INFORMATION HAS BEEN REMOVED FROM THIS DOCUMENT FOR PRIVILEGED TREATMENT (18 C.F.R ) December 8, 2014

Transcription

1 INFORMATION HAS BEEN REMOVED FROM THIS DOCUMENT FOR PRIVILEGED TREATMENT (18 C.F.R ) December 8, 2014 Kimberly D. Bose, Secretary Federal Energy Regulatory Commission 888 First Street, NE Room 1A Washington, DC Re: Tennessee Gas Pipeline Company, L.L.C., Docket No. PF Northeast Energy Direct Project Supplemental Filing -- Adoption of Alternative Route as Part of Proposed Route (Wright, New York to Dracut, Massachusetts Pipeline Segment) Dear Ms. Bose: On September 15, 2014, Tennessee Gas Pipeline Company, L.L.C. ( Tennessee ) filed a request to use the Federal Energy Regulatory Commission s ( Commission ) pre-filing procedures for the proposed Northeast Energy Direct Project ( or Project ). By notice issued October 2, 2014, the Commission approved Tennessee s request to use the prefiling procedures for the Project. On November 5, 2014, Tennessee filed drafts of Resource Reports 1 and 10 and an updated stakeholder mailing list for the Project with the Commission. In the November 5, 2014 draft 0, Tennessee presented evaluations of several major route alternatives for portions of the Project. Among the route alternatives discussed in the draft 0 for the Wright, New York to Dracut, Massachusetts Pipeline Segment (referred to as the Market Path Component of the Project) were the New York Powerline Alternative and the New Hampshire Powerline Alternative (see Sections and of draft 0). These identified alternatives involved co-locating the pipeline along an existing electric transmission line corridor in eastern New York, western Massachusetts, and southern New Hampshire. The New York Powerline Alternative deviates from the proposed route in New York at approximately MP of the Wright to Dracut Pipeline Segment in New York. At that point the New York Powerline Alternative travels in a north/northeast direction, eventually turning east/southeast to interconnect with the mainline proposed route at approximately MP in

2 Federal Energy Regulatory Commission December 8, 2014 Page 2 Massachusetts. The New Hampshire Powerline Alternative deviates from the proposed route in Massachusetts at approximately milepost ( MP ) , and travels in a northerly direction into New Hampshire. At that point, the pipeline would be co-located with an existing powerline corridor and will travel in an easterly direction before turning south and re-entering Massachusetts near Dracut, Massachusetts and rejoining the proposed route of the Wright, New York to Dracut, Massachusetts Pipeline Segment at MP In its ongoing effort to critically evaluate feasible alternatives for the Project, Tennessee has now determined that it will adopt both the New York Powerline Alternative and the New Hampshire Powerline Alternative as its proposed route. Therefore, Tennessee will modify the originally proposed route for the Wright, New York to Dracut, Massachusetts Pipeline Segment of the Project. Tennessee is adopting this revised route for the Project at this early date in the pre-filing process to permit transparent stakeholder/public consultation and the development of the additional resource reports reflecting the revised route as part of the Commission s pre-filing process. The revisions reflected in this filing are the product of countless public outreach meetings conducted by Tennessee with stakeholders, as well as the environmental review process itself. This type of significant revision to the proposed Project in order to address numerous concerns with the original proposed route is a text book example of the merits of the Commission s pre-filing and certificate procedures. The Market Path component of the Project that is being revised originally consisted of approximately 177 miles of new and co-located mainline pipeline. With the adoption of the New York Powerline Alternative and the New Hampshire Powerline Alternative, the proposed revised route will now include approximately 188 miles of new and co-located mainline pipeline facilities as follows: (a) approximately 53 miles of pipeline generally co-located with Tennessee s existing 200 Line and an existing power utility corridor in eastern New York near the proposed Market Path Mid Station No. 1; (b) approximately 64 miles of pipeline generally co-located with an existing power utility corridor in western Massachusetts; and (c) approximately 71 miles of pipeline generally co-located with an existing power utility corridor in southern New Hampshire, extending east to the proposed Dracut, Massachusetts Market Path Tail Station. In addition, the Project originally included construction of eight new pipeline laterals (totaling approximately 73 miles), eight new compressor stations, and 16 new meter stations. As revised, the Project will now include nine laterals (totaling approximately 75 miles), nine new compressor stations, and 15 new meter stations. 1 One of primary reasons that led to Tennessee s decision to adopt the New York Powerline Alternative and New Hampshire Powerline Alternative for the Project is that they will enable a very substantial portion of the proposed new pipeline construction to be located adjacent to, and parallel with, existing utility corridors in the states of New York, Massachusetts and New 1 Tennessee s September 15, 2014 pre-filing request letter stated that the Wright, New York to Dracut, Massachusetts Pipeline Segment included approximately 177 miles of new and co-located pipeline facilities: (a) 52 miles of pipeline generally co-located with the existing 200 Line in western New York and Massachusetts; and (b) approximately 125 miles of new pipeline in Massachusetts. That portion of the Project was proposed to include eight new compressor stations and 16 new meter stations.

