Expanded ENF Report - 261upgrades - FINALpkg - 06.26.18 PDF

EXPANDED ENVIRONMENTAL NOTIFICATION
FORM – 261 UPGRADE PROJECTS,

AGAWAM, MA
JUNE 2018
PREPARED FOR
Tennessee Gas Pipeline Company,
L.L.C.
PREPARED BY
SWCA Environmental Consultants
June 29, 2018
Secretary Matthew Beaton

Executive Office of Energy and Environmental Affairs
Attn: MEPA Unit
100 Cambridge Street, Suite 900
Boston, MA 02144
RE: Expanded Environmental Notification Form

Tennessee Gas Pipeline Company, L.L.C.
261 Upgrade Projects, Agawam, MA
Dear Secretary Beaton:
Tennessee Gas Pipeline Company, L.L.C. (“Tennessee”) is a major transporter of natural gas to local
distribution companies and other end users in the northeast U.S. Tennessee plans to construct the 261
Upgrade Projects (“Projects”), which consist of the Line 261B Pipeline Looping Project (“Looping
Project”) and the Compressor Station 261 Horsepower Replacement Project (“HP Replacement Project”)
in Agawam, Massachusetts. The Projects are proposed in response to the request of Tennessee’s
customers, Columbia Gas of Massachusetts (“CMA”) and Holyoke Gas and Electric Department
(“Holyoke”), and will ensure safe, reliable, and continuous natural gas service to (a) CMA’s Greater
Springfield Service Territory, which provides natural gas to approximately 106,000 customers in 16
municipalities, and (b) Holyoke’s approximately 10,000 customers. The Massachusetts Department of
Public Utilities (“DPU”) recognizes the need for CMA’s additional capacity and recently approved
agreements with CMA, including Tennessee’s agreement, to support this need in Docket DPU 17-172.
The Looping Project, which includes 2.1 miles of 12-inch-diameter loop to be installed on Tennessee’s
existing 261B-100 pipeline, would provide an additional 17,000 dekatherms per day (“Dth/d”) of capacity
to transport incremental natural gas requested by Tennessee’s customers to the existing CMA distribution
system. The majority of the loop will be located within Tennessee’s existing pipeline corridors and will
replace an existing inactive 6-inch-diameter pipeline where feasible. Where the proposed loop deviates
from Tennessee’s existing pipeline corridors, the route is intended to minimize impacts to residences
and/or existing utility structures.
The HP Replacement Project involves the modernization of equipment at Compressor Station 261 (“CS
261”). The 10-inch 261B-100 pipeline and the aforementioned proposed loop begin at CS 261. The HP
Replacement Project involves removing two existing older units (a Solar Saturn installed in 1965 and a
Solar Centaur installed in 1991) and installing a new Solar Taurus 70 unit. The new Solar Taurus 70 unit
is better designed to meet peak flow operating conditions resulting in more reliable service. This design
will provide higher pressure into the 10-inch 261B-100 pipeline, and will increase the operational
reliability of providing approximately 30,800 Dth/d of capacity to serve Holyoke’s customers’ needs at
the nearest delivery point on Holyoke’s distribution system (Agawam).
The Projects will alter more than 25 acres of land during construction, and will therefore exceed the
review thresholds set forth by the Massachusetts Environmental Policy Act (“MEPA”) regulations
relative to Land requiring an Environmental Notification Form and other MEPA review if the Secretary
of Energy and Environmental Affairs so requires. Further, construction of the Project will affect more
than one acre of bordering vegetated wetlands and, as such, exceeds the MEPA review thresholds for
preparation of a mandatory Environmental Impact Report (“EIR”) relative to Wetlands and Waterways.
However, the vast majority of these wetland impacts will be temporary in nature, and there will be no net
EXPANDED ENVIRONMENTAL NOTIFICATION FORM
TABLE OF CONTENTS
Environmental Notification Form
Attachment 1 – USGS Topographic Maps
Attachment 2 – Map Books
Attachment 3 – Environmental Constraints Maps
Attachment 4 – ENF Distribution List
Attachment 5 – Permit and Consultation List
Attachment 6 – Expanded Environmental Notification Form Narrative

Commonwealth of Massachusetts
Executive Office of Energy and Environmental Affairs
Massachusetts Environmental Policy Act (MEPA) Office
Environmental Notification Form

For Office Use Only
EEA#:
MEPA Analyst:
The information requested on this form must be completed in order to submit a document
electronically for review under the Massachusetts Environmental Policy Act, 301 CMR 11.00.
Project Name: 261 Upgrade Projects

Street Address: Multiple public ways and existing pipeline right-of-way.
Municipality: Agawam Watershed: Connecticut River
Universal Transverse Mercator Latitude: Start: 42.034291˚; End: 42.062360˚
Coordinates: Start: 18T 695819.37 m E Longitude: Start:-72.634335˚; End: -72.640291˚
4656291.51 m N
End: 18T 695240.14 m E 4659393.01 m N
Estimated commencement date: Estimated completion date: November 2020
March 2020
Project Type: Natural gas infrastructure Status of project design: 75 %complete
Proponent: Tennessee Gas Pipeline Company, L.L.C.
Street Address: 1001 Louisiana Street, Suite 1000
Municipality: Houston State: TX Zip Code: 77002
Name of Contact Person: Rebecca Weissman, PWS
Firm/Agency: SWCA Environmental Street Address: 15 Research Drive
Municipality: Amherst State: MA Zip Code: 01002
Phone: (413) 256-0202 Fax: E-mail:
Rebecca.weissman@swca.com
Does this project meet or exceed a mandatory EIR threshold (see 301 CMR 11.03)?
Yes No
If this is an Expanded Environmental Notification Form (ENF) (see 301 CMR 11.05(7)) or a
Notice of Project Change (NPC), are you requesting:
a Single EIR? (see 301 CMR 11.06(8)) Yes No
a Special Review Procedure? (see 301CMR 11.09) Yes No
a Waiver of mandatory EIR? (see 301 CMR 11.11) Yes No
a Phase I Waiver? (see 301 CMR 11.11) Yes No
(Note: Greenhouse Gas Emissions analysis must be included in the Expanded ENF.)
Which MEPA review threshold(s) does the project meet or exceed (see 301 CMR 11.03)?
Wetlands, Waterways & Tidelands; Land
Which State Agency Permits will the project require?
401 Water Quality Certification; Non-major Comprehensive Plan Approval; Order of
Conditions under Wetlands Protection Act; Conservation & Management Permit
Identify any financial assistance or land transfer from an Agency of the Commonwealth,
including the Agency name and the amount of funding or land area in acres: Not applicable
Effective January 2011

Summary of Project Size Existing Change Total
& Environmental Impacts
LAND
Total site acreage 36.91 ac (MA only)
New acres of land altered 18.40 acres (temp)

6.64 acres (perm)1
Acres of impervious area N/A (linear project) 0.06 N/A
Square feet of new bordering 289,000 sf (temporary)

vegetated wetlands alteration 38,300 sf (veg cover
type conversion)
0 sf (loss or fill)
Square feet of new other wetland IVW = 7,800 sf (temp.)
alteration LUWW=6,500 sf
(temp)
RFA=200,000 sf
(temp) and 71,900 sf
(veg cover type
conversion)
Acres of new non-water dependent
0
use of tidelands or waterways
STRUCTURES
Gross square footage N/A (linear project)2 2,470 sf N/A
Number of housing units N/A N/A N/A
Maximum height (feet) N/A 25.5 feet N/A
TRANSPORTATION
Vehicle trips per day N/A N/A N/A
Parking spaces N/A N/A N/A
WASTEWATER
Water Use (Gallons per day) N/A N/A N/A
Water withdrawal (GPD) N/A N/A N/A
Wastewater generation/treatment N/A N/A N/A

(GPD)
Length of water mains (miles) N/A N/A N/A
Length of sewer mains (miles) N/A N/A N/A
Has this project been filed with MEPA before?

