Cover Letter, PF14-6, 2013-11-04

Cover letter, Request for Pre-Filing Review, 4 November 2013, Accession Number: 20131104-5066. All the attachments are in a separate gallery.

Project Overview, in Request for Pre-Filing Review, by Transcontinental Gas Pipe Line, for FERC Docket No. PF14-6, 4 November 2013

Transcontinental Gas Pipe Line Company, LLC
2800 Post Oak Boulevard (77056)
P.O. Box 1396
Houston, Texas 77251-1396
713/215-2000

November 4, 2013

Federal Energy Regulatory Commission
888 First Street, N.E.
Washington, D.C. 20426

Attention:Kimberly D. Bose, Secretary
Reference:Request for Pre-Filing Review
Transcontinental Gas Pipe Line Company, LLC
Hillabee Expansion Project
Docket No. PF14-

Ladies and Gentlemen:

Transcontinental Gas Pipe Line Company, LLC (“Transco”) respectfully requests that the Federal Energy Regulatory Commission (“Commission”) Staff initiate a pre-filing review of Transco’s proposed Hillabee Expansion Project (sometimes referred to herein as the “Project”). The Project is an expansion of Transco’s existing natural gas transmission system in Alabama that will enable Transco to provide an approximate 1,131,730 dekatherms per day (“dt/day”) of incremental transportation capacity to be constructed in three phases. The capacity created by the Project will be leased to Sabal Trail Transmission, LLC (“Sabal Trail”). The initial phase of the Hillabee Expansion Project is targeted to be placed in service May 1, 2017.

Project Overview:

In December 2012, Florida Power & Light Company (“FPL”) issued a Request for Proposals (“RFP”) for new natural gas transportation service. Specifically, the RFP requested proposals for (i) an upstream pipeline extending from Transco’s Station 85 in Alabama to a new interconnection hub to be located in Osceola County, Florida (referred to as the “Central Florida Hub”); and (ii) a downstream pipeline that would extend from the Central Florida Hub to FPL’s Martin Plant in Martin County, Florida. In July 2013, FPL announced Sabal Trail as the winning bidder for the upstream pipeline project.

The Sabal Trail Project will provide 1,100,000 dt/d of firm transportation through (1) the capacity leased under Transco’s Hillabee Expansion Project from Transco’s existing Compressor Station 85 in Choctaw County, Alabama to a location near Alexander City, Tallapoosa County, Alabama; and (2) the construction of 460 miles of greenfield mainline facilities from the interconnection with Transco near Alexander City, Alabama to the Central Florida Hub.1 At the Central Florida Hub, Sabal Trail will connect with the downstream pipeline to be constructed by Florida Southeast Connection, LLC (“FSC”).2 The initial phase of each project has a target inservice date of May 1, 2017.

1 The Sabal Trail project is currently undergoing pre-filing review in Docket No. PF14-1.

2 The FSC project is currently undergoing pre-filing review in Docket No. PF14-2.

Request for Pre-Filing Review of Transco’s Hillabee Expansion Project:

In accordance with Section 157.21(d) of the Commission’s regulations, Transco submits the following:

  1. A description of the schedule desired for the project including the expected application filing date and the desired date for Commission approval.

    Transco requests approval to commence the pre-filing process by November 8, 2013. During the pre-filing process, Transco will conduct field surveys for cultural resources, wetlands, and endangered species to identify and address significant issues, and will meet with regulatory agencies and seek landowner input. Transco will coordinate with Commission Staff in order to develop complete Resource Reports and, in coordination with Sabal Trail and FSC, will use Merjent as the third party contractor for the development of the environmental document.

    Transco expects to submit a full draft of Resource Report 1, a list of alternatives, and a list of affected landowners in December 2013. Transco anticipates filing its NGA Section 7(c) certificate application in October 2014. The application will request that the Commission approve the Project by November 2015 to enable Transco to complete the proposed facilities and commence service for Phase 1 of the Project on May 1, 2017.