3 Federal Energy Regulatory Commission December 8, 2014 Page 3 Hampshire. By increasing the percentage of co-location for the proposed pipeline segment, the revised route will reduce the construction of new pipeline facilities in undeveloped portions of the Market Path region, thus reducing environmental impacts and avoiding habitat fragmentation. In addition, the proposed route change will enable Tennessee to avoid (in certain cases) and to minimize (in other cases) the crossing of Article 97 properties and Areas of Critical Environmental Concern in Massachusetts. Through its significant outreach efforts for the Project, Tennessee has been attentive to the public response to the Project. This proposed route modification for the Market Path component of the Project is intended to address comments and concerns expressed by affected stakeholders across various areas of the Project. Additionally, the proposed route modification, which takes advantage of a greater percentage of co-located facilities with existing power utilities, will provide economic service to several areas in northern Massachusetts and southern New Hampshire that are not currently served by an interstate pipeline. The is being developed to serve specifically the New England region. The New England region, as a whole, stands to benefit from the as it will enable New England to sustain its reliance on natural gas-fired generation and to lower energy costs by providing scalable transportation capacity attached to lower cost, near-by domestic natural gas. Access to significant, reliable and abundant quantities of lower priced natural gas will benefit New England consumers and will encourage capital investment in commercial and industrial ventures adding to the region s economy. The Project will provide regional confidence in competitively priced natural gas supplies for decades to come providing stability in a critical fuel source. Tennessee s fully integrated natural gas pipeline transportation system also will enable the Project to provide additional access to diverse supplies of natural gas to expansion customers in the New England region. As demand for natural gas in the region increases, Tennessee s LDC customers have expressed the need for additional firm transportation capacity to serve their growing markets. The proposed revision to the Market Path component of the Project does not result in any change to the proposed total incremental natural gas transportation capacity (up to 2.2 Bcf per day) to be provided by the Project. In this filing, Tennessee submits a revised to reflect the adoption of the New York Powerline Alternative and New Hampshire Powerline Alternative as part of the proposed Project. To assist the Commission and affected stakeholders in their review of the revised, Tennessee is providing clean and redlined versions of the revised report that reflect the revisions to the proposed Project facilities. Tennessee is also providing an updated overall Project map to show the new proposed route of the Project, and revised aerial photographic maps and U.S. Geological Survey topographic mapping for the pipeline route. In addition, Tennessee is submitting updated stakeholder lists (landowner, governmental officials, and regulatory agencies) for the Project. The enclosed stakeholder lists update the information that was provided as part of Tennessee s November 5, 2014 filing for (1) affected landowners (contained in Volume III-Privileged and Confidential Information, Appendix AA), (2) representatives of affected federal, state, and local political jurisdictions (contained in Volume II- Public, Appendix C), and (3) applicable federal and state regulatory agencies (contained in Volume II-Public, Appendix A). All updates to the stakeholder lists are highlighted on the

4 Federal Energy Regulatory Commission December 8, 2014 Page 4 respective attachments. Due to privacy concerns, Tennessee, in accordance with Section of the Commission s regulations, 18 C.F.R (2014), is requesting privileged and confidential treatment of that portion of the updated stakeholder mailing list that includes information regarding affected landowners. Tennessee is also providing clean and redlined versions of the Public Participation Plan in Appendix D. Tennessee notes that its development of the resource reports for the Project is an ongoing process, and that updated drafts of both Resource Reports 1 and 10 will be submitted when the first draft of the Environmental Report (consisting of Resource Reports 1 through 13) is filed with the Commission in March The first draft of the Environmental Report will reflect the proposed pipeline route as revised herein. The second draft of the Environmental Resource Report is anticipated to be filed with the Commission in June Tennessee plans to host open houses in the Project area, including in the area of the revised pipeline route during the period January 2015 through March 2015 to provide additional information and answer questions concerning the Project. In accordance with the Commission s filing requirements, Tennessee is submitting this filing with the Commission s Secretary through the efiling system. Tennessee is also providing complete copies of this filing to the Office of Energy Projects ( OEP ). Any questions concerning the enclosed filing should be addressed to Ms. Jacquelyne Rocan at (713) or to Mr. Richard Siegel at (713) Respectfully submitted, TENNESSEE GAS PIPELINE COMPANY, L.L.C. Enclosures By: /s/ J. Curtis Moffatt J. Curtis Moffatt Deputy General Counsel and Vice President Gas Group Legal cc: Mr. Rich McGuire Mr. Michael McGehee Mr. Eric Tomasi

5 INFORMATION HAS BEEN REMOVED FROM THIS DOCUMENT FOR PRIVILEGED TREATMENT (18 C.F.R ) December 8, 2014 Kimberly D. Bose, Secretary Federal Energy Regulatory Commission 888 First Street, NE Room 1A Washington, DC Re: Tennessee Gas Pipeline Company, L.L.C., Docket No. PF Northeast Energy Direct Project Supplemental Filing -- Adoption of Alternative Route as Part of Proposed Route (Wright, New York to Dracut, Massachusetts Pipeline Segment) Dear Ms. Bose: On September 15, 2014, Tennessee Gas Pipeline Company, L.L.C. ( Tennessee ) filed a request to use the Federal Energy Regulatory Commission s ( Commission ) pre-filing procedures for the proposed Northeast Energy Direct Project ( or Project ). By notice issued October 2, 2014, the Commission approved Tennessee s request to use the prefiling procedures for the Project. On November 5, 2014, Tennessee filed drafts of Resource Reports 1 and 10 and an updated stakeholder mailing list for the Project with the Commission. In the November 5, 2014 draft 0, Tennessee presented evaluations of several major route alternatives for portions of the Project. Among the route alternatives discussed in the draft 0 for the Wright, New York to Dracut, Massachusetts Pipeline Segment (referred to as the Market Path Component of the Project) were the New York Powerline Alternative and the New Hampshire Powerline Alternative (see Sections and of draft 0). These identified alternatives involved co-locating the pipeline along an existing electric transmission line corridor in eastern New York, western Massachusetts, and southern New Hampshire. The New York Powerline Alternative deviates from the proposed route in New York at approximately MP of the Wright to Dracut Pipeline Segment in New York. At that point the New York Powerline Alternative travels in a north/northeast direction, eventually turning east/southeast to interconnect with the mainline proposed route at approximately MP in