Yes (EEA # ) No
Has any project on this site been filed with MEPA before?
Yes (EEA # 15205 ) No; Portions of the HP Replacement Project and the
Hickory Street Yard are located on the same parcel as portions of the CT Expansion Project
(EEA #15205).
1 Represents land disturbance outside Tennessee’s existing rights-of-way.
2 Tennessee has other structures at CS 261 that are not applicable to this Project.
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GENERAL PROJECT INFORMATION – all proponents must fill out this section
PROJECT DESCRIPTION:
The proposed 261 Upgrade Projects (“Projects”) consist of (i) the Line 261B Pipeline Looping Project (“Looping
Project”), which involves approximately 2.1 miles of pipeline loop, and (ii) the Compressor Station 261
Horsepower Replacement Project (“HP Replacement Project”), which involves equipment upgrades at
Tennessee Gas Pipeline Company, L.L.C.’s (“Tennessee”) existing Compressor Station 261 (“CS 261”). Both
projects are located in Agawam, Massachusetts. Figure 2-1 in Appendix A depicts the general location of the
Projects’ components.
The Looping Project consists of installation of 12-inch-diameter pipeline installed adjacent to Tennessee’s
existing 8-inch-diameter 261BP-100 pipeline and/or Tennessee’s existing 10-inch-diameter 261B-100 pipeline,
to the extent practicable. Where the pipeline loop will be installed adjacent to the 261B-100 pipeline,
Tennessee proposes to remove an inactive 6-inch-diameter pipeline from this location and replace it with the
12-inch-diameter loop upgrade. The proposed HP Replacement Project involves the replacement of two
existing turbine compressor units with one new, cleaner-burning turbine compressor unit and auxiliary facilities.
These Projects are proposed in response to the request of Tennessee’s customers, Columbia Gas of
Massachusetts (“CMA”) and the Holyoke Gas and Electric Department (“Holyoke”). The Projects are separate
and distinct and will have independent utility to Tennessee’s customers; however, for Massachusetts
Environmental Policy Act (“MEPA”) review purposes, Tennessee is including both in this Expanded
Environmental Notification Form (“EENF”).
A separate project to serve CMA is the construction of a new meter station in Longmeadow, Massachusetts.
The Longmeadow Meter Station will provide a needed delivery point for CMA (the nearest delivery points are in
Agawam and East Longmeadow), specifically on the east side of the Connecticut River.1 The Longmeadow
Meter Station will enhance system reliability to 55,000 existing CMA customers and supports the ability of CMA
to serve future customers. The Longmeadow Meter Station is scheduled to be constructed beginning in June
2019 and placed into service in November 2019 (CMA requires this additional point of delivery to be operational
by November 2019). The volume of natural gas supplied to the proposed Longmeadow Meadow Station will
come from Tennessee’s existing mainline and is not influenced by the Looping Project or HP Replacement
Project, each described above. Tennessee provides this description of the new meter station for informational
purposes only as the new meter station does not trigger any MEPA review thresholds and has independent
utility from the Looping Project and HP Replacement Project, each described above. The Longmeadow Meter
Station is separate and distinct from the Projects submitted with this EENF (and Tennessee reserves all rights
with respect to this position); however, Tennessee includes this description to avoid any claim regarding
segmentation.
ALTERNATIVES:
Tennessee reviewed construction, fuel source, system, and the No-Action alternatives, and determined that the
proposed Projects, as designed, represent the preferred alternative. If the proposed Projects are not
constructed to meet customer demand (i.e., the No-Action Alternative is selected), the market served by the
customers that have executed binding precedent agreements for all of the Projects’ capacity may experience
energy shortages in times of peak demand or users may revert to the consumption of alternative fuels including
oil. Use of alternative fuels to supply the energy needs of Tennessee’s natural gas customers is not the best
practicable alternative as compared to the use of cleaner-burning natural gas. In addition, although energy
conservation is a valuable measure as part of an overall energy plan, energy conservation alone is not a
solution to the current energy demand of consumers served by these Projects.
As discussed in Chapter 3 of Attachment 6, Tennessee conducted a detailed system alternatives analysis and
route analysis, including consideration of efficiency improvements, a lift and relay option, an uprating option,
and pipeline looping and compression options. The detailed system alternatives analysis allowed the Projects’
designers to select the best configuration of the proposed facilities, including preferred routes and siting for the
proposed Looping Project, to meet the needs of the market. The HP Replacement Project and 2.1-mile, 12-
-3-
inch-diameter Looping Project were ultimately selected as the Preferred Alternatives because they meet the
customers’ objectives, allow for the use of existing pipeline corridors and compressor station facilities, and
minimize impacts to environmental resources and landowners.
MITIGATION:
Chapter 4 of the Project Narrative of this Expanded ENF provides detailed information on mitigation measures
proposed for the Project. A summary of these measures includes the following:
• Approximately 72 percent of the proposed pipeline loop will be located within the existing easement of
Tennessee’s 261B-100 Line, and an additional 17 percent will be co-located with other utility and
roadway corridors or Tennessee’s existing Compressor Station 261 facility.
• The Projects will modify Tennessee’s existing compressor station facility rather than construct a new
greenfield facility.
• Tennessee will develop and adhere to a Project-specific Environmental Construction Management Plan
(“ECMP”) that will incorporate the Federal Energy Regulatory Commission’s (“FERC’s”) Upland Erosion
Control, Revegetation, and Maintenance Plan (“FERC Plan”), Wetland and Waterbody Construction
and Mitigation Procedures (“FERC Procedures”), and all applicable Project plans, permits, and
clearances, and specifies other best management practices (“BMPs”) that will be used to avoid and
minimize adverse environmental impacts;
• Tennessee will use specialized construction techniques and erosion control procedures to avoid and
minimize Project construction impacts, including the use of timber mats, installation of sediment
barriers, and flumed or dam and pump construction methods to minimize impacts to wetland resource
areas at stream crossings:
• Tennessee will employ an on-site environmental inspector to ensure compliance with the Project’s
CMP, which incorporates the FERC Plan and Procedures, as well as federal, state, and local
environmental permit conditions;
• Tennessee will regrade and reseed all disturbed upland and wetland resource areas, except at new
permanent aboveground ancillary facilities;
• Tennessee will consult with the Natural Heritage and Endangered Species Program (“NHESP”) to
develop mitigation measures for crossing of priority habitats of rare species;
• Tennessee will consult with the Massachusetts Department of Environmental Protection (“MassDEP”),
U.S. Army Corps of Engineers (“USACE”), and the Agawam Conservation Commission to develop a
mitigation plan for impacts to wetlands and waterbodies;
• Tennessee will consult with the Massachusetts Historical Commission (“MHC”), FERC, and the
federally recognized American Indian tribes (“Tribes”) to avoid or minimize any adverse impacts to
significant archaeological resources;
• Tennessee will limit construction to daylight hours, unless limited nighttime construction is required due
to site conditions, specialized construction techniques, and/or weather-related events;
• Construction vehicles and equipment will be equipped with mufflers and will be maintained in
accordance with manufacturers’ recommendations to minimize air and noise impacts during
construction; and
• The proposed Taurus 70 turbine will be equipped with custom inlet and exhaust silencers and lube oil
coolers, and Building D piping will be acoustically lagged to reduce the radiated noise transmitted
through the walls of the piping.
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If the project is proposed to be constructed in phases, please describe each phase:
The Looping Project will commence with tree clearing in March 2020, followed by pipeline installation beginning
in June 2020, pending receipt of all applicable permits. The Looping Project is expected to be in-service in
November 2020. The HP Replacement Project is expected to commence construction in May 2020 and be in-
service in November 2020.
AREAS OF CRITICAL ENVIRONMENTAL CONCERN:

Is the project within or adjacent to an Area of Critical Environmental Concern?
Yes (Specify__________________________________)
No
if yes, does the ACEC have an approved Resource Management Plan? ___ Yes ___ No;
If yes, describe how the project complies with this plan.
_______________________________________________________
Will there be stormwater runoff or discharge to the designated ACEC? ___ Yes ___ No;
If yes, describe and assess the potential impacts of such stormwater runoff/discharge to the designated ACEC.
_________________________________________________
RARE SPECIES:
Does the project site include Estimated and/or Priority Habitat of State-Listed Rare Species? (see
http://www.mass.gov/dfwele/dfw/nhesp/regulatory_review/priority_habitat/priority_habitat_home.htm)
Yes (Specify_PH 780/EH 643 ______________________ ) No
HISTORICAL /ARCHAEOLOGICAL RESOURCES:

