The EIS does not state that there would b

impacts associated with the proposed projindicated that adverse impacts would occconstruction and operation of the projectswould be reduced to less than significant laws and regulations, the mitigating measEIS, and our recommendations. 

COMPANIES AND ORGANIZATIONSCO1 – Stop the Pipeline

Companies and Or

CO1-1

Sensitive resources, as well as potential imare discussed in the EIS for interior forest waterbodies (section 4.3.3), steep slopes (

4.1.3; appendix G), shallow bedrock (sectappendix I), wetlands (section 4.4 and app(section 4.6.2.3), air quality (section 4.11farmland/agriculture (sections 2.3.2, 4.2, 

CO1-2

The commentor’s statements regarding thpipeline project, the length of proposed acamount of land that would be disturbed dnoted.

CO1-3

The cutting of mature trees and forest fragas a result of the proposed pipeline projec4.5. These impacts would be minimized reduction of the construction right-of-way regrowth of trees in approximately 54 perforested areas cleared during constructionan upland forest mitigation plan as we haConstitution would employ measures to dnecessary as described in section 4.2.4. Cconduct compaction tests and till compacagricultural and residential areas through similar equipment as identified in the ECPstill be grown in agricultural areas followpipeline as described in section 4.8.1, but allowed to re-establish within the 50-footof-way in upland areas. We also recommConstitution should prepare an impact avor mitigation plan for specialty crops devwith the landowner if possible (section 4.2.3.1 and 4.1.3) and construction impacts (section 4.11.2), homes and structures (seand groundwater (section 4.3.1) are discu

CO1-4

S-187
COMPANIES AND ORGANIZATIONS

CO1 – Stop the Pipeline (cont’d)

Companies and Or

Given Constitution’s proposed mitigation recommendations, we conclude that impabe effectively minimized. Constitution animplement sediment and erosion controls Erosion Control, Revegetation, and Mainthe Wetland and Waterbody Construction Procedures (Procedures), which were revother proposed measures to prevent water and negative effects of stormwater runoffdescribed in sections 2.3 and 4.3 of the EIPlan. Constitution’s Plan requires the insmaintenance of temporary erosion controdaily basis in areas of active construction on a weekly basis in areas with no construoperation, and within 24 hours of each 0.

CO1-4 (cont’d)

The potential for flooding, and related improjects and also upon the pipeline itself fare discussed in sections 4.1.3 and 4.3.3. 

CO1-5

S-188
Section 380.15(b) of the Commission’s si

misinterpreted by the commentor. This sCommission’s regulations is intended to gpreliminary selection of project routes. Tnumerous criteria by which the Commissproposals and uses the criteria to weight tthe other. By no means do these siting guexisting rights-of-ways are the only locaticould be built. Through the Commissionoften discover that many routes are infeasmeet one or more of the suggested criteria pipeline route. In fact, the FERC staff direvaluate collocated options for its pipelinthis project. (See June 11, 2012 commenreports).We have evaluated numerous route alternproposed route in order to assess whether further minimized, including impacts on fsteep slopes. We note that Constitution hroute alternatives into its proposed route oproject, and we concluded that several othwere not environmentally preferable to th

COMPANIES AND ORGANIZATIONSCO2 – Stop the Pipeline

Companies and Or

CO2-1

CO2-2 See the response to comment LA7-4. CO2-3 See the responses to comments CO2-2, FA

Constitution and Iroquois would both imperosion controls based upon our Upland ERevegetation, and Maintenance Plan and Waterbody Construction and Mitigation Pother proposed measures to prevent water and negative effects of stormwater runoffdescribed in sections 2.3 and 4.3 of the EI

CO2-4

S-189
Alternative M, which involves collocation 

88), was evaluated and discussed in detaithe EIS. Use of the median and the contrfor construction of a pipeline is constrainworkspace available, side slopes present, egress during construction, and impacts oroadway operation. We conclude that plawithin the median of I-88 or adjacent to thfeasible. 

COMPANIES AND ORGANIZATIONSCO2 – Stop the Pipeline (cont’d)

Companies and Or

CO2-5

Alternative routes, including those with in

with existing rights-of-way, have been ass

CO2-6

The commentor’s statement regarding envto non-collocated routes is noted.

CO2-7

S-190
The EIS addresses the question about wh

provide natural gas for distribution to compipeline (section 1.1). The potential for tserve as a collector line for future, additiobe modest. We noted that with an increaspounds per square inch gauge (psig), the maximum capacity would be 850,000 DthDth/d (31 percent) greater than the currenrelatively modest allowance for increased preclude the use of the Constitution line anewly emerging, local gas supplies, shouldiscussed in section 4.13.1 of the EIS, the of the Marcellus Shale in proximity to the context of cumulative impacts was consid

COMPANIES AND ORGANIZATIONSCO3 – Stop the Pipeline

Companies and Or

CO3-1

High volume hydraulic fracturing is currethe entire state of New York, not just withhighlighted in orange on the map. 

CO3-2CO3-3 See response to CO3-1.

S-191
See the response to comment FA1-1. Ref

in appendix Q of the draft EIS.The FERC staff reviewed the information S. Kernan Land Trust (Trust) as discussed Desktop data sources were used because have access to the parcel, and no other paprovided a wetland delineation prior to isThe FERC did not reject the Trust’s prefewe recommended in section 3.4.3.2 that Cassess minor route variations in consultat(parcel NY-DE-226.000) and either adopresources of concern or otherwise explain on resources have been effectively avoidemitigated. Subsequently, we issued an eninformation request to Constitution requirof specific minor route variations near thassessment of this new information is prothe EIS. 

COMPANIES AND ORGANIZATIONSCO4 – Elefant for Kernan Land Trust

Companies and Or

CO4-1

S-192
The studies and expert opinions prepared 

lands are available for review by the publnoted above, the FERC staff reviewed the for the Trust as discussed in section 4.8.4 recommended that Constitution further asalternatives in coordination with the TrustEIS is a summary of the information in thintended to be encyclopedic. Our analysiand opinions of the Trust’s scientific expestudies were not included as appendices to staff did not deliberate on their significancThe intent of this ongoing coordination wopportunity to continue to provide input induring Constitution’s assessment, and prewould have known the results of mutual dclose of the comment period for the draft comments subsequently received from the appears such coordination was limited or response to comment CO4-1 regarding an information request filed with constitution draft EIS comment period. We have updaEIS with the new information and with ouroute and construction alternatives and poTrust property. 

COMPANIES AND ORGANIZATIONSCO4 – Elefant for Kernan Land Trust (cont’d)

Companies and Or

CO4-2

S-193
See the response to comment FA1-1. 

COMPANIES AND ORGANIZATIONSCO4 – Elefant for Kernan Land Trust (cont’d)

Companies and Or

CO4-3

S-194
See the response to comment FA1-1.

COMPANIES AND ORGANIZATIONSCO5 – Kernan Land Trust

Companies and Or

CO5-1

S-195
See the response to comment CO4-2.

COMPANIES AND ORGANIZATIONSCO5 – Kernan Land Trust (cont’d)

Companies and Or

CO5-3

See the response to comment FA1-1. As of the EIS, Commission staff recommendshould further assess minor route deviatioavoid, minimize, or mitigate potential impwith the landowner. Constitution’s fulfillrequirement required direct coordination wTrust during its preparation and response. comment CO4-2. The Kernan Land Trust comments to the FERC at any time during review process leading to issuance of the 

CO5-2

See the response to comment FA1-1. Altpercent of the parcels had not been surveytime of the draft EIS, it is not accurate to not include any data for those parcels. As desktop data sources were also used (such topographic maps and databases for waterendangered species, and archaeological siconsideration of resource data in areas wipermission. If the project is certificated, tsurvey all previously un-surveyed parcels be obtained in some cases), and these new used during permitting to supplant and refobtained from desktop sources. 

CO5-4

We assume that the commentor is referrinthan table 4.4.1-4 (as there is no table 4.4and that the referenced text is on page 3-43.4.1-4 provides a number of parameters between the two routes. Selected paramethe focus of the summary text below the tparameters were chosen to highlight the mdissimilar differences between the two altthe draft EIS present the specific quantitiesummarizes the data provided in the tabledescriptive text on page 3-40 relative to tasummary text accurately matches the data wetlands were described in the row labelewetland complexes crossed” on page 3-38 were not omitted from table 3.4.1-4.

CO5-5

S-196
The consideration of the number of nearb

correlated to safety. The FERC takes into landowners that would be crossed by the of nearby residences as social factors (in restrict the construction of structures and during construction) that should be considother factors.

COMPANIES AND ORGANIZATIONSCO5 – Kernan Land Trust (cont’d)

Companies and Or

CO5-7

Given the subjective nature of qualitative direct comparison of alternative routes wiprovided in section 3.0 of the EIS. AccorWetland Inventory maps and wetlands datNYSDEC, the proposed pipeline route dowetlands on the Trust property; rather, it athat the proposed route would be located w500-foot-wide wetland boundary “check zMud Pond wetland, which could be either We also note that consultants hired by the Clapper Lake and Mud Pond wetland comconnected and indicated that additional stuSpring of 2014. Constitution’s wetland insurvey access permission for the Trust parproperty access has submitted a wetland dsubstantiate these claims to the FERC. Wconclusion by the Trust’s environmental cTrust’s wetlands and interior forest do not species. 

CO5-6

CO5-8 See the responses to comments FA1-1 an

The 45 day comment period is the FERCcomment period as dictated by 40 CFR 1response to comment FA1-1.

CO5-9

S-197
COMPANIES AND ORGANIZATIONS

CO5 – Kernan Land Trust (cont’d)

Companies and Or

All comments submitted by the Kernan LCommission (either via mail or posted to reviewed and considered by the FERC staTrust’s letter, the FERC staff met with mLand Trust in August 2012, engaged with FERC scoping meetings, and communicaphone during the pre-filing process. AddConstitution’s application was filed, Trusengaged with Constitution through the CoResolution Service (1-877-337-2237).As stated in the response to CO4-2, so as cumbersome, information provided by the summarized within the EIS, as the FERCfull administrative record for the project. information regarding individual parcels EIS; however, we included a discussion oin section 4.8.4.2. In addition, we includesection 3.4.3.2 of the EIS for Constitution coordination with the Kernan Land Trust either identifying an alternate route or othimpacts on the applicable resources woulminimized, or mitigated. According to the information provided by and Constitution, and our review of wetlaproposed pipeline would not directly impLake or Mud Pond wetland complexes. Tlocated within the NYSDEC’s 500-foot-w“check zone” surrounding the Mud Pond be either uplands or wetlands. The Kernadenied access for Constitution’s wetland not submitted its own wetland delineation recommended by the FERC staff in its coCOE visited the subject property in July 2that the proposed route followed an uplanaffect wetlands. 

CO5-10

S-198
COMPANIES AND ORGANIZATIONS

CO5 – Kernan Land Trust (cont’d)

Companies and Or

S-199
COMPANIES AND ORGANIZATIONS

CO5 – Kernan Land Trust (cont’d)

Companies and Or

The FERC Chairman at the time, Jon WeCongressman Chris Gibson’s October 5, 222, 2012. A copy of the letter was filed o22, 2012 and can be found at http://elibrary.ferc.gov:0/idmws/file_list.a2445. Chris Gibson has submitted severaCommission on behalf of various parties, responded to by the Chairman.

CO5-11

The comment is noted regarding the extenbetween the Trust, Constitution’s represestaff, as well as the information that the TFERC staff. Although the FERC staff encoordination and timely resolution of landpossible, route modifications certainly caapplication is filed. Constitution has adopvariations over the course of the project aof the EIS. See the responses to commenWe recommended in section 3.4.3.2 of thConstitution further assess minor route demeasures to avoid, minimize, or mitigate property (parcel ID NY-DE-226.000), anEIS specifically mentioned the Charlotte concerns about interior forest, invasive spand Mud Lakes wetland complexes. Giveof the subject property in the draft EIS, it that the commentor’s concerns were not iEIS or that they were ignored by the FERFERC issued an environmental informatiConstitution on May 14, 2014 regarding asuggested by the land trust and its agents, measures such as the possibility of an HDpipeline at the subject property. See sectiassessment and updated information for t

CO5-12

S-200
COMPANIES AND ORGANIZATIONS

CO5 – Kernan Land Trust (cont’d)

Companies and Or

S-201
COMPANIES AND ORGANIZATIONS

CO5 – Kernan Land Trust (cont’d)

Companies and Or

S-202
COMPANIES AND ORGANIZATIONS

CO5 – Kernan Land Trust (cont’d)

Companies and Or

S-203
COMPANIES AND ORGANIZATIONS

CO5 – Kernan Land Trust (cont’d)

Companies and Or

S-204
COMPANIES AND ORGANIZATIONS

CO5 – Kernan Land Trust (cont’d)

Companies and Or

S-205
COMPANIES AND ORGANIZATIONS

CO6 – State University of New York

Companies and Or

CO6-1 See the responses to comments CO5-2, C

S-206
COMPANIES AND ORGANIZATIONS

CO6 – State University of New York (cont’d)

Companies and Or

S-207
COMPANIES AND ORGANIZATIONS

CO7 – Concerned Citizens of Trout Creek, NY

Companies and Or

See the response to comment FA1-1. Sechas been revised to clarify that the geotechired by Constitution evaluated the entire areas of steep slopes and karst features. Tpublically available “desktop” data sourcassessment, which was supplemented by 

CO7-1

Recommendations in the draft EIS were pthe same time as the public. Constitution these recommendations prior to issuance stated in section 4.1.1.2 of the EIS, if the Constitution would be required to provide studies prior to the start of construction. available to the public on e-Library. ConOil and Hazardous Materials and IroquoisControl and Countermeasure Plan are also current versions (which were revised per stakeholder comments) have been availabsince November 11, 2013 (Constitution) a(Iroquois).

CO7-2

The commentor’s statement regarding dedraft EIS is noted. Also see the response 

CO7-3

S-208
COMPANIES AND ORGANIZATIONS

CO8 – Center for Sustainable Rural Communities

Companies and Or

The Center for Sustainable Rural Commuintroduction is noted. See the response to regarding adequacy of the EIS. Terrorism 4.12.1 of the EIS.

