2-1 Project Description

2.0 PROJECT DESCRIPTION

2.1 PROPOSED FACILITIES

Constitution proposes to construct and operate a new natural gas transmission pipeline in 

Pennsylvania and New York. Constitution’s project would involve construction and operation of a new 

pipeline, two new M&R stations, and associated pipeline support facilities such as MLVs, blow down 

valves, two side taps, and pig launcher and receiver facilities. M&R stations measure the transfer of one 

gas from one pipeline system to another. MLVs are used to close the pipeline and stop the flow of gas for 

maintenance or safety purposes. An overview map of the pipeline project’s location and facilities is 

provided on figure 2.1-1. Detailed maps showing the location of pipeline route, aboveground facilities, 

and contractor yards are contained in appendix B. 

Constitution also has entered into an agreement with Iroquois to provide additional compression 

and related facilities at the terminus of the pipeline project. Iroquois has proposed to expand its existing 

compression and metering facilities in Wright, New York. An overview map of the proposed Iroquois 

facilities is provided on figure 2.1-2. The facilities associated with Iroquois’ project are discussed 

throughout this document generally under “aboveground facilities.” Because Iroquois’ project would not 

involve substantial pipeline construction, sections of this document describing pipeline construction 

would be solely applicable to Constitution. 

2.1.1 Pipeline Facilities

The proposed pipeline consists of 124.4 miles of 30-inch-diameter pipe located in the counties in 

table 2.1.1-1 and described in detail below. 

The pipeline’s source of natural gas would come from two shippers, Cabot Oil and Gas 

Corporation (Cabot) and Southwestern who would deliver it into the pipeline in Susquehanna County, 

Pennsylvania. The natural gas would be transported to a proposed interconnection with the existing 

Wright Compressor Station operated by Iroquois in Schoharie County, New York. The pipeline route 

generally follows a greenfield (i.e., lands and vegetation, including adjacent areas, that are undisturbed or 

undeveloped) pathway from northeastern Pennsylvania to south-central New York. The maximum 

allowable operating pressure (MAOP) for the new pipeline would be 1,480 pounds per square inch gauge 

(psig). 
Wright Interconnect

Project Compressor 

Station and Westfall

Road M&R Station

Sutton Road Tie-in

Turnpike Road 

M&R Station

White Road Tie-in

Spread 1

Contractor Yard

Spread 2

Contractor Yard

Spread 3

Contractor Yard

Spread 4a

Contractor Yard

Spread 4b

Contractor Yard

Spread 5

Contractor Yard

New York

Pennsylvania

Cortland

Tioga

Onondaga

Broome

Chenango

Madison

Otsego

Albany

Greene

Montgomery

Schenectady

Schoharie

Columbia

Delaware

Sullivan

Susquehanna

Wayne

Dutchess

Ulster

Proposed Route

Aboveground Facility

Contractor Yards

p

0 5 10 15 20

Miles

Figure 2.1-1

Constitution Pipeline Project

Project Overview Map

NEW YORK

PENNSYLVANIA

NJ

MA

MD

CT

NH

VA

VT

DE

RI

2-2
PROPOSED IGTS

METER & REGULATOR

BUILDING (55' x 95') FILTERS

STORAGE VESSEL

GAS COOLERS

PROPOSED EXPANDED

FENCE AREA APPROX.

SHADED ORANGE

(2.43 Ac.)

EXISTING FENCED AREA

(5.02 Ac.)

PROPOSED FENCED AREA

TOTAL (7.45 Ac.)

COMPRESSOR BUILDING

(136' x 80')

AUXILIARY BUILDING

PROPOSED CONSTRUCTION

AREA - TOTAL APPROX.

SHADED BLUE AND

WITHIN DASHED LINE

(12.45 Ac.)

PROPOSED TEMPORARY

WORKSPACE APPROX.

SHADED BLUE

(7.95 Ac.)

DOMESTIC GAS

BUILDING

WESTFALL ROAD

Property Boundary

Proposed Construction Area

Proposed Expanded Fence Area

p

0 100 200 300 400

Feet

Figure 2.1-2

Wright Interconnect Project

Compressor Station Map

Site Location Schenectady

County

NEW YORK

PA

Broome

County

Chenango

County

Herkimer

County

Madison

County

Oneida

County

Otsego

County Albany

County

Fulton

County

Greene

County

Montgomery

County

Saratoga

County

Schoharie

County

Delaware

County

Ulster

County

2-3
Project Description 2-4

TABLE 2.1.1-1

Pipeline Facilities Associated with the Constitution Pipeline Project

State/County/Municipality Milepost Range Length (miles)

PENNSYLVANIA

Susquehanna County

Brooklyn 0.0 – 3.0 3.0

Harford 3.0 – 4.3 1.3

New Milford 4.3 – 13.4 9.2

Jackson 13.4 – 16.1 2.6

Oakland 16.1 – 17.0 1.0

Harmony 17.0 – 25.2 8.2

Pennsylvania (subtotal) 0.0 – 25.2 25.2

NEW YORK

Broome County

Sanford 25.2 – 42.2 17.0

Chenango County

Afton 42.2 – 47.5 5.3

Bainbridge 47.5 – 50.5 3.0

Delaware County

Masonville 50.5 – 52.2 1.7

Sidney 52.2 – 64.2 12.0

Franklin 64.2 – 73.7 9.4

Davenport 73.7 – 89.0 15.4

Harpersfield 89.0 – 93.5 4.5

Schoharie County

Summit 93.5 – 93.9 0.3

Jefferson 93.9 – 94.1 0.2

Summit 94.1 – 96.0 1.9

Jefferson 96.0 – 96.5 0.5

Summit 96.5 – 97.0 0.5

Jefferson 97.0 – 98.9 1.9

Summit 98.9 – 105.1 6.1

Richmondville 105.1 – 109.9 4.9

Cobleskill 109.9 – 112.1 2.1

Middleburgh 112.1 – 115.6 3.5

Schoharie 115.6 – 124.0 8.4

Wright 124.0 – 124.4 0.5

New York (subtotal) 25.2 – 124.4 99.2

Constitution Pipeline Project Total 124.4

____________________

Note: Totals may not sum correctly due to rounding.
2-5 Project Description

2.1.2 Aboveground Facilities

The proposed projects would include both construction of new aboveground facilities and the 

modification of existing facilities. These facilities are listed in table 2.1.2-1.

TABLE 2.1.2-1

Aboveground Facilities for the Constitution Pipeline and Wright Interconnect Projects

Facility Milepost Operator Municipality County, State

New M&R Stations

Turnpike Road M&R Receipt Station (with 

pig launcher and kickoff MLV No. 1)

0.0 Constitution 

(input from) 

Cabot

Brooklyn Susquehanna, PA

Westfall Road M&R Delivery Station (with 

pig receiver and MLV terminus – No. 11)

124.4 Constitution 

(delivery to 

Iroquois and 

TGP)

Wright Schoharie, NY

Compressor Station Modifications

Wright Interconnect Project 124.4 Iroquois Wright Schoharie, NY

Tap Facilities

White Road Tie-in (side tap) 3.3 Constitution 

(input from 

Cabot)

Harford Susquehanna, PA

Sutton Road Tie-in (side tap) 9.4 Constitution 

(input from 

Southwestern)

New Milford Susquehanna, PA

Mainline Valves

MLV No. 2 – Walkers Road 15.2 Constitution Jackson Susquehanna, PA

MLV No. 3 – Vale Road 26.7 Constitution Sanford Broome, NY

MLV No. 4 – O’Brien Road 41.2 Constitution Sanford Broome, NY

MLV No. 5 – Access Road/Town Road 52.1 Constitution Masonville Delaware, NY

MLV No. 6 – Stewart Road 66.7 Constitution Franklin Delaware, NY

MLV No. 7 – County Road 10 81.8 Constitution Davenport Delaware, NY

MLV No. 8 – Clapper Hollow Road 95.1 Constitution Summit Schoharie, NY

MLV No. 9 – Access Road/Dodge Lodge 

Road

108.5 Constitution Richmondville Schoharie, NY

MLV No. 10 – Smith Road 119.6 Constitution Schoharie Schoharie, NY

The Turnpike Road M&R Station would be connected to the existing, non-jurisdictional Central 

Compressor Station via a 700-foot-long, 30-inch-diameter tie-in pipeline. This tie-in pipeline would 

allow Cabot to input natural gas into the Constitution pipeline. The White Road Tie-in would also allow 

for Cabot to input natural gas into the Constitution pipeline via Cabot’s non-jurisdictional White Road 

M&R Station. Cabot’s contribution to the Constitution pipeline at both sources would be limited to a 

maximum of 500,000 Dth/d combined. The Sutton Road Tie-in would connect Southwestern’s nonjurisdictional Sutton Road M&R Station to the Constitution pipeline and would deliver up to 150,000 

Dth/d. The Westfall Road M&R Station would deliver gas to Iroquois’ existing Wright Compressor 

Station for eventual delivery to the existing Iroquois and TGP natural gas pipeline systems. The Westfall 

Road M&R Station would be connected to Iroquois’ existing Wright Compressor Station and proposed 

compressor transfer station by a 500-foot-long, 30-inch-diameter tie-in pipeline. 
Project Description 2-6

Constitution has entered into an agreement for Iroquois to provide additional compression at the 

terminus of Constitution’s pipeline. Iroquois’ proposed expansion would expand its existing compression 

and metering facilities in Wright, New York. Iroquois’ project would provide additional compression 

allowing delivery of up to 650,000 Dth/d of natural gas from the terminus of the proposed Constitution 

pipeline into the existing Iroquois and the TGP systems. 

As part of Iroquois’ project, it would construct, own, and operate several new and modified 

facilities at its existing Wright Compressor Station property in Schoharie County, New York. These 

facilities would include:

• connection with Constitution’s proposed 500-foot-long, 30-inch-diameter tie-in pipeline;

• construction of a new transfer compressor station including the addition of incremental 

compression facilities of about 21,800 horsepower, to supplement the existing 

compression capacity of 14,200 horsepower; 

• expansion of the existing odorization facilities;

• construction of natural gas coolers, station piping, and valves; 

• modification and upgrade of the existing delivery meter and associated piping to the TGP 

system or possible construction of a new delivery meter to support the full capacity of the 

Constitution pipeline; and

• modification of the existing Wright Compressor Station to allow Iroquois to use stationwide compression in the most energy efficient and integrated method.

Expansion of the existing Wright Compressor Station would eliminate the need for a new, 

greenfield compressor station, which was originally planned by Constitution. Iroquois’ expansion would 

be constructed completely within the property boundaries of the existing Wright Compressor Station. 

2.2 LAND REQUIREMENTS 

Table 2.2-1 summarizes the land requirements for the combined Constitution and Iroquois 

projects. A detailed description and breakdown of land requirements and use is presented in section 4.8.1. 

