VALLEY LATERAL PROJECT

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1 VALLEY LATERAL PROJECT DRAFT RESOURCE REPORT 10 Alternatives FERC Docket No. PF June 2015

2 Section TABLE OF CONTENTS Page 10.0 RESOURCE REPORT 10 ALTERNATIVES INTRODUCTION PURPOSE AND NEED NO ACTION ALTERNATIVE Energy Alternatives Energy Conservation Other Energy Sources SYSTEM ALTERNATIVES ROUTE ALTERNATIVES CPV Potential Routing Options Millennium Route Alternatives ROUTE VARIATIONS ABOVEGROUND FACILITIES REFERENCES LIST OF TABLES TABLE Basis for Adoption or Rejection of Route Alternatives for the Valley Lateral Project TABLE Comparison of Alternate Route A with the Proposed Valley Lateral LIST OF APPENDICES APPENDIX 10A Figures Figure Valley Lateral Project System Alternatives Figure Valley Lateral Project Alternative Route Draft Resource Report 10 - Alternatives i Valley Lateral Project

3 RESOURCE REPORT 10 --ALTERNATIVES Filing Requirement Discuss the no action alternative and the potential for accomplishing the proposed objectives through the use of other systems and/or energy conservation. Provide an analysis of the relative environmental benefits and costs for each alternative. ( (l) (1)) Describe alternative routes or locations considered for each facility during the initial screening for the project. ( (l) (2)) (i) For alternative routes considered in the initial screening for the project but eliminated, describe the environmental characteristics of each route or site, and the reasons for rejecting it. Identify the location of such alternatives on maps of sufficient scale to depict their location and relationship to the proposed action, and the relationship of the pipeline to existing rights-ofway. (ii) For alternative routes or locations considered for more in- depth consideration, describe the environmental characteristics of each route or site and the reasons for rejecting it. Provide comparative tables showing the differences in environmental characteristics for the alternative and proposed action. The location of any alternatives in this paragraph shall be provided on maps equivalent to those required in paragraph (c)(2) of this section. Location in Environmental Report Sections 10.2 and 10.3 Sections 10.5, 10.6, and 10.7 Draft Resource Report 10 - Alternatives ii Valley Lateral Project

4 ACRONYMS AND ABBREVIATIONS CPV Dth/d EIA FERC or Commission GIS MW Millennium MP NGA NWI NYISO NYSDEC Orange and Rockland Project CPV Valley, LLC Dekatherms per day Energy Information Administration Federal Energy Regulatory Commission geographical information system Megawatt Millennium Pipeline Company, L.L.C. milepost Natural Gas Act National Wetlands Inventory New York Independent System Operator New York Department of Environmental Conservation Orange and Rockland Utilities, Inc. Valley Lateral Project Draft Resource Report 10 - Alternatives iii Valley Lateral Project

5 10.0 RESOURCE REPORT 10 ALTERNATIVES 10.1 INTRODUCTION Millennium Pipeline Company, L.L.C. (Millennium) is seeking authorization from the Federal Energy Regulatory Commission (FERC or Commission) pursuant to Section 7(c) of the Natural Gas Act 1 (NGA) to construct, install, own, operate, and maintain the Valley Lateral Project (Project). The Project will provide firm natural gas delivery to the new 650 megawatt gas-powered CPV Valley Energy Center proposed by CPV Valley, L.L.C. (CPV) in the town of Wawayanda, New York. The Project, as proposed, includes approximately 7.8 miles of new natural gas pipeline that will extend from Millennium s existing main line pipeline north to the CPV Valley Energy Center as well as ancillary aboveground facilities. The target in-service date for the Project is April The Project consists of the following components and facilities: Approximately 7.8 miles of new pipeline in Orange County, New York; One delivery meter station at the proposed CPV Valley Energy Center, approximate milepost (MP) 7.8; One launcher facility (MP 0.0); and One receiver facility within the proposed delivery meter station at the proposed CPV Valley Energy Center (MP 7.8). As part of the development process for the Project, Millennium evaluated pipeline routing and aboveground facility siting options based on regional topography, potential adverse environmental effects, population density, existing land use, and construction safety and feasibility considerations. Millennium has endeavored to locate the pipeline within or adjacent to, existing utility corridors where practicable, feasible, and in compliance with existing regulatory requirements. Millennium considered route and site alternatives, respectively, in conjunction with the Commission s guidelines, as set forth in 18 Code of Federal Regulations Section This resource report discusses the alternatives considered during the development of the Project including the no-action alternative (Section 10.3), system alternatives (Section 10.4), and site alternatives (Sections 10.5 through 10.7) PURPOSE AND NEED The Project will create firm lateral capacity capable of delivering approximately 130,000 dekatherms per day of natural gas as fuel to the proposed CPV Valley Energy Center to be located in Orange County, New York. Millennium and CPV have entered into a precedent agreement regarding the development of the Project, which provides that Millennium and CPV will enter into a firm transportation service agreement for service on the lateral for a primary term of 15 years. In accordance with the precedent agreement, service on the lateral is anticipated to commence in April 2017 to facilitate the commissioning process of the CPV Valley Energy Center. According to CPV 2, the CPV Valley Energy Center will be a new 650 MW combined-cycle, natural gasfired electric power generating facility constructed to help meet the region s growing energy demands. The energy center will use the most advanced and environmentally-conscious power generation technology 1 15 U.S.C. 717f(c) (2012). 2 See, Draft Resource Report 10 - Alternatives 10-1 Valley Lateral Project