CO8-1

S-209
COMPANIES AND ORGANIZATIONS

CO8 – Center for Sustainable Rural Communities (cont’d)

Companies and Or

CO8-2 The credentials of the commenters are no

S-210
COMPANIES AND ORGANIZATIONS

CO8 – Center for Sustainable Rural Communities (cont’d)

Companies and Or

The potential threats listed by the commeall of the proposed pipeline facilities, not facilities, would be buried at least 36 inchor 24 inches in bedrock thereby making indifficult relative to more easily accessible facilities would be enclosed with security thousands of miles of existing pipelines ain Pennsylvania, New York, and in the reindication that the Constitution pipeline wattractive to terrorists.Constitution stated that the natural gas pipwould include Constitution’s parent compPipeline Company, LLC), has worked and conjunction with the U.S. Department of has been diligent in taking steps to safeguagainst terrorist threats. The pipeline premonitored 24 hours per day by Constitutiand operational personnel would conduct Constitution stated that it could not proviregarding threats or countermeasures in thjeopardizing security. We concur.As stated in section 4.12.1 of the EIS, unfunable to provide more details in this anais faced with a dilemma in deciding how be shared to the public while still providinprotection to infrastructure facilities. The the road leading to the Wright Compressoevacuation route is noted. 

CO8-3

S-211
COMPANIES AND ORGANIZATIONS

CO8 – Center for Sustainable Rural Communities (cont’d)

Companies and Or

S-212
COMPANIES AND ORGANIZATIONS

CO8 – Center for Sustainable Rural Communities (cont’d)

Companies and Or

S-213
COMPANIES AND ORGANIZATIONS

CO8 – Center for Sustainable Rural Communities (cont’d)

Companies and Or

S-214
COMPANIES AND ORGANIZATIONS

CO8 – Center for Sustainable Rural Communities (cont’d)

Companies and Or

S-215
COMPANIES AND ORGANIZATIONS

CO8 – Center for Sustainable Rural Communities (cont’d)

Companies and Or

S-216
COMPANIES AND ORGANIZATIONS

CO8 – Center for Sustainable Rural Communities (cont’d)

Companies and Or

S-217
COMPANIES AND ORGANIZATIONS

CO8 – Center for Sustainable Rural Communities (cont’d)

Companies and Or

S-218
COMPANIES AND ORGANIZATIONS

CO8 – Center for Sustainable Rural Communities (cont’d)

Companies and Or

S-219
COMPANIES AND ORGANIZATIONS

CO8 – Center for Sustainable Rural Communities (cont’d)

Companies and Or

S-220
COMPANIES AND ORGANIZATIONS

CO8 – Center for Sustainable Rural Communities (cont’d)

Companies and Or

CO8-4 Constitution has eliminated contractor ya

S-221
COMPANIES AND ORGANIZATIONS

CO8 – Center for Sustainable Rural Communities (cont’d)

Companies and Or

S-222
COMPANIES AND ORGANIZATIONS

CO8 – Center for Sustainable Rural Communities (cont’d)

Companies and Or

See the response to comment CO8-3. ThSecurity Administration has published segeneral aviation airports which can be acchttp://www.tsa.gov/sites/default/files/assety_guidelines_for_general_aviation_airpo

CO8-5

S-223
COMPANIES AND ORGANIZATIONS

CO8 – Center for Sustainable Rural Communities (cont’d)

Companies and Or

S-224
COMPANIES AND ORGANIZATIONS

CO8 – Center for Sustainable Rural Communities (cont’d)

Companies and Or

S-225
COMPANIES AND ORGANIZATIONS

CO8– Center for Sustainable Rural Communities

Companies and Or

The comments regarding threats posed by terrain vehicle access are noted. See the rCO8-3. Constitution would coordinate reaccess of ATVs and snowmobiles with thlandowners and install suitable barriers (tgates) if necessary. 

CO8-6

S-226
COMPANIES AND ORGANIZATIONS

CO8 – Center for Sustainable Rural Communities (cont’d)

Companies and Or

The comments regarding threats posed by engineering attacks are noted. See the resCO8-3. 

CO8-7

S-227
COMPANIES AND ORGANIZATIONS

CO8 – Center for Sustainable Rural Communities (cont’d)

Companies and Or

S-228
COMPANIES AND ORGANIZATIONS

CO8 – Center for Sustainable Rural Communities (cont’d)

Companies and Or

S-229
COMPANIES AND ORGANIZATIONS

CO8 – Center for Sustainable Rural Communities (cont’d)

Companies and Or

The FERC’s Office of Energy Infrastructoutreach directly with private sector infraand operators of energy delivery systems communication and mitigation of cyber aFERC-jurisdictional energy facilities. Dimitigation measures could compromise thbeyond the scope of this EIS. See the resFA1-1 (regarding adequacy of the EIS) andiscussion of security measures in the EIS

CO8-8

S-230
COMPANIES AND ORGANIZATIONS

CO8 – Center for Sustainable Rural Communities (cont’d)

Companies and Or

S-231
COMPANIES AND ORGANIZATIONS

CO8 – Center for Sustainable Rural Communities (cont’d)

Companies and Or

S-232
COMPANIES AND ORGANIZATIONS

CO8 – Center for Sustainable Rural Communities (cont’d)

Companies and Or

S-233
COMPANIES AND ORGANIZATIONS

CO8 – Center for Sustainable Rural Communities (cont’d)

Companies and Or

S-234
COMPANIES AND ORGANIZATIONS

CO9– Kernan Land Trust

Companies and Or

As discussed in section 4.5 of the EIS a reconstruction right-of-way width from 110 avoid forest clearing of 52 acres. Therefotracts would still be fragmented, direct imwould be reduced by 52 acres due to the rright-of-way width.

CO9-1

S-235
COMPANIES AND ORGANIZATIONS

CO9 – Kernan Land Trust (cont’d)

Companies and Or

As stated in section 5.2 of the draft EIS, tthat Constitution file a draft upland forest the end of the draft EIS comment period. Constitution on May 6, 2014 (http://elibrary.ferc.gov:0/idmws/file_list3683. Several months have elapsed since and the issuance of this final EIS, during had an opportunity to comment on the plaresponse to comment FA1-1, the FERC ccomments on the draft EIS, the PreliminaUpland Forest Plan, and any other materirecord past the end date of the comment ppoint of publication of the final EIS. Any after the end of the comment period were preparation of the final EIS.

CO9-2

S-236
COMPANIES AND ORGANIZATIONS

CO10 – Center for Sustainable Rural Communities

Companies and Or

CO10-1 See the responses to comments LA1-4 an

S-237
COMPANIES AND ORGANIZATIONS

CO10 – Center for Sustainable Rural Communities (cont’d)

Companies and Or

S-238
COMPANIES AND ORGANIZATIONS

CO11 – Earthjustice

Companies and Or

CO11-1 See the response to comments FA1-1 and 

S-239
COMPANIES AND ORGANIZATIONS

CO12 – Hudson Highlands Environmental Consulting 

Companies and Or

CO12-1 See the response to comment FA1-1.

S-240
COMPANIES AND ORGANIZATIONS

CO12 – Hudson Highlands Environmental Consulting (cont’d)

Companies and Or

CO12-2 See the response to CO4-2. Appendix H-

further clarify and present information prEIS. 

S-241
COMPANIES AND ORGANIZATIONS

CO12 – Hudson Highlands Environmental Consulting (cont’d)

Companies and Or

S-242
COMPANIES AND ORGANIZATIONS

CO12 – Hudson Highlands Environmental Consulting (cont’d)

Companies and Or

CO12-3 Section 3.4.3 and Appendix H-1 of the EI

provide additional details and references regarding the propane line. The FERC stprovided the requested information to the 

CO12-4 The commentor’s statements regarding th

EIS are noted. See the response to comm

S-243
COMPANIES AND ORGANIZATIONS

CO13 – Delaware-Otsego Audubon Society, Inc.

Companies and Or

CO13-1 See the responses to comments FA4-29 a

impacts on interior forests, migratory birdproposed plan to address these issues. Coreduce its construction right-of-way width our request for Constitution to assess meaminimize impacts on forested lands. We 100-foot-wide construction right-of-way is reasonable for a 30-inch-wide diameter terrain. This action would result in the prapproximately 52 acres of forest that othecut as originally proposed. Constitution pinformation about mitigation including prother forested blocks in the project area aMigratory Bird and Upland Forest Plan w6, 2014. The perpetual preservation of fo

be at risk, along with other conservation mcompensation for Constitution’s impacts 

S-244
COMPANIES AND ORGANIZATIONS

CO13 – Delaware-Otsego Audubon Society, Inc. (cont’d)

Companies and Or

CO13-2 Table 4.6.1-2 has been updated with som

this comment. However, several species comment (pileated woodpecker, red-eyed summer tanager, white-breasted nuthatchtable because they are absent from the lisconservation concern (which includes infin Flight) in New York as found on Auduat: http://ny.audubon.org/sites/default/files/d

vationconcerninny.pdf. 

CO13-3 See the response to comment FA1-1. See 

the EIS regarding impacts on wildlife habdiscussion of Constitution’s Preliminary MUpland Forest Plan.

S-245
COMPANIES AND ORGANIZATIONS

CO13 – Delaware-Otsego Audubon Society, Inc. (cont’d)

Companies and Or

S-246
COMPANIES AND ORGANIZATIONS

CO14 – Center for Sustainable Rural Communities

Companies and Or

CO14-1 See the response to comment FA1-1 rega

period.

CO14-2 See the response to comment SA2-1 rega

communication towers.

S-247
COMPANIES AND ORGANIZATIONS

CO14 – Center for Sustainable Rural Communities (cont’d)

Companies and Or

CO14-3 Constitution confirmed that the proposed 

light or sound. Constitution also provided report. The EIS has been updated to incluinformation.

CO14-4 We researched the potential impact assoc

communication towers on property valuesection 4.9.5 of the EIS with this informaconsistent evidence that communication t

CO14-5 We have updated section 4.6.1 of the EIS 

impacts of the proposed towers on migratprovided general guidance for tower instamigratory birds, with recommendations sheight to 200 feet or less and not using ligConstitution’s towers are consistent with recommendations.

CO14-6 Constitution indicated that digital subscri

(primary) and cellular (secondary) would supervisory control and data acquisition (communication at these facilities. We coultra-high frequency (UHF) radio as a terbackup system would likely not cause sigimpacts on bat echolocation (see section 4detail and refernces), and would be necesemergency. 

S-248
COMPANIES AND ORGANIZATIONS

CO14 – Center for Sustainable Rural Communities (cont’d)

Companies and Or

CO14-7 Based on our review of Federal Aviation 

regulations found at 49 CFR Part 77.9, wnotice would not be required. Constitutiocoordinate with the FAA regarding proximairports. 

CO14-8 Constitution would seek authorization for 

requirements.

CO14-9 Constitution stated that it did not propose 

monopole; rather, it would be flange moubase and secured in place with stud bolts. that the layered bedrock would be rippablequipment and that blasting would not be foundation. 

CO14-10 See the responses to comments CO1-4 (so

stormwater runoff) and LA1-1 (road dama

S-249
COMPANIES AND ORGANIZATIONS

CO14 – Center for Sustainable Rural Communities (cont’d)

Companies and Or

CO14-11 The comments regarding potential tower 

Additional engineering designs were provJune 3, 2014 and can be accessed at: http://elibrary.ferc.gov:0/idmws/file_list.a

2572

CO14-12 See the response to comment CO8-3.

S-250
See the response to comment FA1-1 rega

period.

COMPANIES AND ORGANIZATIONSCO15 – Stop the Pipeline

Companies and Or

CO15-1

S-251
COMPANIES AND ORGANIZATIONS

CO15 – Stop the Pipeline (cont’d)

Companies and Or

S-252
COMPANIES AND ORGANIZATIONS

CO15 – Stop the Pipeline (cont’d)

Companies and Or

S-253
COMPANIES AND ORGANIZATIONS

CO15 – Stop the Pipeline (cont’d)

Companies and Or

S-254
COMPANIES AND ORGANIZATIONS

CO15 – Stop the Pipeline (cont’d)

Companies and Or

S-255
COMPANIES AND ORGANIZATIONS

CO15 – Stop the Pipeline (cont’d)

Companies and Or

S-256
COMPANIES AND ORGANIZATIONS

CO15 – Stop the Pipeline (cont’d)

Companies and Or

S-257
COMPANIES AND ORGANIZATIONS

CO15 – Stop the Pipeline (cont’d)

Companies and Or

S-258
COMPANIES AND ORGANIZATIONS

CO15 – Stop the Pipeline (cont’d)

Companies and Or

S-259
COMPANIES AND ORGANIZATIONS

CO15 – Stop the Pipeline (cont’d)

Companies and Or

S-260
COMPANIES AND ORGANIZATIONS

CO15 – Stop the Pipeline (cont’d)

Companies and Or

S-261
COMPANIES AND ORGANIZATIONS

CO15 – Stop the Pipeline (cont’d)

Companies and Or

S-262
COMPANIES AND ORGANIZATIONS

CO15 – Stop the Pipeline (cont’d)

Companies and Or

S-263
COMPANIES AND ORGANIZATIONS

CO16 – Otsego County Conservation Association

Companies and Or

Alternate energy sources, including renewdiscussed in section 3.1. 

CO16-1

Sensitive resources, as well as potential imare discussed in the EIS for interior forest waterbodies (section 4.3.3), wetlands (secL), and threatened and endangered specie

CO16-2

A discussion of air emissions can be founEIS. As discussed in section 2.3 of the EIIroquois would implement their respective construction and operation to prevent and and clean-up accidental spills.

CO16-3

The FERC does not regulate production owe have considered production in the cum(4.13) of the EIS. Alternative delivery opsources are discussed in section 3.0 of the 

CO16-4CO16-5 Cumulative impacts are discussed in secti

See the response to comment LA7-5 regaproposed projects.

