould file documentation that they have authorizations required under federal law thereof). Section 4.3.3.5 of the EIS has bprotective measures for waterbodies that crossed by the pipeline but would be withright-of-way. Additionally, we concluded Constitution’s Procedures would minimizwaterbodies.

CO43-26

S-711
COMPANIES AND ORGANIZATIONS

CO43 – Hudson Highlands Environmental Consulting (cont’d) 

Companies and Or

CO43-27 See the response to comments FA1-1 and 

S-712
COMPANIES AND ORGANIZATIONS

CO43 – Hudson Highlands Environmental Consulting (cont’d) 

Companies and Or

S-713
COMPANIES AND ORGANIZATIONS

CO43 – Hudson Highlands Environmental Consulting (cont’d) 

Companies and Or

Field data have not yet been obtained in aaccess was denied by landowners. Data w“desktop” sources such as agency databasmaps, literature, and other available sourc

CO43-28CO43-29 See the response to comments CO5-10 an

If the project is certificated, then Constitupreviously un-surveyed parcels where accand this new field data would be used dursupplant and refine the data originally obtsources. Wetland impacts would be verifNYSDEC; these agencies would identify mitigation.

CO43-30

S-714
COMPANIES AND ORGANIZATIONS

CO43 – Hudson Highlands Environmental Consulting (cont’d) 

Companies and Or

CO43-31 See the response to comments CO5-10 an

As stated in section 4.4.3 of the EIS, Consegregate topsoil, restore contours, and usequipment or timber mats. Section 4.4.3 revised to state that wetlands would be teannual ryegrass during spring, summer, oAroostook (if available) winter rye would Permanent seed mixes can be found in CoWetland restoration would not be considethe affected wetland satisfies the current fwetland; vegetation is at least 80 percent documented for the wetland prior to conswetland areas that were not disturbed by crevegetation is used, the plant species comwith early successional wetland plant comecoregion; and invasive species an noxiouunless they are abundant in adjacent areas construction. Within 3 years after construwould file a report identifying the status oany wetlands where revegetation is not suyears, it would develop and implement (in professional wetland ecologist) a remediaactively revegetate the wetlands and contrevegetation is successful. In our experierestored using methods outlined in our Pr

CO43-32

S-715
COMPANIES AND ORGANIZATIONS

CO43 – Hudson Highlands Environmental Consulting (cont’d) 

Companies and Or

See the response to comment FA6-10. Indiscussed in section 4.5.4 of the EIS and wsection with new information and recommmonitoring and preventing the spread of i

CO43-33

See the response to comment CO43-36. Aof the EIS, the Pennsylvania ECP (Volumthe New York ECP (Volume II Appendix http://elibrary.ferc.gov/idmws/file_list.asp01.

CO43-34

See the responses to Dr. Blossey’s letter ithrough CO24-4. The commentor’s stateRoundup Rodeo is noted. As stated Consherbicide use would be conducted in accoregulations and manufacturer’s recommen

CO43-35

S-716
COMPANIES AND ORGANIZATIONS

CO43 – Hudson Highlands Environmental Consulting (cont’d) 

Companies and Or

The commentor’s statements regarding wnoted. As stated in section 4.4.5 of the EImitigation for the pipeline would be deterNYSDEC, and the PADEP.

CO43-36

Section 4.4.5 of the EIS contains the mosavailable regarding wetland mitigation.

CO43-37

As stated in section 4.4.6 of the EIS, Conto its ECPs and Procedures. As stated in Constitution’s Pennsylvania ECP (VolumNew York ECP (Volume II Appendix J) chttp://elibrary.ferc.gov/idmws/file_list.asp01. A copy of our Procedures containing modifications can be found in Appendix K http://elibrary.ferc.gov/idmws/file_list.asp01. If the project is certificated, then Conrequired to survey all previously un-survemight have to be obtained in some cases)data would be used during permitting to sdata originally obtained from desktop souwould be verified by the COE, the PADEand these agencies would identify any appThe level of mitigation required by the COthe PADEP for unavoidable impacts wouwetland delineations including field assesnot currently surveyed. Our Procedures rdemonstrated to be functional and re-vegerestoration to be considered complete. 

CO43-38

S-717
COMPANIES AND ORGANIZATIONS

CO43 – Hudson Highlands Environmental Consulting (cont’d) 

Companies and Or

The commentor’s statement regarding forWe agree that the reduction in right-of-weliminate the fact that the pipeline would forested segments. See the response to co

CO43-39

Crews would utilize different construction wetland than in upland forests. Reductionwidths are generally only feasible for shoalways require extra workspace to store ththe trench. Most upland forest crossings than wetland crossings, requiring an even workspaces, which still may have to be sinegating any perceived benefit. Within wof the right-of-way can be reduced by the method to float the pipeline into place. Tused in upland areas. Specialized crews awetland areas to minimize the amount of construct. While similar reductions could tracts, these reductions in right-of-way wconsuming and increase the likelihood of and vertical slopes can also create the neeof-way width to safely construct the pipelwidth would be in the temporary right-of-long-term impacts on trees, but the forest fragmented by the permanent right-of-wa

CO43-40

The commentor’s statement regarding cosupport the collocation of pipelines with epractical and recognize the value of colloenvironmental resources. However, it is nfeasible to collocate with an existing utilicomment CO43-8.

CO43-41

S-718
COMPANIES AND ORGANIZATIONS

CO43 – Hudson Highlands Environmental Consulting (cont’d) 

Companies and Or

See the responses to Dr. Blossey’s letter ithrough CO24-4. 

CO43-42CO43-43 See the response to comment FA4-29.

See the response to FA6-11 regarding accproposed meter stations. See section 2.1 information on the cathodic protection be

CO43-44

S-719
COMPANIES AND ORGANIZATIONS

CO43 – Hudson Highlands Environmental Consulting (cont’d) 

Companies and Or

As stated in appendix D of the EIS, the prworkspaces would account for 107.4 acrestated by the commentor. As stated in apareas would be needed due to road crossinslopes, utility crossings, waterbody crossicrossings. As stated in the Executive Sumworkspaces would account for 5.8 percenthe pipeline’s impacts.

CO43-45

The workspace at MP 90.8 is labeled “wethe crossing of wetland DE-1P-W128 as dof the Kernan property boundary. Any wKernan property have not been delineated lack of survey permission. If the project Constitution must survey all previously uincluding the Kernan parcel, (access mighsome cases), and these new field data woupermitting to supplant and refine the data from desktop sources. This process may the size, location, or shape of proposed wthe construction right-of-way is currently or 110 feet wide indicating its presence wdetermined by desktop data due to lack of width may later be adjusted based on field with wetland requirements (i.e., 75 feet w

CO43-46

S-720
COMPANIES AND ORGANIZATIONS

CO43 – Hudson Highlands Environmental Consulting (cont’d) 

Companies and Or

CO43-47 Section 2.3.2.6 of the EIS has been revise

See the response to comments FA4-45 aninduced development.