Construction of Constitution’s project would disturb 1,849.5 acres of land, including the pipeline 

facilities, aboveground facilities, contractor yards, and access roads. Permanent operations would 

encumber 744.3 acres, consisting of 707.2 acres for the new pipeline right-of-way, 5.4 acres for 

Constitution’s aboveground facilities, and 31.7 acres for access roads. The remaining 1,105.2 acres of 

land disturbed by Constitution would be restored and allowed to revert to its former use. Iroquois’ project 

would require 12.5 acres during construction, and would encumber 7.5 acres during operation. 

Collectively, Constitution and Iroquois’ proposed projects would affect 1,862.0 acres during construction 

and 751.8 acres during operations. Additional area would be required for permanent ground beds to 

provide cathodic protection of the pipeline, but the acreage that would be affected for this purpose has not 

yet been determined. However, the design of ground beds is usually finalized following pipeline 

operations and are typically located near the ends of a pipeline and encompass one to two acres in total. 
2-7 Project Description

TABLE 2.2-1

Summary of Land Requirements Associated with the Constitution and Iroquois Project Facilities

Facility

Land Affected During 

Construction (acres) a

Land Affected During 

Operation (acres) b

PIPELINE FACILITIES

Pennsylvania

Pipeline Right-of-Way 318.6 145.5

Additional Temporary Workspace 19.5 0.0

New York

Pipeline Right-of-Way 1,238.7 561.7

Additional Temporary Workspace 87.9 0.0

Pipeline Facilities Total 1,664.7 707.2

ABOVEGROUND FACILITIES b

Pennsylvania

Turnpike Road M&R Station 4.9 3.1

New York

Westfall Road M&R Station 3.3 2.3

Wright Interconnect Project (Iroquois) 12.5 7.5

Aboveground Facilities Total 20.7 12.9

CONTRACTOR YARDS

Pennsylvania 20.0 0.0

New York 90.0 0.0

Contractor Yards Total 110.0 0.0

ACCESS ROADS

Pennsylvania 29.2 10.8

New York 37.4 20.9

Access Roads Total 66.6 31.7

SUBTOTAL – CONSTITUTION PIPELINE PROJECT 1,849.5 744.3

COMBINED PROJECTS TOTAL 1,862.0 751.8

____________________

a Note: The totals shown in this table may not equal the sum of addends due to rounding.

b The Sutton Road and White Road Tie-ins, MLVs, and pig launcher and receiver facilities would be located within the 

operational easement and would not result in additional land impacts beyond those already accounted for above.

2.2.1 Pipeline Facilities

Of the 1,664.7 acres of land that would be disturbed during construction of the pipeline facilities 

and associated workspaces, 707.2 acres would be retained as new permanent pipeline right-of-way. The 

remaining 957.5 acres would be used as temporary workspace.

2.2.1.1 Adjacent Existing Rights-of-Way and Utility Crossings

The proposed pipeline would be collocated within or adjacent to existing pipelines and/or electric 

transmission utility rights-of-way for 11.2 miles (9.0 percent). Additionally, the proposed route crosses
Project Description 2-8

multiple existing pipelines and/or electric transmission utility (i.e. powerline) rights-of-way (1.4 miles of 

crossovers collectively), but these crossings are not considered collocation. A summary of the locations 

where the pipeline would be collocated within or adjacent to existing rights-of-way is presented in table 

2.2.1-1.

TABLE 2.2.1-1

Summary of Pipeline Collocated with Existing Rights-of-Way 

Adjacent Facility

Start 

Milepost

End 

Milepost

Paralleled 

Length 

(feet)

Width of 

Foreign 

Right-ofWay

(feet)

Width of Foreign 

Right-of-Way 

That Would Be 

Used During 

Construction 

(feet)

Width of Foreign 

Right-of-Way 

That Would Be 

Used During 

Operation (feet)

Susquehanna County, Pennsylvania

Powerline 6.2 6.7 2,798 30 0 0

Powerline 10.3 10.7 2,376 120 25 0

Powerline 11.0 11.2 1,003 120 25 0

Bluestone Pipeline 22.0 22.3 1,901 50 0 0

Subtotal Susquehanna County 8,078

Broome County, New York

Powerline 26.5 26.6 475 20 0 0

Powerline 37.4 40.7 17,266 100 10 0

Powerline 40.7 40.7 475 100 25 0

Subtotal Broome County 18,216

Chenango County, New York

Powerline 47.4 47.5 581 400 50 0

Powerline 47.5 47.6 422 400 125 0

Powerline 47.6 47.9 1,478 400 0 0

Powerline 47.9 48.0 370 400 50 0

Powerline 48.0 48.0 158 400 100 0

Powerline 48.0 48.0 106 400 0 0

Powerline 48.0 48.0 106 400 50 0

Powerline 48.0 48.0 158 400 100 0

Powerline 48.0 48.9 4,646 400 50 0

Subtotal Chenango County 8,025

Delaware County, New York

Powerline 52.8 53.1 1,637 250 10 0

Powerline 53.1 53.5 2,376 250 0 0

Powerline 53.5 53.6 370 250 10 0

Powerline 53.6 53.8 1,056 250 25 0

Powerline 53.8 54.2 2,165 250 10 0

Powerline 54.2 55.2 5,491 250 0 0

Powerline 55.2 55.3 211 250 110 0

Powerline 55.3 55.3 370 250 10 0

Subtotal Delaware County 13,676
2-9 Project Description

TABLE 2.2.1-1 (continued)

Summary of Existing Rights-of-Way Collocated with the Proposed Constitution Pipeline

Adjacent Facility

Start 

Milepost

End 

Milepost

Paralleled 

Length 

(feet)

Width of 

Foreign 

Right-ofWay

(feet)

Width of Foreign 

Right-of-Way 

That Would Be 

Used During 

Construction 

(feet)

Width of Foreign 

Right-of-Way 

That Would Be 

Used During 

Operation (feet)

Schoharie County, New York

30” TGP 200 Line 121.3 121.4 370 150 10 0

30” TGP 200 Line 121.4 121.4 158 150 60 0

30” TGP 200 Line 121.4 121.5 211 150 0 0

30” TGP 200 Line 121.5 121.5 53 150 25 0

30” TGP 200 Line 121.5 121.5 158 150 75 0

30” TGP 200 Line 121.5 121.7 1,003 150 25 0

30” TGP 200 Line 121.7 121.9 1,109 150 10 0

30” TGP 200 Line 121.9 122.3 1,901 150 25 0

30” TGP 200 Line 123.3 123.4 634 150 0 0

30” TGP 200 Line 123.4 123.5 158 150 20 0

30” TGP 200 Line 123.5 123.9 2,218 150 0 0

30” TGP 200 Line 123.9 124.4 2,851 150 25 25

30” TGP 200 Line 124.4 124.4 158 150 25 0

Subtotal Schoharie County 10,982

CONSTITUTION PIPELINE PROJECT

TOTAL COLLOCATION 58,977

2.2.1.2 Right-of-Way Configurations

Constitution proposes to use a 100-foot-wide construction right-of-way in upland interior forested 

locations (excluding areas with steep side slopes1 as quantified in section 4.1.3), a 110-foot-wide 

construction right-of-way in non-agricultural uplands, and a 125-foot-wide construction right-of-way in 

upland agricultural lands. Constitution proposes to use a 75-foot-wide construction right-of-way in most 

wetlands. In cases where Constitution proposes the horizontal directional drill (HDD) method, there 

would be no disturbance of the ground surface between the HDD workspaces as described further below. 

Actual right-of-way configurations and widths would vary, in some cases beyond 125-feet-wide 

considering extra workspace, based on site-specific conditions including road and railroad crossings, 

waterbodies, wetland crossings, the need for additional spoil storage, steep topography, the presence or 

absence of an existing right-of-way, and proximity to adjacent utilities. Constitution has submitted 

drawings that depict right-of-way configurations for the proposed 30-inch-diameter pipeline. The typical 

right-of-way configurations proposed by Constitution are included in appendix C and are discussed 

further below. The construction procedures that would be followed are described in detail in section 2.3.

The width of the construction right-of-way for the 30-inch-diameter pipeline would vary 

depending on site-specific factors; the permanent right-of-way would be 50 feet wide across the entire 

 1 Steep side slopes are defined as areas where the pipeline would run parallel to the slope contours and where the 

slope is 15 percent or greater.
Project Description 2-10

project. While many construction right-of-way configurations are possible based on site-specific 

conditions, there are four main variations for uplands, agricultural lands, interior forest areas, and 

wetlands. The trench would be 10 feet wide in all upland configurations, and it would be 12 feet wide in 

wetlands. In upland areas the 110-foot-wide right-of-way would consist of 70 feet on the working side 

and 30 feet on the non-working (spoil) side of the 10-foot-wide pipeline trench. In upland agricultural 

areas requiring additional topsoil segregation, the construction right-of-way would typically be 125 feet

wide, consisting of 70 feet on the working side of the pipeline and 45 feet on the non-working (spoil) side 

of the 10-foot-wide trench. Through upland interior forest, and where no construction safety constraints 

such as steep side slopes are present, the typical 100-foot-wide construction right-of-way would consist of 

60 feet on the working side and 30 feet on the spoil side of the 10-foot-wide trench. Within wetlands, the 

typical 75-foot-wide construction right-of-way would consist of 44 feet on the working side of the 12-

foot-wide trench and 19 feet on the spoil side. Where the HDD or Direct Pipe method is employed in 

uplands or wetlands, there would be no actual construction right-of-way between the HDD entry and exit 

workspaces, and no clearing, trenching or other disturbance of the ground other than site-specific 

workspaces associated with placing the HDD guide wires via foot traffic and minor hand clearing. 

2.2.1.3 Extra Workspace

In addition to the various construction right-of-way configurations described above, Constitution 

has requested a wider construction right-of-way in several locations due to the presence of constraints 

mentioned above and for other, site-specific construction-related reasons. Appendix D identifies where 

Constitution has requested extra workspace for staging areas and resource crossings, including workspace

dimensions, the acreage of impact, associated land use, and the justification for their use. A detailed 

discussion of Constitution’s requests for extra workspace is provided below in section 2.3 and in sections 

4.3.3.7 and 4.4.4. 

Additional extra workspaces beyond those currently identified could be required during 

construction of the pipeline. Prior to construction, Constitution would be required to file a complete and 

updated list of all extra work areas, including any requested additional contractor yards for review and 

approval (see Post-Approval Variance Process in section 2.5.4).

2.2.2 Aboveground Facilities

The proposed aboveground facilities for Constitution’s project include 2 new M&R stations, 2

new tie-ins, 11 MLVs, and pig launcher and receiver facilities (see table 2.1.2-1). Construction of the 

Turnpike Road M&R Station would require 4.9 acres of land, 3.1 acres of which would be used 

permanently during operation. The kickoff MLV (No. 1), interconnecting piping, and a pig launcher 

would be located at the Turnpike Road M&R Station. The Westfall Road M&R Station would affect 3.3 

acres of land during construction and 2.3 acres during operation. The MLV terminus (No. 11), 

interconnecting piping, and a pig receiver would be located at the Westfall Road M&R Station. 

