UNOFFICIAL NORTHEAST (NE)-12 EXPANSION PROJECT

The infamous 24-inch diameter 7.5-mile Neversink Pipeline Segment begins just below Wagoner Meter Station (aka
Sparrowbush) approximately 2.5 miles to the Huguenot Meter Station. It then travels 7.5 miles southeast to the
Westtown Meter Station on Route 284 in Westtown, NY, where the 24-inch segment ends. The reason this segment of
pipe is so well known is because Millennium has plans for a number of new greenfield projects along this line. Once
they have overburdened this segment of pipe with projects they will file a new application with FERC to replace and
loop this segment of pipe. Apparently, there is more profit in segmenting a series of expansion plans than to
responsibly present the series of plans to FERC for review.

Millennium wants to construct a compressor station past the end of the 24-inch 7.5 mile Neversink Segment, on Jacobs
Road. The reasoning behind this is they need to move the gas coming from the west of the pipeline down to Ramapo,
NY. Most of the Millennium pipeline is 30-inch, but the Neversink section of pipe was not replaced back in 2008 to
30-inch. Therefore, in order to boost more gas flow to the Ramapo area a replacement/looping needs to occur on the
Neversink line and/or an added smaller compressor 40 to 100 miles from the Ramapo station.

Question:
If the Neversink Segment is replaced to 30-inch then would increasing horsepower at the existing Ramapo compressor
station (Stony Point) obviate the need for a compressor station in Minisink?

Is this reasonable land use compared to constructing it at an undeveloped site? After all, the gas increase is for
Ramapo, and since a compressor station already exists there, is it feasible to replace the Neversink Segment and add
horsepower at Ramapo, Buena Vista, Bowline, and beyond? If so, this would eliminate a lengthy permitting process
because that station already exists and FERC is familiar with the site plans there and can expedite approval.

Millennium has finally coughed up the information we knew all along would be practical when they recently admitted
in their response to Data Request #10 that moving compression to Sparrowbush and/or replacing the 7.5 mile
Neversink Segment will work. (Millennium Pipeline Company, L.L.C. Docket No. CP11-515-000 Response to FERC
Staff 11/23/11 Data Request Response Date: 12/02/11):

4. Similarly, replacing the approximately 7.5 mile Neversink Segment with 30-inch
pipe and putting a compressor station at Millennium’s existing Wagoner Meter
Station located in the Town of Deerpark, Orange County, New York, would also
provide approximately the same capacity as the proposed compressor station.
Again, even though this alternative is a theoretical possibility, it is unlikely that
Millennium could obtain the necessary land rights and environmental permits and
complete construction in time to meet Millennium’s customers’ 2012
requirements. (emphasis mine)

In order to save face, they add 'time delay' as the reason why they rather not pay serious attention to the alternate
proposal. The Commission cannot and must not allow this to pass as an acceptable reason for Millennium not wanting
to abandon the Minisink compressor station. We are not saying, 'Abandon the project'; instead, we are saying the same
thing we've been saying for some time, 'Replace the Neversink Segment and move the Compressor'. This is precisely
what Millennium intends to do in 2014! They realize what we ALL know to be true, which is that there is a serious
flaw in their pipeline system: the 24-inch Neversink Segment. To that end, they will be submitting a FERC application
to finally replace the Neversink Segment but in the meantime they want to milk the process for what they can get away
with now. And, they are confident they will do so because they are counting on the fact that the Minisink Compressor
Station project is really a small project in the grand scheme of things.

When this nightmare began a few months back I thought this was a huge project but I was mistaken. After having done
much research into other Dockets and Commission Orders and speaking with FERC staff, I am cognizant that the
Commission will probably not give this project much thought right before they look for the easy route to defend
Millennium's proposal. Other Dockets for $250 million, $500+ million puts this community on the dust heap of

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projects. Having said that, I hold out a glimmer of hope that staff will not treat this project as insignificant as compared
to other current workload. In our eyes this project is HUGE! The fact that we have submitted many substantive issues
that are reasonable and practical must be given serious attention because our livelihood is all we have. In looking into
other Dockets I am confident that our residents have done much more research and leg work than most communities
elsewhere. In fact, many of us quickly abandoned the idea that FERC is on the public's side: FERC does not Deny
projects anymore. The only recent Denial that I am aware of happened this past June with Turtle Bay. In that case,
FERC had no choice but to deny the application because that application attempted to put the cart before the horse in
seeking FERC Approval before holding an Open House, etc. Thus FERC Approves applications 99% of the time but
will include mitigation. In regards to our Docket, we have offered various alternatives and Millennium finally agreed
to it in writing (see response to Data Request #10). We have shown our openness to cooperation and a meeting of the
minds on these Alternatives and now it is up to the Commission to Approve one of the Alternatives in Data Request
#10; hopefully, a project that does not involve new greenfield construction.