CO16-5

S-264
COMPANIES AND ORGANIZATIONS

CO16 – Otsego County Conservation Association (cont’d)

Companies and Or

Section 4.1 discusses the four temporal lewere considered throughout the EIS: temlong-term, and permanent. Our first priorprevent environmental impacts associated practicable. Where the complete preventpracticable, then we strive to minimize animpacts. This section further states that “their proposals, developed certain mitigatthe impact of the projects. In some casesadditional mitigation measures could furtimpacts. We will recommend to the Commeasures be included as specific conditioCommission may issue to the Applicants 

CO16-7

See the response to comment FA1-1 regaperiod.

CO16-8

The commentor’s statement regarding OtThe proposed pipeline route does not crosGenerally, impacts on waterbodies and wlimited to the area surrounding the actual would not be expected to extend to Otsegof the draft EIS, Constitution has remove4b. Therefore, there is now one proposed Otsego County – Yard 4a (Glasso Yard). 

CO16-9

The proposed pipeline route is not located note that Charlotte Creek and Ouleout CrDelaware County, upstream of the Susqu4.1.3 of the EIS has been revised to proviinformation regarding flooding. 

CO16-10

CO16-11 See the response to comment CO16-9.

Sensitive resources, such as waterbodies wetlands (section 4.4), as well as potentiaassociated with all of the proposed contrathe one in Otsego County), are discussed 

CO16-12

Potential socioeconomic impacts, includinCounty and all other counties directly affprojects, were evaluated in section 4.9 of 

CO16-13

S-265
COMPANIES AND ORGANIZATIONS

CO16 – Otsego County Conservation Association (cont’d)

Companies and Or

CO16-14 See the response to comment CO16-10.

See the response to comment CO16-9. ImCounty aquifers and groundwater resourcprojects are not anticipated.

CO16-15

Impacts from sedimentation and water turexpected within the immediate vicinity of crossing, although these impacts would be use of trenchless or dry crossing methodsEIS discusses construction and mitigation Constitution would use to minimize impa

CO16-17

As stated in sections 2.3 and 5.1.3 of the EIroquois would prevent or adequately minand leaks of hazardous materials during coperation by adhering to their spill prevenas stated in section 4.3.3.6 of the EIS, if a immediate downstream users of the water degradation in water quality. Impacts on water and groundwater resources are not aaccordance with Constitution’s spill plan, appropriate government officials if reportoccur.

CO16-16

S-266
COMPANIES AND ORGANIZATIONS

CO16 – Otsego County Conservation Association (cont’d)

Companies and Or

See the response to comment CO16-9. AConstitution’s Resource Report 1, the conused for “equipment, pipe, and material sttemporary field offices and pipe preparatiareas.” We have updated section 2.2.3 of information. Constitution’s spill preventiapply to contractor yards. 

CO16-18

Wetland disturbance would be limited to authorized workspaces. Because of the shexcavations, we do not expect constructiohydrology sufficient to impact wetlands dconstruction right-of-way. 

S-267

CO16-19
COMPANIES AND ORGANIZATIONS

CO16 – Otsego County Conservation Association (cont’d)

Companies and Or

As stated in section 4.5.4 of the EIS, implConstitution’s Invasive Species Managemrecommendation to finalize surveys and twash stations before construction would emitigate the potential spread of noxious o

CO16-20

We recognize that there would be a long-treduction of habitat for some migratory bi4.5.3 of the EIS has been updated to incluConstitution’s Preliminary Migratory Bird Plan which includes measures protective oMigratory birds that prefer open herbaceoexperience an increase in habitat from conof the project.

CO16-21

As stated in section 4.6.1.4, displaced wilto seek refuge in adjacent, undisturbed hacompletion of construction as vegetation We believe that the restoration of the distshould be the priority; however, we do respecies may never recolonize the right-oflevels.

CO16-22CO16-23 See the response to comment CO16-9. T

S-268
COMPANIES AND ORGANIZATIONS

CO16 – Otsego County Conservation Association (cont’d)

Companies and Or

The potential impacts of the projects upon discussed in section 4.9.5 of the EIS, and resources are discussed in section 4.8.6. Bhave been updated with new information. comment CO16-13 regarding traffic.

CO16-24

The FERC’s guidance indicates that applirecreational and special use areas that wowithin 0.25 mile of a project. This distanprotection of the resources (FERC 2002). approximately 2 miles from Constitution’Any increases in turbidity within Charlottterm and dissipate before reaching the are

CO16-25

The EIS discusses impacts on housing (seservices (section 4.9.3). As stated in sectvacancy rates (4.2 percent to 8.3 percent) vacant housing units in the counties that wproject (41,975 in Pennsylvania and New crews should not encounter difficulty in fhousing. At a maximum, the workforce wpercent of the vacant housing units.

CO16-26

We concluded that there is no evidence thpipeline results in significantly decreased particularly in counties not crossed by the 

CO16-27

S-269
COMPANIES AND ORGANIZATIONS

CO16 – Otsego County Conservation Association (cont’d)

Companies and Or

Section 4.11.1 of the EIS has been revised expanded discussion of fugitive emission

CO16-28

Impacts on traffic and main roads that wopurposes are discussed in section 4.9.4 of main roads leading from contractor yards right-of-way, and public and private roadvicinity of the construction right-of-way wthe access for the project. The exact routuncertain and would be variable. Given tnoise along these roads, additional noise ftraffic is expected to be negligible. Furthvehicles would be traveling during daytimevening and night-time hours when noise sensitive.

CO16-29CO16-30 See the response to comment LA1-4.

S-270
COMPANIES AND ORGANIZATIONS

CO16 – Otsego County Conservation Association (cont’d)

Companies and Or

As stated in section 4.13.6.2 of the EIS, thgroundwater and surface waterbody resoutemporary and minor.

CO16-34

As described in section 2.5.3 of the EIS, tmonitors under the direction of the FERC monitor construction activities. Both Conmonitors would complete inspections on have stop-work authority. Copies of the Fsummary reports would be available on owww.ferc.gov.

CO16-33

See the response to comment LA10-1. Thconduct regular field inspections during cany condition or requirement imposed by Constitution. Additionally, the EI will be ensuring the company is in compliance wpermit requirements.

CO16-32CO16-31 See the response to comment FA6-15.CO16-35 See the response to comment LA1-1.

The commentor’s statement regarding trathe exact routes and usage would be unceimpossible to estimate how many truck trduring construction of the projects. It is rthat truck traffic would range from modercourse of approximately 9 to 12 months, decrease over time, at least in certain segmpipe, supplies, and equipment is accomplexisting use of I-88 by heavy trucks, conswould not be expected to damage I-88. A4.9.4.1 of the EIS, Constitution would repby the pipeline project. 

CO16-36

S-271
COMPANIES AND ORGANIZATIONS

CO16 – Otsego County Conservation Association (cont’d)

Companies and Or

The geographic and temporal scope of the assessment are described at the beginning EIS, including broader consideration for rwatersheds and air quality control regions

CO16-37

S-272
COMPANIES AND ORGANIZATIONS

CO17 – Lilac Hill Farm

Companies and Or

Traffic is discussed in section 4.9.4 of the section 4.9.4.1, Constitution would repair the pipeline project. As stated in section construction activities would be limited to which would limit noise and lighting impcommentor’s property is 0.5 mile away frimpacts would be small or unnoticeable.

CO17-1

As stated in section 2.7 of the EIS, Constadditional FERC authorization to increase transport volumes beyond those stated in the Commission’s regulations at 18 CFR 

Applicants are required to notify all landodirectly affected, abut a proposed worksp1 mile of a proposed compressor station. list includes the Applicants’ mailing list (as well as anyone that has requested to be comment containing their mailing addres

CO17-2

Potential impacts and mitigation on tourisEIS in section 4.9.2. See the response to regarding high volume hydraulic fracturin

CO17-3

A discussion of pipeline safety is includeEIS. As stated in section 4.12.1, the proputilize remote-controlled valves, rather thvalves. These valves would be controlled Constitution’s staff rather than local emerpersonnel. Because they are remotely opwould not preclude their shut-off.

CO17-4

High volume hydraulic fracturing and wediscussed in the response to comment LAdevelopment of the Marcellus Shale is disto comment CO3-1. The Constitution pipconnected to existing compressor stations end of the route. The EIS discusses the immodifications that would be required at IrCompressor Station.

CO17-5

S-273
COMPANIES AND ORGANIZATIONS

CO18 – Leatherstocking Gas Company LLC

Companies and Or

The commentor’s statements regarding thfor an extension of time is noted.

CO18-1

S-274
COMPANIES AND ORGANIZATIONS

CO18 – Leatherstocking Gas Company LLC (cont’d)

Companies and Or

S-275
COMPANIES AND ORGANIZATIONS

CO18 – Leatherstocking Gas Company LLC (cont’d)

Companies and Or

S-276
COMPANIES AND ORGANIZATIONS

CO18 – Leatherstocking Gas Company LLC (cont’d)

Companies and Or

S-277
COMPANIES AND ORGANIZATIONS

CO18 – Leatherstocking Gas Company LLC (cont’d)

Companies and Or

S-278
COMPANIES AND ORGANIZATIONS

CO18 – Leatherstocking Gas Company LLC (cont’d)

Companies and Or

S-279
COMPANIES AND ORGANIZATIONS

CO19 – National Grid Gas Delivery Companies

Companies and Or

The commentor’s statements in support oare noted.

CO19-1

S-280
COMPANIES AND ORGANIZATIONS

CO19 – National Grid Gas Delivery Companies (cont’d)

Companies and Or

S-281
COMPANIES AND ORGANIZATIONS

CO20 – Independent Power Producers

Companies and Or

The commentor’s statements in support oare noted.

CO20-1

S-282
COMPANIES AND ORGANIZATIONS

CO20 – Independent Power Producers (cont’d)

Companies and Or

S-283
COMPANIES AND ORGANIZATIONS

CO21 – Board of Cooperative Educational Services

Companies and Or

The commentor’s statements regarding thand Technical School are noted.

CO21-1

S-284
COMPANIES AND ORGANIZATIONS

CO21 – Board of Cooperative Educational Services (cont’d)

Companies and Or

S-285
COMPANIES AND ORGANIZATIONS

CO21 – Board of Cooperative Educational Services (cont’d)

Companies and Or

S-286
COMPANIES AND ORGANIZATIONS

CO21 – Board of Cooperative Educational Services (cont’d)

Companies and Or

The commentor’s statements requesting inoted. The Commission will make a detegrant a party’s intervention request. The potential conflicts in land use and student recommendation for safety fencing, is disand 4.8 of the EIS.

CO21-2

S-287
COMPANIES AND ORGANIZATIONS

CO21 – Board of Cooperative Educational Services (cont’d)

Companies and Or

In section 4.8.4.3 of the draft EIS we recoConstitution coordinate with the SchoharEducation School Board of Educators to davoidance, minimization, or mitigation mensure that the pipeline would not hinder implement current or future curriculum ac2014, Constitution proposed a re-route of property. On April 7, 2014, Constitution road it initially requested to locate on the assessment of Constitution’s proposed re-section 3.4.3 of the EIS. 

CO21-3

S-288
COMPANIES AND ORGANIZATIONS

CO21 – Board of Board of Cooperative Educational Services (cont’d)

Companies and Or

As stated in section 4.12.1 of the EIS, onchas determined the HCAs on its pipeline, elements of its integrity management plan the pipeline within the HCAs. The criteriHCAs are defined in section 4.12.1 of the regulations specify the requirements for tmanagement plan at 49CFR Part 192.911management rule for HCAs requires inspevery 7 years. The Constitution Pipeline overall comprehensive integrity managemthese regulations. The regulations do not HCA.

CO21-4

We have included a recommendation in sthat would require Constitution to install fence separating the permanent right-of-wtraining area. This would allow faculty aheavy machinery in areas outside of the oWe understand the nature of the activities including ground vibration from the use ostudents nearby the pipeline, and have cowould be required to meet all federal safe

CO21-5

On April 7, 2014 Constitution stated that would no longer be necessary on school p

CO21-6

S-289
COMPANIES AND ORGANIZATIONS

CO21 – Board of Cooperative Educational Services (cont’d)

Companies and Or

See the response to comment CO21-3 regroute. CO21-7

S-290
COMPANIES AND ORGANIZATIONS

CO21 – Board of Cooperative Educational Services (cont’d)

Companies and Or

CO21-8 See the response to comment CO21-2.

S-291
COMPANIES AND ORGANIZATIONS

CO21 – Board of Cooperative Educational Services (cont’d)

Companies and Or

S-292
COMPANIES AND ORGANIZATIONS

CO21 – Board of Cooperative Educational Services (cont’d)

Companies and Or

S-293
COMPANIES AND ORGANIZATIONS

CO21 – Board of Cooperative Educational Services (cont’d)

Companies and Or

S-294
COMPANIES AND ORGANIZATIONS

CO22 – Trout Unlimited 

Companies and Or

See the response to comment FA1-1 regathe comment period.

CO22-1

See the response to comment FA1-1 regainformation. 

CO22-2

S-295
COMPANIES AND ORGANIZATIONS

CO22 – Trout Unlimited (cont’d)

Companies and Or

See the response to comments FA4-3 and inclusion of pending information in the E

CO22-3

See the response to comment FA1-1 regathe comment period.

CO22-4

S-296
COMPANIES AND ORGANIZATIONS

CO23 – Center for Sustainable Rural Communities

Companies and Or

The commentor’s statements regarding Cletter is noted. We note that Chairman WCongressman Gibson stated “the EIS will issues raised during the public scoping prpublic health concerns raised by Schohariinclude mitigation measures necessary to affected environment.” Section 4.11.1 of revised to include an expanded discussion The potential health effects regarding mesection 4.12 of the EIS. 

