Kenneth E. Webster (716) Attorney. November 3, 2015

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1 national fuel Kenneth E. Webster (716) Attorney November 3, 2015 Ms. Kimberly D. Bose, Secretary Federal Energy Regulatory Commission 888 First Street, N.E. Washington, DC RE: National Fuel Gas Supply Corporation and Empire Pipeline, Inc. Docket No. CP Dear Ms. Bose: On November 2, 2015, National Fuel Gas Supply Corporation and Empire Pipeline, Inc. (collectively Applicants ) submitted an amendment to their Joint Abbreviated Application ( Amendment ) for their. Applicants hereby supplement their Amendment with the enclosed environmental information: Supplement to Resource Report 4 - correspondence from the Pennsylvania Historical and Museum Commission; and Updated Resource Report 10 s. Please direct any questions concerning this filing to the undersigned. Very truly yours, /s/ Kenneth Webster Attorney National Fuel Gas Supply Corporation and Attorney for Empire Pipeline, Inc. Enc. cc: Christine Allen (Project Manager) All Parties NATIONAL FUEL GAS SUPPLY CORPORATION / 6363 MAIN STREET / WILLIAMSVILLE, NY

2 CERTIFICATE OF SERVICE I hereby certify that I have this day served, in accordance with the provisions of Rule 2010 of the Commission s Rules of Practice and Procedure, the foregoing document upon each person designated on the official service list compiled by the Secretary of the Commission in this proceeding. Dated at Williamsville, New York this 3rd day of November, /s/ Janet R. Bayer Janet R. Bayer National Fuel Gas Supply Corp Main Street Williamsville, New York Telephone No. (716)

3 Addendum to Appendix 4-A State SHPO Correspondence

4

5 NATIONAL FUEL GAS SUPPLY CORPORATION AND EMPIRE PIPELINE, INC. UPDATES TO RESOURCE REPORT 10 s FERC Docket No. CP Submitted: November 3, 2015

6 Resource Report 10 s RESOURCE REPORT 10 ALTERNATIVES Additional information for RR10 s is provided below. This information is intended to update that which was provided under Section Pendleton Compressor Station Site s in National Fuel s March 17, 2015 FERC filing. Table updates are shown in red ink Pendleton Compressor Station Site s Table has been updated to present a comparison of the new proposed site on Killian Road (preferred site) for the Pendleton Compressor Station, the previously proposed site, and alternative sites that have been considered. The following subsections provide details regarding the site selection process and criteria that were employed to determine the proposed site for the Pendleton Compressor Station. The preferred site was determined to be the site that best met the Project objectives. All site alternatives and corresponding required transmission lines are identified on an updated Figure , provided following the text. 10-1

7 Resource Report 10 s Siting Criteria Unit Table Comparison of Proposed Pendleton Compressor Station Locations New Proposed Site Killian Road (Preferred Site) Previously Proposed Site Aiken Road 10-2 Site 1 Site 2 Site 3 Site 4 Site 5 (Cambria) 1 Size of Site acres unknown 20 Contiguous Developable Upland Area acres unknown 6 Site Acquisition Feasible and Timely yes/no yes yes yes no no no unknown yes Idle Idle Idle Idle Idle Existing Land Use type Agricultural Zoning type Light Industrial Length of Suction/Discharge pipelines required (approx.) agricultural R2- Residential agricultural R2- Residential agricultural R1- Residential agricultural R1- Residential minimal (connection to transmission line onsite) , Site 6 (Wheatfield) 2 agricultural Forest, open Forest, open R1- M-1, Residential Industrial Industrial-1 minimal (connection to transmission line onsite) 150 feet Required Related Transmission Line Length miles a 3.34 Wetlands on site acres b Waterbody Crossings by Related Transmission Line quantity Potential for Flooding 4 n/a Low site outside of FEMA 100 year floodplain Low site outside of FEMA 100 year floodplain High site within FEMA 100 yr. floodplain Low site outside of FEMA 100 year floodplain High site within FEMA 100 yr. floodplain and portion of property within regulated floodway Low majority of site outside of FEMA 100 year floodplain Low majority of site outside of FEMA 100 year floodplain Low majority of site outside of FEMA 100 year floodplain

