1

Patrick Kelsey
Manheim, PA

October 23, 2014

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

Re: Atlantic Sunrise Project
Docket No. PF14-8
Proposing the CPL South Marietta Extension Alternative (Revision 2)

0 Changes from Previous Revision
The Columbia Gas Transmission Marietta Compressor Station was misidentified as the Texas
Eastern Marietta Compressor Station. This reference point has been relabeled throughout.
1 Introduction
Previous analysis of the Western CPL South Alternative
1
identified significant co-location of that route
with the existing Texas Eastern Marietta Extension
2
as well as the opportunity for increasing the extent
of such co-location. The Texas Eastern Marietta Extension was constructed along an existing electric
transmission line right-of-way between March and September 2011
3
using a 100 ft wide construction
zone
4
that is readily identified in aerial imagery from September 2012 (see Attachment 1). Google
Street View imagery from September and October 2013 indicates that the 100 ft wide clearings created
for this project in forested areas remain devoid of trees (see Attachments 2 and 3).
The recency of completion of the Texas Eastern Marietta Extension and the continued availability of
large cleared areas along the route further motivate examination of co-location of the Central Penn Line
South with this existing route. This document proposes a new alternative to the southern portion of the
Central Penn Line South Primary Route, herein referred to as the CPL South Marietta Extension
Alternative, that provides all of the advantages of co-locating with the Texas Eastern Marietta Extension
while minimizing additional route length required to access those advantages.

1
Regarding the Western CPL South Alternative (Revision 2), filed in FERC Docket No. PF14-8 under Accession No.
20140820-5014 on 8/20/2014, and Regarding the Western CPL South Alternative (Revision 2), Addendum 1, filed in
FERC Docket No. PF14-8 under Accession No. 20140827-5012 on 8/27/2014.
2
Texas Eastern Transmission, LP, 129 FERC 61,151 (2009)
3
Texas Eastern Transmission, LP submits an Advance Notification pursuant to Section 2.55(a)(2)(ii), filed in FERC
Docket No. CP09-68 under Accession No. 20110217-5091 on 2/17/2011.
4
Documented, for example, in the drawing on page 7 of Texas Eastern Transmission, LP submits supplemental
information relating to its February 22, 2011 submission, filed in FERC Docket No. CP09-68 under Accession No.
20110223-5043 on 2/23/2011.
2

2 The CPL South Marietta Extension Alternative
The CPL South Marietta Extension Alternative is shown in Attachment 4, along with the corresponding
portion of the current Central Penn Line South Primary Route
5
. It consists of the following components,
beginning from the southern end and moving north:
1. Interconnect with the Transco mainline adjacent to the existing Texas Eastern Marietta
Extension metering and regulating station on Johnson Road in Lower Chanceford Township, York
County
2. Pipeline alignment paralleling the Texas Eastern Marietta Extension from the Transco mainline
interconnect to a point in Lower Windsor Township, York County just south of Yorkana Borough
3. Deviation from the Texas Eastern Marietta Extension route in the northwest corner of Lower
Windsor Township, York County to avoid potential congestion along the existing right-of-way in
Yorkana Borough near Bluestone Road
4. Pipeline alignment paralleling the Texas Eastern Marietta Extension from a point in Lower
Windsor Township, York County just north of Yorkana Borough to a point near Columbia Gas
Transmissions Marietta Compressor Station on Depot Road in East Donegal Township,
Lancaster County
5. Pipeline alignment from a point near Columbia Gas Transmissions Marietta Compressor Station
in East Donegal Township, Lancaster County to the current Central Penn Line South Primary
Route near Milepost 35 at the border of Lancaster and Lebanon Counties, then continuing north
along the current Central Penn Line South Primary Route.

2.1 Transco Mainline Interconnect
The Transco mainline interconnect point for the CPL South Marietta Extension Alternative is in the
immediate vicinity of the existing Texas Eastern Marietta Extension metering and regulating station as
that provides maximum co-location with the Texas Eastern Marietta Extension and minimum route
length to the Transco. There are sufficient amounts of undeveloped land for such a facility along the
Transco in this area, with access from Johnson Road (see Attachment 5).
2.2 Transco Mainline Interconnect to Yorkana
The CPL South Marietta Extension Alternative alignment from the Transco mainline interconnect point
to just south of Yorkana Borough parallels the existing Texas Eastern Marietta Extension. This alignment
was placed approximately 35 ft from one edge of the Texas Eastern Marietta Extension construction
zone using aerial imagery from September 2012. While this is not a precise placement of the route
relative to a precise location of the existing pipeline, it provides a much more accurate estimate of route
length for the CPL South Marietta Extension Alternative than simply tracing the neighboring electric
transmission line right-of-way, as it follows all of the deviations and direction changes that were
required to construct the Texas Eastern Marietta Extension (see Attachment 6).

