FERC tells Sabal Trail to fix 17 pages of errors

John Peconom of FERC has told Sabal Trail to provide copious detailed information by 27 March 2015, including numerous items about karst limestone, such as:

Utilize publicly available LiDAR data and cave information to further characterize karst areas crossed by the Project facilities.

and

Provide summary assessments of the Direct Pipe, open cut, aerial, and intersect crossing methods as alternatives to the proposed HDD crossings of the Withlacoochee River in Brooks and Lowndes Counties, Georgia and the Suwannee River, Santa Fe River, and Withlacoochee Rivers in Florida. Also, summarize any modified HDD techniques/methods considered at these specific crossings.

Is this just FERC helping one of its funding organizations (FERC is 100% funded by the industries it “regulates”)? Or maybe even FERC is getting tired of Sabal Trail?

Filed with FERC 27 February 2015 as Accession Number: 20150227-3071, “Letter requesting Sabal Trail Transmission, LLC to file within 30 days the Environmental Information Request for the Sabal Trail Project under CP15-17.”

FEDERAL ENERGY REGULATORY COMMISSION

WASHINGTON, D.C. 20426



OFFICE OF ENERGY PROJECTS In Reply Refer To:

OEP/DG2E/Gas 3

Sabal Trail Transmission, LLC

Sabal Trail Project

Docket No. CP15-17-000



February 27, 2015


Ms. Lisa A. Connolly

General Manager, Rates and Certificates

Sabal Trail Transmission, LLC

5400 Westheimer Court, Suite 6N61

Houston, TX 77056


Re: Environmental Information Request for the Sabal Trail Project


Ms. Connolly:


Please provide the information described in the enclosure to assist in our analysis of Sabal Trail Transmission, LLC’s (Sabal Trail) Certificate application for the Sabal Trail Project. File your response in accordance with the provisions of the Federal Energy Regulatory Commission’s (FERC or Commission) Rules of Practice and Procedure. In particular, 18 Code of Federal Regulations (CFR) 385.2010 (Rule 2010) requires that you serve a copy of the response to each person whose name appears on the official service list for this proceeding.


Please file a complete response within 30 days of the date of this letter. If certain information cannot be provided within this timeframe, please indicate which items would be delayed and their projected filing dates. The response must be filed with the Secretary of the Commission at:


Kimberly D. Bose, Secretary

Federal Energy Regulatory Commission

888 First Street NE, Room 1A

Washington, DC 20426


File all responses under oath (18 CFR 385.2005) by an authorized representative of Sabal Trail and include the name, position, and telephone number of the respondent to each item. In addition to the official filing, please provide one hard copy of the response, including all oversize materials, and an electronic copy of the response, to our third-party contractor, Merjent, Inc., and to the federal cooperating agency contacts listed below.

You should be aware that the information described in the enclosure is necessary for us to continue preparation of the environmental impact assessment (EIS). Once we have received your responses and reviewed them for completeness, we will be able to establish a schedule for completing the EIS.

When filing documents and maps, prepare separate volumes as outlined on the Commission’s website at http://www.ferc.gov/help/filing-guide/file-ceii/ceii-guidelines.asp. Any plot plans showing equipment or piping details or other Critical Energy Infrastructure Information should be filed as non-public and labeled “Contains Critical Energy Infrastructure Information — Do Not Release” (18 Code of Federal Regulations 388.112). Cultural resources material containing location, character, or ownership information should be marked “Contains Privileged Information — Do Not Release” and should be filed separately from the remaining information which should be marked “Public.”


Thank you for your cooperation. If you have any questions, please contact me at 202-502-6352.


Sincerely,




John Peconom

Environmental Project Manager

Office of Energy Projects


Enclosure


cc: Public File, Docket No. CP15-17-000


Mark Evans, Senior Project Manager

U.S. Army Corps of Engineers

Jacksonville Permits Section

701 San Marco Boulevard

Jacksonville, FL 32207


Beth Walls, Environmental Scientist

U.S. Environmental Protection Agency

Region 4 NEPA Program Office

61 Forsyth Street, 13th Floor

Atlanta, GA 30303

ENCLOSURE


Sabal Trail Project

Docket No. CP15-17-000


Federal Energy Regulatory Commission

Environmental Information Request



Resource Report 1 — General Project Description

  1. Table 1.1-2 identifies multiple 42-inch-diameter pig launchers that would be installed at compressor and meter stations along the Sabal Trail Project (Project) route. Confirm the size of the proposed pig launchers considering that Sabal Trail Transmission, LLC (Sabal Trail) would install 36-inch-diameter and 24-inch-diameter pipelines.

  2. Verify that the land required for installation of cathodic protection facilities is within the areas surveyed for cultural and biological resources.