6 Federal Energy Regulatory Commission December 8, 2014 Page 2 Massachusetts. The New Hampshire Powerline Alternative deviates from the proposed route in Massachusetts at approximately milepost ( MP ) , and travels in a northerly direction into New Hampshire. At that point, the pipeline would be co-located with an existing powerline corridor and will travel in an easterly direction before turning south and re-entering Massachusetts near Dracut, Massachusetts and rejoining the proposed route of the Wright, New York to Dracut, Massachusetts Pipeline Segment at MP In its ongoing effort to critically evaluate feasible alternatives for the Project, Tennessee has now determined that it will adopt both the New York Powerline Alternative and the New Hampshire Powerline Alternative as its proposed route. Therefore, Tennessee will modify the originally proposed route for the Wright, New York to Dracut, Massachusetts Pipeline Segment of the Project. Tennessee is adopting this revised route for the Project at this early date in the pre-filing process to permit transparent stakeholder/public consultation and the development of the additional resource reports reflecting the revised route as part of the Commission s pre-filing process. The revisions reflected in this filing are the product of countless public outreach meetings conducted by Tennessee with stakeholders, as well as the environmental review process itself. This type of significant revision to the proposed Project in order to address numerous concerns with the original proposed route is a text book example of the merits of the Commission s pre-filing and certificate procedures. The Market Path component of the Project that is being revised originally consisted of approximately 177 miles of new and co-located mainline pipeline. With the adoption of the New York Powerline Alternative and the New Hampshire Powerline Alternative, the proposed revised route will now include approximately 188 miles of new and co-located mainline pipeline facilities as follows: (a) approximately 53 miles of pipeline generally co-located with Tennessee s existing 200 Line and an existing power utility corridor in eastern New York near the proposed Market Path Mid Station No. 1; (b) approximately 64 miles of pipeline generally co-located with an existing power utility corridor in western Massachusetts; and (c) approximately 71 miles of pipeline generally co-located with an existing power utility corridor in southern New Hampshire, extending east to the proposed Dracut, Massachusetts Market Path Tail Station. In addition, the Project originally included construction of eight new pipeline laterals (totaling approximately 73 miles), eight new compressor stations, and 16 new meter stations. As revised, the Project will now include nine laterals (totaling approximately 75 miles), nine new compressor stations, and 15 new meter stations. 1 One of primary reasons that led to Tennessee s decision to adopt the New York Powerline Alternative and New Hampshire Powerline Alternative for the Project is that they will enable a very substantial portion of the proposed new pipeline construction to be located adjacent to, and parallel with, existing utility corridors in the states of New York, Massachusetts and New 1 Tennessee s September 15, 2014 pre-filing request letter stated that the Wright, New York to Dracut, Massachusetts Pipeline Segment included approximately 177 miles of new and co-located pipeline facilities: (a) 52 miles of pipeline generally co-located with the existing 200 Line in western New York and Massachusetts; and (b) approximately 125 miles of new pipeline in Massachusetts. That portion of the Project was proposed to include eight new compressor stations and 16 new meter stations.

7 Federal Energy Regulatory Commission December 8, 2014 Page 3 Hampshire. By increasing the percentage of co-location for the proposed pipeline segment, the revised route will reduce the construction of new pipeline facilities in undeveloped portions of the Market Path region, thus reducing environmental impacts and avoiding habitat fragmentation. In addition, the proposed route change will enable Tennessee to avoid (in certain cases) and to minimize (in other cases) the crossing of Article 97 properties and Areas of Critical Environmental Concern in Massachusetts. Through its significant outreach efforts for the Project, Tennessee has been attentive to the public response to the Project. This proposed route modification for the Market Path component of the Project is intended to address comments and concerns expressed by affected stakeholders across various areas of the Project. Additionally, the proposed route modification, which takes advantage of a greater percentage of co-located facilities with existing power utilities, will provide economic service to several areas in northern Massachusetts and southern New Hampshire that are not currently served by an interstate pipeline. The is being developed to serve specifically the New England region. The New England region, as a whole, stands to benefit from the as it will enable New England to sustain its reliance on natural gas-fired generation and to lower energy costs by providing scalable transportation capacity attached to lower cost, near-by domestic natural gas. Access to significant, reliable and abundant quantities of lower priced natural gas will benefit New England consumers and will encourage capital investment in commercial and industrial ventures adding to the region s economy. The Project will provide regional confidence in competitively priced natural gas supplies for decades to come providing stability in a critical fuel source. Tennessee s fully integrated natural gas pipeline transportation system also will enable the Project to provide additional access to diverse supplies of natural gas to expansion customers in the New England region. As demand for natural gas in the region increases, Tennessee s LDC customers have expressed the need for additional firm transportation capacity to serve their growing markets. The proposed revision to the Market Path component of the Project does not result in any change to the proposed total incremental natural gas transportation capacity (up to 2.2 Bcf per day) to be provided by the Project. In this filing, Tennessee submits a revised to reflect the adoption of the New York Powerline Alternative and New Hampshire Powerline Alternative as part of the proposed Project. To assist the Commission and affected stakeholders in their review of the revised, Tennessee is providing clean and redlined versions of the revised report that reflect the revisions to the proposed Project facilities. Tennessee is also providing an updated overall Project map to show the new proposed route of the Project, and revised aerial photographic maps and U.S. Geological Survey topographic mapping for the pipeline route. In addition, Tennessee is submitting updated stakeholder lists (landowner, governmental officials, and regulatory agencies) for the Project. The enclosed stakeholder lists update the information that was provided as part of Tennessee s November 5, 2014 filing for (1) affected landowners (contained in Volume III-Privileged and Confidential Information, Appendix AA), (2) representatives of affected federal, state, and local political jurisdictions (contained in Volume II- Public, Appendix C), and (3) applicable federal and state regulatory agencies (contained in Volume II-Public, Appendix A). All updates to the stakeholder lists are highlighted on the