    To summarize, the proposed Project timeline is as follows:

    November 2013Pre-filing process begins
    January 2014Open Houses
    June 2014Draft Resource Reports 1 through 12
    October 2014Submit 7(c) Application
    November 2015Requested Date for FERC Order
    April 2016Anticipated Construction Start for Phase 1
    May 2017Target In-Service for Phase 1
    April 2019Anticipated Construction Start for Phase 2
    May 2020Target In-Service for Phase 2
    November 2020Anticipated Construction Start for Phase 3
    May 2021Target In-Service for Phase 3

    Transco is seeking to use the Commission-approved pre-filing process in order to develop its certificate application and obtain timely processing of the certificate application. In that regard, Transco will provide to Commission Staff the information set forth in Section 157.21(f) of the Commission’s regulations. Transco anticipates resolving the issues raised during the scoping process and submitting a complete application.

  2. For LNG terminal facilities, a description of the zoning and availability of the proposed site and marine facility location.

    There are no LNG terminal facilities related to or proposed as part of the Project.

  3. For natural gas facilities other than LNG terminal facilities and related jurisdictional natural gas facilities, an explanation of why the prospective applicant is requesting to use the pre-filing process under this section.

    The Commission Staff’s early review of the environmental document and its involvement in Transco’s public participation plan will allow Transco, interested stakeholders, and the Commission Staff to discuss and address routing, siting, and other environmental issues before developing and filing the certificate application for the Project. In particular, Transco believes that the pre-filing process will be beneficial in the following ways:

    • Facilitating issue identification, study needs, and issue resolution;
    • Conducting site visits, examining alternatives, meeting with agencies and stakeholders, and participating in the public information meetings (open houses);
    • Issuing a scoping notice and conducting scoping for the Project; and
    • Assisting in the review and comment on the Resource Reports comprising Transco’s draft Environmental Reports prior to filing, to ensure that the Commission’s filing requirements are satisfied and that all of the information needed to complete the environmental document is included.
  4. A detailed description of the project, including location maps and plot plans to scale showing all major plant components, that will serve as the initial discussion point for stakeholder review.

    Sabal Trail conducted an open season from August 26, 2013 to September 25, 2013 during which it received requests for firm transportation service from receipt points at Transco’s Station 85 in Choctaw County, Alabama to delivery points across Alabama, Georgia, and Florida. Transco executed a lease agreement with Sabal Trail. Transco will amend the lease agreement to reflect the results of the open season, to provide 1,131,730 dt/day of incremental capacity from Transco’s Station 85 (Zone 4 Pool) in Choctaw County, Alabama to the point of interconnection with Sabal Trail in Tallapoosa County, Alabama, with 818,410 dt/d of such capacity commencing in May 2017 (Phase 1);

    206,660 dt/d of such capacity commencing in May 2020 (Phase 2); and the remaining 106,660 dt/d commencing in May 2021 (Phase 3), as requested by Sabal Trail.

    The facilities to be constructed under the Hillabee Expansion Project will provide the incremental capacity to be leased to Sabal Trail. Transco’s Project facilities currently under review include approximately 43.6 miles of pipeline looping facilities and 88,000 horsepower of compression at new or existing compressor stations. Transco continues to refine the scope of work under the Project and will provide updates to facilities, if necessary. The Project facilities to be installed for each of the three phases is set forth below.

    Phase 1 (2017):

    • The addition of approximately 36,500 (ISO) horsepower at two of Transco’s existing compressor stations, through the installation of new compressor engines:
      • 16,000 (ISO) horsepower unit at Compressor Station 95 in Dallas County, Alabama; and
      • 20,500 (ISO) horsepower unit at Compressor Station 105 in Coosa County, Alabama;
    • A new 32,000 (ISO) Compressor Station 84 in Choctaw County, Alabama ;
    • Re-wheel of two existing compressors at Transco’s existing Compressor Station 95 in Dallas County, Alabama;
    • Approximately 15.6 miles of 42-inch diameter pipeline in three loops in Coosa and Tallapoosa Counties, Alabama;
    • Approximately 4.6 miles of 48-inch diameter pipeline loop in Autauga and Chilton Counties, Alabama;
    • Three pipeline taps connecting to the Sabal Trail meter station; and
    • Appurtenant underground and aboveground facilities.