CO43-48

As stated in section 1.3 of the EIS, the FEConstitution’s request to enter pre-filing opurpose of the pre-filing process is to encinvolvement of interested stakeholders, facooperation, and identify and resolve issuapplication is filed. Constitution filed its 2013. During this almost 14-month-long reviewed and evaluated Constitution’s plathe formal application being filed. Our coof the NEPA process resulted in or facilitchanges, modification of aboveground facmitigation, and avoidance of certain resou

CO43-49

S-721
COMPANIES AND ORGANIZATIONS

CO43 – Hudson Highlands Environmental Consulting (cont’d) 

Companies and Or

S-722
COMPANIES AND ORGANIZATIONS

CO44 – New York State Council of Trout Unlimited 

Companies and Or

The commentor’s statements requesting inoted. The Commission will make a detegrant a party’s intervention status. The coadded to the distribution list as an interve

CO44-1

S-723
COMPANIES AND ORGANIZATIONS

CO44 – New York State Council of Trout Unlimited (cont’d)

Companies and Or

S-724
COMPANIES AND ORGANIZATIONS

CO44 – New York State Council of Trout Unlimited (cont’d)

Companies and Or

S-725
COMPANIES AND ORGANIZATIONS

CO45 – Bluestone Pipeline Company

Companies and Or

The commentor’s general support of the pnoted. As stated in section 2.3.1 of the EIproject would cross underground utilities Prior to construction, Constitution’s contrthe “Call Before You Dig” or “One Call” utility operators, to verify and mark all un(e.g., cables, conduits, and pipelines) alonminimize the potential for accidental damconstruction. As stated in section 4.12.1 indicated it would reimburse the landowndamage to their property as a result of an operation of the proposed pipeline. Accocompensation would include but is not limrepair, rental, or straight compensation fo

CO45-1

S-726
COMPANIES AND ORGANIZATIONS

CO45 – Bluestone Pipeline Company (cont’d)

Companies and Or

As stated in section 4.1.5 of the EIS, adjamanned at valves in case of an emergency operations. As stated in Constitution’s B(Attachment 10 of their New York ECP http://elibrary.ferc.gov:0/idmws/file_list.a0901), “All necessary "one calls" will be hours prior to blasting activities or as requsystem(s). All property owners would be construction before any right-of-way worperformed. Constitution’s contractor wousubmit a detailed site-specific Blasting Speach section of the project where blasting necessary. The site-specific plan must indistance and orientation to nearest undergincluding pipelines.

CO45-2

The commentor’s request is noted. Howeregarding cooperation by Constitution anregarding future collocation or other simiwould be determined by negotiations betwby the FERC. Bluestone Companies pipesubject to the jurisdiction of the FERC; thauthority over siting of its pipelines.

CO45-3

As stated in table 2.2.1-1 of the EIS, the pbe adjacent, but not within Bluestone’s exAlignment sheets can be found at http://elibrary.ferc.gov:0/idmws/file_list.a0901. If approved, final alignment sheets construction in Constitution’s Implement

CO45-4

The commentor’s statement regarding Conoted. During construction, an interested inquire the company affiliation of the crew personnel. The commentor’s request for to be included is noted. 

CO45-5

S-727
COMPANIES AND ORGANIZATIONS

CO45 – Bluestone Pipeline Company (cont’d)

Companies and Or

S-728
COMPANIES AND ORGANIZATIONS

CO46 – Schenevus Central School

Companies and Or

Impacts on traffic are discussed in section pipeline would be located approximately Schenevus Central School. Interstate 88, major conduit for construction-related traschool. Additionally, proposed contractoDavenport, New York are also well southschool. Given the proximity of the contraconstruction right-of-way to each other, wschool, we conclude that extensive truck expected near the school. 

CO46-1

S-729
COMPANIES AND ORGANIZATIONS

CO47 – Concerned Citizens of Trout Creek

Companies and Or

The FERC takes the safety record of any company very seriously. To minimize thincidents may occur, the DOT is responsitaking enforcement actions on issues founpipelines. Since 2008, the DOT has signiinspection and enforcement personnel by its ability to ensure that operators are held complying with pipeline safety laws. The Regulatory Certainty and Job Creation Acwas passed by Congress and signed into lby President Barack Obama. The Act dogive authorization for the DOT to hire adinspectors. The agency is also taking othauthority to improve pipeline safety, inclurequesting $255.3 million for pipeline safAdministration's 2014 budget proposal to additional inspectors, increased coordinatsafety programs, and increasing pipeline 4.12 of the EIS regarding pipeline safety.By signed agreement with the Office of Pthe USDOT-PHMSA), the state inspects hazardous liquid pipeline operators in Necertification by the OPS, the state inspectpipeline safety regulations for intrastate gpipeline operators in New York. This woNew York Public Service Commission. http://primis.phmsa.dot.gov/comm/FactShPL_Safety_Regulatory_Fact_Sheet.htm.

CO47-1

S-730
COMPANIES AND ORGANIZATIONS

CO47 – Concerned Citizens of Trout Creek (cont’d)

Companies and Or

S-731
COMPANIES AND ORGANIZATIONS

CO48 – Concerned Citizens of Trout Creek 

Companies and Or

Impacts due to truck traffic are discussed EIS. See the response to comment CO16

CO48-1

S-732
COMPANIES AND ORGANIZATIONS

CO49 – Unatego Area Landowners Association

Companies and Or

The commentor’s statement in support of noted. The commentor’s statement regarrather than an easement is noted. Compethat would be affected by the proposed pidiscussed in section 4.8.2 of the EIS. 

CO49-1

S-733
COMPANIES AND ORGANIZATIONS

CO49 – Unatego Area Landowners Association (cont’d)

Companies and Or

S-734
COMPANIES AND ORGANIZATIONS

CO49 – Unatego Area Landowners Association (cont’d)

Companies and Or

S-735
COMPANIES AND ORGANIZATIONS

CO50 – Kernan Land Trust

Companies and Or

Section 3.4.3 of the EIS has been revised regarding the Kernan Land Trust property potential impact avoidance, minimizationmeasures.

CO50-1

S-736
COMPANIES AND ORGANIZATIONS

CO50 – Kernan Land Trust (cont’d)

Companies and Or

The Executive Summary is high-level sumnot intended to replace details, statementsthroughout the EIS. A full analysis of the compared to Alternative M, including subalternative M segments, is included in sec

CO50-2

S-737
COMPANIES AND ORGANIZATIONS

CO50 – Kernan Land Trust (cont’d)

Companies and Or

CO50-3 See the response to comment CO26-7.

The complete sentence in the Executive S“Constitution and Iroquois would seek apconstruction of their projects as soon as pall necessary federal authorizations.” Furthat Constitution and Iroquois would be rall federal permits and approvals required proposed projects prior to construction reappear in table 1.5-1 of the EIS. The FERauthorization for construction until it has sponsor has obtained all applicable permi

CO50-4

The projects were not proposed by the FEfederal regulatory agency responsible for to construct and operate interstate natural The FERC is an advocate for the environmand is not an advocate for the proposed prindependent regulatory agency, it would bFERC to attempt to create support for a pfollows its guidelines to encourage public meetings, notices, informational handoutssection 1.0 of the EIS. However, the extelandowner or public citizen supports the pinvolved with the environmental review pchoice. 

CO50-5CO50-6 See the response to comment FA1-1.

Permit conditions that may be imposed by and the NYSDEC are not evaluated by thconditions are the responsibility of those and any notice to the public would be the agencies and is outside of the scope of the 

CO50-7

S-738
COMPANIES AND ORGANIZATIONS

CO50 – Kernan Land Trust (cont’d)

Companies and Or

The Executive Summary has been revised discussion was about agency or otherwise quality wildlife habitats. We recognize thproposed route could also contain high qu

CO50-8CO50-9 See the response to comments FA4-29 an

The Executive Summary has been revised “raptor” was used to describe bald eagles

CO50-10

Typically for large projects, not all surveycompleted prior to construction. For examfor surveys to be completed on parcels whbeen denied by individual landowners uncertificates the project. 

CO50-11

The Executive Summary has been revised species discussion. See the response to coregarding long-term monitoring of the pipinvasive species. 