CO23-1

S-297
COMPANIES AND ORGANIZATIONS

CO23 – Center for Sustainable Rural Communities (cont’d)

Companies and Or

S-298
COMPANIES AND ORGANIZATIONS

CO23 – Center for Sustainable Rural Communities (cont’d)

Companies and Or

S-299
COMPANIES AND ORGANIZATIONS

CO23 – Center for Sustainable Rural Communities (cont’d)

Companies and Or

S-300
COMPANIES AND ORGANIZATIONS

CO23 – Center for Sustainable Rural Communities (cont’d)

Companies and Or

S-301
COMPANIES AND ORGANIZATIONS

CO24 – Cornell University for Kernan Land Trust

Companies and Or

The commentor’s statements regarding innoted. See the responses to comments FFERC staff also recommended in section Constitution extend monitoring for invasi

CO24-1

S-302
COMPANIES AND ORGANIZATIONS

CO24 – Cornell University for Kernan Land Trust (cont’d)

Companies and Or

CO24-2 The commentor’s credentials are noted.

S-303
COMPANIES AND ORGANIZATIONS

CO24 – Cornell University for Kernan Land Trust (cont’d)

Companies and Or

See the responses to comments FA4-9 aninvasive plant species. We have updated with new information and with our conclupotential impacts upon the Trust property

CO24-3CO24-4 See the response to comment CO4-2.

S-304
COMPANIES AND ORGANIZATIONS

CO25 – Advocates for Springfield

Companies and Or

See the response to comments LA1-4 and high volume hydraulic fracturing in both York is discussed in section 4.13. The FEgas well drilling, hydraulic fracturing, or of high volume hydraulic fracturing in Neprohibited and would be dependent upon and local governments and their regulator

CO25-1CO25-2 See the response to comment LA1-4. 

S-305
COMPANIES AND ORGANIZATIONS

CO25 – Advocates for Springfield (cont’d)

Companies and Or

See the responses to comments LA1-4, Cdiscussed in section 4.13.1 of the EIS, the of the Marcellus Shale in proximity to the considered within the context of cumulati

CO25-3

S-306
COMPANIES AND ORGANIZATIONS

CO26 – Otsego 2000

Companies and Or

The commentor’s statements regarding thEIS are noted. 

CO26-1

The commentor’s statements regarding thamenities of the Otsego County area are n

CO26-2

S-307
COMPANIES AND ORGANIZATIONS

CO26 – Otsego 2000 (cont’d)

Companies and Or

The proposed pipeline would cross througRiver watershed and across tributaries of as noted within the EIS in section 4.3, amnot cross the Susquehanna River itself. Teconomy of the region, as well as more spdiscussed throughout the EIS. 

CO26-3

See the response to comment SA2-1 regaproposed communication towers. See the FA4-46 regarding new information about distribution of natural gas via LeatherstocSee the response to comment FA1-1 regaextended comment period.

CO26-4

S-308
COMPANIES AND ORGANIZATIONS

CO26 – Otsego 2000 (cont’d)

Companies and Or

See the response to comment FA4-46 regLeatherstocking proposal. 

CO26-5CO26-6 See the response to comment FA1-1.

The proposed transport volume of the Co650,000 Dth/d of natural gas. Based on Cto one of our environmental information rthe maximum capacity of the pipeline sysDth/d. That estimated maximum delivery our desire to fully understand whether the could serve as a major conduit for newly natural gas, should they occur. There are delivery volume beyond 650,000 Dth/d, aever proposed in the future then additionaother agency permitting would be requiredraft EIS is accurate and current; there arConstitution or Iroquois to expand pipelinWe concluded that a theoretical maximum capacity of natural gas by 31 percent to bAny other “parallel pipeline” would be sureview. Constitution is only proposing on

CO26-7

S-309
COMPANIES AND ORGANIZATIONS

CO26 – Otsego 2000 (cont’d)

Companies and Or

Constitution’s June 2013 application as wfilings identified a proposed transportatioDth/d, not 500,000 Dth/d and expandable comment and the 2014 New York Energy Energy Plan was developed by the New YPlanning Board to meet the needs of the snot involved in the development of this pnor opposes the plan. See also the responand CO26-7.

CO26-8CO26-9 See the responses to comments FA1-1 an

S-310
COMPANIES AND ORGANIZATIONS

CO26 – Otsego 2000 (cont’d)

Companies and Or

S-311
COMPANIES AND ORGANIZATIONS

CO26 – Otsego 2000 (cont’d)

Companies and Or

See the response to comment LA1-4. We final EIS that “high-volume” hydraulic frprohibited in New York. We have updateEIS regarding development of the Marcelextent of production required to support tproposed projects. Specifically, this incluthe Susquehanna County, Pennsylvania suneeded to supply and sustain the Constituproduction at natural gas wells may declin

CO26-10

S-312
COMPANIES AND ORGANIZATIONS

CO26 – Otsego 2000 (cont’d)

Companies and Or

S-313
COMPANIES AND ORGANIZATIONS

CO26 – Otsego 2000 (cont’d)

Companies and Or

See the response to comments FA4-45, LThe proposed projects would not depend a major conduit for, natural gas supplies dwhether or not the State of New York ultivolume hydraulic fracturing. Given these that the proposed projects would not reascollector line for additional supply from tand Utica Shale formations and therefore natural gas development within New YorFERC’s EIS for this project is not dependcompletion of its programmatic SGEIS fohydraulic fracturing.

S-314

CO26-11
COMPANIES AND ORGANIZATIONS

CO26 – Otsego 2000 (cont’d)

Companies and Or

The comments regarding lack of details aconclusions reference section 5 of the EIS a summary containing our conclusions ana detailed explanation of our findings. Dthe resources and issues listed in commenbasis for our conclusions are contained in 

S-315

CO26-12
COMPANIES AND ORGANIZATIONS

CO26 – Otsego 2000 (cont’d)

Companies and Or

S-316
COMPANIES AND ORGANIZATIONS

CO26 – Otsego 2000 (cont’d)

Companies and Or

See the response to comment FA4-3 regasurveys due to a lack of survey permissioroute alternatives, including alternatives twith existing corridors, is provided in secSection 3 has been updated for the final Ecomment CO2-1 regarding Section 380.1Commission’s siting guidelines. 

CO26-13

S-317
COMPANIES AND ORGANIZATIONS

CO26 – Otsego 2000 (cont’d)

Companies and Or

We have updated section 4.5.3 of the EIS impacts that would occur to adjacent tractwould not be directly affected by clearingspecies, such as deer and wild turkey, mahabitats. Forest fragmentation could resuparasitic brown headed cowbirds. Howevsection 4.5.3, we included a recommendadevelop an upland forest mitigation plan wdesigned to include measures protective ohave updated sections 4.5 and 4.6.1 of the provisions of the preliminary plan filed by response to comment FA4-9 regarding inresponses to comments FA4-16 and FA4-M. We acknowledge that in some cases, wetlands or those wetlands along existing generally be of lower quality. However, presented in section 3.4.1, impacts on palwetlands along the proposed route would than those associated with alternative M. are of higher quality than palustrine emerpalustrine scrub-shrub (PSS) wetlands, anwetlands would represent either long-term impacts.Comments provided directly by the Henry and their agents regarding the subject prothe topics listed in comment CO26-14, arresponses to comments CO4, CO5, CO6, 

CO26-14

S-318
COMPANIES AND ORGANIZATIONS

CO26 – Otsego 2000 (cont’d)

Companies and Or

S-319
COMPANIES AND ORGANIZATIONS

CO26 – Otsego 2000 (cont’d)

Companies and Or

CO26-15 See the response to comment CO26-11.

S-320
COMPANIES AND ORGANIZATIONS

CO26 – Otsego 2000 (cont’d)

Companies and Or

The comment regarding the comparison benergy and transported energy is noted. Hproposing the transportation of natural gaproduced and developed in northern Pennalternate energy sources, including wind there are no known plans to build such faproduce the amount of energy on a scale ttransported by the Constitution pipeline odemand of customers of natural gas in NeEngland. See the response to comment Crecently proposed projects that could poteand end user markets. We acknowledge tevaluates the potential impacts of newly psources such as wind and solar power, thoexisting, would be theoretical, and would Conversely, the natural gas supply in SusPennsylvania is existing and available. Tcontinue regardless of whether the Constiis built or not. Additionally, as noted botcommentor, new electric transmission linof miles long) would be required to transpnew wind or solar production areas to the its own set of environmental impacts. W4.13.1 of the EIS to reflect Marcellus Shawould be required to provide and sustain the Pennsylvania production area into the over the long-term. 

CO26-16

The alternative routes depicted in figures TGP 200) and 3.2.3-2 (Dominion) would collocated and largely collocated with exirespectively. As discussed in sections 3.2 evaluated multiple options for system and alternatives that would largely eliminate tconstruction. 

CO26-17

S-321
COMPANIES AND ORGANIZATIONS

CO26 – Otsego 2000 (cont’d)

Companies and Or

The Millennium-Dominion-TGP alternatiapproximately 232 miles long, almost douproposed route. While this alternative wocollocated with existing corridors, it wousubstantial new construction and permaneimpacts on waterbodies, wetlands, forest interior forest), and landowners. Based ophotography, the Millennium (approximaDominion (approximately 40 feet wide), (approximately 60 feet wide) pipelines’ mrights-of-way are too small to provide concleared workspace for a new, adjacent pipmisinterprets that a new pipeline can be inexisting easement and can eliminate envirPipeline easements are generally establishwidth necessary to operate the pipeline in new pipeline adjacent to an existing one w– 100 feet of construction right-of-way. Gconsiderations limiting the use of heavy ean active pipeline (or use of special constestimate that only 25 feet or less of the exof-way may be available to provide overlpermanent rights-of-way for a new pipeliConstitution’s proposed nominal construcof 110 feet in non-agricultural uplands as comparison, and because the Millenniumalternative route would be approximately the proposed route, 45 percent more land occur with implementation of the Millenncollocated alternative even accounting for existing rights-of-way during constructionagreements would also have to be negotiaand permanent rights-of-way and based ois very unlikely that all of the landowners along this 232-mile-long corridor would vprovide easements, thereby also resulting proceedings. We conclude that the Millecollocated alternative is not preferable to route for these reasons. 

CO26-17 (cont’d)

S-322
COMPANIES AND ORGANIZATIONS

CO26 – Otsego 2000 (cont’d)

Companies and Or

We also evaluated route alternatives procYork City (i.e., Millennium, TGP 300, anpotentially from the New York City area England (i.e., Algonquin) in section 3.2.3proposed projects have been designed to customers in New York City (via the exisand to New England (via the existing TGother pipelines may proceed in generally the proposed end user locations, they wouexactly the same end-user markets. This the TGP 200 New England market compaNew England Market. Our experience wreview of aerial photography indicated thMillennium, TGP 300, or Transco Leidy similar to Iroquois’ existing connections aSouth Bronx, New York and South CommNew York would not be feasible due to pconstructability issues in this congested awould not be preferable to the proposed presponse to comment LA7-5 regarding otpotentially affect the proposed projects’ d

CO26-17 (cont’d)

S-323
COMPANIES AND ORGANIZATIONS

CO26 – Otsego 2000 (cont’d)

Companies and Or

The proposed Iroquois Gas Transmission North Project (SoNo) and the proposed T(TGP) Northeast Energy Direct project bothe draft EIS was finalized. Both projects discussion of cumulative impacts in sectioBoth of these companies have conducted market interest. The Northeast Energy Dpre-filing on September 15, 2014. The Soentered into the pre-filing process with thproject has filed a formal Certificate applpublically available information from IroMorgan/TGP, both projects would be phyWright, New York, and may potentially rthe Constitution pipeline if it is certificatecould potentially result in exportation of nReversal of flow on the Iroquois pipeline of some natural gas to New York City froconnection at the Wright Compressor Stawould still have to meet its contractual obusers downstream in New York City. Thnot abandon or terminate service to custosolely to redirect gas to a market of its chproject would require Commission approvapplication is present at this time. We haof the EIS with this information. 

CO26-18

S-324
COMPANIES AND ORGANIZATIONS

CO26 – Otsego 2000 (cont’d)

Companies and Or

The EIS has been updated to clarify that tnatural gas results in fewer emissions comother energy sources such as coal or fuel that methane, a primary component of nagreenhouse gas. We have updated section reflect Marcellus Shale development that provide and sustain natural gas flow from production area into the Constitution pipeWe have also updated section 4.11.1 rega

CO26-19

S-325
COMPANIES AND ORGANIZATIONS

CO26 – Otsego 2000 (cont’d)

Companies and Or

See the response to comment CO26-1. Wwith updated and new information where and based on comments received. 

CO26-20

S-326
COMPANIES AND ORGANIZATIONS

CO26 – Otsego 2000 (cont’d)

Companies and Or

S-327
COMPANIES AND ORGANIZATIONS

CO27 – Concerned Citizens of Trout Creek

Companies and Or

CO27-1 See the response to comments FA1-1 and 

The specifics of any future Marcellus Shaunknown and would be speculative. We development in the project area. Attemptlocations of future development and resulbeyond the scope of this NEPA analysis.

CO27-2

The commentor’s statement regarding the the response to comment FA1-1 regarding comment period.

CO27-3

S-328
COMPANIES AND ORGANIZATIONS

CO28 – Concerned Citizens of Trout Creek

Companies and Or

Section 3.2.2 of the EIS discusses the use systems to meet the purpose and need of tdiscusses collocation with existing pipelin

CO28-1

S-329
COMPANIES AND ORGANIZATIONS

CO29 – Concerned Citizens of Trout Creek

Companies and Or

The commentor’s statements are noted. Tfor police presence during each of the drameetings. Local police were on hand durOneonta and restrained any disagreement parties from further escalation. The panestatements to the attendees requesting resthe meeting. We reiterate here, as the FEcomment meetings, that offering oral comanother mode of submitting comments to prioritized in any way by the FERC staff over other methods. Any individuals that the opportunity to provide written commethemselves, online, or by U.S. mail. All chow they are provided, were weighed and The FERC staff allowed all persons signeto speak if they so chose.

CO29-1

S-330
COMPANIES AND ORGANIZATIONS

CO29 – Concerned Citizens of Trout Creek (cont’d)

Companies and Or

S-331
COMPANIES AND ORGANIZATIONS

CO30 – Concerned Citizens of Trout Creek

Companies and Or

Blasting is discussed in sections 2.3.1 and Given Constitution’s proposed mitigation recommendations, we conclude that impabe effectively minimized. Blasting would underlying rock can’t be dislodged with hincluding track hoes with special implemeother equipment. If blasting does become involves a small scale, controlled, rolling resulting in limited ground upheaval. Thetypically result in large, above ground expresponse to comment LA10-13. The exacdue to blasting is not anticipated, althoughthe EIS, vegetation removal and ground dinfluence flooding and erosion. 