6 available, making it one of New York s cleanest natural gas energy facilities. The CPV Valley Energy Center will generate enough electricity to power more than 650,000 homes in the region when operational. Additionally, this new generation facility will help to lower electricity costs, which could save New York ratepayers more than $400 million a year in reduced electricity costs. The plant will reduce greenhouse gas emissions by nearly half a million tons a year due to the high efficiency of combined-cycle generation and the displacement of older, less-efficient units. In addition, the CPV Valley Energy Center is expected to create construction jobs during CPV s construction, as well as 25 permanent jobs at the facility. The CPV Valley Energy Center project would generate more than $1 billion in economic benefit to the local economy. During its first two decades of operation, the CPV Valley Energy Center project is estimated to provide in excess of $47 million in additional revenue that can be used to help reduce tax burdens, provide funding for infrastructure maintenance, and support local recreational and civic programs. The CPV Valley Energy Center will help address the electric reliability needs of downstate New York. The New York Independent System Operator s (NYISO) established, and the Commission approved, a new capacity zone and related demand curve to address a transmission constraint that limits the deliverability of electric power into the Lower Hudson Valley. Specifically, the NYISO determined that the Upstate New York/Southeast New York Highway interface into the Lower Hudson Valley was constrained because it was bottling MW of generation from areas upstate of the Lower Hudson Valley. 3 Accordingly, the NYISO created the Lower Hudson Valley zone to provide more accurate price signals and encourage the addition of generation and transmission resources to enhance the reliability within the new capacity zone. 4 The CPV Valley Energy Center site is located within this new zone NO ACTION ALTERNATIVE Under the no-action alternative, the Project would not be constructed, and all direct environmental impacts associated with construction and operation of the Project would be eliminated. However, by not constructing the Project, the CPV Valley Energy Center would be required to identify an alternative source of natural gas to service the facility or convert its planned natural gas based energy producing facilities to use alternative energy sources such as coal. The use of alternative energy strategies is impractical, uneconomical, or disadvantageous, and will not satisfy the market needs of CPV s customers. The Project will provide the natural gas supply necessary to meet existing and future natural gas demands in the market area. Under the no-action alternative, this benefit would not be realized Energy Alternatives Energy Conservation Energy conservation reduces the need for natural gas and other energy sources. The Energy Policy Act of 2005 includes guidelines to diversify America s energy supply and reduce dependence on foreign sources of energy, increase residential and businesses energy efficiency and conservation (e.g., EPA Energy Star Program), improve vehicular energy efficiency, and modernize domestic energy infrastructure (U.S. Congress, 2005). However, the U.S. Energy Information Administration (EIA) indicates that, even with the combination of recently enacted energy efficiency policies and the rise in energy prices, U.S. energy consumption will still grow primarily through increased use of natural gas for electricity generation and 3 N.Y. Indep. Sys. Operator, Inc., 144 FERC 61,126 at P 14 (2013), on reh g, N.Y. Indep. Sys. Operator, Inc., 147 FERC 61,152 (2014). 4 Id. at PP Draft Resource Report 10 - Alternatives 10-2 Valley Lateral Project