8 Federal Energy Regulatory Commission December 8, 2014 Page 4 respective attachments. Due to privacy concerns, Tennessee, in accordance with Section of the Commission s regulations, 18 C.F.R (2014), is requesting privileged and confidential treatment of that portion of the updated stakeholder mailing list that includes information regarding affected landowners. Tennessee is also providing clean and redlined versions of the Public Participation Plan in Appendix D. Tennessee notes that its development of the resource reports for the Project is an ongoing process, and that updated drafts of both Resource Reports 1 and 10 will be submitted when the first draft of the Environmental Report (consisting of Resource Reports 1 through 13) is filed with the Commission in March The first draft of the Environmental Report will reflect the proposed pipeline route as revised herein. The second draft of the Environmental Resource Report is anticipated to be filed with the Commission in June Tennessee plans to host open houses in the Project area, including in the area of the revised pipeline route during the period January 2015 through March 2015 to provide additional information and answer questions concerning the Project. In accordance with the Commission s filing requirements, Tennessee is submitting this filing with the Commission s Secretary through the efiling system. Tennessee is also providing complete copies of this filing to the Office of Energy Projects ( OEP ). Any questions concerning the enclosed filing should be addressed to Ms. Jacquelyne Rocan at (713) or to Mr. Richard Siegel at (713) Respectfully submitted, TENNESSEE GAS PIPELINE COMPANY, L.L.C. Enclosures By: /s/ J. Curtis Moffatt J. Curtis Moffatt Deputy General Counsel and Vice President Gas Group Legal cc: Mr. Rich McGuire Mr. Michael McGehee Mr. Eric Tomasi

9 NORTHEAST ENERGY DIRECT PROJECT DOCKET NO. PF DRAFT ENVIRONMENTAL REPORT RESOURCE REPORT 1 GENERAL PROJECT DESCRIPTION PUBLIC Submitted by: Tennessee Gas Pipeline Company, L.L.C Louisiana Street Houston, Texas 77002

10 1-i RESOURCE REPORT 1 GENERAL PROJECT DESCRIPTION SUMMARY OF COMMISSION FILING INFORMATION INFORMATION FOUND IN Provide a detailed description and location map of the Project facilities ( (c)(1)). Describe any non-jurisdictional facilities that would be built in association with the Project ( (c)(2)). Provide current original U.S. Geological Survey ( USGS ) 7.5- minute series topographic maps with mileposts showing the Project facilities ( (c)(3)). Provide aerial images or photographs or alignment sheets based on these sources with mileposts showing the Project facilities ( (c)(3)). Provide plot/site plans of compressor stations showing the location of the nearest noise-sensitive areas ( NSA ) within 1 mile ( (c)(3,4)). Describe construction and restoration methods ( (c)(6)). Identify the permits required for construction across surface waters ( (c)(9)). Provide the names and addresses of all affected landowners and certify that all affected landowners will be notified as required in 157.6(d) ( (c)(10)). Section 1.1 Attachment 1a Section 1.7 Attachment 1a Attachment 1a To be provided in a subsequent filing of this (following identification of specific locations for new compressor stations) Section 1.3 Section 1.6 Section 1.8 Volume III, Appendix AA

11 1-ii TABLE OF CONTENTS 1.0 GENERAL PROJECT DESCRIPTION PROPOSED FACILITIES Purpose and Need Location and Description of Facilities Pipeline Facilities Aboveground Facilities Compressor Stations Meter Stations Mainline Valves, Pig Launcher/Receivers and Cathodic Protection Facilities (Appurtenant Aboveground Facilities) Location Maps, Detailed Site Maps, and Plot/Site Maps LAND REQUIREMENTS Pipeline Facilities Aboveground Facilities Access Roads Additional Temporary Workspace Pipeyards and Contractor Yards Areas of No Access CONSTRUCTION PROCEDURES Pipeline Construction Marking the Corridor Erosion and Sediment Control Clearing, Grading, and Fencing Trenching Pipe Stringing Pipe Bending Pipe Assembly and Welding X-Ray and Weld Repair Coating Field Welds, Inspection and Repair Pipe Preparation and Lowering-In Tie-Ins

12 1-iii Backfilling and Grade Restoration Clean-up and Restoration Hydrostatic Testing and Tie-Ins Alternating Current Mitigation and Cathodic Protection Specialized Construction Procedures Rugged Topography Residential Areas Agricultural Lands Road and Railroad Crossings Trenchless Construction Methods Rock Removal Wetland Crossing Construction Waterbody Crossing Construction Project Specific Alternative Measures or Modifications to Commission s Plan and Procedures Compressor Stations, Meter Stations, and Appurtenant Facilities (Aboveground) Clearing and Grading Foundations Building Design and Construction High Pressure Piping Pressure Testing Infrastructure Facilities Control Checkout and Engine Startup Final Grading and Landscaping Erosion Control Procedures Timeframe for Construction Supervision and Inspection OPERATION AND MAINTENANCE PROCEDURES Cleared Areas Erosion Control Pipeline Facilities Periodic Pipeline and ROW Patrols

13 1-iv Aboveground Facilities FUTURE PLANS AND ABANDONMENT PERMITS AND APPROVALS NON-JURISDICTIONAL FACILITIES LANDOWNER/AGENCY CONSULTATION Landowner Consultation/Public Participation Agency Consultation Threatened and Endangered Species Consultations Interagency and Other Review/Resource Agency Meetings SUMMARY OF CUMULATIVE IMPACTS