Does the project site include any structure, site or district listed in the State Register of Historic Place
or the inventory of Historic and Archaeological Assets of the Commonwealth?
Yes (Specify__________________________________ ) No
If yes, does the project involve any demolition or destruction of any listed or inventoried historic
or archaeological resources? Yes (Specify__________________________________) No
Tennessee’s cultural resource consultant, The Public Archaeology Laboratory, Inc. (PAL), has conducted a
cultural resources due diligence, sensitivity assessment, and archaeological and historic architectural
properties surveys, under permit from the Massachusetts Historical Commission and pursuant the Section 106
of the National Historic Preservation Act of 1966, as amended. See Section 4.7 of the EENF narrative for
additional information.
WATER RESOURCES:
Is there an Outstanding Resource Water (ORW) on or within a half-mile radius of the project site? ___Yes
_X__No;
if yes, identify the ORW and its location. ______________________________________________
(NOTE: Outstanding Resource Waters include Class A public water supplies, their tributaries, and bordering
wetlands; active and inactive reservoirs approved by MassDEP; certain waters within Areas of Critical
Environmental Concern, and certified vernal pools. Outstanding resource waters are listed in the
Surface Water Quality Standards, 314 CMR 4.00.)
Are there any impaired water bodies on or within a half-mile radius of the project site? ___Yes X No; if yes,
identify the water body and pollutant(s) causing the impairment:____________________________________.
Is the project within a medium or high stress basin, as established by the Massachusetts
Water Resources Commission? ___Yes _X_No
STORMWATER MANAGEMENT:
Generally describe the project's stormwater impacts and measures that the project will take to comply
with the standards found in MassDEP's Stormwater Management Regulations: The Projects will have negligible
impacts on stormwater. The pipeline facilities will be buried below-grade and no new impervious surfaces are
proposed as part of the Looping Project. In addition, there will be no change in grade, slope or elevation from
the Looping Project, as all areas will be returned to pre-construction conditions after construction is complete.
The HP Replacement Project will include the construction of a 2,470 square feet pre-fabricated building in a
vegetated upland area, requiring minor grading to create a level surface. This additional impervious area and
grading is negligible and any additional runoff will be incorporated into the site’s existing stormwater runoff.
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MASSACHUSETTS CONTINGENCY PLAN:
Has the project site been, or is it currently being, regulated under M.G.L.c.21E or the Massachusetts
Contingency Plan? Yes ___ No _X__ ; if yes, please describe the current status of the site (including Release
Tracking Number (RTN), cleanup phase, and Response
Action Outcome classification):__________________
Is there an Activity and Use Limitation (AUL) on any portion of the project site? Yes ___ No _X_;
if yes, describe which portion of the site and how the project will be consistent with the AUL:
_____________________.
Are you aware of any Reportable Conditions at the property that have not yet been assigned an RTN?
Yes ___ No _X_ ; if yes, please describe:____________________________________
SOLID AND HAZARDOUS WASTE:
If the project will generate solid waste during demolition or construction, describe alternatives considered
for re-use, recycling, and disposal of, e.g., asphalt, brick, concrete, gypsum, metal, wood: Solid waste will be
generated from construction and removal of the existing 6-inch pipeline. All construction waste will be disposed
in accordance with applicable state and federal regulations.
(NOTE: Asphalt pavement, brick, concrete and metal are banned from disposal at Massachusetts
landfills and waste combustion facilities and wood is banned from disposal at Massachusetts landfills.
See 310 CMR 19.017 for the complete list of banned materials.)
Will your project disturb asbestos containing materials? Yes _X__ No ___ ;
if yes, please consult state asbestos requirements at http://mass.gov/MassDEP/air/asbhom01.htm
Describe anti-idling and other measures to limit emissions from construction equipment: _Tennessee will utilize
standard construction procedures to limit emissions, which include no unnecessary idling and low-sulfur diesel
fuel.
DESIGNATED WILD AND SCENIC RIVER:
Is this project site located wholly or partially within a defined river corridor of a federally
designated Wild and Scenic River or a state designated Scenic River? Yes ___ No _X_ ;
if yes, specify name of river and designation:
If yes, does the project have the potential to impact any of the “outstandingly remarkable”
resources of a federally Wild and Scenic River or the stated purpose of a state designated Scenic River?
Yes ___ No ___ ; if yes, specify name of river and designation: _____________;
if yes, will the project will result in any impacts to any of the designated “outstandingly remarkable”
resources of the Wild and Scenic River or the stated purposes of a Scenic River.
Yes ___ No ___ ;
if yes,describe the potential impacts to one or more of the “outstandingly remarkable” resources or
stated purposes and mitigation measures proposed.
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ATTACHMENTS:
1. List of all attachments to this document. Table of Contents
2. U.S.G.S. map (good quality color copy, 8-½ x 11 inches or larger, at a scale of 1:24,000)
indicating the project location and boundaries. Attachment 1
3.. Plan, at an appropriate scale, of existing conditions on the project site and its immediate
environs, showing all known structures, roadways and parking lots, railroad rights-of-way,
wetlands and water bodies, wooded areas, farmland, steep slopes, public open spaces, and
major utilities. Attachment 2
4 Plan, at an appropriate scale, depicting environmental constraints on or adjacent to the
project site such as Priority and/or Estimated Habitat of state-listed rare species, Areas of
Critical Environmental Concern, Chapter 91 jurisdictional areas, Article 97 lands,
wetland resource area delineations, water supply protection areas, and historic resources
and/or districts. Attachment 3
5. Plan, at an appropriate scale, of proposed conditions upon completion of project (if
construction of the project is proposed to be phased, there should be a site plan showing
conditions upon the completion of each phase). Attachment 2
6. List of all agencies and persons to whom the proponent circulated the ENF, in accordance
with 301 CMR 11.16(2). Attachment 4
7. List of municipal and federal permits and reviews required by the project, as applicable.
Attachment 5
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LAND SECTION – all proponents must fill out this section
I. Thresholds / Permits
A. Does the project meet or exceed any review thresholds related to land (see 301 CMR 11.03(1)
_X__ Yes ___ No; if yes, specify each threshold:
II. Impacts and Permits

A. Describe, in acres, the current and proposed character of the project site, as follows:
Existing Change Total
Footprint of buildings __N/A __ __0.06 ac__ __N/A___
Internal roadways __N/A___ __N/A___ __N/A___
Parking and other paved areas __N/A___ __N/A___ __N/A___
Other altered areas __N/A___ __N/A___ __N/A___
Undeveloped areas __N/A___ __N/A___ __N/A___
Total: Project Site Acreage __N/A___ __0.06 ac___ __N/A___
B. Has any part of the project site been in active agricultural use in the last five years?
_X__ Yes ___ No; if yes, how many acres of land in agricultural use (with prime state or
locally important agricultural soils) will be converted to nonagricultural use? 3.3 acres of
temporary conversion
C. Is any part of the project site currently or proposed to be in active forestry use?
___ Yes _X__ No; if yes, please describe current and proposed forestry activities and
indicate whether any part of the site is the subject of a forest management plan approved by
the Department of Conservation and Recreation:
D. Does any part of the project involve conversion of land held for natural resources purposes in
accordance with Article 97 of the Amendments to the Constitution of the Commonwealth to
any purpose not in accordance with Article 97? ___ Yes _X__ No; if yes, describe:
E. Is any part of the project site currently subject to a conservation restriction, preservation
restriction, agricultural preservation restriction or watershed preservation restriction? ___
Yes__X_ No; if yes, does the project involve the release or modification of such restriction?
___ Yes ___ No; if yes, describe:
F. Does the project require approval of a new urban redevelopment project or a fundamental change
in an existing urban redevelopment project under M.G.L.c.121A? ___ Yes _X__ No; if yes,
describe:
G. Does the project require approval of a new urban renewal plan or a major modification of an
existing urban renewal plan under M.G.L.c.121B? Yes ___ No _X__; if yes, describe:
III. Consistency
A. Identify the current municipal comprehensive land use plan
Title: Town of Agawam Community Development Plan Date July 2004
B. Describe the project’s consistency with that plan with regard to:
1) economic development One of the stated goals on Page 42 of the Town of
Agawam Economic Development Plan (2010) is the continued investment in infrastructure
improvements to address the present and future needs of commercial and industrial properties.
The Projects will support this goal by providing needed natural gas infrastructure to support the
demands of the region.
2) adequacy of infrastructure Page 16 of the Community Development Plan states
that the Town of Agawam is experiencing population growth that is putting a strain on roadways
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and sewer infrastructure. The Projects will have no long-term negative impacts on this
infrastructure. Short-term effects on roadways may occur during construction due to increased
use by construction and personnel vehicles.
3) open space impacts N/A - Projects will not impact public or private protected
open spaces
4) compatibility with adjacent land uses By co-locating the Projects with existing
natural gas and electric transmission line facilities, the Projects are compatible with adjacent
land uses, which includes existing utility infrastructure.
C. Identify the current Regional Policy Plan of the applicable Regional Planning Agency (RPA)
RPA: Pioneer Valley Planning Commission
Title Valley Vision 4: The Regional Land Use Plan for the Pioneer Valley
Date February 2014
D. Describe the project’s consistency with that plan with regard to:
1) economic development The Pioneer Valley Planning Commission’s “Plan for Progress”
(2015) is the region’s economic development strategy. On page 20 of this Plan, a stated goal
is to “support public and private sector funding to replace the region’s aging underground
infrastructure, including, water, sewer, electric, and natural gas conduits.” One of the proposed
strategies for accomplishing this goal is to “to increase the supply of natural gas” (page 21).
The proposed Projects directly support this goal by increasing natural gas supply to the region.
2) adequacy of infrastructure One of the stated goals of Valley Vision 4 is to build and
maintain needed infrastructure to promote smart, sustainable growth, and to upgrade
infrastructure in urban areas. The Projects will provide a needed upgrade to Tennessee’s
infrastructure supporting the Greater Springfield Service Territory, and will be constructed in a
manner that minimizes impacts to residences and the environment.
3) open space impacts N/A - the Projects will not impact public or private protected open
spaces.
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RARE SPECIES SECTION
A. Will the project meet or exceed any review thresholds related to rare species or habitat (see
301 CMR 11.03(2))? _ __ Yes _ X __ No; if yes, specify, in quantitative terms:
(NOTE: If you are uncertain, it is recommended that you consult with the Natural Heritage and
Endangered Species Program (NHESP) prior to submitting the ENF.)
B. Does the project require any state permits related to rare species or habitat? _ X _ Yes _ No
Project will require review by NHESP, due to activities in rare species habitat.
C. Does the project site fall within mapped rare species habitat (Priority or Estimated Habitat?) in the
current Massachusetts Natural Heritage Atlas (attach relevant page)? _X__ Yes ___ No.
D. If you answered "No" to all questions A, B and C, proceed to the Wetlands, Waterways, and
Tidelands Section. If you answered "Yes" to either question A or question B, fill out the
remainder of the Rare Species section below.