7 industrial applications (EIA, 2014). It is possible that the development and implementation of additional conservation measures may have some effect on energy demand; however, the magnitude of energy conservation necessary to equal the capacity of the proposed Project will not be attained in the near-term via current proven methods Other Energy Sources Several alternative energy sources to natural gas currently exist, such as petroleum and coal-based energy, nuclear power, hydropower, and other energy sources, including renewable energy technologies. The purpose of the Project is to supply clean burning natural gas to CPV s proposed natural gas-powered electric generation facility. The only alternative fuel for such plants is coal or oil. Implementation of an alternative energy source would require redesign of CPV s proposed energy center, resulting in schedule delays and increased product costs for consumers. A redesign of the proposed CPV Valley Energy Center would be significantly more time and cost intensive, as a total project overhaul would be required, including an entirely new permitting process as well as a redevelopment of project construction and feasibility analysis. These alternatives were determined not to be technically or economically feasible. Potential impacts and constraints specific to these alternative energy sources are described in the following paragraphs. Coal Although a viable alternative to natural gas for power generation, coal is not as clean-burning as natural gas. Coal emits greater regulated pollutants (e.g., sulfur dioxide and nitrogen dioxide), greenhouse gases (e.g., carbon dioxide), and particulate matter, which require the installation of costly air pollution controls. Coal is associated with significant mine pollution control problems and reclamation issues, as well as storage problems, and costly pollution controls at the burner. Coal consumption in the United States totaled 1,048.3 million short tons for 2009 (EIA, 2011a). This amounts to 21 percent of the total energy used in the United States (EIA, 2011b). Energy generated from the burning of coal is considered a major contributor to acid rain, which continues to be an international ecological and economic problem. Coal also contributes more greenhouse gas emissions than natural gas and petroleum fuels. Further, emissions from coal burning power plants are the primary source of airborne mercury deposition in the United States, accounting for over 50 percent of all domestic human-caused mercury emissions (EPA, 2005). The mining and transportation of coal to end users have additional and more complex adverse environmental impacts. While coal remains a viable option for serving the energy needs of certain customers, it may result in greater environmental impacts than the production and transport of natural gas via transmission pipelines. The relative environmental benefits and efficiency of natural gas make the fuel an attractive alternative to coalfired generation. Compared to the average air emissions from coal-fired power generation, natural gas produces half as much carbon dioxide, less than a third as much nitrogen oxides, and one percent as much sulfur dioxides at the power plant, thereby reducing climate change impacts relative to coal-based sources (EPA, 2007). Therefore, coal does not represent a preferred alternative for replacing the natural gas to be supplied by the proposed Valley Lateral Project. Oil The use of oil for power generation could increase reliance on overseas crude petroleum and petroleum products. Though the construction of an oil transmission pipeline has no advantage over natural gas pipeline transmission in regards to area requirements, oil typically necessitates transportation overseas, requires tank distribution and increases air pollutant emissions when burned. These aspects of oil use create the potential for increased adverse environmental impacts, including the increased risk of oil spills, air quality degradation, and potential impacts associated with land use development required for the construction of new, or expansion of existing, refineries to process the oil. Therefore, oil does not represent a preferred alternative for replacing the natural gas to be supplied by the proposed Valley Lateral Project. Draft Resource Report 10 - Alternatives 10-3 Valley Lateral Project