CO50-12

S-739
COMPANIES AND ORGANIZATIONS

CO50 – Kernan Land Trust (cont’d)

Companies and Or

Deeper than standard burial of the pipelinimpact minimization measure that Constievaluated, but has since removed from colocation, due to technical in-feasibility. Thas been edited to reflect Constitution’s cspecifically asked Constitution if this impmeasure could be used on the Kernan Lanenvironmental information request dated Constitution responded that a significantlconstruction workspace, resulting in increimpacts, would be required to accommodand associated soil stockpiles, negating anthe technique. We concur with this asses

CO50-13

S-740
COMPANIES AND ORGANIZATIONS

CO50 – Kernan Land Trust (cont’d)

Companies and Or

As stated in table 4.9.7-1 of the EIS, Conwould pay almost 13 and 1.5 million dollproperty taxes annually due to operation o4.9.5 has been updated with new informaproperty values. The Executive Summary clarify that the mention of highly variable regarding property insurance. The potentprojects upon property insurance (includito ensure that any impacts are mitigated) discussed in sections 4.9.6 and 4.9.5 of thThese sections have been updated for the 

CO50-14CO50-15 See the response to comment FA4-3.CO50-16 See the response to comment SA2-1.

See the response to comment CO50-4. Athe EIS and in relation to table 1.5-1 whicfederal, state, and local permits, “Constituwould be responsible for obtaining all perrequired to implement the proposed projeregardless of whether they appear in this 

CO50-17CO50-18 See the responses to comments CO42-7 a

S-741
COMPANIES AND ORGANIZATIONS

CO50 – Kernan Land Trust (cont’d)

Companies and Or

The Constitution pipeline was routed and natural gas from supply areas in SusquehaPennsylvania to Schoharie County (Wrighthe natural gas would then be connected tpipelines for delivery to downstream marto supply local municipalities in betweensecondary opportunity is a possibility now Leatherstocking in coordination with Conresponses to comments SA4-1 and SA4-2 M. 

CO50-19

As stated in the footnote, precedent agreecontracts. However, if a proposed projecregulatory or permitting agencies, then obcould not be built and the precedent agreeacknowledge such a circumstance. 

CO50-20

S-742
COMPANIES AND ORGANIZATIONS

CO50 – Kernan Land Trust (cont’d)

Companies and Or

CO50-21 See the responses to comments FA1-1, FA

Section 1.2 of the EIS provides a summarthere is no survey permission. Constitutiupdate that, “landowners have signed eas50% of the right-of-way”. The specific remay or not choose to sign an easement arthe EIS.

CO50-22

S-743
COMPANIES AND ORGANIZATIONS

CO50 – Kernan Land Trust (cont’d)

Companies and Or

The commentor’s statements regarding Ceminent domain are noted.

CO50-23CO50-24 See the response to comment FA1-1.

See the response to comment LA7-5 and purpose and objectives help define the scanalysis, not the project’s purported need

CO50-25

Section 1.2 of the EIS provides informatiagencies that participated in development provides a list of permits and approvals thobtain from the NYSDEC.

CO50-26

The commentor’s statements regarding thnoted. As stated in section 1.3 of the EISthan the FERC, held the open house meettook the opportunity to attend these meetiinformation about the FERC process, but the meetings. 

CO50-27

S-744
COMPANIES AND ORGANIZATIONS

CO50 – Kernan Land Trust (cont’d)

Companies and Or

Section 1.3 states that 101 people commemeeting. This is not the number of persoSection 1.3 further states that the notice owas mailed to more than 2,100 interested federal, state, and local government repreelected officials; environmental and publiNative American Tribes; affected propertinterested parties; and local libraries and nto which any given individual wishes to penvironmental review process is a personnumber of comments on the projects were mail, or electronically. 

CO50-28

The FERC staff typically conducts periodprospective applicants and permitting agefiling phase of projects (i.e., before an apppurpose of these calls is two-fold, to keep the status of a forthcoming application anidentification and possible resolution of iapplication is filed, regular conference cacontinue. The FERC staff actively partichouse meetings sponsored by Constitution extensively with landowners, stakeholderthese meetings. In addition, the FERC alscoping meetings to solicit input from the publication of the draft EIS, and four mormeetings following publication of the draFERC staff participated in 15 meetings wpublic. The FERC staff also met directly the Kernan Land Trust to discuss issues aproperty. As also indicated in Kernan famFERC staff spoke with members of the Kmultiple occasions. See also the response and CO4-2. 

CO50-29

The commentor’s statements regarding alnoted. The FERC cannot comment directallegedly made by Constitution to the KerHowever, route alternatives and minor ropossible at any time during the environmeevidenced by our May 14, 2014 environmrequest to constitution to assess multiple mnear the Kernan land Trust property. The route variations is also possible post-Certof construction, although those scenarios the discovery of unanticipated site-specifright-of-way. 

CO50-30

S-745
COMPANIES AND ORGANIZATIONS

CO50 – Kernan Land Trust (cont’d)

Companies and Or

CO50-31 See the response to comment FA1-1.CO50-32 See the response to comments FA1-1 and 

S-746
COMPANIES AND ORGANIZATIONS

CO50 – Kernan Land Trust (cont’d)

Companies and Or

Section 2 of the EIS describes the proposdescribe impacts. As stated in section 4.5lands within the maintained right-of-way converted to an herbaceous cover type. Tregrowth of shrubs and trees within the temay take decades before these areas resemvegetation that was present before construto comment CO1-4 regarding forest fragm

CO50-33

Proposed right-of-way widths and extra won Constitution’s alignment sheets availahttp://elibrary.ferc.gov:0/idmws/file_list.a0901. Variable right-of-way widths, inclureasons why the right-of-way may be explocations, are discussed in section 2.2.1.2 evaluate expanded workspace areas for bowetlands on case-by-case basis, including utility crossings, need for spoil storage, sttrenchless crossing workspaces, and other proposed expanded right-of-way widths iin section 4.4.4 of the EIS.

CO50-34

The EIS discusses all extra workspaces thAs stated in section 2.2.1.3 of the EIS, adworkspaces could be identified just prior construction or during construction of the Constitution request changes to the worksEIS, it must file those for our review and workspaces that arise after the start of conhandled via the FERC’s variance process provision for landowner approval) as discthe EIS.

CO50-35

The FERC does not design pipeline projespecification of the exact type of MLV to knowledge and expertise necessary to evacomponents, including MLVs. We work Hazardous Materials Safety Administratioensure that all pipeline projects, including and built to the applicable laws, regulatioBecause project design is the responsibilisponsor, we solicit specific information frConstitution to answer our own questions from other agencies and the public.See the response to comment SA2-1 regacommunication towers.

CO50-36

S-747
COMPANIES AND ORGANIZATIONS

CO50 – Kernan Land Trust (cont’d)

Companies and Or

CO50-37 See the response to comment FA4-46.

Spills are a possibility with the constructiproject. See the response to comments CSection 3.4.3 of the EIS has been revised regarding the Kernan Land Trust property NYSDEC-regulated wetlands) and our asimpact avoidance, minimization, and miti

CO50-38

See the response to comment FA4-9. The included in section 4.5 of the draft EIS: “potential spread of invasive species, Consstate-specific Invasive Species Managemwith the applicable state regulatory agencNYSDEC, and the NYSDAM). The Manmeasures designed to control invasive plaproject construction and operation througherbicides, installation of wash stations to have traversed infested areas, and rapid refollowing installation of the pipeline, whiestablishment of desirable plant species aunwanted plant species. Constitution woumonitoring and apply herbicide, as needeconstruction, if Constitution’s operationaidentifies unsuccessful revegetation or pocolonization, it would conduct additional management, such as herbicide applicationon-native vegetation, and consultation wIf deemed necessary, Constitution would along the right-of-way in accordance with manufacturer’s recommendations to contrvegetation.” See the response to commenlong-term monitoring of the pipeline righspecies. 