A. Does the project site fall within Priority or Estimated Habitat in the current Massachusetts Natural
Heritage Atlas (attach relevant page)? _X__ Yes ___ No. If yes,
1. Have you consulted with the Division of Fisheries and Wildlife Natural Heritage and
Endangered Species Program (NHESP)? _X__Yes ___No; if yes, have you received a
determination as to whether the project will result in the “take” of a rare species? ___
Yes ___ No; if yes, attach the letter of determination to this submission.
2. Will the project "take" an endangered, threatened, and/or species of special concern in
accordance with M.G.L. c.131A (see also 321 CMR 10.04)? _X_ Yes ___ No; if yes, provide
a summary of proposed measures to minimize and mitigate rare species impacts
Tennessee is consulting with NHESP, and the Project will require NHESP Project Review.
Tennessee will develop mitigation measures through consultation with NHESP.
3. Which rare species are known to occur within the Priority or Estimated Habitat?
Eastern box turtle and Eastern wormsnake
4. Has the site been surveyed for rare species in accordance with the Massachusetts
Endangered Species Act? ___ Yes __X_ No
The area has been previously surveyed for other projects and the species are known to
occur in this area. Species-specific surveys are anticipated in 2019.
4. If your project is within Estimated Habitat, have you filed a Notice of Intent or received an
Order of Conditions for this project? ___ Yes _X__ No; if yes, did you send a copy of the
Notice of Intent to the Natural Heritage and Endangered Species Program, in accordance
with the Wetlands Protection Act regulations? ___ Yes _ __ No
A Notice of Intent is anticipated to be filed with the Agawam Conservation Commission in
July 2018. A copy of the Notice of Intent will be filed with the NHESP at that time.
B. Will the project "take" an endangered, threatened, and/or species of special concern in
accordance with M.G.L. c.131A (see also 321 CMR 10.04)? _ X_ Yes _ __ No; if yes,
provide a summary of proposed measures to minimize and mitigate impacts to significant
habitat:
Tennessee is consulting with NHESP and the Project will require NHESP Project Review.
Tennessee will develop mitigation measures through consultation with NHESP.
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WETLANDS, WATERWAYS, AND TIDELANDS SECTION
A. Will the project meet or exceed any review thresholds related to wetlands, waterways, and
tidelands (see 301 CMR 11.03(3))? _X__ Yes ___ No; if yes, specify, in quantitative terms:
B. Does the project require any state permits (or a local Order of Conditions) related to wetlands,
waterways, or tidelands? _X__ Yes ___ No; if yes, specify which permit:
C. If you answered "No" to both questions A and B, proceed to the Water Supply Section. If you
answered "Yes" to either question A or question B, fill out the remainder of the Wetlands,
Waterways, and Tidelands Section below.
II. Wetlands Impacts and Permits

A. Does the project require a new or amended Order of Conditions under the Wetlands Protection
Act (M.G.L. c.131A)? _X_ Yes __ No; if yes, has a Notice of Intent been filed? ___ Yes _X_ No;
if yes, list the date and MassDEP file number: ______; if yes, has a local Order of Conditions
been issued? ___ Yes ___ No; Was the Order of Conditions appealed? ___ Yes ___ No. Will
the project require a Variance from the Wetlands regulations? ___ Yes _X__ No.
A Notice of Intent is planned to be filed under the Wetlands Protection Act in July 2018.
B. Describe any proposed permanent or temporary impacts to wetland resource areas located on
the project site:
C. Estimate the extent and type of impact that the project will have on wetland resources, and
indicate whether the impacts are temporary or permanent:
Coastal Wetlands Area (square feet) or Temporary or

Length (linear feet) Permanent Impact?
Land Under the Ocean _______0_________ ___N/A_____________

Designated Port Areas _______0_________ ___N/A_____________
Coastal Beaches _______0_________ ___N/A_____________
Coastal Dunes _______0_________ ___N/A_____________
Barrier Beaches _______0_________ ___N/A_____________
Coastal Banks _______0_________ ___N/A_____________
Rocky Intertidal Shores _______0_________ ___N/A_____________
Salt Marshes _______0_________ ___N/A_____________
Land Under Salt Ponds _______0_________ ___N/A_____________
Land Containing Shellfish _______0_________ ___N/A_____________
Fish Runs _______0_________ ___N/A_____________
Land Subject to Coastal Storm Flowage _______0_________ ___N/A_____________
Inland Wetlands
Bank (lf) ______1,001 lf_____ Temporary________
Bordering Vegetated Wetlands 289,700 sf Temporary
______38,300 sf___ Veg Cover Type Conversion
Isolated Vegetated Wetlands _______7,800 sf___ Temporary_________
Land under Water ______6,500 sf___ Temporary________
Isolated Land Subject to Flooding _________0_______ ____________________
Bordering Land Subject to Flooding _________0_______ ____________________
Riverfront Area 200,000 sf Temporary
_______71,900 sf____ Veg Cover Type Conversion
- 11 -
D. Is any part of the project:
1. proposed as a limited project? _X__ Yes ___ No; if yes, what is the area (in sf)?_All of
Looping Project (approximately 320,000 square feet of BVW (temporary plus vegetation cover type
conversion)__
2. the construction or alteration of a dam? ___ Yes _X__ No; if yes, describe:
3. fill or structure in a velocity zone or regulatory floodway? ___ Yes _X__ No
4. dredging or disposal of dredged material? ___ Yes _X__ No; if yes, describe the volume
of dredged material and the proposed disposal site:
5. a discharge to an Outstanding Resource Water (ORW) or an Area of Critical
Environmental Concern (ACEC)? ___ Yes __ X _ No
6. subject to a wetlands restriction order? ___ Yes _ X _ No; if yes, identify the area (in sf):
7. located in buffer zones? _X__Yes ___No; if yes, how much (in sf) ______
E. Will the project:

1. be subject to a local wetlands ordinance or bylaw? ___ Yes _X__ No
2. alter any federally-protected wetlands not regulated under state law? _ X _ Yes ___ No; if
yes, what is the area (sf)? 7,800 sf
III. Waterways and Tidelands Impacts and Permits

A. Does the project site contain waterways or tidelands (including filled former tidelands) that are
subject to the Waterways Act, M.G.L.c.91? ___ Yes _X_ No; if yes, is there a current Chapter 91
License or Permit affecting the project site? ___ Yes ___ No; if yes, list the date and license or
permit number and provide a copy of the historic map used to determine extent of filled
tidelands:
B. Does the project require a new or modified license or permit under M.G.L.c.91? ___ Yes _X_
No; if yes, how many acres of the project site subject to M.G.L.c.91 will be for non-water-
dependent use? Current ___ Change ___ Total ___
If yes, how many square feet of solid fill or pile-supported structures (in sf)?
C. For non-water-dependent use projects, indicate the following:

Area of filled tidelands on the site:____N/A_________________
Area of filled tidelands covered by buildings:___N/A_________
For portions of site on filled tidelands, list ground floor uses and area of each use:
_____N/A_________
Does the project include new non-water-dependent uses located over flowed tidelands?
Yes ___ No _X__
Height of building on filled tidelands___N/A_____________
Also show the following on a site plan: Mean High Water, Mean Low Water, Water-
dependent Use Zone, location of uses within buildings on tidelands, and interior and
exterior areas and facilities dedicated for public use, and historic high and historic low
water marks.
D. Is the project located on landlocked tidelands? ___ Yes _X_ No; if yes, describe the project’s
impact on the public’s right to access, use and enjoy jurisdictional tidelands and describe
measures the project will implement to avoid, minimize or mitigate any adverse impact:
E. Is the project located in an area where low groundwater levels have been identified by a
municipality or by a state or federal agency as a threat to building foundations? ___Yes
_X_ No; if yes, describe the project’s impact on groundwater levels and describe
measures the project will implement to avoid, minimize or mitigate any adverse impact:
F. Is the project non-water-dependent and located on landlocked tidelands or waterways or