14 TABLE OF CONTENTS (Continued) LIST OF TABLES Environmental Report 1-v Table Summary of Facilities Table Proposed Pipeline Facilities for the Project Table Areas of Pipeline Looping and Co-location for the Pipeline Facilities Table Proposed Compressor Stations for the Project Table Proposed Meter Stations for the Project Table Proposed Appurtenant Aboveground Facilities for the Project Table Summary of Land Requirements for the Project Table Proposed Construction ROW Widths for the Project Pipeline Facilities Table Land Requirements for the Project Pipeline Facilities Table Land Requirements for the Project Aboveground and Appurtenant Facilities Table Land Requirements for the Project Pipeyards and Contractor Yards Table Areas of No Access for the Project by State Table Tennessee Minimum Specifications for Depth of Cover (inches) Table Steep Slopes (15-30 percent) Crossed by the Project Table Steep Slopes (>30 percent) Crossed by the Project Table Steep Side Slopes (15-30 percent) Crossed by the Project Table Steep Side Slopes (>30 percent) Crossed by the Project Table Horizontal Directional Drill Crossings for the Project Table Shallow Depth to Bedrock for the Project Table Cathodic Protection Areas Along the Project Table Permits, Licenses, Approvals, and Certificates Required for Construction, Operation, and Maintenance of the Project Table Libraries Within the Project Area Table Newspapers Within the Project Area Table Agency Meetings Conducted for the Project (As of December 8, 2014)

15 1-vi LIST OF ATTACHMENTS ATTACHMENT 1a FIGURES Project Location Map USGS Topographic and Aerial Imagery Maps

16 GENERAL PROJECT DESCRIPTION Tennessee Gas Pipeline Company, L.L.C. ( Tennessee or TGP ) is filing an application seeking the issuance of a certificate of public convenience and necessity from the Federal Energy Regulatory Commission ( Commission or FERC ) for the construction and operation of the proposed Northeast Energy Direct Project ( or Project ). 1 Tennessee proposes to expand and modify its existing pipeline system in Pennsylvania, New York, Massachusetts, Connecticut, New Hampshire, and Rhode Island. 2 The is being developed to meet the increased demand in the Northeast United States ( U.S. ) for transportation capacity of natural gas. The will provide up to 2.2 billion cubic feet per day ( Bcf/d ) of new firm natural gas transportation capacity to meet the growing energy needs in the Northeast U.S., particularly in New England. The proposed Project involves the following facilities: Approximately 32 miles of pipeline looping on Tennessee s 300 Line in Pennsylvania; Approximately 135 miles of new pipeline proposed to be generally co-located with the Constitution Pipeline Project proposed by Constitution Pipeline Company, LLC ( Constitution ) 3 in Pennsylvania and New York (extending from Tennessee s existing 300 Line near Auburn Center in Troy, Pennsylvania to Wright, New York); Approximately 5352 miles of pipeline generally co-located with the Tennessee s existing 200 Line and an existing utility corridor in New York and Massachusetts; Approximately miles of new pipeline generally co-located with an existing utility corridor in Massachusetts (extending east to Dracut, Massachusetts); In compliance with Section (f)(5) of the Commission's regulations, 18 C.F.R (f)(5)(2014), Tennessee is filing this draft of for the. This draft of reflects the information available as of the date of filing regarding the proposed Project facilities and anticipated land requirements, construction procedures, and permitting/clearance requirements for the. Tennessee will submit an updated version of this to be submitted in a subsequent filing of the ER. Although capacity at Tennessee s existing Cranston Meter Station located in Rhode Island will be increased as a result of the Project, no modifications to the existing meter station facilities or land disturbance are required. Jointly owned by Williams Partners Operating, LLC; Cabot Pipeline Holdings, LLC; Piedmont Constitution Pipeline Company, LLC; and Capital Energy Ventures Corporation. Information contained within this related to the Constitution Pipeline Project was based on the Draft Environmental Impact Statement: Constitution Pipeline and Wright Interconnect Projects, FERC EIS No. 0249D, Docket Numbers CP , CP , and PF ( Constitution DEIS ). Tennessee notes that on December 2, 2014 the Commission issued an Order Issuing Certificates and Approving Abandonment, Constitution Pipeline Company, LLC, 149 FERC 61,199 (2014), for the Constitution Pipeline Project, which adopted the recommendations from, on October 24, 2014, issued the Final Environmental Impact Statement for the Constitution Pipeline Project Final Environmental Impact Statement: Constitution Pipeline and Wright Interconnect Projects, FERC EIS No. 0249F, Docket Numbers CP , CP , and PF ( Constitution FEIS ), issued October 24, At the time the Constitution FEIS was issued by the Commission, Tennessee was in the process of finalizing the drafts of Resource Reports 1 and 10 for filing with the Commission on November 5, 2014 and hads not had an opportunity to finalize its review of the Constitution FEIS and incorporate any revisions to its proposed route based on that review. Tennessee will determine if any revisions to its proposed route are necessary after its review of the Constitution certificate order and Constitution FEIS and incorporate any such revisions in subsequent filings of the ER.