  3. Table 1.5-5 identifies the proposed improvements that would be made to new, improved, and private access roads utilized for construction and operation of the Project, and footnote “e/” identifies that culverts may be part of planned improvements. However, no culvert installations or improvements are identified for any of the proposed access roads listed in table 1.5-5 whereas table 2.3-3 of Resource Report identifies several waterbodies that would be crossed by access roads and culverts would be installed. Reconcile this discrepancy. In addition, identify any state regulatory requirements that apply to such work and verify that Sabal Trail would comply with applicable requirements.

  4. Provide a schedule for completion and submittal of the Buoyancy Control Study referenced in section 1.6.1.7.

  5. Address the following items related to the Sabal Trail Project Erosion and Sediment Control (ESC) Plan provided in appendix 1B:

    1. Rock disposal is addressed inconsistently under sections 3.5.3.3, 3.5.8, and 3.6, and refers to additional requirements in section 3.6.3.3 (a section number that is not used in the ESC Plan). In section 3.5.3.3, Sabal Trail states that rock may be buried within the right-of-way as a means of excess rock disposal, and neglects to meet the requirements of section V.A. of the FERC’s Upland Erosion Control, Revegetation, and Maintenance Plan (FERC Plan) that specifies excess rock be removed from the top 12 inches of soil in cultivated or rotated cropland, managed pastures, hayfields, and residential areas.

      1. Clarify if Sabal Trail is seeking a modification from the FERC Plan requirements for rock disposal; and

      2. if applicable, describe why the FERC Plan requirements are unnecessary, technically infeasible, or unsuitable due to local conditions, and explain how the proposed measures would achieve a comparable level of mitigation; or

      3. provide an updated ESC Plan that clarifies how excess rock would be managed that is consistent with the FERC requirements.

    2. In table 5-1, construction timing windows are noted as applying only to state designated streams. Clarify if Sabal Trail is requesting a modification from sections V.B.1, V.B.7, and V.B.8 of the FERC’s Wetland and Waterbody Construction and Mitigation Procedures (FERC Procedures), which limit the timing and duration of construction in all waterbodies. If applicable, identify the specific waterbodies where this modification would apply and provide a site-specific justification for each modification.

    3. Ensure that the ESC Plan complies with the FERC Plan and Procedures or request and justify proposed modifications as necessary, including but not limited to the following examples:

      1. section 3.6, item 1 relating to the timeline for completing final cleanup;

      2. section 5.2.3, item 4 relating to ensuring the contractor does not clear vegetation between required setbacks and additional temporary workspace (ATWS); and

      3. section 5.2.5.4, item 2.b. relating to the timeline for completing wet crossings.

    4. Sabal Trail requests a modification of FERC Procedures section VI.B.2.b which prohibits trenching in wetlands until the pipeline is assembled and ready for lowering in. Sabal Trail’s modification would allow excavation of the trench in wetlands that are dry enough to support skids and pipe prior to pipeline assembly.

Given that the Project area is subject to tropical storms and other significant rain events, FERC staff is concerned that the proposed modification could result in substantial lengths of open trench in multiple “dry” wetlands that then become saturated by precipitation or flooding events, which could require retrenching in wetlands or result in non-compliance issues (e.g., upland material being washed into wetlands). Staff is also concerned that trenches open for extended periods of time could further dry wetlands and increase impacts on vegetation.

Further describe how the proposed modification would be implemented and explain how the modification would provide equal or greater environmental protection than Procedures section VI.B.2.b.

  1. Identify specific fire suppression measures that may be implemented by Sabal Trail contractors to control/manage a vegetative debris fire.

  2. Provide an updated Spill Prevention, Control, and Containment (SPCC) Plan that describes the measures that Sabal Trail would implement to manage and secure hazardous materials in the event of a natural disaster (e.g., hurricane, karst collapse) during Project construction.

  3. Provide updates to table 1.12-1 approximately every 60 days until issuance of the Final Environmental Impact Statement.

  4. Provide the frequency and methods that Sabal Trail would implement to patrol the pipeline and right-of-way during operations. Specifically address patrol of the pipeline and right-of-way after significant rain events or flooding.

  5. Confirm that Sabal Trail would record and report karst features encountered, karst mitigation measures implemented, sinkhole formation, and any other karst-related information or incidents in its construction status reports, if the Project is approved. Construction status reports during horizontal directional drilling (HDD) activities should also record incidents of lost circulation and implementation of well and spring monitoring protocols, if necessary.

  6. Concerning non-jurisdictional facilities identified in section 1.14, identify any electric transmission lines or other utilities and infrastructure that would be constructed to serve the proposed compressor station sites. For any of these other non-jurisdictional facilities, identify the facility owner/operator and confirm who would be responsible for permitting of the facilities; describe the scope of the facilities (e.g., length, acres of impact); and identify the timing of construction.

Comments Related to Horizontal Directional Drilling

  1. Provide a discussion of the potential for spring and waterbody flows to fall below state-mandated Minimum Flows and Levels as a result of proposed HDD activities. Also, describe how Sabal Trail would ascertain, avoid, minimize, and mitigate Project-related impacts on flow regimes.