- 12 -
tidelands subject to the Waterways Act and subject to a mandatory EIR? ___ Yes _X__
No;
(NOTE: If yes, then the project will be subject to Public Benefit Review and
Determination.)
G. Does the project include dredging? ___ Yes _X__ No; if yes, answer the following questions:
What type of dredging? Improvement ___ Maintenance ___ Both ____
What is the proposed dredge volume, in cubic yards (cys) _________
What is the proposed dredge footprint ____length (ft) ___width (ft)____depth (ft);
Will dredging impact the following resource areas?
Intertidal Yes__ No__; if yes, ___ sq ft
Outstanding Resource Waters Yes__ No__; if yes, ___ sq ft
Other resource area (i.e. shellfish beds, eel grass beds) Yes__ No__; if yes __
sq ft
If yes to any of the above, have you evaluated appropriate and practicable steps
to: 1) avoidance; 2) if avoidance is not possible, minimization; 3) if either
avoidance or minimize is not possible, mitigation?
If no to any of the above, what information or documentation was used to support
this determination?
Provide a comprehensive analysis of practicable alternatives for improvement dredging in
accordance with 314 CMR 9.07(1)(b). Physical and chemical data of the
sediment shall be included in the comprehensive analysis.
Sediment Characterization
Existing gradation analysis results? __Yes ___No: if yes, provide results.
Existing chemical results for parameters listed in 314 CMR 9.07(2)(b)6? ___Yes
____No; if yes, provide results.
Do you have sufficient information to evaluate feasibility of the following management
options for dredged sediment? If yes, check the appropriate option.
Beach Nourishment ___

Unconfined Ocean Disposal ___
Confined Disposal:
Confined Aquatic Disposal (CAD) ___
Confined Disposal Facility (CDF) ___
Landfill Reuse in accordance with COMM-97-001 ___
Shoreline Placement ___
Upland Material Reuse____
In-State landfill disposal____
Out-of-state landfill disposal ____
(NOTE: This information is required for a 401 Water Quality Certification.)
IV. Consistency:
A. Does the project have effects on the coastal resources or uses, and/or is the project located
within the Coastal Zone? ___ Yes _X__ No; if yes, describe these effects and the projects
consistency with the policies of the Office of Coastal Zone Management:
B. Is the project located within an area subject to a Municipal Harbor Plan? ___ Yes _X__ No; if
yes, identify the Municipal Harbor Plan and describe the project's consistency with that plan:
- 13 -
WATER SUPPLY SECTION
A. Will the project meet or exceed any review thresholds related to water supply (see 301 CMR
11.03(4))? ___ Yes _X__ No; if yes, specify, in quantitative terms:
B. Does the project require any state permits related to water supply? ___ Yes _ X __ No; if yes,
specify which permit:
C. If you answered "No" to both questions A and B, proceed to the Wastewater Section. If you
answered "Yes" to either question A or question B, fill out the remainder of the Water Supply Section
below.

A. Describe, in gallons per day (gpd), the volume and source of water use for existing and proposed
activities at the project site:
Municipal or regional water supply ________ ________ ________
Withdrawal from groundwater ________ ________ ________
Withdrawal from surface water ________ ________ ________
Interbasin transfer ________ ________ ________
(NOTE: Interbasin Transfer approval will be required if the basin and community where the proposed
water supply source is located is different from the basin and community where the wastewater
from the source will be discharged.)
B. If the source is a municipal or regional supply, has the municipality or region indicated that there
is adequate capacity in the system to accommodate the project? ___ Yes ___ No
C. If the project involves a new or expanded withdrawal from a groundwater or surface water
source, has a pumping test been conducted? ___ Yes ___ No; if yes, attach a map of the drilling
sites and a summary of the alternatives considered and the results. ______________
D. What is the currently permitted withdrawal at the proposed water supply source (in gallons per
day)? Will the project require an increase in that withdrawal? ___Yes ___No; if yes, then how
much of an increase (gpd)? ____________________
E. Does the project site currently contain a water supply well, a drinking water treatment facility,
water main, or other water supply facility, or will the project involve construction of a new facility?
___ Yes ___No. If yes, describe existing and proposed water supply facilities at the project site:
Permitted Existing Avg Project Flow Total

Flow Daily Flow
Capacity of water supply well(s) (gpd) _______ ________ ________ ________
Capacity of water treatment plant (gpd) _______ ________ ________ ________
F. If the project involves a new interbasin transfer of water, which basins are involved, what is the
direction of the transfer, and is the interbasin transfer existing or proposed?
G. Does the project involve:

1. new water service by the Massachusetts Water Resources Authority or other agency of
the Commonwealth to a municipality or water district? ___ Yes ___ No
2. a Watershed Protection Act variance? ___ Yes ___ No; if yes, how many acres of
alteration?
3. a non-bridged stream crossing 1,000 or less feet upstream of a public surface drinking
- 14 -
water supply for purpose of forest harvesting activities? ___ Yes ___ No
III. Consistency
Describe the project's consistency with water conservation plans or other plans to enhance water
resources, quality, facilities and services:
- 15 -
WASTEWATER SECTION
A. Will the project meet or exceed any review thresholds related to wastewater (see 301 CMR
B. Does the project require any state permits related to wastewater? ___ Yes _X__ No; if yes,
specify which permit:
C. If you answered "No" to both questions A and B, proceed to the Transportation -- Traffic
Generation Section. If you answered "Yes" to either question A or question B, fill out the remainder
of the Wastewater Section below.

A. Describe the volume (in gallons per day) and type of disposal of wastewater generation for
existing and proposed activities at the project site (calculate according to 310 CMR 15.00 for septic
systems or 314 CMR 7.00 for sewer systems):
Discharge of sanitary wastewater ________ ________ ________

Discharge of industrial wastewater ________ ________ ________
TOTAL ________ ________ ________

Discharge to groundwater ________ ________ ________
Discharge to outstanding resource water ________ ________ ________
Discharge to surface water ________ ________ ________
Discharge to municipal or regional wastewater
facility ________ ________ ________
TOTAL ________ ________ ________
B. Is the existing collection system at or near its capacity? ___ Yes ___ No; if yes, then describe
the measures to be undertaken to accommodate the project’s wastewater flows:
C. Is the existing wastewater disposal facility at or near its permitted capacity? ___ Yes___ No; if
yes, then describe the measures to be undertaken to accommodate the project’s wastewater flows:
D. Does the project site currently contain a wastewater treatment facility, sewer main, or other
wastewater disposal facility, or will the project involve construction of a new facility? ___ Yes
___ No; if yes, describe as follows:
Permitted Existing Avg Project Flow Total

Daily Flow
Wastewater treatment plant capacity
(in gallons per day) _______ ________ ________ ________
E. If the project requires an interbasin transfer of wastewater, which basins are involved, what is the
direction of the transfer, and is the interbasin transfer existing or new?
- 16 -
(NOTE: Interbasin Transfer approval may be needed if the basin and community where wastewater
will be discharged is different from the basin and community where the source of water supply is
located.)
F. Does the project involve new sewer service by the Massachusetts Water Resources Authority
(MWRA) or other Agency of the Commonwealth to a municipality or sewer district? ___ Yes ___ No
G. Is there an existing facility, or is a new facility proposed at the project site for the storage,
treatment, processing, combustion or disposal of sewage sludge, sludge ash, grit, screenings,
wastewater reuse (gray water) or other sewage residual materials? ___ Yes ___ No; if yes, what is
the capacity (tons per day):

Storage ________ ________ ________
Treatment ________ ________ ________
Processing ________ ________ ________
Combustion ________ ________ ________
Disposal ________ ________ ________
H. Describe the water conservation measures to be undertaken by the project, and other
wastewater mitigation, such as infiltration and inflow removal.
III. Consistency
A. Describe measures that the proponent will take to comply with applicable state, regional, and
local plans and policies related to wastewater management:
B. If the project requires a sewer extension permit, is that extension included in a comprehensive
wastewater management plan? ___ Yes ___ No; if yes, indicate the EEA number for the plan
and whether the project site is within a sewer service area recommended or approved in that
plan:
- 17 -
TRANSPORTATION SECTION (TRAFFIC GENERATION)
I. Thresholds / Permit
A. Will the project meet or exceed any review thresholds related to traffic generation (see 301 CMR
B. Does the project require any state permits related to state-controlled roadways? ___ Yes _X__
No; if yes, specify which permit:
C. If you answered "No" to both questions A and B, proceed to the Roadways and Other
Transportation Facilities Section. If you answered "Yes" to either question A or question B, fill out
the remainder of the Traffic Generation Section below.
II. Traffic Impacts and Permits