Millennium has expansion plans for the foreseeable future, and that's fine; however, they should not be allowed to
spoon feed their projects to the Commission. They should be forthcoming with FERC and the public about the
expansion they have planned. If this would be any other non-regulated industry we would have no right to request to
see their future plans. But, they are a federally regulated company and as such they have an obligation to the
environment and public to minimize disruption. We now know only some of the plans that Millennium has for our area
in the next few years. Following are some of their Expansion Plans (see entire Appendices for related document
evidence):

Nov. 2012 - (Phase I) Minisink Compressor Station In-service

Nov. 2013 - (Phase 2) New Compressor Station ("probably west" of Minisink) In-service
2014 - Replace 7.5 mile Neversink Segment and Looping
2014 - New Lateral Pipeline 7 to 8 miles from CPV Valley's 630MW Power Plant to Minisink
(Millennium sent Commitment Letter to Town of Wawayanda's Planning Board. The Board Chairwoman,
Barbara Parsons and Town Engineer, Pat Hines confirmed by phone that CPV Valley’s choice is the Millennium
Pipeline.)
Nov. 2015 - Millennium-Iroquois Lateral to Pleasant Valley, NY (Iroquois NYMarc Project)

Notice the stress that these projects alone all have on the same 7.5-mile Neversink Segment: Phase I, Phase II, CPV
Valley new lateral, and the Connector to Pleasant Valley all connect to the same 24-inch pipeline. Both the 2014
Neversink replacement and the Nov. 2015 Millennium-Iroquois Lateral will have to cross the Neversink River. The
Dwarf Wedge Mussel survey will be an issue then as it would be now. Millennium Counsel, Gary A. Kruse, said in our
Nov. 30, 2011 Planning Board meeting that the Dwarf Wedge Mussel was an issue back in 2005 as the reason the
pipeline was not replaced. It seems, however, that the mussel is no longer an issue because they plan on crossing it
soon. Instead of replacing and/or looping the pipeline now they would rather disturb pristine land in this area for 2
years worth of construction for both Phases and CPV Valley; after which time they will tell FERC that the Neversink
needs replacing. With all due respect to the Commission, if this rag tag plan is allowed now then it is true what
residents here and in other communities have said about the FERC process: "this whole process is a dog and pony
show."

On Nov. 30th, Millennium President Joseph Shields spoke before the Town of Minisink Planning Board. Asked
whether there was another compressor station, he said yes, to the west of here. Then in regards to Phases I & II, he
stated: "Both these projects are sold out and paid for"1. Since both Phase I and II are "sold out and paid for"
Millennium has the funding to consolidate both Phases as well as to replace the Neversink Segment now; not in 2014
when significant impact to previously undisturbed environments would be done.

In Millennium's Dec. 2, 2011 response to Data Request #10, Millennium states under oath that replacing the Neversink
and moving (probably a smaller) compressor to Sparrowbush is doable. Unfortunately, they do not want to take the
next step and state the words: "and to avoid impacting a residential community in Minisink we should replace the
Neversink now." Millennium knows as does FERC that replacing the pipeline would probably eliminate one of their
compressor stations or, at least, combine them into one project and move them to Sparrowbush or Ramapo. FERC staff

1
The audio and transcript for this portion of the meeting has been uploaded to the FERC website separately.

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is still preparing the Environmental Assessment (EA) for this project. This is the appropriate time for staff to inquire
and study Millennium's Expansion Plans (also see Appendices and their links for more details). Doing so will help
focus attention on the real problem as Millennium acknowledged in their application as the sole reason for their
proposal. From any angle it is plain to see what the common denominator to all of these various projects is: Neversink
Pipeline Segment. In order to properly assess this project in the EA the Commission must ask itself this key question:

Now that I know about Phases I & II, CPV Valley, Neversink Replacement, and NYMarc in
Millennium's current plans, what is the most advantageous natural gas infrastructure design?

Respectfully,

Michael Mojica
180 Jacobs Rd
Westtown, NY 10998

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Appendices

The following exhibits are taken directly from websites containing Millennium PowerPoint Presentations,
DTE Energy, and Northeast Gas Association (NGA), for which Millennium President Shields is on the
Board of Directors.