  2. Using Floridan Aquifer potentiometric surface/water table maps, identify (and confirm the presence of) drinking water wells and springs within 2,000 feet (downgradient) of proposed HDD locations.

  3. Identify the alternative waterbody crossing method(s) that would be implemented at each HDD location should Sabal Trail be unable to install the pipeline via HDD. Also, describe the procedures and consultations that would occur prior to the initiation of any alternative waterbody crossing method.

  4. Identify the specific polymers referenced in section 2.2 of Resource Report 2 that may be used to minimize drilling fluid loss and provide documentation concerning their potential impact on water quality.  Also, identify alternative bio-degradable drilling mud/fluid that could be used in lieu of bentonite-based muds.

  5. Include your responses to items 2-4 in an updated Best Drilling Practices Plan for the Sabal Trail Project.

  6. Provide a description of how relatively large volumes of water would be transported from their respective sources to the proposed HDD sites, specifically address:

    1. Hillabee Creek (milepost (MP) 1.35) to Cowpens Road/State Highway 22 (MP 2.6);

    2. Private Pond at FL-OS-002.005 (undefined MP) to US Highway 27 (MP 464.9, Toll road 429 (MP 470.1) and Interstate 4 (MP 471.7); and

    3. Private Pond (MP 6.3) to Shingle Creek (MP 9.6).

Also, describe any impacts associated with the transportation of these waters and the measures that would be implemented to avoid and minimize any potential impacts on the environment.

  1. Provide a description of the potential impacts on sensitive species and designated critical habitat resulting from proposed HDD activities and water withdrawals.  Also, describe how these activities could be completed to avoid and minimize impacts on these resources.

  2. Provide copies of correspondence with the U. S. Army Corps of Engineers (COE) regarding the proposed HDD within the Walter F. George Reservoir property. 

  3. Confirm Sabal Trail considered the information below in its characterization of karst near the proposed HDDs at the Suwannee River (MP 266.8), the Santa Fe River (MP 308.3) and the Withlacoochee River (Citrus County Line MP 1.3). Also:

    1. Contact the Florida Geological Survey (FGS), Suwannee River Water Management District, and Southwest Florida Water Management District for LiDAR data and additional information regarding mapped cave systems, including from the National Speleological Society1.  Interpret and incorporate these data and provide a supplemental filing utilizing LiDAR imagery depicting, and correlating fracture traces, sinkholes, caves, springs, discharge features, and other karst features at each referenced HDD crossing.  Specifically discuss whether the HDDs would intersect any mapped cave systems, the connectivity between the karst setting at the crossings and the cave systems and, if so, evaluate the potential HDD impacts on cave hydrology and water quality.  Provide documentation of these agency contacts.

    2. Access karst related information at http://www.dep.state.fl.us/geology/geologictopics/sinkhole/sink_dis_arc_zip.htm and at http://www.dep.state.fl.us/gis/datadir.asp and include any applicable data from these sources in the characterization of the referenced HDD sites.

    3. For table 6.5-6, define the meaning of “LOW,” “MEDIUM,” and “HIGH” risk relative to HDDs and specifically clarify whether the risk assessments refer to the relative probability of technically completing the HDD or the possibility of drilling fluid loss or other environmental impact.

  4. Clarify whether the proposed HDD at the Flint River would encounter karstic bedrock as it is unclear from the geotechnical boring logs whether bedrock was encountered.

  5. Provide summary assessments of the Direct Pipe, open cut, aerial, and intersect crossing methods as alternatives to the proposed HDD crossings of the Withlacoochee River in Brooks and Lowndes Counties, Georgia and the Suwannee River, Santa Fe River, and Withlacoochee Rivers in Florida.  Also, summarize any modified HDD techniques/methods considered at these specific crossings.

Resource Report 2 — Water Use and Quality

  1. Provide a revised table 2.2-3 that addresses the following:

    1. confirm the location of wells at MPs 160.0 and 409.3 relative to Project workspaces as these wells are located substantial distances from the pipeline centerline; and

    2. include irrigation wells listed in table 8.2-7.

  2. Comments from the FSC indicate the Project may impact properties with Water Use Permits (WUPs), and could require permit modifications. Determine if WUPs have been issued for wells listed in revised table 2.2-3, identify their locations, and describe whether Project activities would trigger any permit modifications.

  3. Section 2.2.3.1 describes three sites that would be crossed that are “open” in terms of containing potentially contaminated groundwater. Provide a description of these sites including their approximate size, location (i.e., MP range), known or potential contaminants, the status of any clean-up efforts, consultations with regulatory agencies, and the measures Sabal Trail would implement to manage contaminated groundwater, if present.