Constitution’s Sutton Road and White Road Tie-ins and MLVs 2 through 10 would be entirely within the 

permanent right-of-way and therefore would not encumber any additional acreage. 

Constitution proposes to use remotely controlled MLVs along the pipeline route. Remotely 

controlled MLVs would be continuously monitored at Constitution’s gas control center and in the event 

of an incident, an electronic command for valve closure can be sent. According to information provided 

by Constitution, remotely controlled MLVs provide more real-time data and reliability than automatically 

controlled valves. 

Modifications and construction at Iroquois’ Wright Compressor Station would occur within the 

existing station property boundary. Construction of Iroquois’ project would require 12.5 acres of 
2-11 Project Description

temporary workspace, including 2.1 acres within the existing fence line, 2.4 acres that would be outside 

the existing fence line but within the new, expanded fence line (this area also would be retained 

permanently for operations), and 8.0 acres of temporary workspace outside the proposed new, expanded 

fence line that eventually would be allowed to return to its pre-construction state. Iroquois would not 

need to acquire any additional property for project operation.

2.2.3 Contractor Yards

To support construction activities, Constitution proposes to use six contractor yards on a 

temporary basis. The use of these sites would temporarily affect about 110.0 acres of land. These sites 

are classified as having predominately open land / agricultural land use (see table 2.2.3-1). These yards 

are depicted on the maps in appendix B. 

TABLE 2.2.3-1

Contractor Yards along the Constitution Project Route

State/Yard Municipality

Size

(acres) Land Use

Pennsylvania

Spread 1 Bridgewater/Susquehanna County 20.0 Open Land

Subtotal 20.0

New York

Spread 2 Deposit/Broome County 19.1 Agriculture and Open Land

Spread 3 Sidney/Delaware County 17.8 Agriculture

Spread 4a Oneonta/Otsego County 26.9 Sand and Gravel, Open Land

Spread 4b Maryland/Otsego County 12.5 Open Land and Industrial

Spread 5 Richmondville/Schoharie County 13.8 Agriculture and Open Land

Subtotal 90.0

Constitution Pipeline Project Total 110.0

2.2.4 Access Roads

In addition to public roads, Constitution proposes to use 59 private access roads along the 

pipeline route (18 in Pennsylvania and 41 in New York) to construct the pipeline (see maps in appendix 

B). Of these 59 roads, 41 are existing, 10 would be a combination of existing and new roads, and 8 would 

be all newly constructed. Constitution proposes to maintain all but five of the 59 roads permanently for 

operations. Two of the five proposed temporary access roads would be newly constructed. Constitution 

has proposed a standard 12-foot-wide access road in straight areas, with expansion to 24-feet-wide as 

required for curves and corners. Modifications to existing roads could include tree, brush, or structure 

removal, widening, grading, installation of culverts, and addition of gravel. The location, description, 

length, land use, and type of improvement required (if any) for each of the access roads are listed in 

appendix E.
Project Description 2-12

2.3 CONSTRUCTION PROCEDURES

The projects would be designed, constructed, tested, and operated in accordance with all 

applicable requirements included in the DOT regulations in 49 CFR 192,2 Transportation of Natural and 

Other Gas by Pipeline: Minimum Federal Safety Standards; and other applicable federal and state 

regulations, including the U.S. Department of Labor, Occupational Safety and Health Administration 

requirements. These regulations are intended to ensure adequate protection for the public. Among other 

design standards, Part 192 specifies pipeline material and qualification, minimum design requirements, 

and protection from internal, external, and atmospheric corrosion.

To reduce construction impacts, Constitution would implement its state-specific Environmental 

Construction Plans (ECPs)3

. The ECPs include Constitution’s Upland Erosion Control, Revegetation, 

and Maintenance Plan (Plan) which are based on our Upland Erosion Control, Revegetation, and 

Maintenance Plan (our Plan4

). The ECPs also include Constitution’s Wetland and Waterbody 

Construction and Mitigation Procedures (Procedures), which, similarly, are based upon and contain many 

of the measures found in our Wetland and Waterbody Construction and Mitigation Procedures (our 

Procedures4

). The intent of Constitution’s Plan and Procedures is to identify baseline mitigation measures 

and construction techniques that incorporate guidelines recommended by various resource agencies (such 

as crop productivity monitoring procedures), as well as other guidelines and plans tailored to projectspecific issues. The ECPs contain numerous measures that would prevent or minimize potential impacts 

on resources. As indicated in appendix D, Constitution’s ECPs include some alternative measures that 

differ from our standard Plan and Procedures, such as the use of certain extra workspaces. These 

alternative measures are discussed in more detail in section 4.2.4, 4.3.3, 4.4.3, and 4.4.4, which also 

includes our recommendations for the appropriateness of these modifications. 

Constitution’s Plan and Procedures propose three notable modifications from our standard Plan 

and Procedures. These modifications, their descriptions, and status are listed below in table 2.3-1.

Constitution’s Plan and Procedures also include deviations from our standard Plan and 

Procedures not listed in table 2.3-1, but they are more protective than our requirements, and we have 

found them to be acceptable. Iroquois proposes to adopt our Plan and Procedures, but did not propose 

any modifications from the FERC’s standard Plan and Procedures.

 2 Pipe design regulations for steel pipe are contained in subpart C, Part 192. Section 192.105 contains a design 

formula for the pipeline’s design pressure. Sections 192.107 through 192.115 contain the components of the 

design formula, including yield strength, wall thickness, design factor, longitudinal joint factor, and temperature 

derating factor, which are adjusted according to the project design conditions, such as pipe manufacturing 

specifications, steel specifications, class location, and operating conditions. Pipeline operating regulations are 

contained in subpart L, Part 192. 3 The Pennsylvania ECP (Volume II Appendix I) and the New York ECP (Volume II Appendix J) can also be 

found at http://elibrary.ferc.gov/idmws/file_list.asp?document_id=14160901. 4 The FERC Plan and Procedures are a set of construction and mitigation measures that were developed in 

collaboration with other federal and state agencies and the natural gas pipeline industry to minimize the 

potential environmental impacts of the construction of pipeline projects in general. The FERC Plan and 

Procedures can both be viewed on the FERC Internet website at 

https://www.ferc.gov/industries/gas/enviro/guidelines.asp.
2-13 Project Description

TABLE 2.3-1

Summary of Proposed Modifications to the FERC’s Plan and Procedures

Applicable 

FERC 

Plan/Procedures 

Section Resource Issue Description Status

Section 

Discussed

Plan, at IV.A.2 Construction rightof-way widthProposal to utilize a standard 

construction right-of-way width of 

100 feet in upland interior forested 

locations, 110 feet in other upland 

locations, and 125 feet in all active 

agricultural areas.

Acceptable 2.2.1

Procedures, at 

Sections II.A and 

VI.B.1.a

Construction rightof-way width in 

wetlands; extra 

workspace 

positioning relative 

to waterbodies and 

wetlands

Proposal to use a construction rightof-way width greater than 75 feet in 

wetlands; utilize extra workspace 

within 50 feet of waterbodies and 

wetlands in specific locations as 

listed in appendix D. 

Acceptable 4.4.4

Procedures, at 

VI.D.1

Vegetation clearing 

and maintenance 

associated with 

HDDs

Proposal to clear vegetation at a 10-

foot-wide corridor within wetlands 

that are between HDD entry and 

exit points to facilitate water 

withdrawal for drilling operations.

Not Acceptable - the clearing 

of wetland (and/or upland) 

vegetation between HDD entry 

and exit points is not 

adequately justified.

4.4.3

To avoid or minimize the potential for harmful spills and leaks during construction, Constitution 

has developed a Spill Plan for Oil and Hazardous Materials (Constitution’s Spill Plan) and Iroquois has 

developed Spill Prevention, Control and Countermeasure (SPCC) Plan. Constitution’s Spill Plan and 

Iroquois’ SPCC describes spill and leak preparedness and prevention practices, procedures for emergency 

preparedness and incident response, and training requirements. Additional discussion of Constitution’s

Spill Plan is presented in section 4.3.2. Other resource-specific plans have been developed for the 

proposed pipeline project and are included in the ECPs. These plans are introduced below and are 

discussed in more detail in section 4.0.

2.3.1 General Pipeline Construction Procedures

This section describes the general procedures proposed by Constitution and Iroquois for their 

respective facilities. Constitution’s primary pipeline construction technique in upland areas would be 

standard, sequential assembly line installation (described below). Constitution would have 5 of these 

assembly lines or “spreads” that would each be simultaneously completing construction activities at 

different locations along the route. Iroquois’ construction at the Wright Compressor Station would entail 

standard site and industrial development type activities. 

Other specialized construction methods, such as two-tone cut and fill methods used on steep sideslopes, HDD and Direct Pipe methods used to cross under sensitive resources, residential-specific 

methods, and procedures for crossing of waterbodies and wetlands would also be employed. These 

specialized construction methods are also described below.

Separate crews typically would be used for construction of the aboveground facilities and 

modifications to existing facilities. Construction procedures for aboveground facilities are described in 

section 2.3.3. 
Project Description 2-14

Survey and Staking

After Constitution completes land or easement acquisition and before the start of construction, 

crews would mark the limits of the approved work areas (i.e., the construction right-of-way boundaries 

and extra workspace, the pipeline centerline, and approved access roads). Property owners would be 

notified prior to surveying and staking activities. Wetland boundaries and other environmentally sensitive 

areas identified in easement agreements or by federal and state agencies would be clearly marked with 

visible signage and fenced with erosion control devices for protection. In association with COE 

requirements, Constitution may also use orange safety fencing to identify wetlands of high value. 

Clearing Operations

Clearing would be required to remove trees, brush, and other existing vegetation from approved 

work areas. This would occur by mechanical means including feller-bunchers and hydroaxes. Hand 

cutting with chain saws may also be used in specific areas as needed. Timber would be removed from the 

right-of-way and sold for lumber or pulp if suitable, disposed of at an appropriate receiving facility, or 

chipped on the right-of-way. Constitution would not dispose of any cleared vegetation by burning. The 

transportation of any wood materials would comply with the NYSDEC’s regulations intended to prevent 

the spread of invasive species. Constitution’s state-specific Invasive Species Management Plans are 

described in more detail in section 4.5. Timber may also be cut and stacked at the edge of the right-ofway in accessible area, if requested by the landowner. Wood chips would not be placed in agricultural 

areas, wetlands, or waterbodies. Timber would not be left in piles or stacks on the right-of-way. 

In uplands, tree stumps and rootstock would be removed from the entire width of the permanent 

right-of-way. Additional stump pulling would be conducted in upland extra workspaces if deemed 

necessary for safety reasons. In wetlands, the pulling of stumps would be limited to the trench line and 

other areas where it is deemed necessary for safety reasons (see section 2.3.2.1 for a description of stump 

removal in wetlands). Elsewhere in wetlands, stumps and rootstock would be left intact to promote 

revegetation following construction. Excavated stumps would be removed from the right-of-way for 

disposal at approved locations or made available to landowners upon request. 