8 Nuclear Nuclear energy development is an option that may be considered environmentally-viable, especially in terms of limiting air emissions of criteria pollutants. However, this option has drawbacks, specifically negative public perception concerning safety risks and the long-term environmental effects associated with the disposal of radioactive waste products. As a result, an unfavorable regulatory climate exists, in which the probability of a new nuclear facility coming on-line on a timely basis to serve energy demands is low. Moreover, the time required to design, permit, and construct a nuclear generation facility would be extensive, and would be significantly greater than the amount of time required to design, permit, and construct the Project. Consequently, the nuclear alternative would not be available to meet the short-term energy demands and is, therefore, not a preferred alternative to this Project. Renewable Energy Sources The No-Action Alternative would increase the demand for and use of renewable energies such as solar, hydroelectric, or other energy source (e.g., geothermal, fuel cells, wind). While more of these renewable energy sources are being developed in the U.S., they are not currently available for large-scale application or to the point where they would be viable energy alternatives to support the reliability and purpose of the CPV Valley Energy Center. Therefore, renewable energy systems would not be available to meet the shortterm energy demands achieved by the Project SYSTEM ALTERNATIVES System alternatives are alternatives to the proposed action that make use of other existing, modified, or proposed pipeline systems to meet the stated objectives of the Project. A system alternative may make it unnecessary to construct all or part of the Project, although modifications or additions to the alternative systems may be required to increase their capacity or provide receipt and delivery capability consistent with that of the Project. These modifications or additions could result in environmental impacts that may be less than, comparable to, or greater than those associated with construction of the Project. System alternatives that could result in significantly less environmental impact might be preferable to the Project. However, a viable system alternative must also be technically and economically feasible and practicable, and must also satisfy necessary contractual commitments made with shippers supporting the development of the Project. A viable system alternative to the Project would have to meet the following Project objectives while resulting in fewer environmental effects than the Project: Provide 130,000 Dth/d of firm transportation capacity at approximately 600 psig; Provide a connection to the CPV Valley Energy Center; and, Be operational in time to meet the in-service date of April Any viable system alternative must be compatible with the contractual requirements relating to location and capacity of receipt points, delivery interconnections, and in-service date set forth in these agreements. The distribution system of Orange and Rockland Utilities, Inc. (Orange and Rockland) could be considered as a system alternative. Orange and Rockland s natural gas delivery system consists of approximately 1,800 miles of gas distribution mains and pipes and serves nearly 130,000 customers in New York and Pennsylvania. An Orange and Rockland distribution line connects to the existing Millennium main line pipeline in Minisink, New York and extends northeast along Route 12; however, given that the maximum Draft Resource Report 10 - Alternatives 10-4 Valley Lateral Project

9 allowable operating pressure of this line is only 250 psig, this distribution line is not a viable system alternative to the Project. CPV also considered lateral line alternatives approximately two to three miles in length that would need to be constructed to provide a connection between the CPV Valley Energy Center and other Orange and Rockland distribution facilities (see Appendix A - Figure ). In addition to the need to construct a lateral line to provide a connection to the CPV Valley Energy Center, Orange and Rockland s distribution system would need to be upgraded to meet the pressure and volume requirements for the Project. In addition, CPV determined that the Project was its preferred source of natural gas supply. As such, the Orange and Rockland System Alternative is not a superior alternative ROUTE ALTERNATIVES The preferred alignment for the Project was developed to meet the Project objectives while minimizing environmental and landowner impacts. An alternative route is considered a linear segment of pipeline that does not follow the exact alignment of the preferred route. Sources of existing information, such as field reconnaissance, aerial photography, topographic maps from the United States Geological Survey, National Wetlands Inventory (NWI) maps, and New York State Department of Environmental Conservation (NYSDEC) Freshwater Wetland Maps were used during the route identification and evaluation process CPV Potential Routing Options As described in Section 10.2, the preferred alignment for the Valley Lateral was selected based on an interconnection with the existing Millennium main line pipeline and delivery to the proposed CPV Valley Energy Center location. Millennium began selection of the preferred alignment with four potential routing options initially identified by CPV during review and approval of the CPV Valley Energy Center. A map of these routing options is provided as Figure in Appendix 10A. CPV s potential routing options 1, 2, and 4 start at points along the Millennium pipeline that are a greater distance from the Project terminus (i.e., the proposed CPV Valley Energy Center) than routing option 3. Given the longer length, potential routing options 1, 2, and 4 would impact a greater amount of land (and presumably landowners), and affect a greater number of environmentally sensitive resources and areas, and would increase Project costs. As a result CPV s potential routing options 1, 2, and 4 were not considered economically or environmentally preferable. CPV s potential routing option 3 was identified as the closest point along the Millennium pipeline to the Project terminus, and Millennium identified two routes from that starting point as viable routes for the Project. These alternative routes are discussed in the paragraphs below Millennium Route Alternatives As described above, Millennium identified the closest point along the Millennium main line pipeline to the Project terminus at the CPV Valley Energy Center as the starting point for evaluating viable route alternatives. A map of these route alternatives is provided as Figure in Appendix 10A. A location approximately 0.20 mile southeast of the proposed MP 0.0, at an existing Orange and Rockland meter station site, was also considered as a starting point for the Project. Starting at the existing Orange and Rockland meter station would have crossed a significant wetland area and pond, and would have crossed the existing railroad berm. The proposed starting point is located in an open field and was determined as the preferred location in terms of constructability and to minimize impacts on the identified wetland area. The route alternatives and the reasons for their adoption or rejection are summarized in Table Draft Resource Report 10 - Alternatives 10-5 Valley Lateral Project