  4. The number of Section 10 rivers identified by bold face text in table 2.3-3 (Waterbodies Crossed by the Sabal Trail Project) is greater than the number identified in table 2.3-6 (Sensitive Waterbodies Crossed by the Sabal Trail Project). Clarify if Sabal Trail considers Section 10 rivers to be sensitive waterbodies. If so, provide an update to table 2.3-6 that reconciles with table 2.3‑3. If not, clarify why Section 10 waterbodies would not be considered sensitive.

  5. Explain how “install silt fence” and “N/A” are methods for new and improved access roads to cross waterbodies, as identified for the access roads listed in table 2.3-3.

  6. In conformance with FERC Procedures section V.B.9, provide site-specific crossing plans for the six major waterbodies in table 2.3-5 that would not be crossed using the HDD method. Each plan should identify ATWS; spoil storage locations; the location and manner for equipment crossings; the dewatering intake, pump(s), and discharge locations; and proposed erosion and sediment control measures.

  7. Table 2.3-9 identifies that the Dunnellon Compressor Station and DEF Citrus County Meter Station would be located in Federal Emergency Management Agency (FEMA) flood zones, and figure 2.3-1 identifies numerous access roads (e.g., MPs 86 and 287) that would be constructed within FEMA flood zones. Verify that construction and placement of the aboveground facilities and permanent fill placed for access roads within FEMA flood zones would not cause a stage increase in FEMA flood elevations.

  8. For the locations identified in table 2.3-13 justify why Sabal Trail would not be able to meet the 100-foot setback from wetlands for both parking and refueling activities (separately) and verify that Sabal Trail and its contractors would take appropriate steps (including secondary containment structures) to prevent spills and provide for prompt cleanup in the event of a spill.

  9. Update table 2.4-1 to provide Wetland Rapid Assessment Procedure scores for wetlands affected by the Project between MPs 147.4 and 150.4.

  10. The U.S. Environmental Protection Agency (EPA) commented that the route in Georgia is in an area of limesink wetlands, which have been recognized as sites of high biological diversity and important wildlife habitat, and recommended they be identified and avoided. Discuss if these wetlands are present along the proposed route. If limesink wetlands are present and cannot be avoided, provide measures to preserve or restore these wetland habitats.

  11. Table 2.4-1 identifies wetlands that would be permanently filled for access roads in Alabama, Georgia, and Florida. Provide an aerial-photo based image of each road that depicts the boundaries of these wetlands, the areas that would be filled, and a description why the wetland filling cannot be avoided or further minimized.

  12. Table 2.4-4 provides “NWI data” as a justification for using construction workspace within 75 feet of wetlands, which is not an adequate justification. Provide additional justification for using workspace within 75 feet of each of these wetlands.

Resource Report 3 — Fish, Wildlife, and Vegetation

  1. Regarding federal or state listed sensitive species:

    1. identify any project areas that remain to be surveyed; and

    2. provide a schedule for completing remaining sensitive species surveys.

  2. Provide copies of documentation from the Alabama Department of Conservation and Natural Resources (ADCNR), and the Georgia Department of Natural Resources (GDNR) indicating their concurrence with the Comprehensive Listed Species Survey Protocol Document.

  3. Identify the measures developed and approved in consultation with the ADCNR, GDNR, and Florida Fish and Wildlife Conservation Commission (FWCC) to avoid, minimize, or mitigate construction and operation impacts on sensitive species.

  4. Due to the length of time between the recently completed bald eagle surveys and the proposed construction of the Albany and Dunnellon compressor stations, confirm that bald eagle surveys would be conducted within and adjacent to these project sites prior to construction.

  5. Correspondence from the FWCC dated March 26, 2014 states trap surveys may be necessary to determine the presence of the Florida mouse. Provide the status and schedule of surveys for this species or written concurrence from the FWCC that trap surveys are not required.

  6. Due to the proposed phasing of Project construction, confirm that Sabal Trail would contact the U.S. Fish and Wildlife Service (FWS) within 12 months prior to construction of the Albany and Dunnellon Compressor Stations to determine if any new species have been listed under the Endangered Species Act, and whether additional surveys or consultation are required by the FWS.

Resource Report 4 — Cultural Resources

Note that all material filed with the Commission containing location, character, and ownership information about cultural resources must have the cover and any relevant pages therein clearly labeled in bold lettering: “CONTAINS PRIVILEGED INFORMATION — DO NOT RELEASE.”

  1. File any previously unfiled correspondence with the Alabama, Georgia, and Florida State Historic Preservation Offices (SHPO), including letters, meeting notes, phone logs, etc. Include SHPO letters commenting on surveys, testing, special studies, reports, and plans, including unanticipated discovery plans.

  2. File any previously unfiled correspondence with American Indian tribes including letters, meeting notes, phone logs, etc.

  3. Provide a table summarizing tribal consultation correspondence that details the individual sender and recipient, the tribal affiliation, the date of the correspondence, and the subject of the correspondence.

  4. Identify any areas not yet surveyed including reroutes, access roads, storage yards, etc.

  5. Describe when Sabal Trail anticipates filing any remaining cultural resources reports, including reports for field inventory and testing, as well as plans and special studies such as ground penetrating radar surveys.