    Phase 2 (2020):

    • The addition of approximately 19,500 (ISO) horsepower at two of Transco’s existing compressor stations, include the installation of new compressor engines and uprating of existing compressor engines:
    • 16,000 (ISO) horsepower unit added at Compressor Station 95 in Dallas County, Alabama; and
    • 3,500 (ISO) horsepower uprate at Compressor Station 100 in Chilton County, Alabama;
  5. Re-wheel of three existing compressors at Transco’s existing Compressor Station 95 in Dallas County, Alabama;
  6. Approximately 10.6 miles of 42-inch diameter pipeline in two loops in Choctaw and Coosa Counties, Alabama; and
  7. Appurtenant underground and aboveground facilities.

    Phase 3 (2021):

    • Re-wheel of an existing compressor at Transco’s Compressor Station 100 in Chilton County, Alabama;
    • Approximately 12.8 miles of 42-inch diameter pipeline in two loops in Choctaw, Chilton, and Autauga Counties, Alabama; and
    • Appurtenant underground and aboveground facilities.

    The general location of the proposed facilities is illustrated on the attached map.

  8. A list of the relevant federal and state agencies in the project area with permitting requirements. For LNG terminal facilities, the list shall identify the agency designated by the governor of the state in which the project will be located to consult with the Commission regarding state and local safety considerations. The filing shall include a statement indicating:

    (i) That those agencies are aware of the prospective applicant’s intention to use the pre-filing process (including contact names and telephone numbers);

    (ii) Whether the agencies have agreed to participate in the process;

    (iii) How the applicant has accounted for agency schedules for issuance of federal authorizations; and

    (iv) When the applicant proposes to file with these agencies for their respective permits or other authorizations.

    Transco has contacted federal and state agencies regarding the Project to introduce the Commission’s pre-filing process and ask the agencies to participate in the process. Please refer to the attached Initial Regulatory Contacts table, which identifies the agencies that have been contacted regarding the pre-filing process. Transco has incorporated into its overall project schedule the agency-specific schedules for issuance of required federal and state authorizations. Transco expects to file applications for all necessary federal permits concurrent with the filing of the Section 7(c) certificate application.

  9. A list and description of the interest of other persons and organizations who have been contacted about the project (including contact names and telephone numbers).

    Transco has begun contacting various stakeholders, including landowners and local, state, and federal authorities, to identify and address their concerns. In October 2013, Transco began contacting landowners and interested county and municipal government officials. In November 2013, Transco will contact all state legislative and U.S. congressional representatives whose districts will be affected by the project. A list of stakeholders who have been contacted about the project is attached.

  10. A description of what work has already been done, e.g., contacting stakeholders, agency consultations, project engineering, route planning, environmental and engineering contractor engagement, environmental surveys/studies, and open houses. This description shall also include the identification of the environmental and engineering firms and sub-contractors under contract to develop the project.

    Transco initiated development of the Project earlier this year. Hydraulic modeling simulations were completed to identify the facilities, and existing mapping resources and aerial photography depicting current land use were used for preliminary pipeline routing. The proposed pipeline loops parallel Transco’s existing pipeline.

    In November 2013, Transco’s engineering personnel will begin conducting civil surveys, after notifying landowners, to identify various constraints, including residential neighborhoods, businesses, other pipelines, high tension power lines, and significant environmental features, to further refine the Project route. Environmental and cultural resource surveys will be initiated in February 2014 and are expected to be completed in April 2014.

    Transco will select a preferred route for the Project that takes into consideration impacts on the community and the environment. The drawings identifying the route and construction workspace are scheduled for completion prior to filing the Section 7(c) certificate application.

    Transco has contacted county and municipal officials to introduce the Project and is scheduling follow up meetings to be held later this year. Transco has already contacted numerous federal and state environmental agencies to initiate consultation regarding potential impacts to resources and the associated permitting process. Transco is in the process of scheduling meetings with all of these federal and state agencies identified on the attached Initial Regulatory Contacts table.