8 Resource Report 10 s Siting Criteria Unit New Proposed Site Killian Road (Preferred Site) Previously Proposed Site Aiken Road Site 1 Site 2 Site 3 Site 4 Site 5 (Cambria) 1 2,680 Beach Ridge Rd option / 1,150 XM-10 option 3,740 2,370 1,590 2,060 1, Estimated Access driveway length feet 800 Distance to nearest Noise Sensitive Area (NSA) feet 1, ,950 1, ,200 2,450 Access to public roads and availability of electrical power n/a Good Good Poor Good Good Good Good Good Number of parcels with houses (within 0.5 miles) 3 quantity Topography suitable yes/no yes yes yes yes yes yes yes yes Prime Farmland acres Potential to affect endangered or threatened species, or other sensitive wildlife or fisheries 4 n/a Northern longeared Bat range Northern long-eared Bat range Northern long-eared Bat range Northern longeared Bat range Northern longeared Bat range Northern long-eared Bat range Northern long-eared Bat range Notes: a b Site 6 (Wheatfield) 2 Northern long-eared Bat range The length of the suction pipeline required is 7.55 miles. The length of the discharge pipeline required is 3.64 miles, all of which would be parallel to the suction pipeline. Only the southern 10 acres of the Wheatfield site were surveyed, of which 4 acres were delineated as wetlands. Publicly available data illustrates all 10 acres of the northern portion of the site as forested and freshwater emergent wetlands. 1 Refer to text following this table for additional analysis of the Cambria Site. 2 Refer to text following this table for additional analysis of the Wheatfield Site. 3 Number of parcels with houses within 0.5 miles was calculated using Niagara County parcel data for parcels in this radius that included data in the field Year Built. Note: This methodology differs from actual house count within 0.5 miles of the compressor station of 32 houses which was utilized for other public disclosures related to the Preferred Site. 4 Data Source: NYSDEC Environmental Resource Mapper. 10-3

9 Resource Report 10 s New Proposed Site Killian Road (Preferred Site) This site is 20 acres of primarily farm fields, with a small portion of forest and shrub land. For this preferred site, Empire would construct an approximately 2.07-mile long 16 /24 pipeline (which would become part of its Line EMP-03 after construction) in lieu of the previously proposed 3.05-mile Replacement Pipeline. This site is zoned Light Industrial and permits essential services, such as the subject natural gas infrastructure. This site also allows Empire to avoid significant construction/pipeline replacement along the Frontier Chemical hazardous waste site, addressing a concern expressed by various community stakeholders related to the previously proposed Aiken Road site. Thus, the Killian Road site is considered a more suitable location for the proposed compressor station than the previously proposed site located adjacent to Aiken Road. Previously Proposed Site Aiken Road This property is 40 acres of a combination of farm fields, reverting farm fields, shrub land, and forest. Approximately 9 acres of the site are wetlands. The site proximity to Empire s existing XM-10 line is closer than the new proposed site, but requires Empire to replace 3.05 miles of 16 OD pipeline with a new 24 OD pipeline (replacing almost all of 3.09 miles of National Fuel s existing Line XM-10). The land use is zoned R-2 residential. In response to community stakeholder concerns about land use compatibility within a residential zoning district, and an impasse between the landowner and Empire as to an option to purchase the site, Empire has eliminated this site from consideration. Site 5 (Cambria) In response to various community stakeholder comments, Empire conducted a desktop analysis concerning the feasibility of locating the compressor station near an existing compressor station in the Town of Cambria, Niagara County, New York. Analysis was conducted on a 24 OD pipeline routed northerly from National Fuel s existing Line X to a compressor station site adjacent to a compressor station operated by Tennessee Gas Pipeline on Junction Road in Cambria, New York (approximately 3.64 miles north of Empire s mainline pipeline and 7.55 miles north of National Fuel s existing Line X pipeline) and then routed back to the south with a 16 OD pipeline to an interconnect with the existing Empire mainline pipeline. This preliminary route was selected from GIS/Aerial Imagery with the goal of commencing the review at an existing National Fuel pig launcher/receiver facility located at an interconnect between National Fuel s existing Line X-North and Line XM-10 pipelines. Approximately 3.91 miles of the pipeline route would consist of Empire s replacement of the entire existing Line XM-10 and EMP OD pipelines (from Line X-North to the Empire mainline) with a new 24 OD pipeline to accommodate the required flowrate at Line X-North pressure. This pipeline would be constructed using existing pipeline ROW, including the section adjacent to the Frontier Chemical hazardous waste site. Additionally, 3.64 miles of new 24 OD pipeline north of the Empire mainline would be required to connect to the northern terminus of Line EMP-03 to the compressor station site. The entire length of new 24 OD pipeline required on the suction side of the compressor station (from the southern terminus of existing Line XM-10 to the proposed compressor station) would be 7.55 miles. The new pipeline required on the discharge side of the 10-4