  6. For those historic properties or potential historic properties that Sabal Trail plans to bore or drill beneath to avoid impacts, provide a site-specific boring/‌drilling plan view image at a scale of 1-inch equals 200 feet (or less) depicting the workspace, location of the entry and exit boreholes, and site boundaries, and a profile view illustrating the depth of boring operations between entry and exit points per FERC 2002 guidelines.2

  7. Address the following items for the draft report titled Phase I Cultural Resource Survey of the Alabama Portion of the Sabal Trail Project, Tallapoosa, Chamber, Lee, and Russell Counties, Alabama prepared by Hockersmith et al., 2014:

                1. Provide a copy of Archaeological Resources Protection Act (ARPA) permit No. DACW01-4-14-0157.

                2. File any correspondence not yet filed with the COE regarding the proposed HDD within the Walter F. George Reservoir property, and possible effects on cultural resources.

                3. Provide additional information for the cemeteries and possible burial sites investigated, including:

                  1. With regard to sites 1TP168 (6 displaced headstones) and 1TP178 (a possible grave), conduct additional historical research in order to locate the possible burials. Consult with the landowner, local historians, or the Alabama Historical Commission (AHC). Once adequately located through research and/or testing, describe how the burials would be protected during project construction and operations.

                  2. Regarding site HS-4, an early twentieth century cemetery in Chambers County, Alabama, do additional research in order to precisely define the boundaries of the cemetery. Consult with the landowner, local historians, and AHC as needed. Once adequately located, describe how the cemetery would be protected during project construction and operations.

                  3. Regarding site HS-26, a nineteenth century cemetery in Lee County, Alabama, do additional research in order to precisely define the boundaries of the cemetery. Consult with the landowner, local historians and AHC as needed. Once adequately located, describe how the cemetery would be protected during project construction and operations.

                  4. Regarding site HS-11, the Blessed Trinity Retreat, and specifically the cemetery, which is located within the Project area of potential effect (APE), describe how the cemetery would be protected during project construction and operations. Consult with the landowner and AHC as needed.

              1. Address the following items for the draft report titled Phase I Cultural Resource Survey of the Georgia Portion of the Sabal Trail Project, Stewart, Webster, Terrell, Lee, Dougherty, Mitchell, Colquitt, Brooks, and Lowndes Counties, Georgia prepared by Kosalko et al, 2014:

  1. Provide a copy of ARPA permit No. DACW01-4-14-0158.

  2. File any correspondence not yet filed with the COE regarding the proposed HDD within the Walter F. George Reservoir property, and possible impacts to cultural resources.

  1. Address the following items for the draft report titled Sabal Trail Transmission Phase I Cultural Resource Assessment Survey in Alachua, Citrus, Gilchrist, Hamilton, Lake, Levy, Marion, Orange, Osceola, Sumter, and Suwannee Counties, Florida prepared by Cardno Entrix, 2014:

    1. Provide maps for the nine archaeological sites listed in table 5-2 that are missing from appendix K-1 maps, including sites: 8GI257, 8GI262, 8MR3783, AO-588, AO-568, 8MR1109, 8MR1913, 8MR2348, and 8SM436.

    2. Provide maps for the seven historic structure sites listed in table 6-1 that are missing from appendix K-1 maps, including sites: 8SU498, 8SU460, 8SU461, 8SU462, 8SU464, 8SU466, and 8SU494.

    3. Provide a hard copy set of maps in appendix K-2 at a scale of 1 to 500 (as were provided for the states of Alabama and Georgia).

    4. Provide Appendices B-1 through B-4, Florida Site File Forms (include one hard copy).

    5. The discussion of the Bass Farm Resource Group 8SU498 beginning on page 6-73 describes access road TAR-FL-SUW-004 as a two-track road located approximately 25 feet north of Structure 8SU460 (Barn 1) which is potentially eligible for listing on the National Register of Historic Places (NRHP). Evaluate the two-track road as a possible contributing element to the Bass Farm Resource Group.  If recommended eligible for the NRHP:

      1. describe how the road would be improved and used during pipeline construction;

      2. describe the direct and indirect impacts on Structure 8SU460 (Barn 1) due to access road improvements and use; and

      3. describe direct and indirect impacts on the Bass Farm Resource Group due to access road improvements and use.

    6. Address the following items for Structure 8LV869 (Log House) which is discussed beginning on page 6-109, and which is recommended as potentially eligible for the NRHP:

      1. provide maps at an appropriate scale to show the relation between the Log House and the pipeline centerline;

      2. consider whether the road leading to the Log House, and any other features of the property, are contributing elements to the potential NRHP eligibility; and

      3. assess the direct and indirect impacts on the Log House, and describe any proposed mitigation measures.