17 1-2 Approximately 71 miles of pipeline generally co-located with an existing utility corridor in New Hampshire (extending southeast to Dracut, Massachusetts); Various laterals and pipeline looping segments in Massachusetts, Connecticut, and New Hampshire to serve local markets; Construction of nine eight new compressor stations and 1516 new meter stations, and modifications to existing compressor and meter stations throughout the Project area; and Construction of appurtenant facilities, including mainline valves ( MLVs ), cathodic protection, and pig launcher/receivers through the Project area. To the extent that it is practicable, feasible, and in compliance with existing law, Tennessee proposes to locate proposed pipeline facilities (either pipeline looping segments or co-located pipeline facilities) 4 within or adjacent to its existing right-of-way ( ROW ) associated with its existing 300 Line in Pennsylvania and Connecticut, and the its 200 Line in New York, and Massachusetts, and an existing utility corridor in New York, Massachusetts, and New Hampshire. Table provides a summary of the facilities. Tennessee is requesting issuance of a certificate order for the Project in October 2016 and proposes to commence construction activities in January 2017, in anticipation of placing the Project facilities inservice by November 2018 (with the exception of two proposed pipeline looping segments in Connecticut, which would be placed in-service by November 2019) consistent with the terms and conditions of the precedent agreements executed with Project Shippers. Tennessee s existing pipeline infrastructure consists of approximately 14,000 miles of pipeline designated as the 100, 200, 300, 400, 500, and 800 Lines, based on the region they serve. The proposed focuses on the existing 200 and 300 Lines. The 200 Line consists of multiple pipelines varying from 24 inches to 36 inches in diameter beginning on the suction of Compressor Station 200 in Greenup County, Kentucky, and extending east through Ohio, Pennsylvania, New York, and New England. The 300 Line system consists of two pipelines (24 inches and 30 inches in diameter) beginning on the discharge side of Compressor Station 219 in Mercer County, Pennsylvania, traveling east through Pennsylvania, New Jersey, New York, Connecticut and terminating as a 16-inch-diameter pipeline at Compressor Station 261 in Hampden County, Massachusetts. Facility Name Facility Type TABLE SUMMARY OF NED PROJECT FACILITIES New/ Modified County Length (miles) 3 Nearest MP 4 Associated Pipeline Segment 5 Pennsylvania Loop Pipeline New Bradford N/A N/A Loop Pipeline New Bradford 4.81 N/A Susquehanna 4.24 N/A N/A 4 Pipeline loops are those pipeline segments which are laid parallel to another pipeline and used as a way to increase capacity along what is possible on one line. These lines are connected to move a larger flow of gas through a single pipeline segment. Co-located pipelines are those that are laid parallel to another existing pipeline, but are not connected in any way.

18 1-3 Facility Name Pennsylvania to Wright Pipeline Segment (Pennsylvania Portion) Station 319 Upgrades Supply Path Head Station Pennsylvania to Wright Pipeline Segment (New York Portion) Wright to Dracut Pipeline Segment (New York Portion) Supply Path Mid Station Supply Path Tail Station Facility Type TABLE SUMMARY OF NED PROJECT FACILITIES New/ Modified County Length (miles) 3 Nearest MP 4 Associated Pipeline Segment 5 Pipeline New Susquehanna N/A N/A Compressor Station Compressor Station Pipeline Pipeline Compressor Station Compressor Station Modified Bradford N/A Loop New Susquehanna N/A Pennsylvania Subtotal New York Broome N/A New Chenango 2.44 N/A Delaware N/A Schoharie N/A Schoharie 3.88 N/A New Albany N/A Rensselaer N/A Pennsylvania to Wright Pipeline Segment (Pennsylvania Portion) N/A N/A New Delaware N/A Pennsylvania to Wright Pipeline Segment (New New Schoharie N/A York Portion)

19 1-4 Facility Name Market Path Head Station Market Path Mid Station 1 IGT- Constitution Bi-Directional Meter NED Check NED/200 Line Bi-Directional OPP & Check Wright to Dracut Pipeline Segment (Massachusetts Portion) Pittsfield Lateral North Worcester Lateral Fitchburg Lateral Extension West Nashua Lateral Lynnfield Lateral Haverhill Lateral Concord Delivery Line Facility Type Compressor Station Compressor Station Meter Station Meter Station Meter Station Pipeline TABLE SUMMARY OF NED PROJECT FACILITIES New/ Modified County Length (miles) 3 Nearest MP 4 New Schoharie N/A New Rensselaer N/A New Schoharie N/A 0.03 New Schoharie N/A 0.12 New Schoharie N/A 0.14 New York Subtotal Massachusetts Berkshire N/A New Hampshire 5.57 N/A Franklin N/A Middlesex 2.82 N/A Associated Pipeline Segment 5 Wright to Dracut Pipeline Segment (New York Portion) N/A Pipeline New Berkshire 1.77 N/A N/A Pipeline New Worcester N/A N/A Pipeline New Middlesex 5.20 N/A Worcester 3.70 N/A N/A Pipeline New Middlesex 3.56 N/A N/A Pipeline Pipeline New New Essex 4.75 N/A Middlesex N/A Essex 4.05 Middlesex 1.66 N/A N/A N/A Pipeline New Middlesex 0.51 N/A N/A

20 Facility Name Maritimes Delivery Line Peabody Lateral Market Path Mid Station 2 Market Path Mid Station 3 Market Path Tail Station North Adams Check Dalton West Greenfield Gardner Check Maritimes Fitchburg Lateral Check North Worcester Haverhill Check Check Facility Type TABLE SUMMARY OF NED PROJECT FACILITIES New/ Modified County Length (miles) 3 Environmental Report 1-5 Nearest MP 4 Associated Pipeline Segment 5 Pipeline New Middlesex 1.21 N/A N/A Pipeline New Essex 5.30 N/A N/A Compressor Station Compressor Station Compressor Station Meter Station Meter Station Meter Station Meter Station Meter Station Meter Station Meter Station Meter Station Meter Station Meter Station North Adams Custody (20103) 1 Meter Station New Berkshire N/A New Franklin N/A New Middlesex N/A New Berkshire N/A New Berkshire N/A New Franklin N/A New Worcester N/A New Middlesex N/A 0.06 New Middlesex N/A 1.21 New Worcester N/A New Worcester N/A Wright to Dracut Pipeline Segment (Massachusetts Portion) Wright to Dracut Pipeline Segment (Massachusetts Portion) Concord Delivery Line Maritimes Delivery Line Fitchburg Lateral Extension North Worcester Lateral New Middlesex N/A 0.10 Haverhill Lateral New Essex N/A Lynnfield Lateral Modified Berkshire N/A Existing Facility Existing TGP Line 256A