A. Describe existing and proposed vehicular traffic generated by activities at the project site:
Number of parking spaces _______ _______ _______
Number of vehicle trips per day _______ _______ _______
ITE Land Use Code(s): _______ _______ _______
B. What is the estimated average daily traffic on roadways serving the site?
Roadway Existing Change Total
1. ___________________ ________ ________ ________
2. ____________________ ________ ________ ________
3. ____________________ ________ ________ ________
C. If applicable, describe proposed mitigation measures on state-controlled roadways that the

project proponent will implement:
D. How will the project implement and/or promote the use of transit, pedestrian and bicycle facilities
and services to provide access to and from the project site?
C. Is there a Transportation Management Association (TMA) that provides transportation demand

management (TDM) services in the area of the project site? ____ Yes ____ No; if yes, describe
if and how will the project will participate in the TMA:
D. Will the project use (or occur in the immediate vicinity of) water, rail, or air transportation
facilities? ____ Yes ____ No; if yes, generally describe:
E. If the project will penetrate approach airspace of a nearby airport, has the proponent filed a
Massachusetts Aeronautics Commission Airspace Review Form (780 CMR 111.7) and a Notice
of Proposed Construction or Alteration with the Federal Aviation Administration (FAA)
(CFR Title 14 Part 77.13, forms 7460-1 and 7460-2)?
III. Consistency
Describe measures that the proponent will take to comply with municipal, regional, state, and federal
plans and policies related to traffic, transit, pedestrian and bicycle transportation facilities and
services:
- 18 -
TRANSPORTATION SECTION (ROADWAYS AND OTHER TRANSPORTATION
FACILITIES)
I. Thresholds
A. Will the project meet or exceed any review thresholds related to roadways or other
transportation facilities (see 301 CMR 11.03(6))? ___ Yes _X__ No; if yes, specify, in quantitative
terms:
B. Does the project require any state permits related to roadways or other transportation
facilities? ___ Yes _ X __ No; if yes, specify which permit:
C. If you answered "No" to both questions A and B, proceed to the Energy Section. If you
answered "Yes" to either question A or question B, fill out the remainder of the Roadways Section
below.
II. Transportation Facility Impacts

A. Describe existing and proposed transportation facilities in the immediate vicinity of the project
site:
B. Will the project involve any

1. Alteration of bank or terrain (in linear feet)? ____________
2. Cutting of living public shade trees (number)? ____________
3. Elimination of stone wall (in linear feet)? ____________
III. Consistency -- Describe the project's consistency with other federal, state, regional, and local plans
and policies related to traffic, transit, pedestrian and bicycle transportation facilities and services,
including consistency with the applicable regional transportation plan and the Transportation
Improvements Plan (TIP), the State Bicycle Plan, and the State Pedestrian Plan:
- 19 -
ENERGY SECTION
A. Will the project meet or exceed any review thresholds related to energy (see 301 CMR 11.03(7))?
___ Yes _X__ No; if yes, specify, in quantitative terms:
B. Does the project require any state permits related to energy? ___ Yes _X__ No; if yes, specify
which permit:
C. If you answered "No" to both questions A and B, proceed to the Air Quality Section. If you
answered "Yes" to either question A or question B, fill out the remainder of the Energy Section
below.

A. Describe existing and proposed energy generation and transmission facilities at the project site:
Capacity of electric generating facility (megawatts) ________ ________ ________
Length of fuel line (in miles) ________ ________ ________
Length of transmission lines (in miles) ________ ________ ________
Capacity of transmission lines (in kilovolts) ________ ________ ________
B. If the project involves construction or expansion of an electric generating facility, what are:
1. the facility's current and proposed fuel source(s)?
2. the facility's current and proposed cooling source(s)?
C. If the project involves construction of an electrical transmission line, will it be located on a new,
unused, or abandoned right of way? ___Yes ___No; if yes, please describe:
D. Describe the project's other impacts on energy facilities and services:
III. Consistency
Describe the project's consistency with state, municipal, regional, and federal plans and policies for
enhancing energy facilities and services:
- 20 -
AIR QUALITY SECTION
I. Thresholds
A. Will the project meet or exceed any review thresholds related to air quality (see 301 CMR
B. Does the project require any state permits related to air quality? _X__ Yes ___ No; if yes,
specify which permit: MassDEP Non-Major Comprehensive Plan Approval (NMCPA)
C. If you answered "No" to both questions A and B, proceed to the Solid and Hazardous Waste
Section. If you answered "Yes" to either question A or question B, fill out the remainder of the Air
Quality Section below.

A. Does the project involve construction or modification of a major stationary source (see 310 CMR
7.00, Appendix A)? _ X __ Yes _ __ No; if yes, describe existing and proposed emissions (in
tons per day) of:
B.
Existing 1 Change 2 Total 3
Particulate Matter 0.018 0.007 0.025
Carbon Monoxide 0.096 0.011 0.107
Sulfur Dioxide 0.003 0.015 0.018
Volatile Organic Compounds 0.046 0.006 0.052
Oxides of Nitrogen 0.144 0.039 0.183
Lead negligible negligible negligible
Any hazardous air pollutant 0.001 0.0004 0.0014
Carbon Dioxide 157 128 284
1) Existing are turbines EU#3 and EU#4 which will remain at the facility post-project
2) Change is addition of Taurus 70 combustion turbine
3) Total is Existing + Change
B. Describe the project's other impacts on air resources and air quality, including noise impacts:
The air emissions and potential air quality impacts associated with the proposed project
equipment will be minimized through the application of Best Available Control Technology
(“BACT”) and use of natural gas as fuel, efficient equipment, and advanced combustion controls
as documented as documented in the NMCPA application filed in the MassDEP ePlace online
system (Authorization ID #17-AQ02/03F-000007-APP). Note that the NMCPA application is in
the process of being revised and will be resubmitted to MassDEP ePlace. The revised NMCPA
will reflect changes to the HP Replacement Project as well as to respond to an information
request received on the original application (MassDEP May 15, 2018 letter to Tennessee). The
proposed new compressor turbine will be a Solar Taurus 70-10802S, fueled exclusively with
natural gas, which will replace the existing 1991-vintage Solar Centaur H and 1965-vintage Solar
Saturn T-1001. The new turbine will be equipped with Solar’s lean premix burner technology,
known as SoLoNOxTM. Solar gas turbines with SoLoNOxTM technology ensure uniform lean
air/fuel mixture to limit nitrogen oxides (“NOx”), carbon monoxide (“CO”), volatile organic
compounds (“VOC”), and Hazardous Air Pollutant (“HAP”) emissions. An oxidation catalyst will
also be installed on the turbine to further reduce CO and VOCs/HAPs emissions.
The turbine air emissions will exhaust through a 67.5-foot stack.
21
The NMCPA application documents that the HP Replacement Project will have an insignificant air
quality impact. Specifically, air quality dispersion modeling was conducted to estimate ambient air
impacts from the Project, taking into account worst-case emission rates, five years of weather
data, and other Project source and location parameters. The model results show impacts below
the USEPA Significant Impact Levels (“SILs”), therefore demonstrating the Project will not cause
or contribute to a violation of any National Ambient Air Quality Standard (“NAAQS”) for all
pollutants and averaging times.
Noise level increases modeled noise-sensitive receptors at nearby residences, taking into
account attenuation due to distance, structures, and noise control measures, are predicted to be
less than 10 decibels, and will comply with all MassDEP A-weighted and “pure tone” noise limits.
A sound level assessment is included in the NMPCA online submittal.
III. Consistency
A. Describe the project's consistency with the State Implementation Plan:
The State Implementation Plan (“SIP”) is a plan for each state which identifies how that state will
attain and/or maintain the NAAQS. The HP Replacement Project will be consistent with the SIP,
and the planning documents that support it. This project will comply with the state regulations
that USEPA has approved for meeting clean air standards and associated Clean Air Act
requirements, including regulations contained in 310 CMR 7. No facility-specific orders or
modifications to the SIP will be needed, and the HP Replacement Project will not materially affect
any planning documents demonstrating that the regulatory limits assure air quality standards will
continue to be met.
B. Describe measures that the proponent will take to comply with other federal, state, regional, and
local plans and policies related to air resources and air quality:
The NMCPA application includes a regulatory review showing how the HP Replacement Project will
comply with all applicable federal and state regulations and policies.
22
SOLID AND HAZARDOUS WASTE SECTION
A. Will the project meet or exceed any review thresholds related to solid or hazardous waste (see
301 CMR 11.03(9))? ___ Yes _X__ No; if yes, specify, in quantitative terms:
B. Does the project require any state permits related to solid and hazardous waste? ___ Yes
_X__ No; if yes, specify which permit: Tennessee will obtain Non-Traditional Asbestos Abatement
Work Practice Approval.
C. If you answered "No" to both questions A and B, proceed to the Historical and Archaeological
Resources Section. If you answered "Yes" to either question A or question B, fill out the
remainder of the Solid and Hazardous Waste Section below.