    1. Address the following items for Resource Group 8MR3722 (Drake Ranch) which is discussed beginning on pg. 6-113, and is recommended as potentially eligible to the NRHP:

      1. provide maps at an appropriate scale to show the relation between the pipeline centerline, access roads TAR-FL-MA-009 and TAR-FL-MA-010, and the structures of the Drake Ranch;

      2. describe how the access roads (TAR-FL-MA-009 and TAR-FL-MA-010) would be used during pipeline construction, and evaluate the potential direct and indirect impacts to the Drake Ranch Resource Group from use; and

      3. consider whether the access roads, which are described as “an existing dirt road connecting and continuing beyond clusters of structures [on the Drake Ranch]” are contributing elements to the potential historic property. If recommended NRHP eligible, describe how the planned improvements would impact the Drake Ranch Resource Group eligibility.

    2. For the Resource Group 8CI1454 (Red Level Dolomite Mine) discussion beginning on pg. 6-170, provide additional information to support a recommendation for listing on the NRHP, or assess potential impacts to the property, and provide avoidance or mitigation measures.

    3. The pipeline centerline would cross Linear Resource 8SU499 (Live Oak, Perry and Gulf Railroad) near MP 276 which has not been evaluated for NRHP eligibility, and page 6-230 states that the Project would have no effect on this railroad.  Describe what construction method would be used to cross this feature to support the statement that the unevaluated property would not be impacted.

Resource Report 5 — Socioeconomics

  1. Provide a breakdown by Project phase (2016 and 2020) for the information presented in tables 5.2-1 and 5.3-1, and tables 1, 2, and 3 in appendix 5A.

  2. Update tables 5.2-11, 5.2-12, and 5.2-13 to include the:

    1. county-level data; and

    2. number of hotels, motels, and campgrounds.

  3. Update tables 5.2-14, 5.2-15, and 5.2-16 to identify the distance to the Project from the nearest fire station, hospital and medical facility, and police or sheriff office.

  4. Identify and describe the impacts on temporary housing and tourism that could result from the Project. Specifically, estimate the potential lost tourism income/revenue resulting from construction of the Project.

  5. Identify the anticipated traffic load per day during peak construction.

  6. Provide the full economic impact analysis report by Fishkind & Associates, Inc., as the report provided appears to be annotated (i.e., lacking descriptions of methodologies.)

  7. For each state, provide a table or equivalent discussion that provides the peak construction workforce. Break out this information between the two construction phases.

  8. For each state, provide the total percentage of local hires that would be needed for operation of the Project. Break out this information between the two construction phases.

  9. The number of construction personnel in table 1.8-1 in RR1 and table 5.3-1 in RR5 are inconsistent. Resolve all discrepancies.

  10. For each county, provide the total ad valorem property taxes that would be generated by the Project.

  11. For each state, provide an estimate of the total amount of construction materials and other consumables that would be purchased locally. Break out this information between the two construction phases.

  12. For each state, provide the total output, or economic benefit, that would be experienced in the Project area as a result of construction and operation of the Project. Break out this information between the two construction phases. Complete the following table:

Table [number]

Output of Construction and Operation of the Sabal Trail Project by State and Phase

State

Construction Output ($)

Operation Output ($)

2016



Alabama



Georgia



Florida



2020



Alabama



Georgia



Florida



Source:



Resource Report 6 — Geologic Resources

  1. Provide a revised Blasting Plan that includes a table summarizing the locations (by MP range), where blasting may be required.

  2. In response to comment from the EPA, discuss the potential for the Project to cause acid drainage due to construction in acid-producing rocks in the Piedmont physiographic region.  If such potential exists, describe the impacts of increased acid drainage and measures that Sabal Trail would implement to avoid or minimize impacts.

  3. Provide a revised Karst Mitigation Plan that addresses blasting in karst sensitive areas. Although Sabal Trail has indicated that blasting is unlikely, this revised plan should describe how blasting activities would occur should they become necessary.

  4. Utilize publicly available LiDAR data and cave information to further characterize karst areas crossed by the Project facilities.

  5. Describe the potential impacts on mapped caves crossed and located near the pipeline resulting from trenching and other construction activities

  6. Provide the citations for “USGS 2005b” identified in section 6.5.5 and for “Godt 2001” identified in figure 6.5-9.

  7. Provide a discussion of the Pelham Escarpment and identify the MP and distance to the closest caves in this system.

  8. Table 6.5-1 identifies karst features at or near the Albany Compressor Station and the FSC, Gulfstream, and Citrus County Line Meter Stations; however, these aboveground facilities are not included in table 6.5-2. Provide an update to table 6.5-2 that includes karst features at these aboveground facility locations.

  9. Provide the names of fossiliferous rock formations that would be crossed in Georgia and Florida.

  10. The Wacissa springshed is referenced in table 2.2-4 in Resource Report 2, but is not listed in the springs and springshed section (section 1.3) of appendix 6B in Resource Report 6. Clarify where the Wacissa springshed is located and identify any associated spring discharge point(s).