    Transco has contracted with various consulting engineering and environmental firms to complete the surveys, studies, and drawings needed to support the filing of the permits and clearances required for the Project. These include:

    • Pipeline Engineering — Mustang Engineering
    • Wetland Surveys and Resource Report Preparation — Cardno Entrix
    • Cultural Resource Surveys — HRA Gray & Pape, LLC

    Transco is in the process of selecting a contractor for compressor station engineering.

  11. For LNG terminal projects, proposals for at least three prospective third-party contractors from which Commission staff may make a selection to assist in the preparation of the requisite NEPA document.

    There are no LNG terminal facilities related to or proposed as part of the Project.

  12. For natural gas facilities other than LNG terminal facilities and related jurisdictional natural gas facilities, proposals for at least three prospective thirdparty contractors from which Commission staff may make a selection to assist in the preparation of the requisite NEPA document, or a proposal for the submission of an applicant-prepared draft Environmental Assessment as determined during the initial consultation described in paragraph (c) of this section.

    Transco, Sabal Trail, and FSC will be utilizing the same third party contractor to assist in the preparation of the environmental documents. All three pipelines prepared a Request for Proposal (“RFP”) for a third party contractor to prepare environmental documents. The draft RFP was reviewed by FERC Staff and issued to five prospective contractors. Along with Sabal Trail’s pre-filing request letter, Sabal Trail submitted to Staff under separate cover copies of three proposals and its recommendation for a potential contractor. Based on the proposals and the recommendation for a contractor, Staff has directed Sabal Trail to contract with Merjent. Accordingly, Transco will also contract with Merjent.

  13. Acknowledgement that a complete Environmental Report and complete application are required at the time of filing.

    Transco acknowledges that a complete Environmental Report and a complete application under Section 7(c) of the NGA will be required at the time of filing. Transco anticipates submitting the report and application to the Commission in October 2014.

  14. A description of a Public Participation Plan which identifies specific tools and actions to facilitate stakeholder communications and public information, including a project website and a single point of contact. This plan shall also describe how the applicant intends to respond to requests for information from federal and state permitting agencies, including, if applicable, the governor’s designated agency for consultation regarding state and local safety considerations with respect to LNG facilities.

    Transco’s commitment to stakeholder communications and effective public outreach on the Project is set forth in the Hillabee Expansion Project — Stakeholder Outreach Plan, a copy of which is attached. Transco will respond to requests for information from participating federal and state agencies in a timely manner.

    For stakeholder communications, Transco has established a toll-free information telephone line at (866) 455-9103 as well as an e-mail address at PipelineExpansion@Williams.com. Transco’s land agents will serve as points of contacts with landowners; they will also assist, as necessary, in public outreach efforts with local constituents affected by the Project.

    Transco has established a website for the Project at http://www.williams.com/hillabee. Items on the website include:

    • Project overview
    • Project location maps
    • Route selection process
    • Answers to frequently-asked questions
    • Regulatory overview, with links to the Commission website
    • Construction procedures
    • Pipeline safety
    • News
    • Contact information

    This website will be maintained throughout the Project.

    In order to further inform interested parties, Transco will periodically distribute Project Update newsletters to interested stakeholders.

  15. Certification that a Letter of Intent and a Preliminary WSA have been submitted to the U.S. Coast Guard or, for modifications to an existing or approved LNG terminal, that the U.S. Coast Guard did not require such information.

    There are no LNG terminal facilities related to or proposed as part of the Project.

Accordingly, Transco hereby requests that the Commission Staff initiate a pre-filing review of the Hillabee Expansion Project.

Respectfully submitted,

TRANSCONTINENTAL GAS PIPE LINE COMPANY, LLC

By:[signed]
Bela Patel
Senior Regulatory Analyst
713-215-2659
713-215-3483 (fax)

Enclosures

cc:Lauren O’Donnell, Director, Division of Gas — Environment and Engineering
James Martin, Gas Branch Chief — Environment and Engineering
John Peconom, Environmental Project Manager, Division of Gas — Environment and Engineering

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