Closely following clearing and before beginning grading activities, crews would install erosion 

control devices at the locations outlined in the ECPs. The ECPs also include specifications for the 

installation and maintenance of temporary erosion controls such as silt fence, straw bales, temporary slope 

breakers (interceptor dikes); as well as permanent erosion controls such as permanent trench plugs, slope 

breakers, restoration methods, and revegetation measures. The environmental inspector (EI) would be 

responsible for ensuring that the erosion controls are installed correctly, inspected, and maintained in 

accordance with the ECPs.

Grading

Grading of the construction right-of-way would be scheduled to limit the amount of time between 

clearing and the installation of the pipeline. Where necessary, the entire width of the construction rightof-way, including the temporary construction workspace, would be rough graded with bulldozers to allow 

for safe passage of equipment and to prepare the work surface for pipeline installation activities. 

Backhoes may be used in conjunction with bulldozers in areas where tree stumps, rock outcrops, and 

uneven topographic features need to be removed. A travel lane would be utilized to allow for the passage 

of daily traffic.

Topsoil stripping would occur in agricultural and residential lands, and in other areas as requested 

by landowners. Up to 12 inches of topsoil would be removed and kept segregated from subsoil until 
2-15 Project Description

replacement. Constitution would strip topsoil from the full right-of-way in agricultural lands. 

Constitution has developed a Soil Protection and Subsoil Decompaction Mitigation Plan, which is 

discussed in more detail in section 4.2.

Trenching 

The trench would be excavated with a backhoe or track-mounted excavator to provide at least the 

minimum cover as required by 49 CFR 192. Typically, the trench would be sufficiently deep (5.5 feet

deep to 7.5 feet deep for the 30-inch-diameter pipeline) to provide for a minimum of 3 feet of cover over 

the pipeline. In areas with consolidated rock, the minimum amount of cover would be 24 inches. In 

certain areas such as at crossings of foreign pipelines and utilities, deeper burial would be required 

resulting in an increased trench depth. Constitution’s proposed minimum specifications for depth of 

cover over the pipeline are listed in table 2.3.1-1. Where the HDD or Direct Pipe methods are used the 

pipeline would be installed deep below the ground surface. 

TABLE 2.3.1-1

Constitution’s Proposed Minimum Specifications for Depth of Cover

Location a

Normal Soil (cover 

depth in inches) 

Consolidated Rock 

(cover depth in inches) 

DOT PHMSA Class 1 36 24

DOT PHMSA Class 2, 3, and 4 36 24

Land in Agriculture 48 24

Drainage ditches of public roads or railroad crossings 60 24

Navigable river, stream, or harbor 60 24

Minor stream crossings 60 24

____________________

a As defined by the DOT Pipeline and Hazardous Materials Safety Administration (PHMSA) at 49 CFR 192.5.

Class 1: offshore areas and areas within 220 yards of a pipeline with ≤10 buildings intended for human occupancy.

Class 2: areas within 220 yards of a pipeline with >10 but <46 buildings intended for human occupancy.

Class 3: areas within 220 yards of a pipeline with >46 buildings intended for human occupancy and areas within 100 

yards of either a building or a small, well defined outside area (such as a playground, recreation area, 

outdoor theater, or other place of public assembly) that is occupied by 20 or more persons on at least 5

days a week for 10 weeks in any 12-month period.

Class 4: areas within 220 yards of a pipeline where buildings with four or more stories are prevalent.

The Constitution project would cross underground utilities in numerous locations. Prior to 

construction, the Constitution’s contractors would contact the “Call Before You Dig” or “One Call” 

system, or state or local utility operators, to verify and mark all underground utilities (e.g., cables, 

conduits, and pipelines) along the pipeline route to minimize the potential for accidental damage during 

construction. In areas where the location is not apparent, utility lines would be located by field 

instrumentation and test pits. The proposed route has been designed to avoid existing utility lines to the 

extent possible. However, relocation of utilities may be necessary in some circumstances. Constitution 

would coordinate all required utility relocations with the appropriate owner.

Spoil material excavated from the trench would be temporarily piled to one side of the right-ofway, adjacent to the trench. Subsoil would not be allowed to mix with the previously stockpiled topsoil. 

Where trench dewatering is needed, water would be discharged off the right-of-way into a well-vegetated 

upland area and/or into an approved filter. Any contaminated soil or groundwater encountered would be 

managed in accordance with the Constitution’s Unanticipated Discovery of Contamination Plan

(Contamination Plan). Additionally, Constitution has developed an Unanticipated Cultural and 
Project Description 2-16

Paleontological Resources and Human Remains Discovery Plan (Discovery Plan) should those features be 

discovered during trenching or construction. 

Shallow Bedrock and Blasting

The proposed pipeline would cross numerous areas of shallow bedrock distributed along most of 

the route as discussed in detail in section 4.1. Where bedrock is encountered along the pipeline route, it 

would be broken up and removed using one of the following methods. Where practicable, conventional, 

non-explosive methods would be used, including ripping or hammering the rock with a pointed backhoe 

attachment before excavating it with a backhoe. Rock would be returned to a level no higher than the 

existing rock profile during restoration. In agricultural areas rock would not be used for backfill closer 

than 24 inches in mesic soil or 30 inches in frigid soils from the construction surface of the right-of-way, 

and any excess would be disposed of at a landfill or recycling facility or used for other approved purposes 

within the right-of-way as allowed by the landowner and applicable permits. 

If rock cannot be removed by any of these techniques, blasting may be required to fracture the 

rock prior to its removal. Blasting would be performed under strictly controlled conditions designed to 

prevent potential damage to people and property (such as homes and wells). Constitution has proposed to 

offer both pre- and post-construction testing of water quality and quantity in wells and to mitigate any 

damages caused by construction. Minimum charges needed to perform the blasting would be used. 

Heavy mats may be used to prevent the scattering of debris, and blast monitoring would be conducted. 

Constitution has developed a Blasting Plan to address potential issues and impacts related to blasting (see

section 4.1). 

Constitution also developed a Karst Mitigation Plan to address potential issues associated with 

the presence of shallow carbonate sedimentary (i.e., limestone) rock. This plan is also discussed in 

section 4.1. The plan includes provisions for the use of geotechnical specialists, exploratory testing, and 

geophysical assessment as necessary to prevent or minimize potential impacts. 

Pipe Stringing, Bending, and Welding

Once the trench is excavated, the next process in conventional pipeline construction is stringing 

the pipe along the trench. Stringing involves initially hauling the pipe by tractor-trailer, generally in 40-

foot lengths (joints), from contractor yard onto the right-of-way. The pipe would be off-loaded from 

trucks and placed next to the trench using a sideboom tractor. Typically, several pipe joints are lined up 

end-to-end or “strung” to allow for welding into continuous lengths known as strings. Individual joints 

would be placed on temporary supports or wooden skids and staggered to allow room for work on the 

exposed ends. 

The pipe would be delivered to the contractor yards and work areas in straight sections. Some 

bending of the pipe would be required to enable the pipeline to follow the natural grade and direction 

changes of the right-of-way. Selected joints would be bent by track-mounted hydraulic bending machines 

as necessary prior to line-up and welding. Manufacturer supplied induction bends and pre-fabricated 

elbow fittings may be used in certain circumstances as needed. Following stringing and bending, the 

individual joints of pipe would be aligned and welded together. All welding would be performed 

according to applicable American National Standards Institute, American Society of Mechanical 

Engineers, and American Petroleum Institute standards as well as Constitution’s specifications. Only 

welders qualified to meet the standards of these organizations would be used during construction. 

Every completed weld would be examined by a welding inspector to determine its quality using 

radiographic or other approved methods as outlined in 49 CFR 192. Radiographic examination is a non-
2-17 Project Description

destructive method of inspecting the inner structure of welds and determining the presence of defects. 

Welds that do not meet the regulatory standards and Constitution’s established specifications would be 

repaired or removed. After a weld is approved, the joint would be cleaned and epoxy coated. The coating 

on the remainder of the completed pipe section would be inspected and any damaged areas repaired.

Special tie-in crews would be used at some locations, such as at waterbody and road crossings, at 

changes in topography, and at other selected locations as needed. A tie-in is typically a relatively small 

segment of pipeline specifically used to cross certain features as needed. Once the pipeline segment is 

installed across the feature, the segment is then welded to the rest of the pipeline. 

Lowering-in and Backfilling

Before the pipeline is lowered-in, the trench would be inspected to ensure that it is free of rocks 

and other debris that could damage the pipe or protective coating. Typically, any water that is present in 

the trench would be removed and pumped to a vegetated upland through an approved filter. Constitution 

would use a padding machine to ensure that rocks mixed with subsoil do not damage the pipe. The 

padding would consist of subsoil free from rocks and would surround the pipe along the bottom, both 

sides, and at the top. No topsoil would be used as padding material. Where there is not sufficient 

padding material on site or when the native material that was excavated from the trench is not suitable 

backfill material (i.e., rocky), the acquisition of backfill from other sources may be necessary. 

After the pipe is lowered into the trench, final tie-in welds would be made and inspected, and then 

the trench would be backfilled. All suitable material excavated during trenching would be re-deposited 

into the trench using bladed equipment or backhoes. If rock is excavated from the trench and 

subsequently used as backfill, it would not be allowed to extend above the soil horizon where it naturally 

is found. The top of the trench may be slightly crowned to compensate for settling. 

Cleaning and Hydrostatic Testing

After burial, the inside of the pipeline would be cleaned to remove any dirt, water, or debris 

inadvertently collected in the pipe during installation. A manifold would be installed on one end of the 

pipeline section and a cleaning “pig” (typically a large soft plug used to swab the inside of the pipeline) 

would be propelled by compressed air through the pipeline. 

After cleaning, the pipe would be hydrostatically tested to ensure that the system is capable of 

withstanding the operating pressure for which it was designed. Hydrostatic testing involves filling the 

pipeline with water and pressurizing the water in the pipeline for several hours to confirm the pipeline’s 

integrity. The testing would be done in segments according to Constitution’s requirements and the 

DOT’s specifications in 49 CFR 192. The exact sequence and timing of hydrostatic testing would depend 

on the final schedule for construction (section 2.4). Iroquois anticipates using a combination of nitrogen 

and water from municipal sources for hydrostatic testing. 

Water for hydrostatic testing would potentially be obtained from five streams located along the 

proposed pipeline route. These streams are discussed in more detail in section 4.3. Constitution would 

reuse test water by transferring water from one test segment to another where practicable. Following 

testing, the water would be discharged in vegetated upland areas through a dewatering structure designed 

to slow the flow of water. All testing activities would be conducted within the parameters of the 

applicable water withdrawal and discharge permits. 
Project Description 2-18

Cleanup and Restoration 

Within 20 days of backfilling the trench, all work areas would be final graded and restored to preconstruction contours and natural drainage patterns as closely as possible, weather permitting. Permanent 

slope breakers or diversion berms would be constructed and maintained in accordance with the ECPs as 

needed. Fences, sidewalks, driveways, and other structures would be restored or repaired as necessary. If 

seasonal or other weather conditions prevent compliance with these timeframes, temporary erosion 

controls would be maintained until conditions allow completion of final cleanup. 