5
As defined by the maps provided in Transcontinental Gas Pipe Line Company, LLC submits supplemental
information regarding the Atlantic Sunrise Project, filed in FERC Docket No. PF14-8 under Accession No. 20140722-
5101 on 7/22/2014.
3

2.3 Yorkana Deviation
Space constraints along the existing Texas Eastern Marietta Extension right-of-way near Bluestone Road
in Yorkana Borough may preclude adding another pipeline in this location (see Attachment 7). To
illustrate how this potential issue might be addressed, a deviation of the CPL South Marietta Extension
Alternative from the Texas Eastern Marietta Extension route was developed for this area.
This deviation departs from the Texas Eastern Marietta Extension alignment at a point in Lower Windsor
Township just south of Yorkana Borough, and continues to the west and north of Yorkana Borough,
along existing utility rights-of-way where possible, until it rejoins the Texas Eastern Marietta Extension
route (see Attachment 8).
If subsequent site analysis determines that such a deviation is not required, the overall length of the
CPL South Marietta Extension Alternative would be reduced and its total co-located length would be
increased.
2.4 Yorkana to Columbia Gas Transmissions Marietta Compressor Station
The CPL South Marietta Extension Alternative alignment from just north of Yorkana Borough to just
south of the Susquehanna River crossing parallels the existing Texas Eastern Marietta Extension. This
alignment was produced using the technique described in Section 2.2.
The CPL South Marietta Extension Alternative crosses the Susquehanna River alongside the crossing of
an existing Texas Eastern 36 inch gas pipeline. The alignment for the final 1500 ft down to the river on
the York County side, the crossing, and on to a point near the Columbia Gas Transmission Marietta
Compressor Station on the Lancaster County side follows the location of the existing Texas Eastern
pipeline (see Attachment 9).
2.5 Lancaster County
The remainder of the CPL South Marietta Extension Alternative route proceeds as directly as possible to
the Central Penn Line South Primary Route near Milepost 35 at the border of Lancaster and Lebanon
Counties. From the point where it crosses PA-283 to where it joins the current Central Penn Line South
Primary Route, this alternative route uses the same alignment as the originally proposed Central Penn
Line South Primary Route
6
. Like most of the current Central Penn Line South Primary Route, the
Lancaster County portion of the CPL South Marietta Extension Alternative offers few opportunities for
co-location with existing linear utilities.
2.5.1 Mount Joy Wellhead Protection Area
The originally proposed Central Penn Line South Primary Route passed to the west of Mount Joy and
was subsequently moved to the east of Mount Joy in order to accommodate concerns regarding
proximity of the route to the Mount Joy Wellhead Protection Area. At the point of closest approach, the
original Central Penn Line South Primary Route passed within 1000 ft of the Mount Joy Wellhead
Protection Area.

6
Drawing F-AM-CPLS-A, sheets 27-31 in Transcontinental Gas Pipeline Company, LLC submits Initial Draft Resource
Report 1 and a Summary of Alternatives Considered for the Atlantic Sunrise Project, filed in FERC Docket No. PF14-8
under Accession No. 20140430-5144 on 4/30/2014.
4