CO50-39

S-748
COMPANIES AND ORGANIZATIONS

CO50 – Kernan Land Trust (cont’d)

Companies and Or

As stated in section 2.3.1 of the EIS, in arrock, the minimum amount of cover woulentire sentence within section 2.3.1 of the agricultural areas rock would not be used 24 inches in mesic soil or 30 inches in friconstruction surface of the right-of-way, be disposed of at a landfill or recycling faapproved purposes within the right-of-waor site access control) as allowed by the lapplicable permits.” The Kernan Land Tclassified as agricultural land. 

CO50-40

S-749
COMPANIES AND ORGANIZATIONS

CO50 – Kernan Land Trust (cont’d)

Companies and Or

The phrase “mitigate any damages caused used in the context of water wells that couconstruction. Constitution has committed (section 4.3.2.1 of the EIS). Section 3.4.3 revised with new information regarding thproperty and our assessment of potential minimization, and mitigation measures.

CO50-41

See the response to comment CO5-10 regand Mud Pond wetland complexes. The Efor approving imported soils (if needed) asoil is certified free of noxious weeds and otherwise specified by the landowner, as the EIS. Our Plan states “Fertilize and a

in accordance with written recommenfrom the local soil conservation authomanagement agencies, or landowner.

would have the opportunity to coordinate regarding potential alterations to soil pH.

CO50-42

Section 4.1.1.2 of the EIS includes a discugeotechnical feasibility studies for the procrossings. Section 4.3.3.4 of the EIS inclfeasibility of using a trenchless crossing mhigh quality waterbodies. 

CO50-43

Construction across a local or county road from crossing or constructing within an instated in section 3.4.1.2 of the EIS, disrupduring blasting is one of the issues identifRoad crossings (not interstate highways) areas can typically be staged to allow for during construction, timed for off-peak pemanaged to prevent or limit impacts on m

CO50-44

S-750
COMPANIES AND ORGANIZATIONS

CO50 – Kernan Land Trust (cont’d)

Companies and Or

The EIS does not indicate that there are ewith winter construction. Section 2.3.2.6 Winter Construction Plan was developed methods and procedures that would be usduring the winter season, and address the ice when it becomes necessary. Constructhe winter is quite common and affords ceas avoiding bird nesting and fish spawnin

CO50-45

Section 3.0 of the EIS provides a comprehproposed route as compared to other alteralternative M.

CO50-46CO50-48 See the response to comment CO42-33.

Constitution determined its target in-servagreements with their shippers. A pipelinthe duration of construction by increasing construction spreads (see section 2.3.1). crew would not be rushed through construproject, rather multiple, additional crews simultaneously thereby completing constrdistinct segments along the route. Based status and schedule, it does not appear thaMarch 2015 is feasible. 

CO50-47

See the response to comment FA6-10 regmonitoring of the pipeline right-of-way fo

CO50-49

S-751
COMPANIES AND ORGANIZATIONS

CO50 – Kernan Land Trust (cont’d)

Companies and Or

See the response to comment CO5-10. Shas been revised with new information reLand Trust property and our assessment oavoidance, minimization, and mitigation m

CO50-50CO50-51 See the response to comment CO43-23.

Wetland impacts from the proposed route 4.4 of the EIS and impacts on interior forin section 4.5.3 of the EIS.

CO50-52

S-752
COMPANIES AND ORGANIZATIONS

CO50 – Kernan Land Trust (cont’d)

Companies and Or

As stated in section 3.1 of the EIS, the dethe northeastern United States is well docof adequate pipeline capacity to deliver renatural gas. It would be reasonable to assof natural gas supply” could mean a diffethe no-action alternative was chosen, then could be proposed in the same, similar, or the proposed projects. Also see the respo41.

CO50-53

References for existing natural gas supply discussed in section 3.1 of the EIS. Energin New York and New England are discuthe EIS. 

CO50-54

The full sentence in section 3.1 of the EIS section 4.9 for a full discussion of the potassociated with the proposed projects, incsecondary spending, and tax revenues durwell as increased property tax revenues to during operations. See the response to coregarding property values. As stated in seEIS, Constitution would repair any roads pipeline project.

CO50-55

As stated in section 3.4.1.1 of the EIS, the Constitution’s decision to deem alternativrequested that Constitution’s project not bYork City Water Supply Watershed. Secadditional reasons why alternative K was a significant environmental advantage ovsuch as more impacts on Important Bird Astreams designated as drinking water supp

CO50-56

S-753
COMPANIES AND ORGANIZATIONS

CO50 – Kernan Land Trust (cont’d)

Companies and Or

The quantitative data used to compare the alternative K route can be found in table 3data provided in this table were used to dtext in the section.

CO50-57

As depicted in table 3.4.1-1 of the EIS, in crossings of Important Bird Areas and FoImportance, alternative K would cross momore forest edge habitat. As stated in secaccording to Audubon New York, Importtypically discrete habitats that provide essspecies including sites for breeding, migroverwintering. These areas also typically birds that are under regulatory protectionconsidered at risk or especially vulnerable places where large numbers of birds may Blocks of Importance are contiguous blocproviding habitat for many wildlife specieaddition to the total miles of blocks crossby alternative K are larger, more contiguocrossed by the proposed route.

CO50-58

See the response to comment CO2-1. We of pipelines with existing utilities where pthe value of collocation in regard to envirHowever it is not always practical, feasibpreferable to collocate with an existing utsection 3.4.1.1 of the EIS, collocation of aexisting utility lines could result in a corr200 and 325 feet whereas the proposed prtypical construction right-of-way of 125 f

CO50-59

Constitution’s statements regarding alternto the schedule and rendering the project factor that was considered, but it was not factor. If an alternative route was otherwclear environmental advantages over the pproject timing and schedule would not be See the response to comment CO43-23 redata for the alternatives analysis.

CO50-60

S-754
COMPANIES AND ORGANIZATIONS

CO50 – Kernan Land Trust (cont’d)

Companies and Or

See the response to comment CO43-23 redata for the alternatives analysis. Section provides an analysis of placing the pipelinI-88 and placing the pipeline adjacent to Icontrolled access areas managed by the N

CO50-61

Constitution filed a response to RecommeApril 8, 2014 (http://elibrary.ferc.gov:0/idmws/file_list2518). On May 14, 2014 we requested thadditional crossing methods for the Kernaalso a suite of alternative routes based on land Trust and its agents. Constitution reand its response can be viewed at http://elibrary.ferc.gov:0/idmws/file_list.a2572. Section 3.4.3 of the EIS has been information regarding the Kernan Land Tassessment of potential impact avoidancemitigation measures. 

CO50-62

S-755
COMPANIES AND ORGANIZATIONS

CO50 – Kernan Land Trust (cont’d)

Companies and Or

See the response to comment SA2-1 regacommunication towers.

CO50-63

Section 4.1.1 of the EIS has been revised was discussing two separate topics: overasurficial geology. 

CO50-64

All of the alternative routes discussed in sincluded evaluation of steep slopes, shalloof waterbody crossings. In addition, sectprovides information regarding specific mfollowed for areas of steep slopes. Descrlocalized topography along 124 miles of pbeyond the scope of this EIS. However, sissues are discussed within the EIS (such the EIS) and listed (appendix G) where ap

CO50-65CO50-66 See the response to comment CO41-11.

