20160616-0028 FERC PDF (Unofficial) 06/16/2016

dec Orate UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION 2
290 BROADWAY FILED
SECRE 0/',RY Or" THE
NEW YORK, NY 10007-1866 r'

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JUN- 6 2016 t'Erc ", r

Kimberly D. Bose, Secretary

Federal Energy Regulatory Commission
2 oR]G(age
888 First Street, NE, Room IA
Washington, DC 20426

RE: CP16-17-000, Valley Lateral Project Environmental Assessment

Dear Secretary Bose:

The Environmental Protection Agency (EPA) has reviewed the information presented in the
Federal Energy Regulatory Commission's (FERC) May 2016 environmental assessment (EA) for
the Millennium Pipeline Company, L.L.C.'s Valley Lateral Project. The Valley Lateral Project
would consist of 7.9 miles of new, 16 inch-diameter natural gas pipeline extending from
Millennium's existing mainline to the CPV Valley Energy Center in Orange County, New York;
a tap valve with associated piping and pig launcher facility; a pig receiver; and a new delivery
meter station and associated piping. The purpose of the facility is to provide 130,000
dekatherms per day of firm natural gas to the CPV Valley Energy Center now being constructed.

EPA has several comments on the EA as follows:

Purpose and Need: While the purpose of the pipeline is to provide CPV Valley Energy Center
with a supply of natural gas, the EA does not state whether the pipeline is now fully subscribed
and/or at capacity. The document should discuss whether the pipeline has a higher capacity (i.e.,
is able to provide greater than 130,000 dekatherms per day), and may be used for other shippers.
EPA also requests that the document more fully discuss the proposed interconnect to the Valley
Lateral by the proposed Eastern Systems Upgrade project. It should be stated clearly whether this
interconnect would be providing more natural gas to the Valley Lateral, and whether the Eastern
Systems Upgrade requires this interconnect to function.

Water Quality: Section 1.1 of the EA states, "blasting could be necessary along the western
portions of the project that are located atop the Austin Glen Formation..." According to
Resource Report 6 Table 6A-3, the bedrock in this area is between 0-19 inches deep, and is
primarily greywacke, a hard mineral, which is very likely to necessitate blasting. As this area is
adjacent to Rutgers Creek, the EA should discuss the possible impacts to water quality of the
creek and/or other water supplies from blasting.

Internet Address (UR L) ~ httpg/www.spa.gnv

Roc/cled/necycletde ~ printed with Vegetable Oll Baaed Inks on Roc/orna paper (Mlnlmum 50% poatconeumer contend
20160616-0028 FERC PDF (Unofficial) 06/16/2016

Greenhouse Gases: Page 110: The EA states, "Emissions of GHGs from the proposed Project
and other regional projects would not have any direct impacts on the environment in the Project
area. Currently, there is no standard methodology to determine how a project's relatively small
incremental contribution to GHGs would translate into physical effects on the global
environment." We recommend deleting this statement in future NEPA documents, and using
estimated direct and indirect GHG emissions levels as a general proxy to compare emissions
levels from the proposal, alternatives, and potential mitigation. Climate change is a global
problem resulting from the emissions of many individual sources whose impacts are global.
Additionally, all project-level proposals could be viewed to have a relatively small incremental
contribution when compared to global GHG concentrations. These comparisons of project-level
emissions to aggregated total emissions for geographic areas obscure rather than illuminate
consideration of GHG emissions under NEPA.

While the EA does provide a quantitative analysis of greenhouse gases (GHG), the document
does not describe any measures to reduce GHG emissions associated with the project, including
reasonable alternatives or other practicable mitigation opportunities, nor disclose the estimated
GHG reductions associated with such measures.

Vegetation: While Table B-7 summarizes the impacts to forests, neither the Table, nor the EA
identify the quantitative impacts to forest interiors, which are of importance to endangered bats,
many of our migratory birds and are more susceptible to invasive species. This information
should also be included in the cumulative impacts section of the EA.

EPA is also concerned with Millennium's revegetation success measure. By using a criteria such
as "similar in density and cover to adjacent undisturbed lands," Millennium is not taking into
account that many areas are already compromised by invasive species, and should not be used as
a baseline for functional ecosystems. Any easements, especially those in forested area should be
cleared of invasive species during yearly maintenance efforts.

Alternative pipeline routes: EPA is concerned that reasonable alternatives, have not been
evaluated appropriately.

~ The Orange and Rockland (OR) alternative appears to be dismissed by FERC, due in part
to the statement by Millennium that the OR pipeline system would require additional
capacity. It may be prudent to have that statement verified by OR. Table C-I does show
that the OR alternative has fewer environmental impacts to wetlands, forested wetlands,
forest and waterbodies. EPA would disagree with the finding that this route does not offer
an environmental advantage over the Valley Lateral unless there were a more detailed
analysis presented.
~ EPA also questions the dismissal of CPV Alternative 2 which would collocate the Valley
Lateral along existing roadway rights-of-way. While Table C-2 shows that Alternative 2
will cross one more wetland, and a longer length of wetland than the proposed
alternative, other environmental impacts to forested wetlands, and forests are diminished.
If HDD techniques are used, the wetlands impacts might also decrease. Alternative 2
should be evaluated further.
20160616-0028 FERC PDF (Unofficial) 06/16/2016

Thank you for the opportunity to comment on the environmental assessment. If you have any
questions, please call Lingard Knutson of my staff at (212) 637-3747.

Sincerely,

Grace Mus eci, Chief

Environmental Review Section
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