20130924-0018 FERC PDF (Unofficial) 09/24/2013

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September 18, 2013
Kimberly D. Bose, Secretary Federal Energy Regulatory Commission 888 First Street NE, Room 1A Washington, DC 20426

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Paul V. Rush, P.E.

Dapuiy Commissioner Bureau of Wafer Supply

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prush@dsp.nyo.gov

ypp Ph()SS Gas Transmission, LLC Incremental Market (AIM) Project Initial Draft Resource Reports 1 and 10 Federal Energy Regulatory Commission FERC Docket No. PF13Algonquin Algonquin

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485 Columbus Avenue Valhaga, New York 10595 T: (845) 340-7800 F: (845) 334-7175

IMI00 DEP Log:2013-CNC4077-OT.1

Dear Ms. Bose:
The New York City Department of Environmental Protection (DEP) has reviewed Spectra Energy Corp's initial pre-filing National Environmental Policy Act (NEPA) Resource Reports 1 8'c 10 for the AIM Project under Docket No. PF13-16-000.

The AM Project proposes to replace approximately 31.4 miles of existing pipeline, add an additional 12.2 miles of new pipeline, upgrade facilities at six existing compressor stations, construct three metering stations and modify numerous existing metering facilities in New York and other states in the northeast to meet the additional demand for natural gas.
Sections of the AM pmject site are located in various East of Hudson municipalities and drainage basins of the New York City's Water Supply. As the drinking water supply reservoirs are unfiltered and phosphorous restricted, water quality impacts to the reservoir from pollutant-laden runoff must be avoided or mitigated.
Upon review of the submitted documents, DEP respectfully submits the following comments for the Commission's consideration:

Resource Reoort

General Proiect Descriotion:

Section 1.4.1.2indicates that additional temporary workspace (ATWS) is often needed when wetlands, stream crossing and other listed features are encountered. The document indicates that Algonquin has attempted to locate the ATWS in accordance with the FERC Wetland and Warerbody Construction and Mitigation Procedures and in consultation with state and federal agencies. As yet, details regarding these locations are not included in this document, though they will be included in the future resource reports. Section 1.5.1.10 indicates that ATWSs will be located at least 50 feet

20130924-0018 FERC PDF (Unofficial) 09/24/2013

from wetlands, except where topographic conditions are a constraint. In these instances, the ATWS will be at least 10 feet from the wetland's edge. Please note that a minimum of 100 foot wetland setback should be maintained for ATWS within the New York City (NYC) Watershed and alternate locations should be explored in areas where topography does not allow a 100 foot'setback.

Section 1.5.1.9 states that the open-cut crossing method may be used. This method makes no effort to isolate flow fiom construction activities and may be a source of turbidity. This process should not be used in the NYC Watershed and is unlikely to be permitted in New York State.

Tbe proposed Hudson River horizontal directional drilling discussed in Section 1.5.1.9 should take place outside of the Hudson River spawning fish migration periods.
Section
that trench spoils will be temporarily placed in a ridge along the trench. When working in wetlands, temporary storage of spoils should be on mats to minimize impacts to the wetland.

1.5.1.10 indicates

The Hudson River biological field surveys should also include species that are candidates for inclusion on the endangered species list (e.g. American eel and river herring) in addition to the Atlantic and short-nosed sturgeon identified in Section 1.12.3.
Consideration should also be given to conducting rare plant surveys along the length of the proposed construction. Open disturbed areas are preferred by several rare plant species.
Furthermore, an invasive species prevention and management plan should be developed to help prevent the introduction and spread of invasive plant species due to construction activities.

Table 1.11-1in Appendix 1E includes DEP's Stormwater Pollution Prevention Plan requirement by, but it does not include the Land Use Permit (LUP) also required by DEP for access over the Catskill aqueduct. The table should be revised accordingly to include the LUP.
Thank you for the opportunity to proidde comments. You may reach me at caarcialRdeo.nvc. aov or (914) 773-4455 with any questions or if you care to discuss the matter further.

Sincerely,

Cynthia Garcia SENORA Coordination Section

X:

D. Sipe, FERC D. Whitehead, NYSDEC

R. Kulikowski, NYC Mayor's Office

20130924-0018 FERC PDF (Unofficial) 09/24/2013

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