S-756
COMPANIES AND ORGANIZATIONS

CO50 – Kernan Land Trust (cont’d)

Companies and Or

Section 4.1.3.8 of the EIS states that the ewould cross 45.5 miles of shallow depth trequire blasting. As depicted in table 3.4Segment 5/6 would cross 29.7 miles of shHowever, the corresponding segment of twould cross 0.2 mile less shallow depth talternative M Segment 5/6. The alternatisection 3.0 do not provide an analysis of troute. They are an analysis of the segmenwhich corresponds to the area of the propaddition, as stated in section 4.1.3.8 it is eportion of the bedrock would be ripped usexcavation techniques and that blasting w

CO50-67

See the response to comment CO5-4. In we recommend that prior to construction, with the Secretary the results of any outstYork and Pennsylvania federal and state-identify additional mitigation measures dwith the applicable federal and state agenfederal and state agencies would be most Constitution with development of protectfor these species. This recommendation wlikely to adversely affect determinations. response to comment FA4-3 regarding su

CO50-68

As described in section 2.3.1 of the EIS, bbroken up and removed where practical bthe rock with a pointed backhoe attachmewith a backhoe. If rock cannot be removehammering, then blasting may be requireareas where shallow depths to bedrock oc

CO50-69CO50-70 See the response to comment CO50-68.

S-757
COMPANIES AND ORGANIZATIONS

CO50 – Kernan Land Trust (cont’d)

Companies and Or

See the response to comment SA1-2. Conupdate on June 3, 2014 for a reroute extenMP 30.53 designed to avoid the landslide 

CO50-71CO50-72 See the response to comment CO1-5.CO50-73 See the response to comment LA10-1.

S-758
COMPANIES AND ORGANIZATIONS

CO50 – Kernan Land Trust (cont’d)

Companies and Or

See the response to comment CO1-5. See comment CO41-16 regarding erosion conconstruction and restoration, Constitution install and maintain erosion and sediment minimize erosion and stormwater runoff. been completed, the vegetation covering tway, as well as features such as permanenminimize stormwater runoff and erosion. damage from construction of the proposeanticipated. 

CO50-74

Although shallow bedrock is anticipated tthe Kernan Land Trust property, it is uncloccurs within 5.5 to 7.5 feet of the ground occur within the proposed trenching zonewould first attempt to remove the bedrock means such as ripping or hammering the backhoe attachment as described in sectioOnly if bedrock does occur within the trenot rippable using mechanical means, woevaluated. Constitution’s Blasting Plan rcontractor to also prepare a site-specific bincludes site-specific details and blasting would be tailored to ambient conditions adescribed in section 4.1.5 of the EIS. 

CO50-75

As stated in section 4.4.3 of the EIS, blasacross an estimated 1.6 miles of wetlandsmaintain the original wetland hydrology bspecific blasting plans tailored to the locatrench plugs, and restoring pre-constructi

CO50-76

The commentor’s statement regarding priAlternative M is noted.

CO50-77

S-759
COMPANIES AND ORGANIZATIONS

CO50 – Kernan Land Trust (cont’d)

Companies and Or

As stated in table 4.2.2-3 of the EIS, data soils were obtained from the NRCS rathe

CO50-78

As stated in section 4.2.4 of the EIS, in agsoils become saturated before topsoil segrAgricultural Inspector would either halt wconstruction to proceed as long as rutting determined depths. Our recommending awould be monitored by the Agricultural Ithird-party compliance monitors would althis recommendation.

CO50-79

See the responses to comments CO5-10 ((blasting). Section 3.4.3 of the EIS has binformation regarding the Kernan Land Tassessment of potential impact avoidancemitigation measures.

CO50-80

See the responses to comments CO5-10 ((minor route variations), and SA4-2 (alter

CO50-81

S-760
COMPANIES AND ORGANIZATIONS

CO50 – Kernan Land Trust (cont’d)

Companies and Or

See the response to comment FA6-10 regmonitoring of the pipeline right-of-way fo

CO50-82CO50-83 See the response to comment FA1-1.CO50-84 See the responses to comments CO5-10 (

S-761
COMPANIES AND ORGANIZATIONS

CO50 – Kernan Land Trust (cont’d)

Companies and Or

See the response to comment FA6-10 regmonitoring of the pipeline right-of-way fothe response to comment CO42-33 regardmonitoring of adherence to required mitigParty Letter and the Executive Summary staff has determined that approval of the psome adverse environmental impacts, but reduced to less-than-significant levels witimpact avoidance, minimization, and mitiproposed by the Applicants and with addiare recommending. As stated in section 4monitoring would be carried out until wetdeemed satisfactory by the FERC.

CO50-85

S-762
COMPANIES AND ORGANIZATIONS

CO50 – Kernan Land Trust (cont’d)

Companies and Or

See the response to comment CO5-10 (wof the draft EIS specifically mentioned thabout the Clapper and Mud Lakes wetlan

CO50-86

The discussion of interior forest in section been revised. 

CO50-87

S-763
COMPANIES AND ORGANIZATIONS

CO50 – Kernan Land Trust (cont’d)

Companies and Or

See the response to comment SA4-2 regaalternative M. See the response to commreduction in the right-of-way width.

CO50-88

We acknowledge that modified habitat tyfor some wildlife species, such as migratoforests, but can be a positive for other speedge habitats. Although the proposed rouundisturbed lands within the Kernan parcphotography indicated that several clearewith herbaceous or scrub habitat (which mdeer), along with access roads, already ocparcel, as would be expected within a “wsubject to selected tree harvest. 

CO50-89

S-764
COMPANIES AND ORGANIZATIONS

CO50 – Kernan Land Trust (cont’d)

Companies and Or

Constitution’s Preliminary Migratory BirPlan was filed on May 6, 2014 (http://elibrary.ferc.gov:0/idmws/file_list3683). The plan was developed in coordiand state agencies. The EIS has been updassessment of this draft plan. See the respFA4-29 and FA4-30 regarding mitigation adherence to the proposed mitigation. 

CO50-90CO50-91 See the response to comment FA1-1.CO50-92 See the response to comment CO50-68.

The commentor’s statements regarding Ceminent domain are noted.

CO50-93

S-765
COMPANIES AND ORGANIZATIONS

CO50 – Kernan Land Trust (cont’d)

Companies and Or

The commentor’s statements regarding Ceminent domain are noted. See the resporegarding easement negotiations.

CO50-94

See the response to comment CO50-22 relandowners that have signed an easement 

number or percentage of landowners who signed easement agreemtns is immaterial environmental review process.

CO50-95

See the response to comment CO50-62. Scomment FA6-10 regarding long-term moright-of-way for invasive species. 

CO50-96

S-766
COMPANIES AND ORGANIZATIONS

CO50 – Kernan Land Trust (cont’d)

Companies and Or

The commentor’s statement regarding the socioeconomic analysis is noted. Our levconsistent with the FERC standard (GuidEnvironmental Report Preparation, AuguOrder 12898, and CEQ guidance (CEQ 1for an adequate assessment of potential im

CO50-97

Section 4.9.1 of the EIS further states thawould result more than 325 local jobs and during construction. Section 4.9.5 has beinformation concerning property values. 4.9.2 of the EIS, the impacts on tourism dthe pipeline are expected to be minimal.

CO50-98

We concluded in section 4.9.5 of the EIS evidence that the presence of a pipeline reproperty values. Property taxes are discuthe EIS. Also, construction and operation expected to result in the loss of jobs or in

CO50-99

Constitution and the FERC have worked businesses that would be impacted by the in section 4.9.5 of the EIS, Constitution wlandowners at current market value for anmeasureable loss resulting from constructaddition, landowners would be compensatimber that is removed from their property As stated in section 4.8.2 of the EIS, an ebetween a company and a landowner typicompensation for losses resulting from colosses of non-renewable and other resourcduring construction, and long-term restricthat would not be permitted on the perma

CO50-100

S-767
COMPANIES AND ORGANIZATIONS

CO50 – Kernan Land Trust (cont’d)

Companies and Or

Table 4.9.3-1 of the EIS provides a summfire departments, police departments, schhospital beds in the area of the proposed pcontained in table 4.9.3-1 were used as ththat the public service infrastructure appeEmergency personnel would only be needaccident, thus anticipated demand cannot surmised.