Restoration activities would be conducted in accordance with state and municipal permit 

requirements. Soils that supported vegetation prior to construction would be revegetated using seed 

mixes, application rates, and timing windows recommended by local soil conservation authorities or other 

duly authorized agencies (such as the Natural Resources Conservation Service [NRCS]), landowner 

requests, and in accordance with the ECPs. The right-of-way would be seeded within six working days 

following final grading, weather and soil conditions permitting, unless otherwise directed by local soil 

conservation authorities. Additionally, monitoring of revegetation after construction would be conducted

to evaluate and correct areas requiring remediation. 

Cathodic Protection and Alternating Current Mitigation

Constitution would install cathodic protection equipment along the pipeline to prevent the 

corrosion of metal surfaces over time. Cathodic protection equipment could consist of rectifiers, test 

leads, and sacrificial anode beds. The design and location of cathodic protection systems has not yet been 

determined but would be submitted to Commission staff for review and approval prior to construction. 

The ground beds are usually located near the ends of the pipeline and encompass one to two acres in total. 

Constitution would also develop an alternating current mitigation plan for areas where the pipeline 

parallels adjacent power lines. The alternating current mitigation plan would be designed to ensure safety 

and prevent corrosion facilitated by the presence of nearby high voltage power lines. 

2.3.2 Special Construction Techniques

Construction involving wetlands, waterbodies, or construction across or within roads, highways, 

railroads, and streets, would require construction techniques that differ from the standard measures 

implemented in general areas. Constitution’s special construction techniques are summarized below. 

2.3.2.1 Wetland Crossings

The proposed pipeline would cross palustrine forested, palustrine scrub-shrub, and palustrine 

emergent wetlands. Wetland resources are discussed in detail in section 4.4. Construction within, and 

restoration of wetlands would be performed in accordance with the wetland construction and mitigation 

measures contained in the ECPs and Constitution’s Procedures. 

Clearing of vegetation in wetlands would be limited to trees and shrubs, which would be cut flush 

with the surface of the ground and removed from the wetland. Stump removal, grading, topsoil 

segregation, and excavation would be limited to the area immediately over the trenchline in order to avoid 

excessive disruption of wetland soils and the native seed and rootstock within the wetland. A limited 

amount of stump removal and grading may also be conducted in other areas if dictated by safety-related 

concerns.

During clearing, sediment barriers such as silt fence and staked straw bales would be installed and 

maintained adjacent to wetlands and within temporary extra workspaces as necessary to minimize the 
2-19 Project Description

potential for sediment runoff. Sediment barriers would be installed across the full width of the 

construction right-of-way at the base of slopes adjacent to wetland boundaries. If trench dewatering is 

necessary in wetlands, the trench water would be discharged into stable, vegetated, upland areas and/or 

filtered through a filter bag or siltation barrier in accordance with the ECPs. No heavily silt-laden water 

would be allowed to flow into a wetland.

Construction equipment working in wetlands would be limited to that essential to clear the rightof-way, excavate the trench, fabricate and install the pipeline, backfill the trench, and restore the right-ofway. The specific method of construction used in wetlands would depend on the stability of the soils at 

the time of construction. 

Standard pipeline construction, similar to construction methods described for uplands, may be 

conducted in non-saturated wetlands. In areas of saturated soils or standing water, low-ground-weight 

construction equipment and/or wooden mats would be used to reduce rutting and the mixing of topsoil 

and subsoil. In unsaturated wetlands and unfrozen wetlands, the top 12 inches of topsoil from the 

trenchline would be stripped and stored separately from the subsoil. 

Where wetland soils are saturated and/or inundated, the pipeline may be installed using the pushpull technique. The push-pull technique involves stringing and welding the pipeline outside of the 

wetland and excavating the trench through the wetland using a backhoe supported by equipment mats. 

The water that seeps into the trench is used to “float” the pipeline into place together with a winch and 

flotation devices attached to the pipe. After the pipeline is floated into place, the floats are removed 

allowing the pipeline to sink into place. Pipe installed in saturated wetlands is typically coated with 

concrete or equipped with set-on weights to provide negative buoyancy. After the pipeline sinks to the 

bottom of the trench, a trackhoe working on equipment mats backfills the trench and completes cleanup. 

Trenchless construction techniques, such as conventional bore, HDD, and Direct Pipe would also be used 

to cross under certain wetlands (see section 2.3.2.2). 

Because little or no grading would occur in wetlands, restoration of contours would be 

accomplished during backfilling. Prior to backfilling, trench breakers would be installed where necessary 

to prevent the subsurface drainage of water from wetlands. Where topsoil has been segregated from 

subsoil, the subsoil would be backfilled first, followed by the topsoil. Equipment mats, terra mats, and 

timber riprap used for equipment support would be removed from wetlands following backfilling.

For wetlands at the base of slopes, permanent interceptor dikes and trench plugs would be 

installed in upland areas adjacent to the wetland boundary. Temporary sediment barriers would be 

installed where necessary until revegetation of adjacent upland areas is successful. Once revegetation is 

successful, sediment barriers would be removed from the right-of-way and properly disposed.

2.3.2.2 Waterbody Crossings

Waterbody crossings would be constructed in accordance with federal, state, and local permits 

and the ECPs. Surface water resources are discussed further in section 4.3.2, and aquatic resources are 

discussed in section 4.6.2. Discussion of potential impacts on fisheries resources, including agency 

consultations regarding construction timing restrictions, is also included in section 4.6.2. Constitution 

would cross waterbodies using methods including dry open-cut (if dry or frozen at the time of crossing), 

dry crossings (flume pipe, cofferdam, or a dam and pump), or trenchless crossings (conventional bore, 

HDD, or Direct Pipe). All three of the trenchless crossing methods are proposed for use for at least one 

waterbody. 
Project Description 2-20

Where standing water is present within a channel, but flow is not discernible, a dry crossing (e.g., 

flume crossing, dam and pump, or cofferdam) method would be used to allow for construction under dry 

conditions. The specific dry crossing method to be used at waterbodies would be decided at the time of 

construction based on site conditions. 

Wet, open-cut crossing methods are not proposed for any waterbodies, but could be considered if 

the dry crossing options are rendered infeasible. Wet, open-cut construction methods involve trenching 

within the waterbody under flowing conditions, with backfill and restoration occurring quickly (typically 

within 24 to 48 hours) to limit impacts on the stream. Implementation of these methods would require 

additional review by the COE, PADEP, NYSDEC, and the Commission.

The pipeline crossings would typically require extra workspaces on each side of the waterbody to 

stage construction, fabricate the pipeline, and store materials. These extra workspaces would be located a 

minimum of 50 feet from the waterbody edge, except where the adjacent upland consists of actively 

cultivated or rotated cropland or other disturbed land, or where site-specific for a reduced setback is 

necessary (section 4.3.3 and appendix D).

Constitution would install temporary equipment bridges over waterbodies. Bridges may include 

clean rock fill over culverts, equipment pads supported by flumes, railcar flatbeds, flexi-float apparatus, 

and other types of spans. These bridges would remain in place throughout construction until they are no 

longer needed. Each bridge would be designed to accommodate normal to high stream flows and would 

be maintained to prevent soil from entering the waterbody. All construction equipment would be required 

to use the bridges, except for the clearing equipment needed for installation of the equipment bridges. 

The number of clearing equipment crossings of each waterbody would be limited to one piece of 

equipment as specified in Constitution’s Procedures. Sediment barriers would be installed immediately 

after initial disturbance of the waterbody or adjacent upland. Sediment barriers would be properly 

maintained throughout construction and reinstalled as necessary (such as after backfilling of the trench) 

until replaced by permanent erosion controls, or restoration of adjacent upland areas is complete and 

revegetation has stabilized the disturbed area.

Dry Crossing Construction Methods

Dry open-cut crossings of waterbodies involve conventional trenching of channels that are dry or 

frozen at the time of crossing (contain no discernible flow). This construction technique is similar to the 

standard pipeline installation process described above for uplands. However, Constitution identified it 

would complete construction and backfill within 24 hours for minor water bodies (less than 10 feet wide) 

and within 48 hours for intermediate waterbodies (10 to 100 feet wide). Constitution has committed to 

keep temporary diversion structures available onsite in the event that unexpected rainfall causes any 

waterbody being crossed by the dry open-cut method to begin flowing prior to completion of the crossing. 

In that case, a flume crossing, dam and pump or cofferdam method would then be employed.

The flume method is a standard dry waterbody crossing method that involves diverting the flow 

of water across the construction work area through one or more flume pipes placed in the waterbody. The 

first step involves placing a sufficient number of adequately sized flume pipes in the waterbody to 

accommodate the highest anticipated flow during construction. After the flume pipe(s) are placed in the 

waterbody, sand bags or equivalent dam diversion structures are installed in the waterbody upstream and 

downstream of the trench area. These devices serve to dam the stream and divert the water flow through 

the flume pipe(s), thereby isolating the water flow from the construction area between the dams. The 

flume pipe(s) and dams would remain in place during pipeline installation and until the final cleanup of 

the stream bed and bank is completed.
2-21 Project Description

The dam and pump method is another standard dry waterbody crossing construction method that 

may be used as an alternative to the flume method. This method is similar to the flume crossing method 

except that pumps and hoses are used instead of flumes to move water across or around the construction 

work area. The technique involves installing a pump upstream of the crossing and running a discharge 

hose from the pump across the construction area to a discharge point downstream of the construction area. 

After the pump is installed and operational, sandbags or equivalent dam diversion structures would be 

installed upstream and downstream of the trench area to isolate the water flow from the construction area 

between the dams. An energy dissipation device would be used to prevent scouring of the stream bed at 

the discharge location. Water flow would be maintained throughout the dam-and-pump operation until 

the pipeline is installed and banks are restored and stabilized.

A cofferdam is a temporary structure that could be installed within waterbodies to isolate a 

portion of the work area during construction, thereby allowing pipeline installation and construction to 

proceed under dry conditions. Cofferdams would typically be used for waterbody crossings with larger 

high flow volumes that may be unsuitable for flume or dam and pump methods. A cofferdam consists of

installing the pipeline across the waterbody in stages, using the cofferdam to divert the water around the 

workspace (i.e., a portion of the stream’s width) in each stage. This process allows work to proceed under 

dry conditions during each stage after the work area is dewatered, and it could take two or more stages to 

complete the crossing. Cofferdam construction methods may include but not be limited to sand bags, 

sheet piling, timber lagging, and inflatable dams.

Cofferdam crossings would be designed in accordance with all applicable federal and state 

permits to ensure that the cofferdam could withstand elevated waterbody flows during the course of the 

work. Dewatering operations of the work areas isolated by the cofferdam would require silt-laden water 

to be pumped and discharged to an appropriate dewatering device (e.g., filter bags) in a vegetated upland

area before it would be allowed to flow back towards the waterbody.