10 TABLE Basis for Adoption or Rejection of Route Alternatives for the Valley Lateral Project Description Length (miles) Preferred Route 7.73 Alternate Route A 7.18 Basis for Adoption or Rejection Adopted to minimize landowner impact, avoid existing residences and commercial/industrial buildings, minimize effects on environmentally sensitive areas and improve constructability. Rejected due to a greater number of existing residences and commercial/industrial buildings within 50 feet of the construction workspace, a greater potential to encounter contaminated sediments along the railroad, a greater number of waterbodies crossed, and crossing of public land. Alternate Route A Alternate Route A would be nearly identical to the proposed Valley Lateral route from MP 0.0 to approximate MP 2.0. The alignment then extends north, continuing adjacent to an existing railroad corridor and an existing electric transmission corridor for the majority of its length to Interstate Highway 84. While locating Alternate Route A along the railroad corridor minimizes clearing of new right-of-way, the presence of the existing railroad corridor also presents a greater potential to encounter contaminated soils along the route. Contaminated soils could be present from operation of the railroad itself, or from existing or abandoned industries along the rail corridor. Testing and properly disposing of contaminated soils during construction increases Project costs and could delay the Project schedule. After diverging from the proposed Valley Lateral route, a portion of Alternate Route A runs parallel to Rutgers Creek, a designated trout stream and an old base for the abandoned section of the railroad. Construction along and adjacent to Rutgers Creek in this location would be difficult, potentially causing significant stream impact. Alternate Route A also crosses an entrance to, and an open field area of Shannen Park. Shannen Park is a municipal park designated as a protected area. Construction across the park could temporarily impact park visitors by interrupting access to the park and/or creating visual and noise disturbance during construction. Alternate Route A is also located within 50 feet of a greater number of residences and commercial/industrial buildings, which increases landowner impact and increases construction costs. Alternate Route A crosses and travels along the bank of another stream, Joe s Creek, and has a point of inflection within the creek. The creek crossing and construction along Joe s Creek would be difficult and potentially result in significant wetland and stream impact. Alternate Route A then extends parallel and close to Caitlin Creek. Construction adjacent to Catlin Creek would be difficult, potentially expensive and could result in significant wetland and stream impacts. Alternate Route A would then cross McBride Road, where limited workspace is available due to the presence of the existing railroad and existing facilities on both sides of the route (including a gas station). There is also a rock quarry nearby, an indication that there is a likelihood of encountering rock during construction, which would potentially necessitate blasting. Blasting has the potential to affect nearby residences and businesses from the temporary noise generated during the blast and could involve additional monitoring of water wells if present in the vicinity of the blast. Draft Resource Report 10 - Alternatives 10-6 Valley Lateral Project

11 Based on these factors, Alternate Route A was not considered preferable to the proposed Valley Lateral route. Table presents a comparison of Alternative Route A with the proposed Valley Lateral route. TABLE Comparison of Alternate Route A with the Proposed Valley Lateral Environmental/Engineering Factor Alternate Route A Proposed Valley Lateral Pipeline Length (miles) Length of Adjacent ROW (miles) a/ Length of ROW Adjacent to Active Railroad (miles) b/ Number of Roads Crossed Residences within 50 feet of Construction ROW c/ Commercial/Industrial Buildings within 50 feet of Construction ROW c/ Number of Waterbodies Crossed d/ Public Lands Crossed (number/miles) e/ 1 / / 0 Shallow Depth to Bedrock (miles) f/ a/ Estimated from 2013 aerial photography, and utility and transportation layers. Based on an assumed 50 foot permanent easement centered on the Proposed Valley Lateral and Alternate Route pipelines. b/ New York GIS Railroads c/ Estimated based on an assumed 110-foot wide construction ROW centered on the Proposed Valley Lateral and Alternate Route pipelines. Accessory structures such as sheds not included. d/ Waterbodies were calculated using National Hydrography Data Sets. Waterbodies are a combination of streams, rivers, ponds and lakes. e/ Source: New York GIS Public Lands / Municipal Lands. f/ Areas identified to have shallow depth to bedrock are described as having bedrock less than 5 feet from the surface as determined by NRCS SSURGO. In summary, the proposed Valley Lateral route moves the alignment east, further away from residential and commercial/industrial areas, the rock quarry, the railroad, and Shannen Park. Moving the alignment to the east also results in fewer waterbody crossings and achieves these crossings in a more perpendicular manner, minimizing impacts on stream banks. Draft Resource Report 10 - Alternatives 10-7 Valley Lateral Project