CO50-102

The commentor’s statement regarding the landscape of the project area is noted. Vitourism are discussed in sections 4.8.6 anrespectively. There are existing linear prowithin the project area such as pipelines, as well as other developments. Outdoor rdiscussed in section 4.8.4 of the EIS, and quality are discussed in sections 4.3.2 and respectively. The commentor’s statemenfor second / retirement homes is noted as property values (and tax bases) would be sales regardless of whether they were primretirement residences, and are discussed i(property values) and 4.9.7 (tax bases) of has been updated with new information cvalues. 

CO50-101

S-768
COMPANIES AND ORGANIZATIONS

CO50 – Kernan Land Trust (cont’d)

Companies and Or

Section 4.9.5 has been updated with new property values.

CO50-104

The commentor’s statements regarding thprogram are noted. An analysis of the proscope of the EIS, as is an assessment of hmight attempt to generate public support 

CO50-103

S-769
COMPANIES AND ORGANIZATIONS

CO50 – Kernan Land Trust (cont’d)

Companies and Or

CO50-105 See the response to comment CO50-1

S-770
COMPANIES AND ORGANIZATIONS

CO50 – Kernan Land Trust (cont’d)

Companies and Or

As stated in table 4.9.7-1 of the EIS, the sproperty taxes during construction and opprojects was the Center for Governmentaand Iroquois would be assessed property and would make payments directly to the reached the conclusion that property valua direct result of the project, it is reasonabproperty taxes could increase as value of time, and therefore, the Applicants’ tax asalso rise. 

CO50-106

See the response to comment CO50-27 reopen house meetings.

CO50-107

See the response to comment CO29-1.Thstatement regarding the draft EIS commeThe FERC held four comment meetings tproposed projects. The panel instructed tall attending and speaking at the meetingsmore heavily attended than others. Becaumeetings was to obtain comments on the were called in their order of attendance to our scoping meetings preference for potenlandowners was given). The draft EIS copublic meetings and anyone is invited to awhether they support or oppose the projecconcerns), for whatever reasons that are pcomments, regardless of how they are proequally, appended to this EIS and directly staff.

CO50-108

S-771
COMPANIES AND ORGANIZATIONS

CO50 – Kernan Land Trust (cont’d)

Companies and Or

The commenters’ statements regarding hiproperty are noted. Historic resources are potential impacts are minimized or mitigacrews locate and document them. See the FA4-3 regarding pending surveys. We harecommendation in section 4.10.4 of the Ebegin construction (if approved) prior to csection 106 consultation. The landowner Constitution access to survey the parcel. regarding the project resulting in the likelforest unit, leading to the end of the Charowned and managed conservation unit, ancompensation would be sufficient are notEIS has been revised with new informatioLand Trust property and our assessment oavoidance, minimization, and mitigation m

CO50-109

The commentor’s statements regarding thincrease in Constitution’s capacity is noteinterstate natural gas transportation, availregional demand, a theoretical 31 percent delivery is modest. Section 4.13 of the Eregard to continuing natural gas supply in Pennsylvania. See the responses to commSee the response to comment LA9-4 regareserves.

CO50-110

The commentor’s statement is noted. Hoof the EIS states, within the last 20 years, has developed the horizontal drilling techwith hydraulic fracturing (fracking), whicover 50 years, to recover natural gas from statement already refers to hydraulic fractdrilling or high-volume hydraulic fracturiover 50 years.

CO50-111

S-772
COMPANIES AND ORGANIZATIONS

CO50 – Kernan Land Trust (cont’d)

Companies and Or

See the response to comment CO5-10 (wresponse to comment CO41-16 regarding the responses to comments CO7-2 and COConstitution’s spill plan. 

CO50-112

A description of Constitution’s proposed configurations can be found in section 2.2response to comment CO9-1 regarding in

CO50-113

The commentor’s statements regarding wimpacts are noted. The EIS acknowledgewould permanently be altered such as conmaintained, grassy right-of-way in some changes would affect wildlife. For exampEIS states that “The fragmentation of largconstruction and operation of the project impacts on BCCs (author note - birds of cby reducing available breeding, nesting, ainterior nesting species, such as the wood warbler, and Canada warbler, which are pproject area.” See the response to commeindirect effects to forest resulting from credge and updates to the EIS. During operwould mow up to a 50-foot-wide permanmore than once every three years; howevmay be mowed more frequently to facilitaemergency access. The mowing would bthe April 15 to August 1 window to avoid birds. As described in table 2.6-1 of the Einspections during operations would occumonths. We conclude that due to the timinfrequency of maintenance and inspectiowould be minimal. 

CO50-114

S-773
COMPANIES AND ORGANIZATIONS

CO50 – Kernan Land Trust (cont’d)

Companies and Or

Section 3.0 of the EIS provides a comprehproposed route as compared to other alteranalyses and justification for route compathere. 

CO50-115

As stated in section 4.9.1 of the EIS, the CResearch examined the economic benefitprojects, including providing an estimate and indirect jobs. As stated in section 4.9estimated seven new full-time, local emphired to operate the facilities on a permanof new, full-time positions would result in hires during operation. Operation of Iroqrequire no additional workforce.

CO50-116CO50-117 See the response to comment FA6-13.

S-774
COMPANIES AND ORGANIZATIONS

CO50 – Kernan Land Trust (cont’d)

Companies and Or

The commentor’s statement regarding cumnoted. We have updated the cumulative ithe conclusion.

CO50-118

Section 5.1.4 of the EIS states that the maimpacts would be from temporary workspareas would return to pre-construction conconstruction. We acknowledge that this wimpact in some instances taking decades tconstruction conditions. The section furthConstitution would maintain a 30-foot-wiselective removal of trees within forested total of 12.5 acres through the operationa

CO50-119

Constitution would conduct annual post-cof all wetlands affected by construction to revegetation and the success of restoratiorevegetation is successful. If revegetation three years, under the direction of FERC, develop in consultation with a professionremedial revegetation plan to actively revwetlands.

CO50-120CO50-121 See the response to comment FA4-2.

S-775
COMPANIES AND ORGANIZATIONS

CO50 – Kernan Land Trust (cont’d)

Companies and Or

See the response to comment CO5-10 (wresponse to comment FA6-10 regarding lthe pipeline right-of-way for invasive spethe EIS has been revised with new informKernan Land Trust property and our asseimpact avoidance, minimization, and miti

CO50-122

S-776
COMPANIES AND ORGANIZATIONS

CO51 – Pennsylvania Sierra Club

Companies and Or

The discussion of interior forest in section been revised. See the response to commestormwater runoff and sediment and erosi4.1.3 of the EIS has been revised to proviinformation regarding flooding. Section 4potential impacts on water resources from 

CO51-1

The proposed projects would consist existing compressor station. As stated in the proposed Wright Interconnect Pconstruction of a new transfer compressaddition of incremental compression fahorsepower, to supplement the existing c14,200 horsepower.Air quality impacts and proposed mitigatisection 4.11.1 of the EIS. See the responand section 4.7 of the EIS regarding threaspecies. Sensitive waterbodies are discusthe EIS.

CO51-2

Sensitive resources, as well as potential are discussed in the EIS for interfragmentation (section 4.5.3), soil comnoise (section 4.11.2), aquifers and watair quality (section 4.2.1), and wetlands (L). See the response to comment CO41-runoff and sediment and erosion controls

CO51-3

S-777
COMPANIES AND ORGANIZATIONS

CO51 – Pennsylvania Sierra Club (cont’d)

Companies and Or

The commentor’s statements regarding See the response to comment FA1-1.