  11. Identify the unnamed spring and its springshed depicted east of the Kings Bay Springshed on figure 4 in appendix 6C.

  12. In section 6.5.1.3, Sabal Trail states that a buffer zone would be established around “open hole” karst features in work areas. Section 7.1.2 of appendix 6F also indicates that areas of ground subsidence or surface depression would also be marked until further evaluation is completed.  Confirm that a buffer zone would be established around buried/‌mantled karst features that are mapped as areas of ground subsidence or surface depression or are found through geophysics or other investigative methods.

  13. Provide the bridging capabilities (e.g., distance) of the pipeline for crossing voids and collapse features and relate this to the maximum and typical karst feature size found in the Project area.

  14. Section 7.12 of appendix 6F describes methods for mitigating voids and sinkholes and notes that if sand infill does not provide a stable subgrade for pipe support, then compaction grouting may be required.  Clarify the following items:

    1. elaborate on what constitutes a “stable subgrade;”

    2. discuss the circumstance where there is not a stable subgrade and compaction grouting would not be required;

    3. discuss the success in using these methods for long term stabilization of sinkhole voids on other pipelines in the general area;

    4. discuss whether compaction grouting would impact groundwater quality where the potentiometric surface of the underlying groundwater is present within a sinkhole or underlying void; and

    5. in response to FGS comments, explain how the proposed karst mitigation measures would not inhibit recharge of the Floridan Aquifer and would prevent future re-initiation of subsidence through raveling

  15. In section 6.5.1 of Resource Report 6, Sabal Trail indicates that in the event of underlying collapse, repositioning or replacing the pipe to a stress-free state would be a mitigation measure to be utilized only during “extreme” circumstances. Clarify what an extreme circumstance would be and who would make that determination.

  16. Based on comments received from the Florida State Clearinghouse, confirm that all geologic/engineering studies, analyses, testing, and mitigation plans related to the karst environment have been or would be completed under the direction of a state licensed professional geologist and/or engineer with experience in this geologic setting.

  17. Address the potential for compressor station vibrations to trigger subsidence in the Project area and describe what mitigation measures would be taken to address this potential hazard.

Resource Report 8 — Land Use, Recreation, and Visual Resources

  1. Some ATWS dimensions listed in table 8.2-4 are not consistent with those shown on the alignment sheets. Examples include ATWS 5053, 1426, 4042, and 4001. Resolve all discrepancies between table 8.2-4 and the alignment sheets and provide corrected materials as necessary.

  2. The ATWS totals in table 8.2-4 are not consistent with ATWS totals in tables 1.5-1 and 8.2-2. Resolve the discrepancies.

  3. Per the FERC Plan, section III.C., verify that Sabal Trail would develop grazing deferment plans in cooperation with willing landowners, grazing permittees, and land management agencies. If not, provide justification and identify measures that would be adopted to protect grazing animals during construction.

  4. Provide the Project Temporary Repair plans and procedures referenced in section 8.2.3.2. Ensure the plan identifies the specific timeframes for temporary (immediately, within 24 hours, etc.) and permanent repairs to damaged irrigation and drainage systems.

  5. Provide a table that lists the locations of lands managed for silviculture (logging). Also, identify the amount of silviculture land that would be impacted by construction and operation of the Project.

  6. Provide a table that lists the locations of lands managed for participating in forest certification programs. Also, identify the amount of land participating in forest certification programs that would be impacted by construction and operation of the Project.

  7. In response to comments, provide an update regarding the status of the planned Global Village development near the proposed Reunion Compressor Station, including and any communications between Sabal Trail and the developer.

  8. Specify the timing for temporary (immediately, within 24 hours, etc.) and permanent septic system repairs described in section 8.3.3.

  9. The total public and private ownership acreage in table 8.4-2 is inconsistent with the total project acreage in table 8.2-2. Clarify how public and private acreage was calculated and resolve the discrepancy between these tables.

  10. Section 8.4.1.1, Florida, lists several conditions and mitigation measures for conservation lands owned or managed by the Southwest Florida Water Management District and Florida Office of Greenways and Trails. Verify if Sabal Trail would adopt these conditions and measures. If not, describe why.

  11. Regarding the Florida National Scenic Trail (FNST), provide the following:

  1. a discussion of the Project’s consistency/conformance with the FNST Comprehensive Plan, including confirmation there would be no tree clearing between HDD drill entry and exit points and consideration of permanent Project facilities that may affect the trail’s visual character such as aboveground facilities and pipeline markers;

  2. a discussion of Sabal Trail’s consultations with the managing authority(ies) of the trail crossings, including the U.S. Forest Service and Florida Department of Environmental Protection’s (FDEP) State Lands Division;

  3. a description of mitigation measures requested by the land managing agency(ies) and verification that Sabal Trail would adopt these measures; and

  4. a site-specific crossing plan that shows:

    1. the Project construction and permanent workspace;

    2. the locations of the detour or portage;

    3. where signage would be placed;

    4. the approximate timeframe in which the detour or portage would be established; and

    5. an agency and Sabal Trail contact number.