Trenchless Crossing Methods

Conventional boring consists of creating a tunnel-like shaft for a pipeline to be installed below 

roads, waterbodies, wetlands, or other sensitive resources without affecting the surface of the resource. 

Bore pits would be excavated on both sides of the resource to the depth of the adjacent trench and graded 

to match the proposed slope of the pipeline. A boring machine would then be used within the bore pit to 

tunnel under the resource or wetland by using a cutting head mounted on an auger. The auger would 

rotate and be advanced forward as the hole is bored. The pipeline would then be pushed through the bore 

hole and welded to the adjacent section of pipeline. 

The HDD construction method would be used at five locations, and the Direct Pipe construction 

method would be used at two locations. The proposed HDD and Direct Pipe locations cross under 

waterbodies and/or wetlands, in each case. Roads would also be crossed using these methods at four 

crossings. The locations and lengths of the proposed HDD and Direct Pipe crossings and the resources 

they would cross under are summarized in table 2.3.2-1. Constitution has prepared conceptual sitespecific construction plans for the two major waterbody crossings (Bennettsville Creek and Schoharie 

Creek) as well as all proposed HDD and Direct Pipe crossings. We find these conceptual plans to be 

generally acceptable with the exception of one HDD crossing (see section 4.10.4.). 
Project Description 2-22

TABLE 2.3.2-1

Proposed Horizontal Directional Drill and Direct Pipe Locations for the Constitution Pipeline

Approximate Milepost

Length 

(feet)

Potential 

Installation 

Method

Proposed Alternative 

Crossing Method if the 

Trenchless Method 

Fails

Reason for 

Start End Evaluation Status

Pennsylvania

15.3 15.7 2,210 HDD Open-cut crossing 

(Wetlands)

Dry crossing 

(Waterbodies)

Avoidance of 

wetlands, 

waterbody, 

Lakeview 

Road 

(Highway 

1019)

Conceptual design 

complete; awaiting 

site access for 

geotechnical 

evaluations

New York

47.7 48.0 1,630 HDD Open-cut crossing 

(Wetlands)

Dry crossing 

(Waterbodies)

Avoidance of 

Bennettsville 

Creek, other 

waterbodies, 

wetlands

Conceptual design 

complete; awaiting 

site access for 

geotechnical 

evaluations

54.4 55.3 5,500 HDD Open-cut crossing 

(Wetlands)

Dry crossing 

(Waterbodies)

Avoidance of 

wetlands, 

waterbodies

Conceptual design 

complete; awaiting 

site access for 

geotechnical 

evaluations

85.8 86.1 3,188 HDD Open-cut crossing 

(Wetlands)

Avoidance of 

wetlands

Conceptual design 

complete; awaiting 

site access for 

geotechnical 

evaluations

87.8 88.2 2,050 HDD Open-cut crossing 

(Wetlands)

Dry crossing 

(Waterbodies)

Avoidance of 

wetlands, 

Middle Brook, 

other 

waterbodies, 

and Highway 

23

Conceptual design 

and geotechnical 

study complete;

awaiting laboratory 

results and 

analysis

101.5 101.6 570 Direct Pipe Open-cut crossing Avoidance of 

wetlands and 

Baldwin Road

Conceptual design 

complete; awaiting 

site access for 

geotechnical 

evaluations

119.8 120.0 744 Direct Pipe Dry crossing 

(Waterbodies)

Avoidance of 

Smith Road, 

Schoharie 

Creek, Holiday 

Way

Preliminary design 

of Direct Pipe 

method in 

progress

The HDD method would also avoid disturbing surface and shallow subsurface features (such as 

waterbodies, wetlands, vegetation, manmade structures, and public use and protected areas) between two 

construction areas. The HDD method typically involves establishing workspaces in upland areas on both 

sides of the feature(s) to be crossed and confining the work and equipment to these areas. The process 

commences with the drilling of a pilot hole in an arced path beneath the feature using a drill rig positioned 

on the entry side of the crossing. When the pilot hole is completed, reamers are attached and are used to 

enlarge the hole in one or more passes until its diameter is sufficient to accommodate the pipeline. As the 
2-23 Project Description

hole is being reamed, a pipe section long enough to span the entire crossing is fabricated (staged and 

welded) on one side of the crossing (typically the exit side) and then hydrostatically tested to ensure the 

integrity of the welds. When the reaming is complete, the prefabricated pipe section is pulled through the 

pre-reamed drilled hole back to the entry side. Constitution would weld the proposed pipeline at the midpoint for HDDs at MP 15.3, 47.6, and 54.3 due to a lack of workspace to accommodate a fully assembled 

HDD pipeline segment awaiting pullback into the reamed hole. The use of a mid-point weld would allow 

Constitution to use shorter extra workspaces for these proposed HDD crossings. 

Between HDD entry and exit points foot traffic would be required to place guide wires to track 

the progress and guide the movement of the drilling cutterheads. These guide wires would be placed in 

upland and wetland areas but would not be laid on the bed of any waterbodies. 

Constitution proposes to clear a 10-foot-wide corridor between the HDD or Direct Pipe entry and 

exit holes, including within wetlands, at Middle Brook, Bennettsville Creek, and Schoharie Creek. We 

consider this proposal in section 4.4, but have currently found the need to be unsupported by Constitution 

without additional justification. Pathways to the water source in support of drilling operations can 

typically be routed in a meandering fashion, thereby avoiding trees and any substantial clearing. In 

section 4.4 we recommend that Constitution not clear any trees between the HDD entry and exit sites 

during construction. Minor brush clearing, less than 3 feet wide, using hand tools only is allowed to 

facilitate the use of the HDD tracking system, or acquisition of water for makeup of the HDD slurry. 

Throughout the drilling process, a slurry of naturally occurring, non-toxic, bentonite clay and 

water would be pressurized and pumped through the drilling head to lubricate the drill bit, remove drill 

cuttings, and hold the hole open. This slurry, referred to as drilling mud or drilling fluid, has the potential 

to be inadvertently released to the surface. Constitution would monitor the pipeline route and the 

circulation of drilling mud throughout the HDD operation for indications of an inadvertent drilling mud 

release and would immediately implement corrective actions if a release is observed or suspected. The 

corrective actions that Constitution would implement, including the agencies it would notify and the steps 

it would take to clean up and dispose of a release, are outlined in its Draft HDD Contingency Plan, which 

is discussed in section 4.3.3.

It is possible for HDD operations to fail, primarily due to the encountering of unexpected 

geologic conditions during drilling or if the pipe were to become lodged in the hole during pullback 

operations. Potential causes for abandoning a drill hole include the loss of drill bits or pipe down the hole 

due to a mechanical break or failure; a prolonged release of drilling mud that cannot be controlled; failure 

of the HDD pullback where a section of pipe cannot be retracted and has to be abandoned; or an inability 

to correct a severe curvature of the pilot hole drill path. In any event, reasonable attempts would be made 

to overcome the obstacles preventing successful completion of the drill. Such measures could include redrilling the pilot hole in a slightly different location or re-conditioning of the pilot hole. Constitution 

would be required to seek approval from the Commission and other applicable agencies prior to 

abandoning any proposed HDD (or Direct Pipe) crossing in favor of another construction method. If an 

HDD or Direct Pipe hole were to be abandoned, Constitution would seal and grout with cement at least 

the upper 35 feet of the bore hole(s), with the top five feet filled with soil to allow for revegetation. 

Constitution’s preferred alternative crossing methods in the event that any proposed trenchless crossing 

were to fail are listed in table 2.3.2-1. 

Not all geotechnical data testing pertaining to the feasibility of the proposed HDD and Direct 

Pipe crossings have been provided by Constitution, often due to a lack of survey permission. These 

geotechnical assessments would be required by the Commission prior to the start of drilling operations

(see section 4.1.1.2). If any of the proposed HDD or Direct Pipe crossings are found to be infeasible, 
Project Description 2-24

Constitution would be required to submit specific proposed alternate construction methods for review and 

approval by the Commission and other applicable agencies. 

The Direct Pipe procedure is another trenchless construction method that is similar to HDD, but is

also combined with processes related to microtunnelling. A single, continuous process allows the 

trenchless installation of pre-fabricated pipeline simultaneously with development of the bore hole. A 

Direct Pipe installation is different from an HDD because a much larger initial cutterhead is used, 

eliminating the reaming process. Excavation and hole boring is performed with a navigable 

microtunnelling machine and cutterhead. Temporary flushing pipes located inside the pipeline are used to

transport the drilling fluids to the cutterhead and earthen cuttings to the surface. The pressure used to 

advance the boring process and simultaneously install the pipeline is applied directly to the pipeline by a 

piece of equipment called a “pipe thruster.” The force applied on the pipeline pushes the cutting head 

forward. Reliable installation and monitoring methods ensure accurate measurement of the pipe’s 

location along the intended pathway. 

Direct pipe installations may be shorter and more shallow than HDD installations because the 

bore hole is continuously cased, thereby limiting the risk of hole collapse and the inadvertent release of 

drilling fluids. The Direct Pipe technology for a 30-inch-diameter pipeline is currently limited to 

crossings of roughly 900 feet in length or shorter. Subsurface geology (including boulders) may affect 

the successful use of this method.

2.3.2.3 Drag-Section and Stove-Pipe Specialized Construction Methods

The drag-section and stove-pipe methods could be used to reduce the amount of workspace and 

the duration of construction activity in the immediate vicinity of residences and other areas where 

workspace may be limited. The drag-section method first involves excavating a trench long enough to 

accommodate several pipe sections. Then, a section of pipe fabricated at either end of the trench is

carried along the travel lane, lowered into the ditch, and welded into place. Immediately after, the trench 

is backfilled. At any given time with this method, the excavation of the trench is limited to length of the 

prefabricated pipe segment being installed. The steps for the stove pipe method are similar except that 

only one pipe section would be installed at a time (typically 40 feet). 

2.3.2.4 Typical Road and Railroad Construction Methods

The pipeline project would cross numerous public or private roads and railroads. Two of the 

railroads that would be crossed are active and two are inactive, although one inactive railroad is used as a 

trail. These roads and railroads are listed in appendices F-1 and F-2, respectively, along with the 

proposed crossing method. Roads would either be conventionally bored, open cut, or crossed by HDD or 

Direct Pipe. All railroads would be conventionally bored. A description of the conventional boring, 

HDD, and Direct Pipe construction techniques is provided above. Open-cut road crossing methods are 

described below. The use of conventional boring, HDD, and Direct Pipe methods would avoid road and 

rail surface impacts, but the use of the open-cut crossing method would not. Road crossing permits would 

be obtained from applicable federal, state, and local agencies. These permits would dictate the specific 

requirements for the day-to-day construction activities and methods at each crossing. 

Open-Cut Road Crossing Method

Where paved, road crossings are open-cut, the pavement over the trench would be cut and 

removed. This would be followed by the excavation of the trench and installation of the pipeline. 