CO30-1

Constitution and Iroquois would both imperosion controls based upon our Plan and other proposed measures to reduce or preof stormwater runoff. Blasting would not erosion. See the response to comment CO

CO30-2

See the response to comment CO30-1. Aof the EIS, the minimum charges needed would be used.

CO30-3

According to Constitution’s Blasting Planduring daylight hours and homeowners w72 hours prior to blasting activities. Charthe minimum needed to break up and disl

CO30-4

S-332
COMPANIES AND ORGANIZATIONS

CO30 – Concerned Citizens of Trout Creek (cont’d)

Companies and Or

See the response to FA1-1 regarding exteperiod.

CO30-5

S-333
COMPANIES AND ORGANIZATIONS

CO31 – Allegheny Defense Project

Companies and Or

The commentor’s motion to intervene and the proposed projects is noted.

CO31-1

S-334
COMPANIES AND ORGANIZATIONS

CO31 – Allegheny Defense Project (cont’d)

Companies and Or

S-335
COMPANIES AND ORGANIZATIONS

CO31 – Allegheny Defense Project (cont’d)

Companies and Or

See the response to comment response LAindependent regulatory agency with speciby law that does not permit the Commissidevelopment of interstate natural gas propnationwide scale. The Commission is tasreviewing individual interstate natural gawhen an established market demand drivethe parameters defining the bounds of the determined that it is neither a prudent use nor within our authority, to conduct a “prdiscussing all natural gas development, trconsumption on a regional, or nationwide to the widely varying nature and scope of prepare focused environmental analysis fnot a generic analysis to be used on all pr

CO31-2

S-336
COMPANIES AND ORGANIZATIONS

CO31 – Allegheny Defense Project (cont’d)

Companies and Or

S-337
COMPANIES AND ORGANIZATIONS

CO32 – Center for Sustainable Rural Communities

Companies and Or

Section 3.1.2.3 of the EIS has been updatcommentor’s statements regarding solar einformation included in the EIS was intengeneralized discussion of how an alternatas solar power might compare to the propFERC staff reviews applications for interpipeline projects in accordance with an apobjective(s) in order to disclose the enviroproposal to inform the decision makers anNEPA, evaluate reasonable alternatives to the FERC as a matter of policy and in accNatural Gas Act and other governing reguthe development of the natural gas (or othindustry’s infrastructure regionally or on basis, nor does it have the authority to perenergy projects. As such, the FERC staffreasonable alternatives does not include sobjectives, determining what an applicantbe, nor does it include redefining the obje

CO32-1

S-338
COMPANIES AND ORGANIZATIONS

CO32 – Center for Sustainable Rural Communities (cont’d)

Companies and Or

S-339
COMPANIES AND ORGANIZATIONS

CO32 – Center for Sustainable Rural Communities (cont’d)

Companies and Or

S-340
COMPANIES AND ORGANIZATIONS

CO33 – Business Council of NY State

Companies and Or

The commentor’s statements in support oare noted.

CO33-1

S-341
COMPANIES AND ORGANIZATIONS

CO33 – Business Council of NY State (cont’d)

Companies and Or

S-342
Section 3.4.3 of the EIS has been updated 

assessment of minor route variations for pand ALT-B-NY-BR-001.000. 

COMPANIES AND ORGANIZATIONSCO34 – The Christensen Family Trust

Companies and Or

CO34-1

S-343
COMPANIES AND ORGANIZATIONS

CO34 – The Christensen Family Trust (cont’d)

Companies and Or

S-344
COMPANIES AND ORGANIZATIONS

CO34 – The Christensen Family Trust (cont’d)

Companies and Or

S-345
COMPANIES AND ORGANIZATIONS

CO34 – The Christensen Family Trust (cont’d)

Companies and Or

S-346
COMPANIES AND ORGANIZATIONS

CO35 – Chesapeake Bay Foundation

Companies and Or

See the response to comments response L4.

CO35-1

S-347
COMPANIES AND ORGANIZATIONS

CO35 – Chesapeake Bay Foundation (cont’d)

Companies and Or

S-348
COMPANIES AND ORGANIZATIONS

CO35 – Chesapeake Bay Foundation (cont’d)

Companies and Or

S-349
COMPANIES AND ORGANIZATIONS

CO35 – Chesapeake Bay Foundation (cont’d)

Companies and Or

S-350
COMPANIES AND ORGANIZATIONS

CO35 – Chesapeake Bay Foundation (cont’d)

Companies and Or

CO35-2 The commentor’s statement regarding the 

S-351
COMPANIES AND ORGANIZATIONS

CO36 – Center for Sustainable Rural Communities

Companies and Or

The commentor’s statements regarding thRichmondville are noted.

CO36-1

S-352
COMPANIES AND ORGANIZATIONS

CO36 – Center for Sustainable Rural Communities (cont’d)

Companies and Or

S-353
COMPANIES AND ORGANIZATIONS

CO36 – Center for Sustainable Rural Communities (cont’d)

Companies and Or

See the response to comment FA1-1 regathe comment period.

CO36-2

S-354
COMPANIES AND ORGANIZATIONS

CO36 – Center for Sustainable Rural Communities (cont’d)

Companies and Or

S-355
COMPANIES AND ORGANIZATIONS

CO36 – Center for Sustainable Rural Communities (cont’d)

Companies and Or

S-356
COMPANIES AND ORGANIZATIONS

CO36 – Center for Sustainable Rural Communities (cont’d)

Companies and Or

S-357
COMPANIES AND ORGANIZATIONS

CO37 – Kernan Land Trust

Companies and Or

CO37-1 See the response to comment FA1-1. 

S-358
COMPANIES AND ORGANIZATIONS

CO37 – Kernan Land Trust (cont’d)

Companies and Or

CO37-2 See the response to comment CO4-1.

S-359
COMPANIES AND ORGANIZATIONS

CO37 – Kernan Land Trust (cont’d)

Companies and Or

S-360
COMPANIES AND ORGANIZATIONS

CO37 – Kernan Land Trust (cont’d)

Companies and Or

CO37-3 See the responses to comments FA4-9, FACO37-4 See the response to comment CO5-12.CO37-5 See the response to comments FA1-1, CO

S-361
COMPANIES AND ORGANIZATIONS

CO37 – Kernan Land Trust (cont’d)

Companies and Or

S-362
COMPANIES AND ORGANIZATIONS

CO37 – Kernan Land Trust (cont’d)

Companies and Or

CO37-6 The commentor’s statements regarding thCO37-7 See the response to comment CO4-2.

See the response to comment CO5-10. Scomment CO4-2.

CO37-8CO37-9 See the response to comment CO4-2.

Section 401 and 404 permits are discusseEIS. These permits may be issued followby the appropriate agency. As stated in sand Iroquois would be responsible for obtapprovals. Further as stated in recommenApplicants would not be allowed to begin obtain all necessary federal permits. In somay not be completed until all field survefield surveys in some locations will be deacquisition of survey access. Survey accewill be dependent on whether the CommiCertificate for the project. 

CO37-10CO37-11 See the responses to comments CO4-2 an

S-363
COMPANIES AND ORGANIZATIONS

CO37 – Kernan Land Trust (cont’d)

Companies and Or

S-364
COMPANIES AND ORGANIZATIONS

CO37 – Kernan Land Trust (cont’d)

Companies and Or

S-365
COMPANIES AND ORGANIZATIONS

CO37 – Kernan Land Trust (cont’d)

Companies and Or

S-366
COMPANIES AND ORGANIZATIONS

CO37 – Kernan Land Trust (cont’d)

Companies and Or

S-367
COMPANIES AND ORGANIZATIONS

CO37 – Kernan Land Trust (cont’d)

Companies and Or

CO37-12 See the response to comment CO4-2.

S-368
COMPANIES AND ORGANIZATIONS

CO37 – Kernan Land Trust (cont’d)

Companies and Or

See the response to CO5-4. Constitution’do not have survey access permission for Trust’s “preliminary” wetland boundary wwetland delineation for our comparison. consultant’s assert that the Commission uresulted in a “bad analysis.” However, wdata that we could obtain given that the Tthe opportunity to conduct a wetland delin

CO37-13

S-369
COMPANIES AND ORGANIZATIONS

CO37 – Kernan Land Trust (cont’d)

Companies and Or

S-370
COMPANIES AND ORGANIZATIONS

CO37 – Kernan Land Trust (cont’d)

Companies and Or

S-371
COMPANIES AND ORGANIZATIONS

CO37 – Kernan Land Trust (cont’d)

Companies and Or

S-372
COMPANIES AND ORGANIZATIONS

CO37 – Kernan Land Trust (cont’d)

Companies and Or

See the responses to comments FA4-9, FAhave updated section 3.4.3 of the EIS witand with our conclusion regarding route aalternatives and potential impacts upon th

CO37-14

S-373
COMPANIES AND ORGANIZATIONS

CO37 – Kernan Land Trust (cont’d)

Companies and Or

The conclusions in the draft EIS did not rvariations in regard to the Trust property; to facilitate additional assessment of alterresponses to comments CO4-1, CO4-2 anresponse to comment CO12-3 regarding tthe responses to comments SA4-1, SA4-2regarding alternative M. See the response regarding Section 380.15(b) of the Commguidelines. Typically, the FERC does not require fielevaluations of alternatives. Additionally, compare equivalent source types of data ianalysis, such as all desktop data (or all fimixing data types even if field data are avscenario. The use of two different data soinaccurate, inappropriate, or unfair comparoutes or scenarios. 

S-374

CO37-15
COMPANIES AND ORGANIZATIONS

CO37 – Kernan Land Trust (cont’d)

Companies and Or

S-375
COMPANIES AND ORGANIZATIONS

CO37 – Kernan Land Trust (cont’d)

Companies and Or

S-376
COMPANIES AND ORGANIZATIONS

CO37 – Kernan Land Trust (cont’d)

Companies and Or

S-377
COMPANIES AND ORGANIZATIONS

CO37 – Kernan Land Trust (cont’d)

Companies and Or

S-378
COMPANIES AND ORGANIZATIONS

CO37 – Kernan Land Trust (cont’d)

Companies and Or

S-379
COMPANIES AND ORGANIZATIONS

CO37 – Kernan Land Trust (cont’d)

Companies and Or

S-380
COMPANIES AND ORGANIZATIONS

CO37 – Kernan Land Trust (cont’d)

Companies and Or

CO37-16 See the response to comment FA1-1.

S-381
COMPANIES AND ORGANIZATIONS

CO37 – Kernan Land Trust (cont’d)

Companies and Or

S-382
COMPANIES AND ORGANIZATIONS

CO37 – Kernan Land Trust (cont’d)

Companies and Or

S-383
COMPANIES AND ORGANIZATIONS

CO37 – Kernan Land Trust (cont’d)

Companies and Or

See the response to comment CO37-10. Tdetermines significance on the basis of ennot on the outcomes of other permit authodetermination considers the application, bmitigation measures presented before us. respective federal permit authorizations, oopportunity to impose additional restrictioApplicants that would likely only reduce significant impact. Furthermore, the Comadditional mitigation or conditions to reduresources under the jurisdiction of the othagencies. 

CO37-17

S-384
COMPANIES AND ORGANIZATIONS

CO37 – Kernan Land Trust (cont’d)

Companies and Or

S-385
COMPANIES AND ORGANIZATIONS

CO38 – Skyhill Farm LLC

Companies and Or

As stated in section 4.3.2.1 of the EIS, exproposed compressor station facilities is e6 feet deep. As discussed in the EIS, theroverburden above the karst bedrock in thanot anticipate the need for blasting. The eCompressor Station has been in operation since 1993 with no known impacts on surThe FERC procedures, which have been arequire that “bulk storage of hazardous mchemicals, fuels, and lubricating oils have containment systems to prevent spills.”As stated by Iroquois in its Resource Repphase at the Wright InterconnectPproject refueling of vehicles and storage of fuel, Spills or leaks of hazardous liquids could hazard to the groundwater system and ultThe potential for this impact is expected tminimized by the proper implementation (author note – spill prevention, control, aPlan. Iroquois is mandated through the Fprepare a site-specific SPCC Plan for the preventative measures that shall be followwaste spill as well as mitigation measures to immediately contain and clean up a spiThe best management practices that woulConstitution during construction in areas addressed in section 4.1.5 of the DEIS.

CO38-1

Section 4.1.3.2 of the EIS discusses faults proposed projects.

CO38-2

Section 4.1.3.1 of the EIS discusses earthproposed projects.

CO38-3CO38-4 See the response to comment CO1-5 regaCO38-5 See the response to comment CO38-1.

The formula for pipeline impact radius 4.12.1 of the EIS. The potential impact pipeline would be 796 feet. It is theorepipeline impact radius for multiple pipestation located in the same area could eximpact radius for any single one of the pscenario would likely require the simmultiple facilities.

CO38-6

S-386
COMPANIES AND ORGANIZATIONS

CO38 – Skyhill Farm LLC (cont’d)

Companies and Or

See the response to comments LA4-2 and description and listing of class designatio4.12.1 of the EIS and is based on populatvicinity of the pipeline, not on the potentidispersal.

CO38-7

S-387
COMPANIES AND ORGANIZATIONS

CO38 – Skyhill Farm LLC (cont’d)

Companies and Or

See the response to comments LA5-6 and leakage is discussed in Section 4.11.1.

CO38-8

See the response to comment CO38-3. Tthe R.D. Jacobi / Tectonics 353 (2002) 75magnitude. These events are too small to damage to structures at the surface. This findings of the DEIS. The NYCDEP studcommentor (Geophysical Evaluation of InNatural Gas Production on New York CitWater Supply Infrastructure 2011) describof induced seismicity associated with higfracturing and recommended buffer distanwere to occur. High volume hydraulic frathe scope of the Constitution Pipeline ProInterconnect Project, or the EIS.