21 Facility Name Facility Type Longmeadow 1 Meter Station Lawrence Meter (20121) 1 Station Granite/Pleasan t St. (20206) 1, 2 Everett 1 Meter Station Meter Station TABLE SUMMARY OF NED PROJECT FACILITIES New/ Modified County Length (miles) 3 New Hampden N/A Modified Essex N/A Flow Change Essex N/A New Middlesex N/A Environmental Report 1-6 Nearest MP 4 Proposed Facility Existing Facility Existing Facility Proposed Facility Associated Pipeline Segment 5 Existing TGP Line 200 Existing TGP Line 270B Existing TGP Line 273B Existing TGP Line 270C Massachusetts Subtotal Connecticut Stamford Loop Pipeline New Fairfield 1.51 N/A N/A 300 Line CT Loop Pipeline New Hartford N/A N/A Stamford (20124) Meter Station Long Ridge Meter (20434) 1 Station New Britain Meter (20129) 1 Station Wright to Dracut Pipeline Segment (New Hampshire Portion) West Nashua Lateral Fitchburg Lateral Extension Haverhill Lateral Market Path Mid Station 4 Pipeline Modified Fairfield N/A 1.51 Stamford Loop Modified Fairfield N/A Modified Hartford N/A Existing Facility Existing Facility Existing TGP Line 339A Existing TGP Line 350A Connecticut Subtotal New Hampshire Cheshire N/A N/A New Hillsborough N/A N/A Rockingham 4.77 N/A N/A Pipeline New Hillsborough 8.38 N/A N/A Pipeline New Hillsborough 5.08 N/A N/A Pipeline New Rockingham 2.01 N/A N/A Compressor Station New Hillsborough N/A Wright to Dracut Pipeline Segment

22 1 Facility Name West Nashua Facility Type Meter Station Cranston (20750) 1, 2 Meter Station TABLE SUMMARY OF NED PROJECT FACILITIES New/ Modified County Length (miles) 3 Environmental Report 1-7 Nearest MP 4 New Hillsborough N/A New Hampshire Subtotal Rhode Island Flow Change Providence N/A Rhode Island Subtotal N/A Project Total Existing Facility Associated Pipeline Segment 5 (New Hampshire Portion) Existing TGP Line 265E Mileposts for these facilities are not provided because these facilities are located along other pipeline segments of Tennessee's existing system that are not proposed to be modified as part of this Project. 2 Although capacity at these two identified existing meter stations will be increased as a result of the Project, no modifications to the existing station facilities or land disturbance will be required. Tennessee is evaluating whether there will be increased flow at other existing meter stations and will provide that information in a subsequent filing of the Environmental Report ( ER ). 3 N/A-Not Applicable for aboveground facilities (compressor stations and meter stations). Pipeline length applies only to the proposed pipeline facilities as reflected in the attached detailed topographic and aerial photography maps included with this. Addends may not exactly total due to rounding. 4 N/A-Not Applicable for proposed pipeline facilities. The nearest mileposts are provided for the existing compressor station and the existing and new meter stations located along new proposed pipeline segments only. Mileposts are not provided for meter stations located along TGP s existing system. For new compressor stations, the mileposts provided reflect an area where Tennessee is evaluating potential sites along the associated pipeline segment. 5 N/A-Not Applicable for proposed pipelines. This column indicates the associated pipeline segment for each aboveground facility (compressor stations and meter stations). 1.1 PROPOSED FACILITIES Purpose and Need Tennessee proposes to construct, install, and operate the Project facilities to meet the growing energy needs in the Northeast and, more specifically, New England. The Project, as described further herein, is a major new pipeline project that consists of (1) approximately 167 miles of new and co-located pipeline and two pipeline looping segments on Tennessee s existing 300 Line in Pennsylvania, and compression facilities designed to receive gas from Tennessee s 300 Line for deliveries to Tennessee s existing 200 Line system and/or Market Path Component of the, as defined below, near Wright, New York, Iroquois Gas Transmission System, LP, and/or the Constitution Pipeline Project (may be referred to as the Supply Path Component of the ), and (2) approximately miles of new and co-located pipeline facilities extending from Wright, New York to an interconnect with the Joint Facilities of Maritimes & Northeast Pipeline System and Portland Natural Gas Transmission System ( Joint Facilities ) at Dracut, Massachusetts and Tennessee s existing 200 Line near Dracut, Massachusetts (may be referred to as the Market Path Component of the ). In addition, the Project includes the construction of nine eight new compressor stations, modifications at an existing compressor station, and