10 Resource Report 10 s compressor station (from the proposed compressor station back to the Empire mainline) would be an additional approximately 3.64 miles. This discharge side pipeline would utilize the same ROW as the northern end of the suction side pipeline ( Double Pipeline ROW ), 25 feet offset from the suction side pipeline. The total length of new or replacement pipeline required would be approximately miles, although due to co-location of a portion of the pipeline, the length of ROW used would be 7.55 miles. This 7.55-mile pipeline ROW would use an existing pipeline and abandoned railroad corridor, but would need to be expanded in width onto adjoining properties along the Double Pipeline ROW to accommodate two new transmission pipelines. The railroad ROW is already congested with two separate brine lines and other utilities currently utilizing the subterranean space. The 24 OD pipeline would be offset a distance of 25 feet from existing utilities, with the 16 OD pipeline offset an additional 25 feet. The majority of the route would be located in agricultural land and would require a standard 100 feet typical construction ROW to accommodate two transmission pipelines in the ROW, plus typically an additional 25 feet of additional temporary workspace for agricultural mitigation techniques. Other land use types crossed by this route include forest, open, roadway, and residential. Additionally, approximately 5 acres of National Wetlands Inventory (NWI) mapped wetlands would be impacted by construction of these pipelines. This pipeline route is also in close proximity to residential subdivisions. A new compressor station would need to be constructed adjacent to the existing Cambria Compressor Station, which is functionally independent and connected to an independent pipeline system (with different downstream connectivity) and already operates at capacity and at lower operating pressure. Of this proposed site, 20 acres would be necessary for construction and approximately 8 acres would be permanently developed, and approximately 81 percent is forested and the rest is open land. The forested area would need to be cleared prior to construction and the permanent 8 acre site would not be allowed to revert to this cover type following construction of the compression facilities. This proposed alternate site and pipeline route as described, based on the limited field review available, appears to be constructible, but would add a significant length (approximately 48,312 feet or 9.15 miles) of pipeline to the Project. In addition to substantial incremental environmental impacts to wetlands and forested habitat for wildlife (including ly the threatened northern long-eared bat, which is in range), this alternative would have temporary impacts on local traffic during construction in the area with its six additional road crossings. The Cambria site, in particular its required miles of pipeline, presents unnecessary impacts to environmental resources and is therefore not preferred. Site 6 (Wheatfield) Empire conducted additional desktop analysis on siting the compressor station on the same parcel as the proposed Wheatfield Dehydration Facility site in the Town of Wheatfield, Niagara County, New York. The proposed pipeline route that would connect National Fuel s Line X-North to the Wheatfield alternative site would be approximately 3.34 miles in length. The pipeline would 10-5