CO38-9

S-388
COMPANIES AND ORGANIZATIONS

CO38 – Skyhill Farm LLC (cont’d)

Companies and Or

S-389
COMPANIES AND ORGANIZATIONS

CO38 – Skyhill Farm LLC (cont’d)

Companies and Or

See the response to comment CO1-5. Thor wetlands located at the Iroquois projecboth mapping and their field survey. The Kill, is approximately 2,200 feet from the anticipated to be an issue at the site for thunable to locate information from the FEMrisk of flooding at this site. 

CO38-10

S-390
COMPANIES AND ORGANIZATIONS

CO38 – Skyhill Farm LLC (cont’d)

Companies and Or

See the response to comment CO38-1. Tpossible spills at the proposed Minisink Cnoted.

CO38-11CO38-12 See the response to comment CO38-6.

S-391
COMPANIES AND ORGANIZATIONS

CO39 – Allegheny Defense Project

Companies and Or

See the response to comments LA1-4 regEIS. The cumulative impacts section of texpanded with new information. The comdeny the proposed projects is noted.

CO39-1

S-392
COMPANIES AND ORGANIZATIONS

CO39 – Allegheny Defense Project (cont’d)

Companies and Or

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. Unless proposed in tandem and clearly deother, such as the proposed Constitution pWright Interconnect projects, proposed prdemonstrably sufficient feasibility, purpoalone. Proposed projects may be based oexisting infrastructure, but can’t be based whose certification status is uncertain. Pror programmatic EIS is not warranted for Even if the FERC were to develop a progMarcellus Shale extraction, the resultant anaught, as the FERC has no authority to dor impose mitigation measures or best ma(where warranted) on the proponents of th

CO39-2

S-393
COMPANIES AND ORGANIZATIONS

CO39 – Allegheny Defense Project (cont’d)

Companies and Or

The comments regarding President Obamadministration’s statements are noted. Than impartial, independent review of propoEIS as well as other non-environmental i1.2.1 of the EIS) will be used by the Commaking process. The Commission’s decicongressional or presidential review or ch

CO39-3

S-394
COMPANIES AND ORGANIZATIONS

CO39 – Allegheny Defense Project (cont’d)

Companies and Or

S-395
COMPANIES AND ORGANIZATIONS

CO39 – Allegheny Defense Project (cont’d)

Companies and Or

S-396
COMPANIES AND ORGANIZATIONS

CO39 – Allegheny Defense Project (cont’d)

Companies and Or

See the response to comment CO39-2. Tsources of information (both internal and of the status of the natural gas industry, inthe Commission and under consideration This does not suggest, nor should it be imdriving this industry or engaged in regionplanning.

S-397

CO39-4
COMPANIES AND ORGANIZATIONS

CO39 – Allegheny Defense Project (cont’d)

Companies and Or

S-398
COMPANIES AND ORGANIZATIONS

CO39 – Allegheny Defense Project (cont’d)

Companies and Or

S-399
COMPANIES AND ORGANIZATIONS

CO39 – Allegheny Defense Project (cont’d)

Companies and Or

S-400
COMPANIES AND ORGANIZATIONS

CO39 – Allegheny Defense Project (cont’d)

Companies and Or

S-401
COMPANIES AND ORGANIZATIONS

CO39 – Allegheny Defense Project (cont’d)

Companies and Or

S-402
COMPANIES AND ORGANIZATIONS

CO39 – Allegheny Defense Project (cont’d)

Companies and Or

S-403
COMPANIES AND ORGANIZATIONS

CO39 – Allegheny Defense Project (cont’d)

Companies and Or

S-404
COMPANIES AND ORGANIZATIONS

CO39 – Allegheny Defense Project (cont’d)

Companies and Or

S-405
COMPANIES AND ORGANIZATIONS

CO39 – Allegheny Defense Project (cont’d)

Companies and Or

S-406
COMPANIES AND ORGANIZATIONS

CO39 – Allegheny Defense Project (cont’d)

Companies and Or

S-407
COMPANIES AND ORGANIZATIONS

CO39 – Allegheny Defense Project (cont’d)

Companies and Or

S-408
COMPANIES AND ORGANIZATIONS

CO39 – Allegheny Defense Project (cont’d)

Companies and Or

S-409
COMPANIES AND ORGANIZATIONS

CO39 – Allegheny Defense Project (cont’d)

Companies and Or

S-410
COMPANIES AND ORGANIZATIONS

CO39 – Allegheny Defense Project (cont’d)

Companies and Or

S-411
COMPANIES AND ORGANIZATIONS

CO39 – Allegheny Defense Project (cont’d)

Companies and Or

The FERC staff reviews applications for pipeline projects in accordance with an apobjective(s) in order to disclose the enviroproposal to inform the decision makers anNEPA, evaluate reasonable alternatives to applications are not limited to only those extracted from either the Marcellus or Utindustry contemplates projects on an indimarkets develop and a supply is available they are financially viable. The Commisswith the industry to develop project plann

CO39-5

S-412
COMPANIES AND ORGANIZATIONS

CO39 – Allegheny Defense Project (cont’d)

Companies and Or

S-413
COMPANIES AND ORGANIZATIONS

CO39 – Allegheny Defense Project (cont’d)

Companies and Or

S-414
COMPANIES AND ORGANIZATIONS

CO39 – Allegheny Defense Project (cont’d)

Companies and Or

S-415
COMPANIES AND ORGANIZATIONS

CO39 – Allegheny Defense Project (cont’d)

Companies and Or

As stated in section 4.13.1.1 of the EIS, dMarcellus Shale natural gas resource is noProduction and gathering activities, and thfacilities used for these activities, are not but are overseen by the affected region’s with jurisdiction over the management anMarcellus Shale gas resource. The FERCrestricted to facilities used for the transpointerstate commerce, and does not extend intrastate transportation.The increase of bobcats in New York is nto comment FA4-9 regarding invasive spedoes not specifically discuss the hemlock 4.5.4 of the EIS does discuss invasive speash borer and didymo. 

CO39-6

S-416
COMPANIES AND ORGANIZATIONS

CO39 – Allegheny Defense Project (cont’d)

Companies and Or

S-417
COMPANIES AND ORGANIZATIONS

CO39 – Allegheny Defense Project (cont’d)

Companies and Or

S-418
COMPANIES AND ORGANIZATIONS

CO39 – Allegheny Defense Project (cont’d)

Companies and Or

S-419
COMPANIES AND ORGANIZATIONS

CO39 – Allegheny Defense Project (cont’d)

Companies and Or

S-420
COMPANIES AND ORGANIZATIONS

CO39 – Allegheny Defense Project (cont’d)

Companies and Or

The Allegheny National Forest is located from the proposed projects. Therefore imNational Forest from the proposed projecAny gas production occurring within the Forest would be subject to the approval aForest Service. The FERC has no obligatto compel the U.S. Forest Service to manits jurisdiction in any manner. The U.S. Fby the laws governing its agency, as is the project would cross two New York State routed to minimize impacts as discussed i4.8 of the EIS.

CO39-7

S-421
COMPANIES AND ORGANIZATIONS

CO39 – Allegheny Defense Project (cont’d)

Companies and Or

S-422
COMPANIES AND ORGANIZATIONS

CO39 – Allegheny Defense Project (cont’d)

Companies and Or

The specific production of natural gas is bEIS and the authority of the FERC. Prodwhether it occurs within state or federal laprivate lands) has no bearing on the FERCanalyze it. 

CO39-8

S-423
COMPANIES AND ORGANIZATIONS

CO39 – Allegheny Defense Project (cont’d)

Companies and Or

S-424
COMPANIES AND ORGANIZATIONS

CO39 – Allegheny Defense Project (cont’d)

Companies and Or

The commentor’s statements regarding reproduction to end-use of fossil fuels are nto comment CO26-19 concerning how the natural gas, which may displace other foscoal, may result in fewer future emissions The FERC does not regulate the productiexport of coal or oil, and the effects of poresources upon the global climate are beyEIS. 

CO39-9

S-425
COMPANIES AND ORGANIZATIONS

CO39 – Allegheny Defense Project (cont’d)

Companies and Or

S-426
COMPANIES AND ORGANIZATIONS

CO39 – Allegheny Defense Project (cont’d)

Companies and Or

The commentor’s statements regarding viPennsylvania Constitution are noted. The federal laws and statutes governing its exno authority to interpret Pennsylvania lawresponse to comment CO26-18 regarding Direct Project (formerly called the NortheSee the response to comment LA1-4 regaassessment and FA4-44 regarding cumula

CO39-10

S-427
COMPANIES AND ORGANIZATIONS

CO39 – Allegheny Defense Project (cont’d)

Companies and Or

S-428
COMPANIES AND ORGANIZATIONS

CO39 – Allegheny Defense Project (cont’d)

Companies and Or

Section 4.13.6.4 of the EIS further states 

projects constructed in the area would be 

vegetation cover to the disturbed areas unbuildings or other impervious surfaces. Osome wildlife displaced during constructiwould return to the newly disturbed area undisturbed habitats after completion of cConstruction of any Marcellus Shale devealso result in some long-term loss of wildaboveground structures and well pads. In projects could result in mortality to bird aon wildlife species from construction of aarea of the proposed projects generally wtemporary, and minor, although some dispermanent. Therefore, cumulative impacsignificant for any individual wildlife spepopulation in the region of influence.

CO39-11

S-429
COMPANIES AND ORGANIZATIONS

CO39 – Allegheny Defense Project (cont’d)

Companies and Or

CO39-12 See the response to comments CO39-2 an

S-430
COMPANIES AND ORGANIZATIONS

CO39 – Allegheny Defense Project (cont’d)

Companies and Or

S-431
COMPANIES AND ORGANIZATIONS

CO40 – Damascus Citizens for Sustainability

Companies and Or

CO40-1 See the response to comment FA1-1.

S-432
COMPANIES AND ORGANIZATIONS

CO40 – Damascus Citizens for Sustainability (cont’d)

Companies and Or

See the response to comment LA5-6 and comment FA1-1.

CO40-2

The discussion of radon in section 4.11.1updated with new information. 

CO40-3

The commentor’s suggestion that the FERmonitoring is noted.

CO40-4

The storage or processing of natural gas iproposed projects. Section 4.11.1.4 of thissues including non-project activities thareduction of radon levels prior to combusbeen updated with new information. 

CO40-5

S-433
COMPANIES AND ORGANIZATIONS

CO40 – Damascus Citizens for Sustainability (cont’d)

Companies and Or

The FERC has no regulatory authority ovmeasures that may be used to reduce radonatural gas consumption. Section 4.11.1.updated with new information. 

CO40-6

S-434
COMPANIES AND ORGANIZATIONS

CO41 – Earthjustice

Companies and Or

CO41-1 See the response to comment FA1-1.

The cutting of mature trees and forest fragas a result of the proposed projects as discthe EIS. These impacts would be minimireduction of the construction right-of-way regrowth of trees in approximately 54 perforested areas cleared during constructionConstitution’s Preliminary Migratory BirPlan, as we have recommended. Constituboth implement sediment and erosion conPlan and Procedures, which were revised other proposed measures to prevent negatstormwater runoff. See the response to coregarding flooding.

CO41-2

S-435
COMPANIES AND ORGANIZATIONS

CO41 – Earthjustice (cont’d)

Companies and Or

As stated in section 4.11.1.3 of the EIS, ocompressor station would not be expected impacts on local or regional air quality. Ediesel- and gasoline-fueled construction eengines for both projects would be minimstandards required at the time of manufacand vehicles, and would comply with the road emission regulations.

CO41-3CO41-4 See the response to comment LA1-4.

S-436
COMPANIES AND ORGANIZATIONS

CO41 – Earthjustice (cont’d)

Companies and Or

Sensitive resources, as well as potential imare discussed in the EIS for interior forest fragmentation (section 4.5.3), waterbodiequality (section 4.11.1), wildlife (section and safety (4.12).

CO41-5

See the response to comment FA1-1. Cumdiscussed in section 4.13 of the EIS.

CO41-6CO41-7 See the response to comment FA1-1 and 

S-437
COMPANIES AND ORGANIZATIONS

CO41 – Earthjustice (cont’d)

Companies and Or

S-438
COMPANIES AND ORGANIZATIONS

CO41 – Earthjustice (cont’d)

Companies and Or

CO41-8 See the response to comment FA4-46.

S-439
COMPANIES AND ORGANIZATIONS

CO41 – Earthjustice (cont’d)

Companies and Or

CO41-9 See the response to comment FA1-1 and 

As provided in table 4.8.1-1 of the EIS, aresidential areas would account for 24.2 pdisturbed during construction rather than the commentor. Compaction testing in agresidential areas is consistent with our UpRevegetation, and Maintenance Plan (Plastated in section 4.4.3 of the EIS, wetlanddecompacted as necessary. See the resporegarding study of potential trenchless crowaterbodies.

CO41-10

S-440
COMPANIES AND ORGANIZATIONS

CO41 – Earthjustice (cont’d)

Companies and Or

See the response to comment FA1-1. As of the EIS, geotechnical studies for the reeither ongoing or not started due to lack oGeotechnical study results for the three coprovided as part of Constitution’s applicaaccessed at http://elibrary.ferc.gov:0/idmws/file_list.a0901. Any studies requested by the Comreviewed by the FERC staff and would be eLibrary system for public review.

CO41-11

S-441
COMPANIES AND ORGANIZATIONS

CO41 – Earthjustice (cont’d)

Companies and Or

Selected waterbodies would be crossed wtechniques; all others are proposed for dry which would limit impacts on water qualiplans for surface water quality monitoring conducted under dry conditions and the stwould be restored prior to restoration of tquality monitoring could be a condition oagencies such as the COE, the PADEP, o

CO41-12

If an in-stream blasting plan was necessarreviewed and approved by the FERC staf4.6.2.3 of the EIS, the in-stream blasting pwould comply with state-specific regulaticonditions. Additionally, Constitution mufederal and state authorities at least 48 howithin the waterbody, or as specified in aFinally, Constitution must maintain downblasting within streams.