A. Is there any current or proposed facility at the project site for the storage, treatment, processing,
combustion or disposal of solid waste? ___ Yes ___ No; if yes, what is the volume (in tons per day)
of the capacity:
Storage ________ ________ ________
Treatment, processing ________ ________ ________
Combustion ________ ________ ________
Disposal ________ ________ ________
B. Is there any current or proposed facility at the project site for the storage, recycling, treatment or
disposal of hazardous waste? ___ Yes ___ No; if yes, what is the volume (in tons or gallons per day)
of the capacity:

Storage ________ ________ ________
Recycling ________ ________ ________
Treatment ________ ________ ________
Disposal ________ ________ ________
C. If the project will generate solid waste (for example, during demolition or construction), describe
alternatives considered for re-use, recycling, and disposal:
D. If the project involves demolition, do any buildings to be demolished contain asbestos?

___ Yes ___ No
E. Describe the project's other solid and hazardous waste impacts (including indirect impacts):
III. Consistency
Describe measures that the proponent will take to comply with the State Solid Waste Master Plan:
23
HISTORICAL AND ARCHAEOLOGICAL RESOURCES SECTION
I. Thresholds / Impacts
A. Have you consulted with the Massachusetts Historical Commission? _X__ Yes ___ No; if yes,
attach correspondence. For project sites involving lands under water, have you consulted with the
Massachusetts Board of Underwater Archaeological Resources? ____Yes __X__ No; if yes, attach
correspondence
B. Is any part of the project site a historic structure, or a structure within a historic district, in either
case listed in the State Register of Historic Places or the Inventory of Historic and Archaeological
Assets of the Commonwealth? ___ Yes _X__ No; if yes, does the project involve the demolition of
all or any exterior part of such historic structure? ___ Yes _X__ No; if yes, please describe:
C. Is any part of the project site an archaeological site listed in the State Register of Historic Places
or the Inventory of Historic and Archaeological Assets of the Commonwealth? __X_ Yes ___ No; if
yes, does the project involve the destruction of all or any part of such archaeological site? ___ Yes
___ No; if yes, please describe: Review of the Inventory of Historic and Archaeological Assets of the
Commonwealth indicates that the Projects are in the vicinity of several previously-recorded
archaeological sites and historic architectural properties. Tennessee’s cultural resource contractor,
The Public Archaeology Laboratory, Inc. has initiated consultation with the MHC by submitting a
Project Notification Form, a Cultural Resources Due Diligence Report, and a State Archaeologist’s
permit application. See Section 4.7 of the EENF narrative in Attachment 6.
D. If you answered "No" to all parts of both questions A, B and C, proceed to the Attachments and
Certifications Sections. If you answered "Yes" to any part of either question A or question B, fill out
the remainder of the Historical and Archaeological Resources Section below.
II. Impacts
Describe and assess the project's impacts, direct and indirect, on listed or inventoried historical and
archaeological resources:
The proposed Projects’ impacts, direct and indirect, on listed or inventoried historic and archaeological
resources has not yet been determined. Under permit from the MHC, PAL initiated an intensive
(locational) archaeological survey and an historic architectural properties reconnaissance survey and
effects assessment in June 2018 and will complete in July 2018. Results of the surveys will be
presented in technical reporting that will be submitted to the MHC, American Indian Tribes, and other
cultural resources interested stakeholders for review and comment.
III. Consistency
Describe measures that the proponent will take to comply with federal, state, regional, and local
plans and policies related to preserving historical and archaeological resources:
Tennessee is required to assist the FERC to comply with Section 106 of the National Historic
Preservation Act of 1966, as amended, and is committed to coordinating with the MHC and other
stakeholders to avoid, minimize, or mitigate any potential effects the proposed project may have on
significant historic and archaeological resources.
24
ATTACHMENT 1
USGS TOPOGRAPHIC MAP
Looping Project
Springfie ld South Quadrangle

West Springfield Quadrangle
Existing CS 261
.
!
Hickory Street
Pipeyard
Pipeline Centerline
Line 261B Pipeline
Looping Project Limit
of Work
Compressor Station
261 Horsepower
Replacement Project
Limit of Work
Hickory Street Pipe
Yard
CHICOPEE WILBRAHAM
WESTFIELD WEST
Data Source: USGS Topo Map SPRINGFIELD
SPRINGFIELD
Attachment 1. Massachusetts AGAWAM HAMPDEN
261 Upgrade Projects SOUTHWICK EAST
LONGMEADOW
USGS 7.5-Minute LONGMEADOW
Topographic Quadrangle SUFFIELD

GRANBY SOMERS
ENFIELD
Connecticut
¯
EAST
Hampden County, MA, Town of Agawam GRANBY
EAST WINDSOR
WINDSOR LOCKS
Hartford County, CT, Town of Suffield
0 1,000 2,000 Latitude 42.034717° N
14 Jun 2018 Feet Longitude -72.633895° W
SWCA Project No.: 045687.00
ATTACHMENT 2
MAP BOOKS
encompass
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LL# 12
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T © 2017 DigitalGlobe ©CNES (2017) Distribution Airbus DS © 2018 Microsoft Corp
encompass
N MP MP
2.0 2.1
LL# 15.01
LL# 17
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SILVE
LL# 15.02
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LL# 15
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SUFFIELD STREET
encompass
MP
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LL# 825
KOR
LL# 825.01
HIC
N-100
M
A
6-
10
0
M
A
6-
20
0
MA1-20
MA1-10
0
A-300
0
A-200
A-100
T
New Generator
Exhaust
65x38 Auxillary
Building
Cable Trays New Exhaust

Station 261 Silencer
Filter
Separator
MA1-4 00
B-200
MA
1-3
New Suction
00
B-100
Header
MA C
2-2
00
B-300
New Blowdown
Silencer
Scale: 1:2,400
Cable Tray 1 New Suction Filter Separator Wetlands
Created By: EWS
Header Delineated by
Cable Tray 2 Station 261 HP SWCA (2018)
Date Produced: 08 Jun 2018 261 UPGRADE PROJECT - AUX Building Replacement
Background: 2016 Aerial Imagery (ESRI) COMPRESSOR STATION 261 Gen Exhaust LOD Parcel
pipe Station 261 Boundary
/
15 Research Drive 0 100 200 400 Boundary Waterbodies
Amherst, Massachusetts 01002 Feet New Blowdown Delineated by
(413) 256-0202 phone HAMPDEN COUNTY, MA Exhaust
(413) 256-1092 fax
0 25 50 100 Silencer SWCA (2018)
Meters TOWN OF AGAWAM Silencer
www.swca.com
Document Path: K:\GIS Holding_Projects\2017AnomalyDigs\261B Upgrades\HPReplacementOverview.mxd

ATTACHMENT 3
ENVIRONMENTAL CONSTRAINTS MAPS
New Generator
MA1-3 00 Exhaust
Cable Trays 65x38 Auxillary
Station Building
4 00 2+00 261 New Exhaust
1- .
!
A
M Silencer
B-200
B-100
Filter Separator
New
Suction
Header
0
20
2- 00
MA 2-1
MA C
0+00 !
.
B-300
New
Blowdown
Silencer
WMA 1A
WCT 1B
1
Massac husetts
Connecticut WMA 1B
Scale: 1:2,400
SHEET 1 OF 7 Pipeline Centerline Waterbodies Delineated by
Created By: EWS
SWCA (2018)
Proposed Permanent Easement Wetlands Delineated by SWCA
Date Produced: 20 Jun 2018
261 UPGRADE PROJECT (2018)
Background: 2016 Aerial Imagery (ESRI)
ENVIRONMENTAL RESOURCES MAP Temporary Work Area
/
15 Research Drive 0 100 200 400 Pipe Yard
Amherst, Massachusetts 01002 Feet Open Ended Wetlands
(413) 256-0202 phone
0 25 50 100 Delineated by AECOM
(413) 256-1092 fax HAMPDEN COUNTY, TOWN OF AGAWAM, MA (November 2013)
www.swca.com Meters
Document Path: K:\GIS Holding_Projects\2017AnomalyDigs\261B Upgrades\1.2Looping_HPR_EnvResourcesMaps_20180620.mxd