CO51-4

S-778
The commentor’s requests for delayed iss

are noted. See the response to comment Fsection 4.1.3.4 of the EIS, a geotechnical provided an analysis of steep slopes and kcrossed by the proposed route. A well-deat MP 30.3 was identified. Constitution sslope stability analysis at this location. Wrecommendation for this study since it hatime the draft EIS was published. ConstitJune 3, 2014 for a reroute extending from designed to avoid the landslide area. The not identify any other areas of the proposrequire a formal slope stability analysis.

COMPANIES AND ORGANIZATIONSCO52 – Concerned Citizens of Trout Creek

CO52-1

As stated in section 4.1.1.2 of the EIS, pr

Constitution should file geotechnical studcrossing locations. Any information requ

prior to construction would be filed on ouwould be available to the public. Constituand Hazardous Materials and Iroquois’ Spand Countermeasure Plan are also on e-Lversions have been available for public re

11, 2013 (Constitution) and June 13, 2013 response to comment FA1-1 regarding ou

CO52-2

S-779
See the responses to the Earthjustice lette

commentor at comments CO41-2 and COto comment LA7-5 regarding public need

COMPANIES AND ORGANIZATIONSCO53 – James Bacon for CWCWC

S-780

CO53-1
COMPANIES AND ORGANIZATIONS

CO53 – James Bacon for CWCWC (cont’d)

S-781
COMPANIES AND ORGANIZATIONS

CO53 – James Bacon for CWCWC (cont’d)

CO53-2 See the response to comment FA8-3. 

See the responses to comments LA7-5 regcomment FA8-3 regarding eminent doma

CO53-3

In section 4.8.4.2 of the EIS, we have increcommendation that Constitution file an minimization, or mitigation plan for specsugar bush operation at MP 79.5), in coorlandowner if possible. Section 4.9.5 has binformation concerning property values.

CO53-4

Section 4.9.5 has been updated with new property values and mortgages. Issues rediscussed in section 4.9.6 of the EIS. We recommendations in section 4.9 of the EIdocumentation of issues related to insuranrelation to the Constitution pipeline. We differences for these issues between the ingas pipeline and well drilling and product

CO53-5

S-782
COMPANIES AND ORGANIZATIONS

CO53 – James Bacon for CWCWC (cont’d)

S-783
COMPANIES AND ORGANIZATIONS

CO53 – James Bacon for CWCWC (cont’d)

See the response to comment LA9-4 regareserves.

CO53-6

CO53-7 Section 3.1.2.3 of the EIS discusses renewCO53-8 See the response to comment SA4-2 rega

S-784
COMPANIES AND ORGANIZATIONS

CO53 – James Bacon for CWCWC (cont’d)

See the response to comment LA7-5 regathe pipeline project is certificated by the Cauthorization conveys with it the right of may be used for obtaining access for condPipelines that are not under FERC jurisdicomment) may face different reality regarauthority (e.g., state regulations or the Na

CO53-9

S-785
COMPANIES AND ORGANIZATIONS

CO53 – James Bacon for CWCWC (cont’d)

The information provided in the attached the Interstate Natural Gas Association of Constitution’s proposed construction worof the guidelines and recommendations in 

CO53-10

S-786
COMPANIES AND ORGANIZATIONS

CO53 – James Bacon for CWCWC (cont’d)

S-787
COMPANIES AND ORGANIZATIONS

CO53 – James Bacon for CWCWC (cont’d)

S-788
COMPANIES AND ORGANIZATIONS

CO53 – James Bacon for CWCWC (cont’d)

S-789
COMPANIES AND ORGANIZATIONS

CO53 – James Bacon for CWCWC (cont’d)

S-790
COMPANIES AND ORGANIZATIONS

CO53 – James Bacon for CWCWC (cont’d)

S-791
COMPANIES AND ORGANIZATIONS

CO53 – James Bacon for CWCWC (cont’d)

S-792
COMPANIES AND ORGANIZATIONS

CO53 – James Bacon for CWCWC (cont’d)

S-793
COMPANIES AND ORGANIZATIONS

CO53 – James Bacon for CWCWC (cont’d)

S-794
COMPANIES AND ORGANIZATIONS

CO53 – James Bacon for CWCWC (cont’d)

S-795
COMPANIES AND ORGANIZATIONS

CO53 – James Bacon for CWCWC (cont’d)

S-796
COMPANIES AND ORGANIZATIONS

CO53 – James Bacon for CWCWC (cont’d)

S-797
COMPANIES AND ORGANIZATIONS

CO53 – James Bacon for CWCWC (cont’d)

S-798
COMPANIES AND ORGANIZATIONS

CO53 – James Bacon for CWCWC (cont’d)

S-799
COMPANIES AND ORGANIZATIONS

CO53 – James Bacon for CWCWC (cont’d)

S-800
COMPANIES AND ORGANIZATIONS

CO53 – James Bacon for CWCWC (cont’d)

S-801
COMPANIES AND ORGANIZATIONS

CO53 – James Bacon for CWCWC (cont’d)

S-802
COMPANIES AND ORGANIZATIONS

CO53 – James Bacon for CWCWC (cont’d)

S-803
COMPANIES AND ORGANIZATIONS

CO53 – James Bacon for CWCWC (cont’d)

S-804
COMPANIES AND ORGANIZATIONS

CO53 – James Bacon for CWCWC (cont’d)

S-805
COMPANIES AND ORGANIZATIONS

CO53 – James Bacon for CWCWC (cont’d)

S-806
COMPANIES AND ORGANIZATIONS

CO53 – James Bacon for CWCWC (cont’d)

S-807
COMPANIES AND ORGANIZATIONS

CO53 – James Bacon for CWCWC (cont’d)

S-808
COMPANIES AND ORGANIZATIONS

CO53 – James Bacon for CWCWC (cont’d)

S-809
COMPANIES AND ORGANIZATIONS

CO53 – James Bacon for CWCWC (cont’d)

S-810
COMPANIES AND ORGANIZATIONS

CO53 – James Bacon for CWCWC (cont’d)

S-811
COMPANIES AND ORGANIZATIONS

CO53 – James Bacon for CWCWC (cont’d)

S-812
COMPANIES AND ORGANIZATIONS

CO53 – James Bacon for CWCWC (cont’d)

S-813
COMPANIES AND ORGANIZATIONS

CO53 – James Bacon for CWCWC (cont’d)

S-814
COMPANIES AND ORGANIZATIONS

CO53 – James Bacon for CWCWC (cont’d)

S-815
COMPANIES AND ORGANIZATIONS

CO53 – James Bacon for CWCWC (cont’d)

S-816
COMPANIES AND ORGANIZATIONS

CO53 – James Bacon for CWCWC (cont’d)

S-817
COMPANIES AND ORGANIZATIONS

CO53 – James Bacon for CWCWC (cont’d)

S-818
COMPANIES AND ORGANIZATIONS

CO53 – James Bacon for CWCWC (cont’d)

S-819
COMPANIES AND ORGANIZATIONS

CO53 – James Bacon for CWCWC (cont’d)

S-820
COMPANIES AND ORGANIZATIONS

CO53 – James Bacon for CWCWC (cont’d)

S-821
COMPANIES AND ORGANIZATIONS

CO53 – James Bacon for CWCWC (cont’d)

S-822
COMPANIES AND ORGANIZATIONS

CO53 – James Bacon for CWCWC (cont’d)

S-823
COMPANIES AND ORGANIZATIONS

CO53 – James Bacon for CWCWC (cont’d)