11 Resource Report 10 s commence at National Fuel s existing Nash Road Meter and Regulator Station at Line X-North, located approximately 630 feet east of Nash Road in the Town of North Tonawanda, Niagara County, New York. The pipeline would then be routed westward with the intent of locating adjacent to the existing National Grid power line corridor. The pipeline would abut a 75-footwide ROW that contains two high voltage aboveground power lines that are 25 feet apart, in addition to two brine pipelines located between the power lines, and a third line outboard of the powerlines. The area surrounding this existing ROW is heavily populated, and where it is undeveloped, forested wetlands are prevalent. Assuming a 75-foot-wide construction ROW for construction of the pipeline, approximately 17 acres of NWI wetlands would be crossed, the majority of which are forested. In a proposed 50-foot-wide permanent ROW of approximately 20 acres, over half of the acreage impacted is wetlands (approximately 12 acres). Forested wetlands would not be allowed to revert back to previous conditions following construction if they are located in the permanently maintained ROW. Safety would be a concern during construction of this pipeline due to the proximity to the existing aboveground power lines. It would be difficult to construct a pipeline adjacent to the towers and also avoid homes and existing infrastructure, while maintaining a safe working distance from the outside conductor. Seven road crossings would be necessary for the construction of this pipeline. The crossing of Nash, Witmer, and Ward Roads would likely require horizontal directional drilling (HDD) due to residential and commercial congestion and the limited work areas at these crossings. Drill site workspace and access roads would be required at each side of the three roads, behind houses and/or commercial buildings fronting the roads, in order to diagonally drill the road and existing utility obstructions. This is not a favorable crossing method in highly populated areas due to noise, site acreage requirements at both ends of the drill (to support the drill rig and support equipment), site access requirements (for equipment set-up, drill rig service, materials and water supply), and the duration of the construction. In addition, it has not yet been determined that HDD is feasible, as geotechnical studies have not been performed. Without the use of HDD it is quite possible that this route is infeasible. Even assuming that HDD is feasible, the proposed route would likely be viewed as highly unfavorable by numerous community stakeholders given the close proximity to subdivisions and construction related impacts at the three main road crossings. Based on Empire s desktop review, the route may ly be constructible, but there would be major concerns as to safety, noise and timing based on workspace limitations and allowable working hours. Additionally, there would be significant incremental environmental impacts, particularly with respect to wetlands. National Fuel surveyed approximately half of this 20-acre site for the purpose of siting the dehydration facility. the survey area of approximately 10 acres, 4 acres are wetland. Based on publicly available NWI wetland data, (USFWS 2015), approximately 85 percent of the northern half of this site are forested wetlands, and the remaining 15 percent are freshwater emergent wetlands. There is not adequate acreage at the Wheatfield site to locate both the dehydration facility and the compressor station outside of delineated wetlands. As such, siting the compressor station within the Wheatfield Dehydration Facility site is not preferred. 10-6

12 Resource Report 10 s 10.6 REFERENCES USFWS FWS Wetlands & Riparian Data. Available online at Accessed November 3,

13 Resource Report 10 s APPENDIX 10-A FIGURE UPDATE

14 FERC PDF (Unofficial) 11/3/2015 4:10:15 PM Legend Site 5 (Cambria) Bracket Pointing to Begin and end Point of Required Transmission Pipeline Existing XM-10 Line Alt. 1 Site Boundary/Required Transmission Pipeline Alt. 2 Site Boundary/Required Transmission Pipeline Alt. 3 Site Boundary/Required Transmission Pipeline Alt. 4 Site Boundary/Required Transmission Pipeline Alt. 5 Site Boundary/Required Transmission Pipeline Alt. 6 Site Boundary/Required Transmission Pipeline Previously Proposed Site Boundary/Required Transmission Pipeline New Proposed Site Preferred Site Boundary/Required Transmission Line (EMP-03) 5 Required Transmission Pipeline Miles Site 1 3 Required Transmission Pipeline 1.10 Miles Along Existing XM-10 Line Project Location 2 Required Transmission Pipeline 2.40 Miles of Existing XM-10 Line 1 Required Transmission Pipeline 3.90 Miles Along Existing XM-10 Line Site 3 New Proposed Site "Preferred Site" New Proposed Site "Preferred Site" Required Transmission Pipeline (EMP-03 Line) Site 4 Site 6 (Wheatfield) 6 Required Transmission Pipeline Orleans Niagara Pennsylvania Warren McKean New York Allegany Potter Yate s Steuben Tioga a Crawford Cattaraugus Ontario Cayuga Erie Wyom ing Livingston c Se n e Chautauqua Wayne Monroe Genesee Erie Previously Proposed Site Site 2 Schu yler Chemung Br ad f or d 4 Required Transmission Pipeline 0.60 Miles Along Existing XM-10 Line Coordinate System: North American Datum, 1983 Universal Transverse Mercator, Zone 18, North, Meters Source: USGS Topographic maps from USDA NRCS 2002 DRG of Niagra County New York Figure Site s Considered for Pendleton Compressor Station E Note: Required Transmission Lines for s 1-4 and Previously Proposed would share ROW with existing XM-10 Line Miles Date: 11/03/15 P:\GIS\projects\112C06774_NorthernAccess\MXD\ResourceReports\RR10_3rdFreeze\NatFuel_10-5-1_11X17.mxd Previously Proposed Required Transmission Pipeline 3.05 Miles Along Existing XM-10 Line

15 Document Content(s) CP15-115_Supplement to Amendment _RR4_RR10 ( ).PDF