CO41-13

S-442
COMPANIES AND ORGANIZATIONS

CO41 – Earthjustice (cont’d)

Companies and Or

As stated in section 4.4.4 of the EIS, the FConstitution’s state-specific ECPs specify should not be within 50 feet of wetlands ealternative measure has been requested by approved by the FERC. Areas where Conextra workspace and stated that a 50-foot is infeasible (including its site-specific jusidentified in appendix D of the EIS. We hexceptions and deem them acceptable. Secomment FA4-3 regarding un-surveyed aproposed a crossing method for each wetlimpacted by the proposed pipeline (appenon expected conditions. However, the exwould be confirmed at the time of construmoisture conditions at crossings cannot badvance. If Constitution ultimately propocrossing from a trenchless method to a treFERC and applicable agencies would havthe proposal. As stated in section 4.4.4 of wetland vegetation would regenerate quicto 3 years, and emergent wetlands would vegetation maintenance. We have decadeexperience observing and assessing rightsfound that PEM and PSS wetlands can be following construction. Temporary impawould be long-term outside the maintainewoody vegetation would take several yearpermanent within the maintained corridor

CO41-14

S-443
COMPANIES AND ORGANIZATIONS

CO41 – Earthjustice (cont’d)

Companies and Or

As stated in section 4.3.2.1 of the EIS, the be excavated to a depth of 6 to 8 feet in mproposed pipeline would cross approximasurficial aquifers which have depths less t1). As discussed in section 4.3.2.1, Constfurther minimize impacts by using constrdescribed in its site-specific ECPs, such apermanent trench plugs and interceptor dito comment LA8-1 regarding herbicide utrench would not result in consumptive ustherefore, we do not expect drawdowns oThe discussion regarding the Clinton Stresection 4.3.2.1 of the EIS has been update

CO41-15

S-444
COMPANIES AND ORGANIZATIONS

CO41 – Earthjustice (cont’d)

Companies and Or

Constitution and Iroquois would both imperosion controls based upon our Plan and other proposed measures (such as their stprevention plans) to prevent negative effestormwater runoff. These measures are dand 4.3 of the EIS and in Constitution’s Pthe sediment and erosion control measureconstruction plans, can be reviewed in Cohttp://elibrary.ferc.gov:0/idmws/file_list.a0901. Constitution’s Plan requires the inspectiotemporary erosion control measures at leaareas of active construction or equipment basis in areas with no construction or equwithin 24 hours of each 0.5 inch rainfall einclude measures to ensure revegetation oimpacts from runoff during operation.

CO41-16

S-445
COMPANIES AND ORGANIZATIONS

CO41 – Earthjustice (cont’d)

Companies and Or

CO41-17 See the responses to comment CO26-14 a

S-446
COMPANIES AND ORGANIZATIONS

CO41 – Earthjustice (cont’d)

Companies and Or

See the response to comments CO1-4 and compaction. In addition, after constructioIroquois would conduct follow-up inspecupland areas after the first and second grodocument the success of restoration. Conrequired to continue restoration efforts begrowing season if the disturbed area has nrestored. The FERC would also conduct inspections of the projects following consadditional restorative measures until revecomplete. 

CO41-18

As stated in our February 20, 2014 letter tconclusion was based upon “the informatConstitution’s biological survey reports, sreceived from Constitution, our analysis oof the proposed action as reported in the Ecoordination with the FWS”; not merely onegative findings. Based on that informathe project is not likely to adversely affect 

wedgemussel, and northern monkshood. 4.7.2 of the EIS, the FWS stated that bat srequired within the New York portion of based on adherence to our recommendatiomitigation measures in consultation with as well as our recommendation in section upland forest mitigation plan, we concludoperation of the project would not result isensitive bat species. These mitigation mavailable for review by the public on our the response to comment FA4-41 regardineared bat.

CO41-19

S-447
COMPANIES AND ORGANIZATIONS

CO41 – Earthjustice (cont’d)

Companies and Or

CO41-20 See the response to comments FA4-29, F

S-448
COMPANIES AND ORGANIZATIONS

CO41 – Earthjustice (cont’d)

Companies and Or

Air quality is discussed in section 4.11.1 Air Act (CAA) is the basic federal statute in the United States. The CAA establisheQuality Standards (NAAQS) to protect ththe public. Primary standards are the limexposure to a pollutant by sensitive publiasthmatics, children and the elderly. The periodically reviewed by the EPA based oprocess. As required by the CAA, each senforceable state implementation plan (SIhow that state will meet these NAAQS. ESIP to its unique air pollution concerns, bpurpose of implementing and enforcing reair quality in the state meets the NAAQSThe EIS presents estimated emissions for operational project phases using appropridescribed in section 4.11.1.3. Section 4.1potentially relevant laws and explains how comply with all applicable requirements, mitigation is needed. Projected construction and operational emConstitution pipeline and Wright Intercondescribed in relation to the various state arequirements, which are designed to be prhealth including construction workers and communities. Ozone is discussed in sectiBecause the projected levels of NOx appr

threshold of 100 tons per year (tpy), we reApplicants should each file for review anConstruction Emission Plan identifying htheir construction schedules for the respecprojects within Schoharie County (which nonattainment area for ozone) and ensure of NOx would remain under the General C

threshold. Subsequent to the filing of the recalculated its estimated construction emthat it was revising downward its original NOx to approximately 70 tpy. See the res

FA6-14. Given these new data, we conclEmission Plan is no longer needed. 

CO41-21

S-449
COMPANIES AND ORGANIZATIONS

CO41 – Earthjustice (cont’d)

Companies and Or

Fugitive emissions and mitigation measursection 4.11.1. We have updated this secleakage and venting that may occur durinpipeline and the expanded compressor staother similar unintentional releases would subject to numerous factors and so were nanalyses. We have updated the EIS to indare possible. Under the CEQ guidance regarding climaGHGs, if an action has annual direct emis25,000 metric tons per year, then the agenthis an indicator that a quantitative and qumay be meaningful for decision makers.” guidance “CEQ does not propose that this threshold of significant effects, but rather minimum level of GHG emission that madescription in the appropriate NEPA analinvolving direct emissions of GHGs.” Ththat environmental documents “reflect the climate change and provide useful informmethodology of comparing an individual emissions to total U.S. emissions is standdocuments, and is supported by CEQ guidclimate change is a global problem that reemissions, there are more sources and actterms of both absolute numbers and typesencountered when evaluating the emissioFrom a quantitative perspective, there are and fewer sources that would even be cloGHG emissions. The global climate chanmore the result of numerous and varied somight seem to make a relatively small addatmospheric GHG concentrations. The Crecommend that environmental documentcontext and be realistic in focusing on ensinformation is provided to decision makethe agency finds are a significant source oEnvironmental Quality. 2010. Draft NEConsideration of the Effects of Climate CGas Emissions, February 18, 2010.As mentioned above, operation of the pipcompressor station (combustion, vented awould result in GHG emissions of 175,000.003 percent of total U.S. GHG emissionglobal GHG emissions. This provides decontext for making an informed decision 

CO41-21 (cont’d)

S-450
COMPANIES AND ORGANIZATIONS

CO41 – Earthjustice (cont’d)

Companies and Or

S-451
COMPANIES AND ORGANIZATIONS

CO41 – Earthjustice (cont’d)

Companies and Or

See the response to comment SA6-8 regacumulative impacts section. Existing comundergone the state and federal permit anprocess. Emissions from any recently conforeseeable compressor stations are discu4.13.6.10 of the EIS. We have updated se

indicate that emissions from existing and 

stations in the region as listed in table 4.1those as described in section 4.11.1 for thProject and that potential impacts would bmitigated in accordance with the PADEP permitting requirements. 

CO41-22

See the response to comments FA4-45, LThe specifics of future industrialization oHowever, any future industrial developmthe appropriate federal, state, and county/which may include local zoning ordinancSee the response to comment FA4-46 regLeatherstocking project.

CO41-23

S-452
COMPANIES AND ORGANIZATIONS

CO41 – Earthjustice (cont’d)

Companies and Or

S-453
COMPANIES AND ORGANIZATIONS

CO41 – Earthjustice (cont’d)

Companies and Or

S-454
COMPANIES AND ORGANIZATIONS

CO41 – Earthjustice (cont’d)

Companies and Or

As discussed in section 4.13 of the EIS, wcumulative impacts was indicated, impacextent practicable; however, in some casecan only be described qualitatively. This for projects that are in the planning stageseconomic conditions, availability of finanissuance of permits; or for which there is information available. Available informacumulative impacts analysis to the extent information was not always available to qSee the response to comments LA1-4 and natural gas extraction from the Marcellus impacts.

CO41-24

S-455
COMPANIES AND ORGANIZATIONS

CO41 – Earthjustice (cont’d)

Companies and Or

Section 4.13.6.3 of the EIS has been revisimpacts. See the response to comment Ccumulative impacts on air quality.

CO41-25CO41-26 See the response to comments FA1-1 and 

S-456
COMPANIES AND ORGANIZATIONS

CO41 – Earthjustice (cont’d)

Companies and Or

See the response to comment FA4-12 regthird-party compliance monitoring progracompliance with a FERC permit conditioinspections by EIs and the FERC’s complconducted to ensure timely discovery and remediation. Enforcement of permit requFERC-jurisdictional projects would be thagency issuing the permit.

CO41-27

The commentor’s statements regarding thsection are noted.

S-457

CO41-28
COMPANIES AND ORGANIZATIONS

CO41 – Earthjustice (cont’d)

Companies and Or

As discussed in section 4.13 of the EIS, thCentral Compressor Station was placed inis currently being modified for use by WiPipeline. This facility was permitted by tconstruction had begun before Constitutiowith the Commission. Section 4.13.6.10 include additional information regarding emissions for the Williams Central Comp

CO41-29

S-458
COMPANIES AND ORGANIZATIONS

CO41 – Earthjustice (cont’d)

Companies and Or

The commentor’s statement regarding the section is noted. As stated in section 3.1 alternative would avoid the environmentaproposed projects, but it would result in thmeans to satisfy the demand for natural genergy. Even if the project were to be canenergy would not go away. The no-action likely lead end users to seek energy from other fossil fuels and renewable energy soevaluated each type of renewable energy to the proposed projects.

CO41-30

S-459
COMPANIES AND ORGANIZATIONS

CO41 – Earthjustice (cont’d)

Companies and Or

The comment is noted. We assume that treferring to the EmKey-Dominion-TGP 2alternatives. This alternative would be 23 proposed pipeline. As stated in section 3alternative was also rejected due to more greater land disturbance, impacts on more total environmental impacts relative to th(including a crossing of the Susquehanna upon collocation with a proposed pipeline ultimate approval and construction is unccollocated alternatives would be two or ththe proposed pipeline and can not be catelonger” routes.

CO41-31CO41-32 See the response to comment FA4-16.

Compensatory wetland mitigation is discuthe EIS. Constitution would at a minimum monitor revegetation efforts after the first seasons and to continue efforts until the dnon-nuisance species are similar to adjaceby construction. All sediment and erosiobe routinely inspected by the FERC moniconstruction. See the response to commetree planting and monitoring for invasive section 2.5.5 of the EIS, Constitution woufor invasive plant species on at least an anfollowing construction. Specialized consoptions are discussed in section 2.3 of the are part of Constitution’s proposal. Climin section 4.13.6.10 of the EIS. 

CO41-33

S-460
COMPANIES AND ORGANIZATIONS

CO41 – Earthjustice (cont’d)

Companies and Or

CO41-34 See the response to comment LA7-5.

S-461
COMPANIES AND ORGANIZATIONS

CO41 – Earthjustice (cont’d)

Companies and Or

Each of the points raised by the commentSummary will be discussed in detail below to CO41-36 through CO41-80.

CO41-35

S-462
COMPANIES AND ORGANIZATIONS

CO41 – Earthjustice (cont’d)

Companies and Or

S-463
COMPANIES AND ORGANIZATIONS

CO41 – Earthjustice (cont’d)

Companies and Or

S-464
COMPANIES AND ORGANIZATIONS

CO41 – Earthjustice (cont’d)

Companies and Or

S-465
COMPANIES AND ORGANIZATIONS

CO41 – Earthjustice (cont’d)

Companies and Or

S-466
COMPANIES AND ORGANIZATIONS

CO41 – Earthjustice (cont’d)

Companies and Or

S-467
COMPANIES AND ORGANIZATIONS

CO41 – Earthjustice (cont’d)

Companies and Or

S-468
COMPANIES AND ORGANIZATIONS

CO41 – Earthjustice (cont’d)

Companies and Or

CO41-36 See the response to comment FA1-1.

S-469
COMPANIES AND ORGANIZATIONS

CO41 – Earthjustice (cont’d)

Companies and Or

See the response to comments CO1-4 and section 2.5.5 of the EIS, restoration of upconsidered successful if the right-of-way successful based on visual assessment of surface conditions are similar to adjacent construction debris is removed, and properestored. 

CO41-37

S-470
COMPANIES AND ORGANIZATIONS

CO41 – Earthjustice (cont’d)

Companies and Or

See the response to comments CO1-4 and section 4.2.4 of the EIS, temporary erosiobe installed prior to construction. These dinspected regularly to determine whether necessary and would only be removed folrevegetation of an affected area. Constitution would follow many proceduagricultural and residential areas such as allowable rutting depth of 4 inches in satu(section 4.2.4), reducing the proposed conwidth from 110 feet, as originally proposeinterior forest areas where practicable (seconstruction right-of-way width to 75 feeareas where site-specific conditions requiusing low ground weight equipment or optimber mats in saturated wetlands to prev4.4.3). We require decompaction measuragricultural areas as a higher priority relaas forested uplands) due to concerns such condition and crop yields. 

CO41-38

S-471
COMPANIES AND ORGANIZATIONS

CO41 – Earthjustice (cont’d)

Companies and Or

CO41-39 See the responses to comments CO1-4, C

S-472
COMPANIES AND ORGANIZATIONS

CO41 – Earthjustice (cont’d)

Companies and Or

CO41-40 The commentor’s statement regarding rut

Information regarding soil limitations, incerosion and compaction potential along thaccess roads, and additional temporary win section 4.2.2 of the EIS. 