The CPL South Marietta Extension Alternative is significantly further to the west of the Mount Joy
Wellhead Protection Area than the original Central Penn Line South Primary Route was (see Attachment
10
7
). At the point of closest approach, the CPL South Marietta Extension Alternative is approximately
5,200 ft from the Mount Joy Wellhead Protection Area, increasing to approximately 6,200 ft of
separation at the northern end and 7,100 ft of separation at the southern end. The configuration of the
CPL South Marietta Extension Alternative relative to the Mount Joy Wellhead Protection Area allows
unlimited expansion of that protection area to the north, east and south without approaching the route.
It also allows the protection area to expand to the west an additional 3,000 ft (its approximate current
width) while still maintaining a separation of over 2,000 ft.
3 Metrics
Several major characteristics measured for each route are compared in the following tables. Table 1
presents the results for the CPL South Marietta Extension Alternative as described above, using the
Yorkana deviation. Table 2 shows the changes that would occur if it turns out the Yorkana deviation is
not required. All of the measurements for the CPL South Primary Route are for the portion of that route
that would be replaced by the CPL South Marietta Extension Alternative. It should be noted that nearly
all of the forested land crossed by the CPL South Marietta Extension Alternative is already completely or
substantially cleared, whereas all of the forested land crossed by the Central Penn Line South Primary
Route would have to be cleared.
As Table 1 shows, compared to the corresponding portion of the current Central Penn Line South
Primary Route, the CPL South Marietta Extension Alternative would deliver a 21.1 mile increase in total
length co-located with existing linear utilities.
In exchange, 4.8 additional miles of pipeline would have to be constructed. Although the CPL South
Marietta Extension Alternative is longer, it interconnects with the Transco mainline sufficiently further
south than the Central Penn Line South Primary Route for the distance between compressor stations
(proposed Station 610 and existing Station 195) to remain essentially unchanged between the two
alternatives.
As there are more than 4.8 additional miles of forest crossing on the CPL South Marietta Extension
Alternative, and there is a negligible amount of forest crossed by the CPL South Marietta Extension
Alternative in Lancaster County, the 4.8 additional miles would effectively be built in forested areas
along portions of the route co-located with the Texas Eastern Marietta Extension. This means that all of
those additional miles would be constructed using the existing 100 ft wide clearings remaining from the
construction of the Texas Eastern Marietta Extension, which would be of especially low impact given
that those areas are predominantly non-residential, non-agricultural, and would require at most a small
incremental additional clearing of trees entirely from non-interior forest.
As Table 2 shows, the CPL South Marietta Extension Alternative improves further if the Yorkana
deviation is not necessary. In this case, only 4.4 additional miles are required relative to the Central
Penn Line South Primary Route, and total co-located length increases by an additional mile.

7
The boundaries of the Mount Joy Wellhead Protection Area were verified by the zoning officers of Mount Joy
Borough and neighboring East Donegal Township on October 8, 2014.
5


Table 1. Route Metrics if Yorkana Deviation is Used
Metric CPL South
Primary
Route
CPL South
Marietta
Extension
Alternative
Change
Length of Corresponding Segment to Transco (miles)

35.0 39.8 +4.8
Length of Corresponding Segment to Station 195 (miles)

43.6 43.8 +0.2
Length Adjacent to Interstate Pipeline ROW (miles)

0.4 25.8 +25.4
Length Adjacent to Electric Transmission Line ROW (miles)

5.3 1.0 -4.3
Total Length Co-located (miles) 5.7 26.8 +21.1
Forested Land Crossed (miles)

4.4 9.9 +5.5
Forest Interior Crossed (miles)

0.3 0 -0.3
Agricultural Land Crossed (miles)

29.5 28.2 -1.3
Karst Terrain Crossed (miles)

17.2 10.7 -6.5



Table 2. Route Metrics if Yorkana Deviation is not Used
Metric CPL South
Primary
Route
CPL South
Marietta
Extension
Alternative
Change
Length of Corresponding Segment to Transco (miles)

35.0 39.4 +4.4
Length of Corresponding Segment to Station 195 (miles)

43.6 43.4 -0.2
Length Adjacent to Interstate Pipeline ROW (miles)

0.4 26.8 +26.4
Length Adjacent to Electric Transmission Line ROW (miles)

5.3 1.0 -4.3
Total Length Co-located (miles) 5.7 27.8 +22.1
Forested Land Crossed (miles)

4.4 9.3 +4.9
Forest Interior Crossed (miles)

0.3 0 -0.3
Agricultural Land Crossed (miles)

29.5 29.0 -0.5
Karst Terrain Crossed (miles)