23 1-8 approximately 7573 miles of market delivery laterals and pipeline looping segments located in the states of Pennsylvania, New York, Massachusetts, Connecticut, and New Hampshire. Additionally, the Project includes construction of 1516 new meter stations and additional modifications to existing meter stations throughout the Project area. Upon completion, the Project will provide up to 2.2 Bcf/d of additional natural gas transportation capacity to meet the growing energy needs in the Northeast U.S., particularly in New England. This includes needs of local distribution companies ( LDCs ), gas-fired power generators, industrial plants, and other New England consumers. Tennessee has reached commercial agreement, subject to the customary approvals, for approximately 500,000 dekatherms per day ( Dth/d) of long-term firm transportation capacity on the Market Path Component of the proposed with The Berkshire Gas Company, Columbia Gas of Massachusetts, Connecticut Natural Gas Corporation, Liberty Utilities (EnergyNorth Natural Gas) Corporation, National Grid, Southern Connecticut Gas Corporation, City of Westfield Gas and Electric Light Department, and two other LDCs, which demonstrates the market need for the Project capacity. Negotiations continue with additional Project Shippers on both the Supply Path and Market Path Components of the Project. This Project and its in-service date of November 2018 are supported by the shippers committed to the Project s capacity. Multiple studies have concluded that additional pipeline infrastructure is needed in the region to serve increasing demand from LDCs and the power sector. 5 As a result of the fact that current natural gas transportation infrastructure is inadequate to meet the growing demand in the New England region, gas prices in New England are the highest in the U.S. 6 Limited natural gas transportation infrastructure also has led to extremely high electricity prices in the Northeast U.S., and threatens the reliability of the region s electric grid. 7 In fact, National Grid recently announced an increase in the electric rates they will charge their customers, by an average of 37 percent, this winter due to continued constraints on the natural gas pipelines serving the region, which decrease natural gas availability at times of peak demand, causing some generators to buy gas on the spot market at higher prices, switch over to alternate fuels or not run at all. 8 Additional natural gas infrastructure may benefit the region in the form of lower energy costs and enhanced reliability to both the gas transmission system and the power grid, while also reducing the region s reliance on coal and oil-fired power plants with the added benefit of reducing greenhouse gas emissions. A recent study by the Interstate Natural Gas Association of America Current natural gas transportation infrastructure is inadequate to meet the growing demand in the New England region. See, e.g., U.S. Dept. of Energy, Quadrennial Energy Review Meeting, Statement of Gordon van Welie, President and Chief Executive Officer of ISO New England, at pp. 4-5 (Apr. 21, 2014), available at U.S. Dept. of Energy, Energy Information Administration, High Prices Show Stresses in New England Natural Gas Delivery System at 1 (Feb. 7, 2014), available at Id. at 8; see also U.S. Dept. of Energy, Energy Information Administration, Natural Gas Explained: Natural Gas Prices (Jun. 29, 2010), available at See ISO New England, 2013 Wholesale Electricity Prices in New England Rose on Higher Natural Gas Prices: Pipeline Constraints and Higher Demand Pushed Up Prices for Both Natural Gas and Power at 1 (Mar. 18, 2014), available at Id. at 2. See also Massachusetts Office of The Attorney General, Overview of Electricity & Natural Gas Rates, available at National Grid, National Grid Files for Winter Rates in Massachusetts (Sept. 24, 2014), available at

24 1-9 ( INGAA ) Foundation and ICF International predicted that 6.0 Bcf/d of new natural gas pipeline capacity will be needed in the Northeast U.S. by 2020, and 10.1 Bcf/d of capacity will be needed by The New England region as a whole will benefit from the Project as it will enable New England to sustain its electric grid and lower energy costs to compete on a more level economic playing field with other regions of the nation with access to low-cost gas. As part of Tennessee s fully integrated natural gas pipeline transportation system, the Project will provide incremental access to diverse and economic supplies of natural gas to customers in the New England region. As demand for natural gas in New England increases, Tennessee s LDC Project Shippers have expressed the need for additional firm transportation capacity to serve their growing residential, commercial, industrial, and power generation markets. Construction of the Project, therefore, will help to alleviate the natural gas pipeline capacity constraint in New England by increasing capacity in high-demand markets in New England. The Project will serve the emergent need for significant natural gas transportation capacity into New England by delivering sufficient incremental supplies that will, based upon basic market forces of supply and demand, put considerable downward pressure on energy commodity prices which are among the highest in the U.S. This will assure greater reliability and fuel certainty in the electric generation sector via the expanded natural gas pipeline transportation infrastructure. The proposed interconnection with the Joint Facilities, together with the anticipated reversal of the primary flow direction of the Joint Facilities and Maritimes & Northeast Pipeline, will potentially enable the Project to access more markets in the region, including those in New Hampshire and Maine, the Atlantic Canada region, as well as markets on Algonquin Gas Transmission s ( AGT ) system through its HubLine Pipeline. Additionally, the Project significantly increases capacity via a backhaul on Tennessee s existing 200 Line system and will increase deliverability at an important supply feed to the Algonquin Gas Transmission via an existing Tennessee-Algonquin interconnect at Mendon, Massachusetts. A significant portion of the Market Path Component facilities are proposed to be co-located with existing utility corridors other than Tennessee s existing ROW through the Commonwealth of Massachusetts. Tennessee s existing system is located in densely populated and developed parts of Connecticut and Massachusetts. When Tennessee evaluated the market need in New England, and the scope of facilities that would be required to provide the infrastructure that New England needs to reduce its high energy costs and enhance electric reliability, Tennessee conducted extensive evaluation of options to: (1) loop the pipeline along its existing 200 Line pipeline corridor in southern Massachusetts; or (2) construct a new pipeline along a route across northern Massachusetts, utilizing existing utility corridors where feasible., or (3) construct a new pipeline along a route across eastern New York, western Massachusetts and southern New Hampshire, utilizing existing utility corridors where feasible. An evaluation of the alternatives that Tennessee is considering is set forth in the draft 0 filed November 5, 2014of this filing. Based on an evaluation that includes environmental and landowner impacts, quickest time-to-market gas delivery, constructability, and many other factors, Tennessee has proposed the New York, Massachusetts and New Hampshire a northern route for the Market Path Component which predominantly follows existing utility corridors for its Project. Tennessee believes that the Project would provide the transformative solution that New England needs to reduce energy costs, enhance electric reliability and 9 The INGAA Foundation, North American Midstream Infrastructure through 2035: Capitalizing on Our Energy Abundance at 12 (Mar. 18, 2014), available at