S-824
COMPANIES AND ORGANIZATIONS

CO53 – James Bacon for CWCWC (cont’d)

S-825
COMPANIES AND ORGANIZATIONS

CO53 – James Bacon for CWCWC (cont’d)

S-826
COMPANIES AND ORGANIZATIONS

CO53 – James Bacon for CWCWC (cont’d)

S-827
COMPANIES AND ORGANIZATIONS

CO53 – James Bacon for CWCWC (cont’d)

S-828
COMPANIES AND ORGANIZATIONS

CO53 – James Bacon for CWCWC (cont’d)

S-829
COMPANIES AND ORGANIZATIONS

CO53 – James Bacon for CWCWC (cont’d)

S-830
COMPANIES AND ORGANIZATIONS

CO53 – James Bacon for CWCWC (cont’d)

S-831
COMPANIES AND ORGANIZATIONS

CO53 – James Bacon for CWCWC (cont’d)

S-832
COMPANIES AND ORGANIZATIONS

CO53 – James Bacon for CWCWC (cont’d)

S-833
COMPANIES AND ORGANIZATIONS

CO54 – Bruce S. Kernan for Kernan Land Trust

See the responses to comments CO50-53 response to comment CO50-22 regarding agreements.

CO54-1

S-834
COMPANIES AND ORGANIZATIONS

CO54 – Bruce S. Kernan for Kernan Land Trust (cont’d)

S-835
COMPANIES AND ORGANIZATIONS

CO55 – Stanton Family Farms, LLC.

The comments referenced in the public mcan be found at PM1-8 through PM1-17. 

CO55-1

The supporting information provided by tnoted. Section 3.4.3 of the EIS has been information regarding the Stanton propertpotential impact avoidance, minimizationmeasures.

CO55-2

S-836
COMPANIES AND ORGANIZATIONS

CO55 – Stanton Family Farms, LLC. (cont’d)

S-837
COMPANIES AND ORGANIZATIONS

CO55 – Stanton Family Farms, LLC. (cont’d)

S-838
COMPANIES AND ORGANIZATIONS

CO55 – Stanton Family Farms, LLC. (cont’d)

S-839
COMPANIES AND ORGANIZATIONS

CO55 – Stanton Family Farms, LLC. (cont’d)

S-840
COMPANIES AND ORGANIZATIONS

CO55 – Stanton Family Farms, LLC. (cont’d)

S-841
COMPANIES AND ORGANIZATIONS

CO55 – Stanton Family Farms, LLC. (cont’d)

S-842
COMPANIES AND ORGANIZATIONS

CO55 – Stanton Family Farms, LLC. (cont’d)

S-843
COMPANIES AND ORGANIZATIONS

CO55 – Stanton Family Farms, LLC. (cont’d)

S-844
COMPANIES AND ORGANIZATIONS

CO55 – Stanton Family Farms, LLC. (cont’d)

S-845
COMPANIES AND ORGANIZATIONS

CO55 – Stanton Family Farms, LLC. (cont’d)

S-846
COMPANIES AND ORGANIZATIONS

CO55 – Stanton Family Farms, LLC. (cont’d)

S-847
COMPANIES AND ORGANIZATIONS

CO55 – Stanton Family Farms, LLC. (cont’d)

S-848
COMPANIES AND ORGANIZATIONS

CO55 – Stanton Family Farms, LLC. (cont’d)

S-849
COMPANIES AND ORGANIZATIONS

CO55 – Stanton Family Farms, LLC. (cont’d)

S-850
COMPANIES AND ORGANIZATIONS

CO55 – Stanton Family Farms, LLC. (cont’d)

S-851
COMPANIES AND ORGANIZATIONS

CO56 – Laborers International Union of North America (Local 785)

CO56-1 The commentor’s statements in support o

S-852
COMPANIES AND ORGANIZATIONS

CO57 – Breathe Easy Susquehanna County

The commentor’s statements requesting dprojects is noted. Potential impacts and mproposed projects on air quality are discuthe EIS. See the response to comment COinduced development.

CO57-1

See the response to comment CO41-29 reCentral Compressor Station.

CO57-2

Section 4.11.1 of the EIS has been revised expanded discussion of fugitive emissionrequest for the Picarro surveyor is noted. study from upstream source to midstream drilling to interstate transport) is beyond t

CO57-3

As discussed in section 4.9.8 of the EIS, trelated to the proposed projects would be an unanticipated pipeline failure. As discof the EIS, the proposed projects would nsignificant impact on local or regional air 

CO57-4

S-853
COMPANIES AND ORGANIZATIONS

CO58 – Joint Landowners Coalition of New York Inc.

CO58-1 The commentor’s statements in support o

S-854
COMPANIES AND ORGANIZATIONS

CO59 – Flying Changes B&B LLC.

CO59-1 The commentor’s statements in support o

S-855
COMPANIES AND ORGANIZATIONS

CO59 – Flying Changes B&B LLC. (cont’d)

S-856
COMPANIES AND ORGANIZATIONS

CO60 – Laborers International Union of North America (Local 785)

CO60-1 The commentor’s statements in support o

S-857
COMPANIES AND ORGANIZATIONS

CO60 – Laborers International Union of North America (Local 785) (cont’d)

S-858
COMPANIES AND ORGANIZATIONS

CO60 – Laborers International Union of North America (Local 785) (cont’d)

S-859
COMPANIES AND ORGANIZATIONS

CO61 – Upstate Landowners Group LLC

CO61-1 The commentor’s statements in support o

The commentor’s request to deny approveasement agreements between ConstitutioLandowners Group have been reached is to comment FA8-3.

CO61-2

S-860
COMPANIES AND ORGANIZATIONS

CO61 – Upstate Landowners Group LLC (cont’d)

S-861
COMPANIES AND ORGANIZATIONS

CO62 – Laborers International Union of North America(Local 785)

S-862

CO62-1 The commentor’s statements in support o
COMPANIES AND ORGANIZATIONS

CO63 – Unatego Are Landowners Association

CO63-1 The commentor’s statements in support o

The draft EIS was prepared by the FERC Williams as stated by the commentor. Seupdated with new information concerning the response to comment FA8-3.

CO63-2

S-863
COMPANIES AND ORGANIZATIONS

CO63 – Unatego Are Landowners Association (cont’d)

CO63-3 See the response to comment FA8-3.

S-864
COMPANIES AND ORGANIZATIONS

CO63 – Unatego Are Landowners Association (cont’d)

S-865
COMPANIES AND ORGANIZATIONS

CO64 – Leatherstocking Gas Company LLC

We have updated sections 1.1 and 4.13 winformation as applicable. It is not possibcumulative impacts analysis of any naturasystems considered by Leatherstocking winformation about the systems. Thereforeassumptions to update the cumulative impaccordingly. 

CO64-1

S-866
COMPANIES AND ORGANIZATIONS

CO64 – Leatherstocking Gas Company LLC (cont’d)

S-867
COMPANIES AND ORGANIZATIONS

CO64 – Leatherstocking Gas Company LLC (cont’d)

Even though Leatherstocking’s proposal ithe FERC, we have made reasonable assuour cumulative impacts analysis (section 

CO64-2

S-868
COMPANIES AND ORGANIZATIONS

CO64 – Leatherstocking Gas Company LLC (cont’d)

S-869
COMPANIES AND ORGANIZATIONS

CO64 – Leatherstocking Gas Company LLC (cont’d)

S-870
COMPANIES AND ORGANIZATIONS

CO64 – Leatherstocking Gas Company LLC (cont’d)

S-871
COMPANIES AND ORGANIZATIONS

CO64 – Leatherstocking Gas Company LLC (cont’d)

S-872