Provide evidence that the plan was developed in consultation with the land managing agency, and confirm that necessary local approvals would be obtained.

  1. Provide an update on Sabal Trail’s application to the Florida Board of Trustees of the Internal Improvement Trust Fund (BOT), which applies to state lands in Florida. At a minimum, include the following:

  1. a description of any site-specific mitigation measures requested by the special interest area and/or BOT;

  2. verification that Sabal Trail would adopt these measures; and

  3. clarification that the BOT’s policy “Use of Natural Resources Lands by Linear Facilities” would supersede the special interest area’s management goals and/or policies where the Project would not be suitable or consistent (e.g., Goethe State Forest, Withlacoochee State Forest).

  1. Provide an update of Sabal Trail’s discussions with the FDEP and the Audubon Society regarding the location of the Project through the Green Swamp, including a description of any site-specific mitigation measures requested.

  2. Several of the management plans for the special use areas described in section 8.4.1.1 state that colocation is preferable or required. Where an adjacent or nearby road or utility corridor is available, justify why the Project would not be collocated through each of these areas.

  3. Provide site-specific crossing plans for the special use areas where a detour or portage would be used during construction (Trail Two West, Marjorie Harris Carr Cross Florida Greenway, Halpata Tastanaki Preserve Trail, etc.). At a minimum, provide the following on each plan:

      1. the construction and permanent workspace;

      2. locations of the detour or portage;

      3. where signage would be placed;

      4. the approximate timeframe in which the detour or portage would be established; and

      5. an agency and Sabal Trail contact number.

Provide evidence that each plan was developed in consultation with and approved by the land managing agency.

  1. For special use areas crossed, identify any mitigation measures Sabal Trail would implement, including any site-specific mitigation measures requested by the landowner or manager. Verify whether Sabal Trail would adopt these measures, and if any measures conflict with the FERC Plan or Procedures, describe how each proposed modification would provide equal or better environmental protection than the FERC Plan and Procedures, or explain why the FERC Plan or Procedures would be infeasible or unworkable based on project-specific conditions.

  2. Confirm that Sabal Trail would adopt the measures listed in section 8.4.2.1 to minimize disturbance to Conservation Reserve Program and Farm Service Agency conservation program areas.

  3. Provide a description of the existing conditions (land use, utility corridors, structures, etc.) at each scenic highway crossing.

Resource Report 9 — Air and Noise Quality

  1. Provide a Fugitive Dust Control Plan that includes:

    1. the specific measures Sabal Trail would implement and how they would be implemented (as described in section 9.2.6.1 and 9.2.7.1);

    2. a statement that the environmental inspector (EI) would have the authority to determine if/when dust control measures are necessary; and

    3. a statement that the EI would have the authority to stop work if the contractor does not comply with dust control measures.

  2. Provide emissions calculations for the natural gas-fired process heater to be installed at the FGT Hunters Creek Meter and Regulation Station. Identify the emissions limits for the Generic Facility Exemption of Rule 62-210.300(3)(b)1 and demonstrate that the station emissions meet the requirements of this exemption.

  3. Provide step-by-step calculations of the estimated noise impacts from the HDD sites. Provide the estimated near field noise levels, noise attenuation calculations, and all assumptions supporting the calculations. For those that would require noise mitigation, provide specific information on the noise mitigation measures and demonstrate how they would meet the applicable noise requirements.

  4. Provide the following information for the blowdown valve identified at MP 340.0 in table 1.1-2:

    1. explain why the blowdown valve would have to be located proximal to residences and whether a more isolated location could be utilized;

    2. the maximum anticipated level of noise (in decibels) expected to be experienced at the nearest residence;

    3. any applicable local noise ordinances;

    4. the potential frequency of such events; and

    5. any noise mitigation measures (silencers, homeowner notification, etc.) that would be implemented to minimize impacts on nearby residences.

  5. Sabal Trail indicates that landowners would be notified in advance of nighttime HDD operations. Describe how far in advance this notification would be provided and in what manner (e.g., traditional mail, door notifications, signage, etc.).

Resource Report 11 — Reliability and Safety

        1. Provide the total mileage of each U.S. Department of Transportation Class Location for the total length of the pipeline (e.g., 200 miles of Class 1 pipe, 80 miles of Class 2 pipe, etc.).


1 Cave maps can be acquired by accessing this database: http://www.geohydros.com/FGS/cave-db/Internal_Pages/database.htm .  More cave maps are available and can be requested by contacting the Florida Speleological Society: http://www.floridacaving.com/

2 Federal Energy Regulatory Commission (2002). Guidelines for Reporting on Cultural Resources Investigations for Pipeline Projects. Office of Energy Projects, Washington DC. Page 18.

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