Trenching would typically be accomplished using a backhoe or trackhoe augmented by hand-shoveling 

where necessary to expose and protect existing utilities. Any existing utilities that are exposed during the 
2-25 Project Description

excavation would be supported at their existing elevations. This support would be maintained throughout 

the crossing operation until the backfilling is completed. If the roadway surface is paved, the pavement 

would be restored in accordance with the road crossing permit requirements. Gravel surfaces would also 

be repaired to as good or better conditions following restoration.

Constitution would use appropriate measures to ensure that road construction activities do not 

prevent passage by emergency and other vehicles. Measures could include the use of temporary travel 

lanes during construction or the installation of steel plate bridges over the work area to allow traffic flow 

during open trenching. Traffic flow and access to homes would be maintained, except for the temporary 

periods when road blockage is unavoidable due to actual pipeline installation. In circumstances where 

traffic volumes are high or congested, Constitution would use a police presence to direct traffic and 

ensure public safety. 

2.3.2.5 Residential Areas

The proposed pipeline route crosses numerous residential properties and would pass within 50 

feet of at least six identified homes. Residential structures within 50 feet of construction work areas are 

discussed in more detail in section 4.8.3.1; Constitution has developed site-specific residential 

construction plans for these homes. Special care would be taken when residential areas are adjacent to 

construction activities to minimize neighborhood and traffic disruption and to control noise and dust to

the extent practicable.

In general, Constitution indicated that when working near or adjacent to residential areas, it 

would:

• maintain at least a 25-feet-wide buffer from any residence and the construction work 

area, where feasible;

• notify local residents at least 7 days in advance of construction activities;

• maintain access to homes, except for short periods necessary for installing the pipeline;

• install safety fencing along the work areas for at least 100 feet on both sides of a 

residence and install additional fencing along the work boundary;

• preserve trees and landscaping, where possible;

• preserve and replace topsoil in lawns;

• restore affected structures such as fences, mailboxes, and gates;

• ensure pipe is welded and installed as quickly as reasonably possible consistent with 

prudent pipeline construction practices to minimize construction time affecting a home or 

neighborhood; and

• backfill the trench within 10 days and complete final cleanup within 10 additional days, 

weather permitting.

2.3.2.6 Winter Construction

Constitution has proposed to place its project into service in March 2015, and would seek 

approval to begin construction as soon as all necessary federal approvals can be obtained. This schedule 

may involve construction during the winter of 2014/2015. Therefore, Constitution developed a Winter 

Construction Plan to address specialized methods and procedures that would be used to protect resources 

during the winter season. The key elements of the Winter Construction Plan include:
Project Description 2-26

• use of special snow plowing equipment that would prevent mixing of snow and 

underlying soil;

• storage of snow over the trenchline prior to excavation to prevent deep frost penetration 

of the soil;

• clearing of snow from roads without blocking driveways or other access points;

• coordination with individual landowners on a site-specific basis if snow storage adjacent 

to the construction right-of-way is desired; 

• minimization of the amount of open trench and use of safety fencing where snow may 

cover an open trench; 

• suspension of backfill and topsoil replacement if unfeasible due to frozen conditions;

• use of mulch and erosion control devices to stabilize topsoil and subsoil piles; and

• delaying final cleanup activities until soils have thawed.

We have reviewed the Winter Construction Plan and have found its mitigating measures 

acceptable. 

2.3.2.7 State-owned Lands

Constitution is proposing to cross two state-owned lands in New York: the Clapper Hollow State 

Forest in Schoharie County, and the Melondy Hill State Forest in Chenango County. The proposed routes 

across these two state forests have been modified by Constitution in consultation with the NYSDEC in 

order to minimize potential impacts. Constitution has developed site-specific crossing plans that we find 

acceptable. These crossings are discussed further in section 4.8.4.1

2.3.2.8 Agricultural Lands

The proposed pipeline crosses numerous agricultural lands including row crops, specialty crops, 

pastures, and organic farms. These resources are discussed in detail in section 4.8. Measures that would 

be used by Constitution to prevent or minimize impacts on agricultural lands would include: 

• preservation, segregation, and replacement of topsoil across the full construction right-ofway;

• removal of rock (4 inches in size or larger) to a depth of 12 inches or to the subsoil 

horizon;

• repair or replacement of drain tiles or irrigation systems damaged during construction; 

and

• initiation of a crop-monitoring program to assess the yields of restored areas postconstruction. 

In addition to the other plans already discussed in this section, Constitution has developed or 

adopted three other specialized plans to further prevent or minimize potential impacts. These plans 

include: Special Crop Productivity Monitoring Procedures (provided by the NYSDAM and adopted by 

Constitution); Seeding, Fertilizing, and Lime Recommendations for Gas Pipeline Right-of-way 

Restoration in Farmlands (also provided by the NYSDAM and adopted by Constitution); and an Organic 

Farm Protection Plan. 
2-27 Project Description

2.3.2.9 Rugged Topography

Rugged topography, such as steep, vertical slopes and steep side slopes (i.e., slopes running 

parallel to the proposed route), is present in numerous areas along the proposed pipeline route. These 

areas are listed in appendix G. In the steepest areas, Constitution would employ a technique called 

“winching” that involves placing heavy equipment at the top of the slope to serve as an anchor point, and 

then connecting one or more additional pieces of equipment together with a cable. This provides stability 

and safety to the equipment operators as work proceeds up and down the steep slope. 

Another construction method used in areas with steep side slopes is called the “two-tone” cut and 

fill method. Typically, the up-slope side of the construction right-of-way is cut during grading, and the 

soil excavated from the cut is then be used to fill the down-slope edge of the construction right-of-way to 

provide a safe and level working surface for heavy equipment. Pipeline construction then occurs on the 

level surface as it would in typical construction. Then, during restoration, the spoil material are placed 

back into the cut and compacted to match the original topography and contours. Constitution would 

require extra workspace in these areas for storage of excavated material from the temporary cut and fill 

areas, as well as for temporary storage of material such as trench spoil, excess rock, and felled timber. 

Subsurface springs or seeps encountered during excavation activities would be directed down-slope 

through drainage pipes or French drains. 

Right-of-way restoration in rugged areas, including restoration of pre-construction contours, 

would begin within 10 days of pipeline installation to minimize potential erosion issues. Permanent 

trench breakers would be installed in the trench surrounding the pipeline in areas of steep slopes with high 

erosion potential and to prevent the high velocity channeling of water along the trench line. Constitution 

indicated that cement sacks would not be utilized to construct trench breakers. Seeding and mulching 

would be performed in these areas to promote revegetation and slope stability. 

2.3.3 Aboveground Facility Construction Procedures

Both Constitution and Iroquois have proposed aboveground facilities for their proposed projects 

(see table 2.1.2-1 above). Constitution’s facilities include two new M&R stations, two side taps, a pig 

launcher, a pig receiver, MLVs, and assorted ancillary facilities at various points along the proposed 

route. Construction activities associated with these facilities would include installation of erosion 

controls, clearing, grading, installation of concrete foundations, construction of metal buildings 

appurtenances, fencing, pressure testing, and restoration grading and landscaping. Initial work at the 

M&R stations would focus on preparing the sites for equipment staging, fabrication, and construction. 

Foundation holes and pipe trenches would be excavated with standard construction earthmoving 

equipment, unless blasting is required. Following foundation work, station equipment and structures 

would be brought to the site and installed, using any necessary trailers or cranes for delivery and 

installation. Following installation of the facilities, associated equipment, piping, and electrical systems 

would be installed, and the sites would be graveled, as necessary, and fenced. Necessary equipment 

testing and start-up activities would occur on a concurrent basis.

The construction methods associated with Iroquois’ expansion of the Wright Compressor Station 

would proceed in a manner similar to that described immediately above, but in a single location at the 

terminus of the pipeline project and on a larger scale. Iroquois’ proposed facilities include a new 

compressor building, cooling facility, additional piping, and other ancillary facilities. The compressor 

building would be approximately 80 feet wide by 100 feet long. The roof would peak at 58 feet tall, 

although the exhaust stack would reach a height of 63 feet. A steel frame would be covered with siding, 

although the exterior design has not yet been completed. The cooling facility would be approximately 40

feet long by 25 feet wide. Telephone service would be extended over from the existing connections 
Project Description 2-28

within the Wright Compressor Station, and expanded electrical service would be required. Prior to 

placement into service, Iroquois’ new facilities would be tested and operated on a trial basis. 

2.4 CONSTRUCTION SCHEDULE 

Both Constitution and Iroquois have proposed in-service dates of March 2015. The Applicants 

would seek to begin construction of their projects as soon as possible following the receipt of all 

necessary federal authorizations. Constitution would first commence clearing activities at special status 

streams, access roads, trenchless construction workspaces, and M&R stations and subsequently clear 

vegetation at remaining areas along the mainline pipeline right-of-way.

2.5 ENVIRONMENTAL COMPLIANCE INSPECTION AND MITIGATION MONITORING

2.5.1 Coordination and Training

Constitution and Iroquois would incorporate the mitigation measures identified in their permit 

applications as well as additional requirements of federal, state, and local agencies into their construction 

drawings and specifications. Constitution and Iroquois would also provide copies of applicable 

environmental permits and construction drawings and specifications to their construction contractors. 

Constitution and Iroquois would develop an environmental training program tailored to the 

proposed projects and their requirements. The program would be designed to ensure that:

• qualified environmental training personnel provide thorough and focused training 

sessions regarding the environmental requirements applicable to the trainees’ activities;

• all individuals receive environmental training before they begin work on any construction 

workspaces;

• adequate training records are kept; and

• refresher training is provided as needed to maintain high awareness of environmental 

requirements. 

Constitution and Iroquois would also conduct training for construction personnel regarding 

proper field implementation of the ECPs and other project-specific plans and mitigation measures. 

2.5.2 Environmental Inspection

Constitution and Iroquois would be represented on each construction spread5 or work area by a 

Resident Engineer/Chief Inspector, who would have overall authority on the construction spread for 

quality assurance and compliance with mitigation measures, other applicable regulatory requirements, and 

company specifications. One or more Environmental Inspectors (EI) would be employed per spread by 

Constitution and Iroquois during active construction and restoration. The EIs would be on-site during 

active construction and would have peer status with all other activity inspectors. The EI would have 

authority to stop construction activities that violate the measures set forth in the documents and permit 

authorizations for both projects, as well as authority to order corrective actions. At a minimum, the EI 

would be responsible for:

 5 A spread is an individual segment of the overall project staffed by its own labor and equipment. The project 

would consist of 5 spreads.
2-29 Project Description

• ensuring compliance with the measures set forth in the ECPs (for the pipeline project) 

and all other environmental permits and approvals, as well as environmental requirements 

in landowner agreements;

• identifying, documenting, and overseeing corrective actions as necessary to bring an 

activity back into compliance;

• verifying that the limits of authorized construction work areas and locations of access 

roads are properly marked before clearing;

• verifying the location of signs and highly visible flagging marking the boundaries of 

sensitive resource areas, waterbodies, wetlands, or areas with special requirements along 

the construction work area;

• identifying erosion/sediment control and stabilization needs in all areas;

• locating dewatering structures and slope breakers to ensure they would not direct water 

into sensitive areas such as known cultural resource sites or sensitive species habitat;

• verifying that trench dewatering activities do not result in the deposition of sand, silt, 

and/or sediment near the point of discharge in a wetland or waterbody. If such deposition 

is occurring, the EI would stop the dewatering activity and take corrective action to 

prevent a reoccurrence;

• advising the Resident Engineer/Chief Inspector when conditions (such as wet weather) 

make it advisable to restrict construction activities to avoid excessive rutting;

• approving imported soils and verifying that the soil is certified free of noxious weeds and 

soil pests, unless otherwise specified by the landowner;

• determining the need for and ensuring that erosion controls are properly installed, as 

necessary, to prevent sediment flow into wetlands, waterbodies, sensitive areas, and onto 

roads;

• inspecting and ensuring the maintenance of temporary erosion control measures at least 

daily in areas of active construction or equipment operation, on a weekly basis in areas 

with no construction or equipment operation; and within 24 hours of each 0.5 inch or 

greater of rainfall in Pennsylvania, with slightly more stringent inspection requirements 

in New York6

;

• ensuring restoration of contours and topsoil;

• ensuring the repair of all ineffective temporary erosion control measures as soon as 

possible but not longer than 24 hours after identification; 

• ensuring that the Applicants’ contractors implement and comply with their spill 

prevention and mitigation plans;

• keeping records of compliance with conditions of all environmental permits and 

approvals during active construction and restoration; and

• identifying areas that should be given special attention to ensure stabilization and 

restoration after the construction phase.

