20160610-5164 FERC PDF (Unofficial) 6/10/2016 12:46:51 PM

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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 2
290 BROADWAY
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...pi!: NEW YORK, NY 10007-1866

JUN 1,'0 2016

Kimberly D. Bose, Secretary
Federal Energy Regulatory Commission
888 First St., N.E.
Room lA
Washington, DC 20426

RE: Docket Nos. PFI6-3, Eastern System Upgrade Project

Dear Secretary Bose:

The Environmental Protection Agency (EP A) has reviewed the information presented in the
Federal Energy Regulatory Commission's (FERC) May 11,2016 Notice ofIntent (NOI) to
prepare an environmental assessment for Millennium Pipeline Company, LLC's (Millennium)
Eastern System Upgrade (ESU) Project in Sullivan, Delaware, Orange and Rockland Counties,
New York. Millennium proposes to construct and operate about 7.8 miles of 30- and 36-inch-
diameter pipeline loop in Orange County, New York. The planned pipeline loop would
transport natural gas from Millennium's existing Corning Compressor Station to an existing
interconnect with Algonquin Gas Transmission, LLC in Ramapo, New York. Millennium would
also construct a new compressor station in Sullivan County, New York; install additional
compression at the Hancock Compressor Station in Delaware County, New York; and modify
the Westtown Meter Station in Orange County, New York and the Ramapo Meter Station in
Rockland County, New York. According to Millennium, the ESU Project would be designed to
transport approximately 200,000 dekatherms per day of additional natural gas service.

While the NOI includes a thorough list of environmental impacts to be discussed in the EA, EPA
also suggests the following issues be analyzed:

1. A full discussion of the purpose and need of the proposed proj ect which quantifies energy
demand and the need for such facilities in the region. EPA is also concerned that the
proposed Eastern System Upgrade is connecting into the Valley Lateral Project (CPI6-17)
now under review by FERC. The EA must discuss this interconnect and its purpose in detail,
and whether the Eastern System Upgrade would be constructed and meet the purpose and
need with or without the Valley Lateral being completed.

2. EPA also requests a clarification of the loop length and placement. In the description above,
taken from the notice of intent, it states the pipeline loop is 7.8 miles long, in Orange County,
NY. However, it also states that "the planned pipeline loop would transport natural gas from
Millennium's existing corning Compressor station to and existing interconnect with
Algonquin Gas Transmission, LLC in Ramapo, New York."

3. Rockland County, New York is in non-attainment status for the 8-hour 2008 ozone standard,
therefore a general conformity applicability analysis will be required for construction in
Rockland.

Internet Address (URL) http://www.epa.gov

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20160610-5164 FERC PDF (Unofficial) 6/10/2016 12:46:51 PM

4. An evaluation ofthe alternatives to the proposed project, including reasonable alternatives

not within the jurisdiction of the lead agency.

5. A comprehensive evaluation of cumulative, indirect, and secondary impacts. The cumulative

impacts analysis should consider the environmental impacts of the project as a whole, and, if
any, as one of a number of the other proposed and/or approved actions in the area that would
have the potential to impact the same resources. This should include information on all
proposed and reasonably foreseeable projects in Sullivan, Delaware, Orange and Rockland
Counties in New York State. This should include, but not be limited to: FERC jurisdictional
projects, intrastate pipelines and compression, gathering pipelines, gas processing facilities,
gas wells, industrial or commercial facilities, and housing developments.

6. Greenhouse Gas Emissions - EPA recommends that FERC include an estimate of the direct
and indirect greenhouse gas (GHG) emissions caused by the proposal, a discussion ofthe
incremental impacts of the estimated GHGs, and an analysis of reasonable alternatives and/or
practicable mitigation measures to avoid, reduce, or compensate for GHG emissions caused
by the proposal. Incremental emissions mix rapidly in the atmosphere and have global-scale
incremental impacts that increase significantly over time. In addition, C02 emissions have
centuries-long impacts, including global scale changes in ocean acidity, sea level, and mean
temperature, as well as changes to local drought and precipitation levels. For purposes of
informing decisionmakers and the public, EPA recommends this context be provided, and
that estimated GHG emissions levels should be used as a general proxy to compare emissions
levels from the proposal, alternatives, and potential mitigation. In other words, higher levels
of incremental emissions cause higher levels of incremental impacts and risks. In addition,
we recommend that the design of the proposed action consider GHG reduction measures and
improvements to the proposal's resilience to projected climate change scenarios. We
recommend that the EA make clear whether commitments have been made to implement
measures to avoid, reduce, or compensate for GHG emissions and/or to adapt to climate
change and that the EA describe measures to reduce GHG emissions associated with the
project, including reasonable alternatives and other practicable mitigation opportunities, and
disclose the estimated GHG reductions

7. Climate Change Adaptation - EPA recommends that FERC provide a summary discussion of
climate change and ongoing and reasonably foreseeable effects of climate change relevant to
the project and the project study area relevant to the proposal, based on U.S. Global Change
Research Program assessments.' These future climate scenarios included in the assessments
can be useful when considering measures to improve the resiliency of the proposed project to
the impacts of climate change as well as mitigation for potential impacts of the proposal that
will be exacerbated by climate change.

1 https://ceq.doe.gov/current_developments/GHG _accou ntinL methods_7 Jan2015. htm I

20160610-5164 FERC PDF (Unofficial) 6/10/2016 12:46:51 PM

8. As compressor station safety and emissions are of considerable importance to surrounding

communities, we suggest that a portion of the EA discuss the safety aspects of this type of
facility, and that Millennium produce a health impact assessment to evaluate the emissions
from the proposed new Compressor Station in Sullivan County and the augmented Hancock
Compressor Station in Delaware County.

9. In 1993, Council of Environmental Quality guidance, Pollution Prevention and the National
Environmental Policy Act, encouraged federal agencies to include the concepts of pollution
prevention in EAs during the scoping alternatives analysis, mitigation measure development,
and decision-making processes. We suggest that all pollution prevention practices for
pipeline construction and operations be discussed within the EA.

10. Environmental Justice concerns should be analyzed and discussed in the EA regarding the
placement of the new station.

Thank you for the opportunity to comment. If you have any questions concerning this letter,
please contact Lingard Knutson of my staff at (212) 637-3747.

Sincerely,

~~
Grace Musumeci, Chief
Environmental Review Section
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20160610-5164 FERC PDF (Unofficial) 6/10/2016 12:46:51 PM
Document Content(s)

Eastern System Upgrade sco.PDF........................................1-4