12 10.6 ROUTE VARIATIONS Route variations differ from system alternatives or route alternatives in that they are identified to reduce impacts on specific localized features, are typically shorter in length than route alternatives, generally less than 1,000 feet from the original proposed route, and entail typically localized environmental considerations such as reducing or avoiding impacts on specific features. At this time, no route variations have been identified for the Project. However, Millennium will continue to consider route variations to address concerns raised during FERC s scoping process ABOVEGROUND FACILITIES Project aboveground facilities are limited to one meter station, one launcher facility, and one receiver facility. The meter station and receiver facility will be located at the proposed CPV Valley Energy Center facility at approximately MP 7.8 (see Figure ). The launcher facility will be located at the beginning of the Valley Lateral at the interconnection with Millennium s existing pipeline system. The proposed siting of the new aboveground facilities was governed by the location of Millennium s existing system and by the location of the CPV Valley Energy Center, and minimizes the use of new right-of-way. Because the selected sites for the proposed aboveground facilities present no or minimal environmental impacts, no additional site considerations were necessary REFERENCES United States Energy Information Administration [EIA]. 2011a. U.S. Coal Supply and Demand: 2010 Review. Available online at: Website accessed on June 12, EIA. 2011b. Annual Energy Review Available online at: website accessed June 12, Energy Information Administration (EIA) AEO2014 Early Release Overview. Accessed online at on May 20, Unites States Environmental Protection Agency [EPA] National Emissions Inventory Data & Documentation. Last updated on November Available at: website accessed on June 12, EPA Natural Gas: Electricity from Natural Gas. Last updated December 28, Available at: cleanenergy/energy-and-you/affect/natural-gas.html, website accessed on June 12, United States Congress H.R.6. Energy Policy Act of Accessed online at on May 20, United States Geologic Service [USGS] National Gap Analysis Program (GAP) Protected Areas Data Viewer. Shannen Park. Accessed November 13, Draft Resource Report 10 - Alternatives 10-8 Valley Lateral Project

13 APPENDIX 10A Figure Valley Lateral Project System Alternatives Figure Valley Lateral Project Alternative Route Draft Resource Report 10 - Alternatives Valley Lateral Project

14 CPV Valley Energy Center. O&R System Option 2 MP 7 MP 6 MP 5 MP 3 MP 4 O&R System Option 1 MP 2 MP 1 MP 0 V:\PROJECTS\AUGUSTA\MilleniumCPV\MXD\Figures\Figure10_4_1_SystemAlternatives_8x11P_2015June03.mxd Data sources: ESRI, TRC, and Millennium Pipeline Legend Proposed Route Milepost Proposed Valley Lateral Orange and Rockland System Option 1 Orange and Rockland System Option 2 Existing Millennium Pipeline Existing O&R Distribution Pipeline County Boundary Town Boundary Created: 6/18/2015 K Miles Valley Lateral Project System Alternatives Figure Gabriel Drive Augusta, ME 04330

15 . CPV Valley Energy Center MP 7 Alternate Route A MP 5 MP 6 MP 4 MP 3 MP 2 MP 1 MP 0 V:\PROJECTS\AUGUSTA\MilleniumCPV\MXD\Figures\Figure10_5_1_AlternativeRoutes_8x11P_2015June18.mxd Data sources: ESRI, TRC, and Millennium Pipeline Legend Proposed Route Milepost Proposed Valley Lateral Potential Alternate Route Existing Millennium Pipeline County Boundary Town Boundary Created: 6/18/2015 K Miles Valley Lateral Project Alternative Routes Figure Gabriel Drive Augusta, ME 04330