 6 Twice per week inspections in areas with no active construction and greater than 5 acres in size and the 

initiation of inspections once rain events reach the 0.5-inch threshold, whether or not the rain event is 

continuing (as per NYSDEC requirements).
Project Description 2-30

2.5.3 FERC Third-Party Compliance Monitoring

Constitution has committed to funding a FERC third-party compliance monitoring program 

during the construction phase of the pipeline project. Under this program, a contractor, is selected by, 

managed by, and reports solely to the FERC staff to provide environmental compliance monitoring 

services. The FERC Third-party Compliance Monitor would provide daily reports to the FERC on 

compliance issues and make recommendations to the FERC Project Manager on how to deal with 

compliance issues and construction changes, should they arise. In addition to this program, FERC staff 

would also conduct periodic compliance inspections during all phases of construction.

2.5.4 Post-Approval Variance Process

The pipeline alignment and work areas identified in this draft EIS should be sufficient for 

construction and operation (including maintenance) of the projects. However, minor route realignments 

and other workspace refinements sometimes continue past the project planning phase and into the 

construction phase. These changes could involve minor route realignments, shifting or adding new extra 

workspaces or staging areas, adding additional access roads, or modifications to construction 

methods. We have developed a procedure for assessing impacts on those areas that have not been 

evaluated in this draft EIS and for approving or denying their use following any Certificate issuance. In 

general, biological and cultural resources surveys were conducted using a survey corridor larger than that 

necessary to construct the facilities. Where survey approvals were denied, constitution would complete 

the required surveys following a Certificate issuance. If Constitution or Iroquois request to shift an 

existing workspace or require a new extra workspace subsequent to issuance of a Certificate, these areas 

would typically be within the previously surveyed area. Such requests would be reviewed using a 

variance request process.

A variance request for route realignments or extra workspace locations along with a copy of the 

survey results would be documented and forwarded to the FERC in the form of a “variance request” in 

compliance with recommended condition number 5 in section 5.2 of this EIS. The FERC would take the 

lead on reviewing the request. Typically, no further resource agency consultation would be required if the 

requested change is within previously surveyed areas and no sensitive environmental resources are 

affected. The procedures used for assessing impacts on work areas outside the survey corridor and for 

approving their use are similar to those described above, except that additional surveys, analyses, and 

resource agency consultations would be performed to assess the extent of any impacts on biological, 

cultural, and other sensitive resources and identify any avoidance or minimization measures 

necessary. All variance requests for Constitution’s project and their approval status would be 

documented according to the FERC’s compliance monitoring program as described above. Any variance 

activity by either Applicant (whether submitted through the third party compliance monitoring program or 

directly to FERC) and subsequent FERC action would be available on the FERC’s e-library webpage

under the docket number for the respective project (CP13-499 or CP13-502). 

After Constitution and Iroquois complete any additional surveys, landowner consultation, 

analyses, and/or resource agency consultations, the new work area and supporting documentation 

(including a statement of landowner approval) would be forwarded to the FERC in the form of a variance 

request, which would be evaluated in the manner described above for approval or denial.

2.5.5 Post-Construction Monitoring

After construction, Constitution and Iroquois would conduct follow-up inspections of all 

disturbed upland areas after the first and second growing seasons to determine the success of restoration. 

Restoration of upland areas would be considered successful if the right-of-way vegetation is visually 
2-31 Project Description

successful in density and cover, surface conditions are similar to adjacent undisturbed lands, construction 

debris is removed, and proper drainage has been restored. For at least 2 years following construction, 

Constitution and Iroquois would submit quarterly reports to the FERC that document any problems 

identified by Constitution, Iroquois, or landowners and describe the corrective actions taken to remedy 

those problems. Constitution would perform monitoring for invasive plant species on at least an annual 

basis for 3 years following construction. The monitoring period for invasive species would be extended 

as needed or as required by permits or regulatory agencies. 

In accordance with its ECPs, Constitution would monitor the success of wetland revegetation 

annually for the first 3 years (or as required by permit) after construction or until wetland revegetation is 

successful. Wetland revegetation would be considered successful when the cover of herbaceous and/or 

woody species is at least 80 percent of the type, density, and distribution of the vegetation in adjacent 

undisturbed wetland areas or as compared to documented, pre-project conditions. In accordance with its

Procedures, if revegetation is not successful at the end of 3 years, Constitution would develop and 

implement (in consultation with a professional wetland ecologist) a plan to actively revegetate the 

wetland with native wetland herbaceous and woody plant species. 

After construction, the FERC, cooperating agencies, and/or other agencies would continue to 

conduct oversight inspection and monitoring to assess the success of restoration. If it is determined that 

the success of any of the restoration activities are not adequate at the end of the respective timeframes, 

Constitution and Iroquois would be required to extend their post-construction monitoring programs.

2.6 OPERATION, MAINTENANCE, AND SAFETY CONTROLS

Constitution and Iroquois would operate and maintain the proposed pipeline and/or aboveground 

facilities in compliance with the DOT’s regulations provided in 49 CFR 192, the Commission’s guidance 

at 18 CFR 380.15, and the maintenance provisions of their Plan and Procedures. Constitution and 

Iroquois would operate and maintain the newly constructed pipeline facilities in the same manner as they 

currently operate and maintain their existing systems. The pipeline right-of-way would be patrolled by 

either aerial flyovers or ground surveys on a schedule as described in table 2.6-1, although additional 

ground surveys would be conducted as necessary.

TABLE 2.6-1

Maximum Scheduled Intervals Between Patrols for the Proposed Constitution Pipeline Project

Class Location of Linea At All Highway and Railroad Crossings 

(inspection interval)

At All Other Locations (inspection 

interval)

1 and 2 No longer than every 7.5 months, and at least 

twice each calendar year.

No longer than every 15 months, and at 

least once each calendar year.

3 No longer than every 4.5 months, and at least 

four times each calendar year.

No longer than every 7.5 months, and at 

least twice each calendar year.

4 No longer than every 4.5 months, and at least 

four times each calendar year.

No longer than every 4.5 months, and at 

least four times each calendar year.

_____________________

a As defined by DOT’s Pipeline and Hazardous Materials Safety Administration at 49 CFR 192.5:

Class 1: offshore areas and areas within 220 yards of a pipeline with ≤10 buildings intended for human occupancy.

Class 2: areas within 220 yards of a pipeline with >10 but <46 buildings intended for human occupancy.

Class 3: areas within 220 yards of a pipeline with >46 buildings intended for human occupancy; and areas within 100 

yards of either a building or a small, well defined outside area (such as a playground, recreation area, outdoor 

theater, or other place of public assembly) that is occupied by 20 or more persons on at least five days a week 

for 10 weeks in any 12-month period.

Class 4: areas within 220 yards of a pipeline where buildings with four or more stories are prevalent.
Project Description 2-32

The new pipeline would be patrolled to identify:

• erosion concerns occurring along the right-of-way;

• the performance status of water control devices and stormwater structures;

• the condition of the banks at waterbody and wetland crossings;

• third-party activity along the pipeline right-of-way; 

• the condition/success of vegetation and plantings;

• the presence of invasive plant species; and 

• any other conditions that could threaten the pipeline.

Constitution’s management staff would be notified by its inspectors of any conditions that need 

attention. Corrective measures would be performed as needed. Aboveground facilities such as M&R

stations and MLVs would also be inspected to ensure proper working conditions. The pipeline cathodic 

protection system would also be monitored and inspected periodically to ensure proper and adequate 

corrosion protection.

Maintenance of the proposed pipeline permanent right-of-way in uplands generally would consist 

of mowing once every 3 years. However, Constitution may mow a 10-foot-wide strip centered over the 

pipeline in both upland and wetland areas (with the exception of the HDD segments), along with selective 

cutting and removal of trees greater than 15 feet high located within 15 feet of the pipeline within 

wetlands, to facilitate inspections. All workspaces affected temporarily during construction would be 

stabilized and seeded, and then allowed to eventually revert back to pre-project conditions. 

The pipeline facilities would be clearly marked at line-of-sight intervals and at crossings of roads, 

railroads, and other key points. The markers would indicate the presence of the pipeline and provide a 

telephone number and address where a company representative could be reached in the event of an 

emergency or before any third party excavation in the area of the pipeline. Constitution and Iroquois 

participate in the “Call Before You Dig” and “One Call” programs and other related pre-excavation 

notification organizations.

Iroquois would also inspect and maintain the proposed compressor station facilities, including

calibrating equipment; checking; the odorization system; assessing cathodic protection systems; checking

safety systems; and monitoring pressures, temperature, and vibration data. Iroquois would also mow and 

maintain the landscaping around the compressor station. 

2.7 FUTURE PLANS AND ABANDONMENT

Constitution and Iroquois have not identified or proposed any plans for future expansion of their 

systems or abandonment of any of the projects’ facilities. We have received comments from the public 

concerning the possible future expansion of Constitution’s project to transport additional and newly 

developed supplies of natural gas. Such an expansion, if proposed, would require a new, separate NEPA 

review by the FERC and additional permitting by other local, state, and federal agencies. 

In response to an information request from the FERC, Constitution indicated if its pipeline inlet 

pressures were to be increased to Constitution’s maximum operating pressure of 1,440 psig, then the 

maximum volume that the pipeline would be able to transport would be 850,000 Dth/d, assuming there 

were no other constraints at the delivery point. This scenario would possibly allow Constitution to deliver 
2-33 Project Description

an additional 200,000 Dth/d of natural gas beyond the level currently proposed. However, Constitution 

would need additional FERC authorization to increase any volumes above the proposed 650,000 Dth/d.