Exhibit A

(from http://www.dtegasstorage.com/pdfs/customerMeeting2011.pdf; p. 28):

Millennium’s pipeline map (in green) shows the M-I Connector (Millennium to Iroquois Pipeline to Pleasant
Valley, NY)

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Exhibit B

(from http://www.dtegasstorage.com/pdfs/customerMeeting2011.pdf; p. 37):

Millennium’s Future Expansion plans; including Phase 1 and 2 Expansion; also, Iroquois Lateral Connector.

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Exhibit C

(from http://www.northeastgas.org/pdf/system_enhance0511.pdf; p. 4):

Millennium considers Replacing the Neversink and Pipeline Looping in 2014.

Note: Millennium recently stated, in their response to FERC’s Data Request #10, that Replacement/Looping
of the Neversink Segment and/or Moving the compressor to Sparrowbush was feasible. However, they state
that timing is now an issue. Prior to submitting the application to FERC in the Summer, Millennium had
sufficient time to acquire any necessary permits related to the Neversink replacement but chose not to do so.

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Exhibit C.1

(from http://www.northeastgas.org/pdf/system_enhance1111.pdf; p4):

NYMarc Project in-service Nov. 2015

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Exhibit D

(from: http://northeastgas.org/pdf/s_brownell_millennium.pdf; p. 8):

Phase I and Phase II

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Exhibit E

EXPANSION I – Two New Compressor Stations

(from: http://northeastgas.org/pdf/s_brownell_millennium.pdf; p. 9):

Millennium President Joseph Shields told the Town of Minisink Planning Board on Nov. 30, 2011:

“Both these projects are sold out and paid for”.

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Exhibit F

EXPANSION II – Looping and Compression

(from: http://northeastgas.org/pdf/s_brownell_millennium.pdf; p. 10):

As recent as April 13, 2011

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Exhibit G

CPV Valley’s 630MW Power Plant – New 7-8 mile Lateral Pipeline in Minisink
(from: 110927currie_4.pdf (application/pdf Object) ; p. 8):

As recent as Sep. 27, 2011.

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Exhibit H

Expansion Plans – Two Compressor Stations

(from: 110927currie_4.pdf (application/pdf Object) ; p. 9):

As recent as Sep. 27, 2011.

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Exhibit I

Expansion Plans – FERC Will Approve by Jan-Feb 2012

(from: 110927currie_4.pdf (application/pdf Object) ; p. 10):

As recent as Sep. 27, 2011.

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Exhibit J

Expansion Phase I – Construct Minisink Station

(from: 110927currie_4.pdf (application/pdf Object) ; p. 11):

As recent as Sep. 27, 2011.

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Exhibit K

Next Expansion – Looping and Compression

(from: 110927currie_4.pdf (application/pdf Object) ; p. 12):

As recent as Sep. 27, 2011.

Note: Millennium’s ‘Myths vs Reality’ web page says replacing the Neversink Segment and adding a compressor
station would have greater impact on the environment and community. Yet they propose to add, at least, 2 new
compressor stations in the area and still replace the Neversink and add another compressor on top of that!

(from http://www.millenniumpipeline.com/mcs_mythsvsreality.html):

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Exhibit L

System Enhancements – The Map

(from: 110927currie_4.pdf (application/pdf Object) ; p. 13):

As recent as Sep. 27, 2011.

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Exhibit M

Open Season for Phases I and II and More? – In-Service Dates from Nov. 2012 to Nov. 2015

(from http://www.millenniumpipeline.com/documents/Final_Open_Season_Package_10AM.PDF; p. 1):

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Exhibit N

On Monday and Tuesday, Dec. 5 and 6, 2011, I spoke over the phone with Town of Wawayanda Planning
Board Chairwoman, Barbara Parsons and Town Engineer, Pat Hines. They both said CPV Valley is going
with Millennium Pipeline and that Millennium sent them a commitment letter to that effect. Millennium has
several options for the:

Fuel Right-of-Way Alternatives: The two potential natural gas sources include a direct
interconnection with the Millennium interstate pipeline system, via a new 7 to 8 mile lateral
or a 2 to 3 mile O&R, Local Distribution company main extension that will originate at
Minisink and would terminate in New Hampton. Both would be the subject of its own
permitting and environmental review process, with location and final routing to be approved
by others. CPV conducted a map level environmental review of these alternatives, which is
presented in Section 17.0, Cumulative Impacts, of this DEIS. (emphasis mine)

Here's the map with all of the new Millennium lateral pipeline options. The 2 shorter new pipeline routes, on
the upper right-side, are for Orange & Rockland Utilities (O&R): http://cpvvalley.com/pdf/approval-
process/Volume%20I/CPV%20Valley%20FIGURES/Figs_Sect17CumulativeImpacts.pdf

Note: All 4 potential Millennium pipeline routes connect to the Neversink Segment.

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