17.2 10.7 -6.5


6

4 Additional Advantages
Much of the CPL South Marietta Extension Alternative could be considered a solved problem due to
the recent completion of the Texas Eastern Marietta Extension. Texas Eastern was able to build the
Marietta Extension pipeline facilities ahead of schedule and under budget
8
, indicating reduced execution
risk for like projects in the same area (notably, none of the forecast contingency expenses materialized).
The alignment sheets and archeological, historical, and geological survey data contained in the CP09-68
docket will no doubt be of value, potentially reducing many from-scratch efforts along this route to less
intensive reuse/augment/verify tasks.
While both routes contend with elevation changes throughout their southern extents, it is readily
apparent from Attachment 4 that the large portion of the CPL South Marietta Extension Alternative that
is co-located with the Texas Eastern Marietta Extension is characterized by long, straight pipeline
segments, whereas the corresponding portion of the Central Penn Line South Primary Route is
characterized by numerous changes in direction. It seems reasonable to anticipate that construction of
the CPL South Marietta Extension Alternative would require simpler site surveying and reduced and/or
simplified on-site pipe-forming.
5 Conclusion
The Commission encourages construction in existing rights-of-way on the basic theory that impacts,
small and large, would be minimized
9
. The CPL South Marietta Extension Alternative provides a
significant increase in total length co-located with existing rights-of-way in exchange for what appears to
be a minor increase in total project pipeline facilities. It seems entirely possible, indeed, probable, that
this alternative route would substantially minimize project impacts.
I ask that the Commission encourage the construction of the CPL South Marietta Extension Alternative
over the construction of the current Central Penn Line South Primary Route.
Please contact me with any questions or requests for reference material via phone at 484.437.9962 or
via email at kelsey@ieee.org .



8
Page 17 (Exhibit K, 15 of 20) of Texas Eastern Transmission, LP submits an updated statement of costs for the
TEMAX and TIME III Projects, filed in FERC Docket No. CP09-68 under Accession No. 20120229-5218 on 2/29/2012.
9
Quoted from Texas Eastern Transmission, LP, 131 FERC 61,164, at P 25, and as expressed by the
Commission numerous other times.

Attachment 1


Aerial imagery from September 2012 showing portion of Texas Eastern Marietta Extension construction zone near Craley Road

100 ft wide clearing created during
Marietta Extension construction
Road patch at Texas Eastern Marietta
Extension crossing Point
100 ft wide Marietta Extension
construction zone
Attachment 2


Google Street View image from September 2013 looking north along Texas Eastern Marietta Extension from Burkholder Road

Attachment 3


Google Street View image from October 2013 looking south along Texas Eastern Marietta Extension from Gun Club Road

Attachment 4




CPL South Marietta Extension Alternative and corresponding portion of CPL South Primary Route
CPL South Marietta Extension
Alternative
Transco Mainline
CPL South Primary Route
To Leidy
Line
CPL South Marietta Extension Alternative CPL South Primary Route Co-location with existing linear utilities
1. Transco Mainline Interconnect
2. Paralleling Texas Eastern Marietta Extension
3. Yorkana Deviation
4. Paralleling Texas Eastern Marietta Extension
5. Lancaster County Alignment
Attachment 5


CPL South Marietta Extension Alternative Transco mainline interconnect point

CPL South Marietta
Extension Alternative
Transco Mainline

Potential Locations for CPL South Marietta
Extension Alternative Transco Interconnect Facility
To Station 195

Attachment 6


Example of the difference between tracking the Texas Eastern Marietta Extension alignment and the adjacent power line

Adjacent power line
CPL South Marietta
Extension Alternative
Attachment 7


Potentially congested area near Bluestone Road in Yorkana Borough, York County

Electrical Transmission Towers
Texas Eastern
Marietta Extension
Potentially
Congested Area
Attachment 8


CPL South Marietta Extension Alternative deviation from the Texas Eastern Marietta Extension route in Lower Windsor Township,
near Yorkana Borough, York County
Departs Texas Eastern
Marietta Extension
Alignment Here
CPL South Marietta
Extension Alternative
Returns to Texas Eastern
Marietta Extension
Alignment Here
Texas Eastern
Marietta Extension
Potentially
Congested Area
Attachment 9


CPL South Marietta Extension Alternative Susquehanna River crossing

Departs Texas Eastern
Alignment Here
CPL South Marietta
Extension Alternative
Columbia Gas Transmission
Marietta Compressor Station
Parallels Existing 36
Texas Eastern Line
Texas Eastern Marietta Extension
Pig Launch/Recovery Facility
Attachment 10


CPL South Marietta Extension Alternative, northern portion, including distance from Mount Joy Wellhead Protection Area

CPL South Marietta
Extension Alternative
Current Central Penn Line
South Primary Route
Same as Original Central Penn Line
South Primary Route
Mount Joy Wellhead
Protection Area