CO41-41

S-473
COMPANIES AND ORGANIZATIONS

CO41 – Earthjustice (cont’d)

Companies and Or

See the response to comment CO41-38. Cwould monitor the condition and effectiveerosion control devices. In addition, our monitors would also inspect installed eroshydrology, and revegetation. Restoration considered complete until hydrology and 

CO41-42

S-474
COMPANIES AND ORGANIZATIONS

CO41 – Earthjustice (cont’d)

Companies and Or

See the responses to comments CO41-10 addition, as stated in section 2.3.1 of the Ewould be final graded and restored to preand natural drainage patters as closely as way must be seeded within six working dgrading, (weather and soil conditions permprocess of revegetation and limit likelihooerosion. Temporary erosion controls wouvegetation can provide the same degree o

CO41-43

S-475
COMPANIES AND ORGANIZATIONS

CO41 – Earthjustice (cont’d)

Companies and Or

We recommended in section 4.1.3.4 of thadopt the recommendations and mitigatioslope and karst areas provided in the GeoMemorandum dated October 4, 2013. Thincludes additional field visits and reconnperformed by qualified geologists and engidentifying landslide hazards. See the resLA10-1.

CO41-44

S-476
COMPANIES AND ORGANIZATIONS

CO41 – Earthjustice (cont’d)

Companies and Or

CO41-45 See the response to CO41-43.

As discussed in section 2.3.2.9 of the EISuse the “two-tone” construction method oto ensure safe working conditions. This mgenerally requires an expanded constructi

CO41-46

S-477
COMPANIES AND ORGANIZATIONS

CO41 – Earthjustice (cont’d)

Companies and Or

The commentor’s statement regarding avis noted. We have determined that Constthe mitigation measures in the October 4, Reconnaissance Memorandum would be resource.

CO41-47

Waterbodies are proposed to be crossed utrenchless methodologies, which would lierosion, sedimentation, or turbidity. See comment FA4-34 and section 4.3.3 of the Constitution’s Trenchless Feasibility Studaccessed in full at: http://elibrary.ferc.gov:0/idmws/file_list.a0901, (see volume II appendix N). Consttrenchless crossings based on a number osensitivity/high quality of habitats and lanworkspace requirements, geotechnical coand overall construction feasibility, we cofeasible or practicable to use trenchless mbore, HDD, and direct pipe) at every watespecific waterbody crossing methods and provided in appendix K of the EIS. 

CO41-48

S-478
COMPANIES AND ORGANIZATIONS

CO41 – Earthjustice (cont’d)

Companies and Or

S-479
COMPANIES AND ORGANIZATIONS

CO41 – Earthjustice (cont’d)

Companies and Or

Constitution provided an assessment of thtrenchless crossing methods for high qualwetlands, and other features in their trenc(Volume II, Appendix N of their Novembexceptional value wetlands in the area betencompass 0.38 acre, which is below the assessment used in the analyses. Roaring fishery near and/or adjacent to the except22 feet wide, which is below the 30-foot-assessment used in the analyses. We concrossing is not warranted in this area for t

CO41-49

S-480
COMPANIES AND ORGANIZATIONS

CO41 – Earthjustice (cont’d)

Companies and Or

See the response to comment CO41-14. A4.4.3-1 of the EIS, 91.8 acres of wetlands construction of the proposed pipeline. Thproject’s wetland impacts would occur wright-of-way and associated temporary was footnoted in table 4.4.3-1 of the EIS. Wlocations where Constitution has proposeworkspaces within wetlands, and found thProcedures require Constitution to reduce feet wide within wetlands.

CO41-50

S-481
COMPANIES AND ORGANIZATIONS

CO41 – Earthjustice (cont’d)

Companies and Or

As discussed in section 4.6.1.4 of the EISits general blasting plan that “Blasting in sensitive areas, such as streams and wildlresource sensitive areas, may include addwhich will be included in the site-specific Plans.” As we recommended in section 4Constitution would be required to develop plans in coordination with the state resourfisheries and aquatic resources from the pblasting in waterbodies.

CO41-51

The commentor’s statements regarding basoils, index mapping, and cumulative impcrossings are noted. The FERC Plan, whConstitution, includes special provisions segregation of topsoil in agricultural and other locations as requested by the landowresources are identified within the main bappendices of the EIS. Cumulative impacsection 4.13 of the EIS.

CO41-52

S-482
COMPANIES AND ORGANIZATIONS

CO41 – Earthjustice (cont’d)

Companies and Or

S-483
COMPANIES AND ORGANIZATIONS

CO41 – Earthjustice (cont’d)

Companies and Or

The commentor’s statements regarding thSection 4.5 of the EIS has been updated tinformation provided by Constitution regand also in regards to invasive species.

CO41-53

S-484
COMPANIES AND ORGANIZATIONS

CO41 – Earthjustice (cont’d)

Companies and Or

S-485
COMPANIES AND ORGANIZATIONS

CO41 – Earthjustice (cont’d)

Companies and Or

S-486
COMPANIES AND ORGANIZATIONS

CO41 – Earthjustice (cont’d)

Companies and Or

S-487
COMPANIES AND ORGANIZATIONS

CO41 – Earthjustice (cont’d)

Companies and Or

See the responses to comments FA4-29 (dimpacts, including fragmentation, and mi(stormwater runoff). The comments regaeffects of forests are noted. See the respo9 and FA6-10 regarding invasive species, to interior forests. The comment regardinchemistry following tree clearing is noted and we have updated the EIS to include thAlthough stream chemistry changes are pclearing, we expect that these stream-specdiminished somewhat with a linear projecspread over larger areas and numerous strwatersheds, as opposed to large-scale timlocation potentially affecting one or a sm

CO41-54

S-488
COMPANIES AND ORGANIZATIONS

CO41 – Earthjustice (cont’d)

Companies and Or

S-489
COMPANIES AND ORGANIZATIONS

CO41 – Earthjustice (cont’d)

Companies and Or

S-490
COMPANIES AND ORGANIZATIONS

CO41 – Earthjustice (cont’d)

Companies and Or

S-491
COMPANIES AND ORGANIZATIONS

CO41 – Earthjustice (cont’d)

Companies and Or

S-492
COMPANIES AND ORGANIZATIONS

CO41 – Earthjustice (cont’d)

Companies and Or

As stated in section 4.5.2 of the EIS, thesare not protected by any state or federal rproposed pipeline would cross 0.6 mile o110 foot right-of-way would impact 8 acrright-of-way would impact 7.27 acres of tagree that the cutting of trees would increreaching the ground and likely alter soil muntil vegetation becomes re-established. above, this impact would be reduced by thway width and restoration (including seedfollowing construction. See also the resp1.

CO41-55

See the responses to comment FA4-29 (sedirect and indirect forest impacts, includinmitigation). The EIS discusses impacts uavian species and other non-avian species

CO41-56

S-493
COMPANIES AND ORGANIZATIONS

CO41 – Earthjustice (cont’d)

Companies and Or

S-494
COMPANIES AND ORGANIZATIONS

CO41 – Earthjustice (cont’d)

Companies and Or

We issued an environmental information on August 29, 2013, requesting clarificatidischarged hydrostatic test water would bwatersheds. In response, Constitution proResource Report 2 in November 2013. SConstitution’s Resource Report 2 states, “have not been identified, but all discharge within a well vegetated upland area withiNo inter-basin transfers are expected to ohydrostatic testing.” (http://elibrary.ferc.gov:0/idmws/file_list0901). Constitution would use a dewatergeotextile fabric and hay bales for discharwater. Although not designed for this purstructure could serve a dual purpose by fifragments from the test water. 

CO41-57

See the responses to comments FA4-9 aninvasive species, particularly in relation t

CO41-58

S-495
COMPANIES AND ORGANIZATIONS

CO41 – Earthjustice (cont’d)

Companies and Or

See the responses to comments CO13-1 aecological value of forest interior to migrspecies, the time required to produce matedge or grassy habitats, and the generally successional or grassy habitats are acknowbeen edited to clarify these points. The Eimpacts on interior forest dwelling speciebirds (sections 4.5.3 and 4.6.1.3) and that new corridors could result in issues such (section 4.6.1.3) and spread of invasive spThe statement in the EIS that the new edghabitat to some wildlife species is correctdiminish the impacts on species that requforests. 

CO41-59

S-496
COMPANIES AND ORGANIZATIONS

CO41 – Earthjustice (cont’d)

Companies and Or

The commentor’s statements are noted. Hreferenced is regarding the overall proposjust wildlife in the area of interior forestsforest mitigation plan recommendation stshould consult, mitigate, and justify its ac

CO41-60

S-497
COMPANIES AND ORGANIZATIONS

CO41 – Earthjustice (cont’d)

Companies and Or

Our conclusions of impacts on the small-long-eared bat, and the silver-haired bat wfactors, including the Upland Forest Mitigmore so on section 4.7.3 of the EIS, wherprior to construction, Constitution should avoidance, minimization or mitigation mewith the FWS and the PGC for constructiOctober 31 to minimize impacts on these would file any such measures with the Se

CO41-61

In section 4.7.3 of the EIS, we recommenconstruction, Constitution should file with results of any outstanding surveys for New Pennsylvania state-listed species and idenmitigation measures developed in consultapplicable state agencies. These surveys the level of impact with no mitigation; horecommendation also requires consultatioimpacts would be reduced. Further, the liproject alone would cause the species to bimprobable.

CO41-62

The commentor’s statement regarding the PADEP and the Susquehanna River Basin regulations is noted.

CO41-63

S-498
COMPANIES AND ORGANIZATIONS

CO41 – Earthjustice (cont’d)

Companies and Or

As discussed in section 4.13.6.3 of the EIimpacts in the area of the proposed projecinconsequential, the overall impact in the considered minor in comparison to the abhabitats in the broader area and given impConstitution’s Preliminary Migratory BirPlan. The Applicants also would be requvegetation in temporarily disturbed areas, project-related facilities would likely be hby state permitting agencies. As discusseaesthetic reasons it is unlikely that any releft unrestored following construction. Dhydrology is not expected.

CO41-64

We have updated section 4.13.6.3 regardion forest resources in general and for FERparticular. Impacts and mitigation for fordiscussed in sections 4.5.5, 4.8.6, and 4.1general, Constitution would be required tdisturbed right-of-way is stabilized with hinvasive species are controlled, and then tto re-grow in the former temporary workswith our Procedures section V.D.1, Constvegetation maintenance in riparian zones shading of adjacent streams. Our experiegrowing conditions, re-growth of trees is by undesirable or early successional speccomment CO41-54. 

CO41-65

S-499
COMPANIES AND ORGANIZATIONS

CO41 – Earthjustice (cont’d)

Companies and Or

CO41-66 See the response to comment CO41-64.

S-500
COMPANIES AND ORGANIZATIONS

CO41 – Earthjustice (cont’d)

Companies and Or

The commentor’s statement regarding Conoted.

CO41-67

S-501
COMPANIES AND ORGANIZATIONS

CO41 – Earthjustice (cont’d)

Companies and Or

It is assumed all trees marked for retentioAs discussed in section 2.3.1 of the EIS, tand stacked at the edge of the right-of-warequested by the landowner. Wood chips agricultural areas, wetlands, or waterbodibe left in piles or stacks on the right-of-wchips would be in accordance with section Plan.

CO41-68

S-502
COMPANIES AND ORGANIZATIONS

CO41 – Earthjustice (cont’d)

Companies and Or

As stated in section 2.3.1 of the EIS, soils vegetation prior to construction would be mixes, application rates, and timing windlocal soil conservation authorities or otheagencies (such as the Natural Resources C[NRCS]), landowner requests, and in accoRevegetation would not be considered cois similar in density and cover of non-nuiadjacent undisturbed lands.

CO41-69CO41-70 See the response to comment CO41-10.CO41-71 See the response to comment CO41-65.

S-503
COMPANIES AND ORGANIZATIONS

CO41 – Earthjustice (cont’d)

Companies and Or

CO41-72 See the response to comment CO41-59.CO41-73 See the response to comment CO41-58.

S-504
COMPANIES AND ORGANIZATIONS

CO41 – Earthjustice (cont’d)

Companies and Or

S-505
COMPANIES AND ORGANIZATIONS

CO41 – Earthjustice (cont’d)

Companies and Or

The commentor’s statement regarding invfertilizer application is noted. Constitutiorecommendations of the local NRCS.

CO41-74

Section 1 of Constitution’s New York InvManagement Plan states “Therefore, Conis to control the invasive species to the ex

uplands (emphasis added by the FERC stby the invasive species to the point where values of the systems/habitats are adverseConstitution’s invasive species plan furthspread of seeds, roots, or other viable planused in areas containing invasive plant spwashed with clean water (no soaps or chefrom an area populated with invasive spewould apply regardless of whether the situplands. The statements made by the comelevated wash stations while others areas elevated wash station. 

CO41-75

S-506
COMPANIES AND ORGANIZATIONS

CO41 – Earthjustice (cont’d)

Companies and Or

As stated in section 4.3.3.5 of the EIS, Cowould use intake screens (which would hof invasive species propagules) for water would use municipal water sources (whicinvasive species) for dust control activitie

CO41-76

S-507
COMPANIES AND ORGANIZATIONS

CO41 – Earthjustice (cont’d)

Companies and Or

The commentor’s statements regarding innoted. See the response to comment FA6would be responsible for the area that it dconstruction and would not have access to project as would be allowed by the FERC landowner easement agreements.

CO41-77CO41-78 See the response to comment CO41-57.

S-508
COMPANIES AND ORGANIZATIONS

CO41 – Earthjustice (cont’d)

Companies and Or

CO41-79 See the response to comment CO41-58.CO41-80 The commentor’s statements are noted.

S-509
COMPANIES AND ORGANIZATIONS

CO41 – Earthjustice (cont’d)

Companies and Or

S-510
COMPANIES AND ORGANIZATIONS

CO41 – Earthjustice (cont’d)

Companies and Or

S-511