28+00
!
.
26+00 !
.
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.
!
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20+00
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MA
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00 2
. 16+00
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MA1-10
12+00 0
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0
.
!
8+00
6+00
S .
!
A-200 !
.
T
4+00
.
!
A-100
Scale: 1:2,400
SHEET 2 OF 7 Pipeline Centerline Temporary Work Area
Created By: EWS
SWCA Project No.: 045687.00 Proposed Temporary Access Waterbodies Delineated by
261 UPGRADE PROJECT Road SWCA (2018)
ENVIRONMENTAL RESOURCES MAP Wetlands Delineated by SWCA
Existing Permanent Easement
/
15 Research Drive 0 100 200 400
(2018)
Amherst, Massachusetts 01002 Feet
(413) 256-0202 phone Proposed Permanent Easement
0 25 50 100
(413) 256-1092 fax HAMPDEN COUNTY, TOWN OF AGAWAM, MA
www.swca.com Meters

46+00
!
.
44+00
!
.
42+00 !
.
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40+00
.
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!
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36+00 !
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.
34+00
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.
32+00 !
.
N-100
30+00
!
.
Scale: 1:2,400
SHEET 3 OF !.7 Pipeline Centerline Temporary Work Area
Created By: EWS
SWCA Project No.: 045687.00 Proposed Permanent Access NHESP Priority Habitat
261 UPGRADE PROJECT Road
ENVIRONMENTAL RESOURCES MAP Waterbodies Delineated by
Existing Permanent Easement SWCA (2018)
/
(413) 256-0202 phone Proposed Permanent Easement Wetlands Delineated by SWCA
0 25 50 100
(413) 256-1092 fax HAMPDEN COUNTY, TOWN OF AGAWAM, MA (2018)
www.swca.com Meters

H
64+00
.
!
62+00
.
! K
60+00 !
.
. 58+00
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!
56+00
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52+00
.
!
.
!
50+00
L
M
LA
!
.
48+00
Scale: 1:2,400
Created By: EWS
SWCA Project No.: 045687.00 Proposed Temporary Access NHESP Priority Habitat
ENVIRONMENTAL RESOURCES MAP Wetlands Delineated by SWCA
Existing Permanent Easement (2018)
/
(413) 256-0202 phone Proposed Permanent Easement
0 25 50 100
www.swca.com Meters

F
. 82+00
!
80+00
!
.
78+00
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.
76+00
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.
74+00
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.
PH 780
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.
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MA
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-1
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M
MA4-300 M
66+00
!
.
Scale: 1:2,400
Created By: EWS
SWCA Project No.: 045687.00 Proposed Permanent Access NHESP Priority Habitat
/
0 25 50 100
www.swca.com Meters

100+00
!
.
EA
98+00
!
.
96+00
!
.
94+00
!
.
0
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00
-2
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M
92+00
.
!
6
. 90+00
!
E-200
PH 780
88+00
!
.
FA
86+00
!
.
84+00
!
.
Scale: 1:2,400
Created By: EWS
SWCA Project No.: 045687.00 Proposed Temporary Access NHESP Priority Habitat
/
0 25 50 100
www.swca.com Meters

PH 805
110+88
!
.
110+00
!
.
7
108+00
!
.
106+00
!
.
104+00
!
.
102+00
!
.
PH 780
Scale: 1:2,400
SHEET 7 OF 7 Pipeline Centerline Proposed Permanent Easement
Created By: EWS
SWCA Project No.: 045687.00 Proposed Permanent Access Temporary Work Area
ENVIRONMENTAL RESOURCES MAP Proposed Temporary Access NHESP Priority Habitat
/
Road
(413) 256-0202 phone
0 25 50 100 Existing Permanent Easement
www.swca.com Meters

Attachment 4
261 Upgrade Projects
Expanded Environmental Notification Form
Distribution List
Secretary Matthew A. Beaton Agawam Planning Board
Executive Office of Energy and Environmental Agawam Town Hall
Affairs (EEA) 36 Main Street
Attn: MEPA Office Agawam, MA 01001
100 Cambridge Street, Suite 900
Boston, MA 02114 Agawam Conservation Commission
Agawam Town Hall
Department of Environmental Protection 36 Main Street
Commissioner’s Office Agawam, MA 01001
One Winter Street
Boston, MA 02108 Agawam Health Department
Agawam Town Hall
Department of Environmental Protection 36 Main Street
Western Regional Office Agawam, MA 01001
Attn: MEPA Coordinator
State House West – 4th Floor Department of Agricultural Resources
436 Dwight Street Attn: MEPA Coordinator
Springfield, MA 01103 16 West Experiment Station
University of Massachusetts
Massachusetts Department of Transportation Amherst, MA 01003
Public/Private Development Unit
10 Park Plaza Natural Heritage & Endangered Species
Boston, MA 02116 Program
Massachusetts Division of Fisheries & Wildlife
Massachusetts Department of Transportation 1 Rabbit Hill Road
District #2 Westborough, MA 01581
MEPA Coordinator
811 North King Street Energy Facilities Siting Board
Northampton, MA 01060 Attn: MEPA Coordinator
One South Station
Massachusetts Historical Commission Boston, MA 02110
The MA Archives Building
220 Morrissey Boulevard Department of Energy Resources
Boston, MA 02125 Attn: MEPA Coordinator
100 Cambridge Street, 10th Floor
Pioneer Valley Planning Commission Boston, MA 02114
60 Congress Street
Springfield, MA 01104-3419 U.S. Army Corps of Engineers
Regulatory Division, New England District
Agawam Office of the Mayor Attn: Alan Anacheka-Nasemann
Mayor William P. Sapelli 696 Virginia Road
36 Main Street Concord, MA 01742-2751
Agawam, MA 01001
Department of Environmental Protection
Agawam City Council Bureau of Air and Waste
Agawam Town Hall Western Regional Office
36 Main Street State House West – 4th Floor
Agawam, MA 01001 436 Dwight Street
Springfield, MA 01103
Attachment 5
Permits and Approvals
Permit/Approval Administering Agency Status
Federal
Section 7(c) application under Federal Energy Regulatory Commission Anticipate submittal September 2018.
the Natural Gas Act
Section 404 MA GP U.S. Army Corps of Engineers New England Anticipate submittal August 2018.
District
Section 7 Clearance U.S. Fish and Wildlife Service To be initiated July 2018.
NPDES – Construction U.S. Environmental Protection Agency Exempt.
Section 106 Clearance MA Historical Commission Project Notification Form submitted
May 24, 2018; consultation ongoing.
CZM Consistency MA Coastal Zone Management Agency Not Applicable / not in coastal zone.
Massachusetts State
MEPA ENF Certificate Massachusetts Environmental Policy Act EENF filed herein.
MEPA EIR Certificate Massachusetts Environmental Policy Act Anticipate submittal of EIR 4th quarter
2018.
401 Water Quality Certification Massachusetts Department of Environmental Anticipate submittal September 2018.
Protection
Order of Conditions under Agawam Conservation Commission / Anticipate submittal of Notice of Intent
Wetlands Protection Act Department of Environmental Protection July 2018.
MESA Project Review / MA Natural Heritage & Endangered Species Anticipate submittal of Project Review
Conservation & Management Program Request with Notice of Intent July 2018.
Permit (Looping Project only)
Non-major Comprehensive Plan Massachusetts Department of Environmental Application submitted December 14,
Approval (HP Replacement Protection 2017; currently under review.
Project only)
Local
Road opening permits Agawam Department of Public Works Anticipate submittal prior to
construction.
Building Permit Approval Agawam Building Department Applicability to be determined.
ATTACHMENT 6
EXPANDED ENVIRONMENTAL NOTIFICATION FORM
NARRATIVE
261 UPGRADE PROJECTS,
AGAWAM, MA
Prepared for
1001 Louisiana Street, Suite 1000
Houston, Texas 77002
Prepared by
15 Research Drive
Amherst, Massachusetts 01002
(339) 203-7045
www.swca.com
SWCA Project No. 45687.00
June 2018
Expanded ENF – 261 Upgrade Projects
ACRONYMS
ACEC Area of Critical Environmental Concern
APE Area of Potential Effects
API American Petroleum Institute
AQCR Air Quality Control Region
ATWS additional temporary workspace
BLSF bordering land subject to flooding
BMP best management practices
BVW bordering vegetated wetland
CAA Clean Air Act
CEQ Council on Environmental Quality
CFR Code of Federal Regulations
CH4 methane
CMA Columbia Gas of Massachusetts
CMR Code of Massachusetts Regulations
CO carbon monoxide
CO2 carbon dioxide
CO2e carbon dioxide equivalent
CS 261 Compressor Station 261
CVP certified vernal pool
dB decibel
dBA A-weighted decibel
DOT Department of Transportation
DPU Department of Public Utilities
Dth/d dekatherms per day
ECMP Environmental Construction Management Plan
EDR Environmental Data Resources, Inc.
i
EENF Expanded Environmental Notification Form
EI environmental inspector
EIR Environmental Impact Report
ENF Environmental Notification Form
ERP Environmental Results Program
FEMA Federal Emergency Management Agency
FERC Federal Energy Regulatory Commission
FERC Plan FERC’s Upland Erosion Control, Revegetation, and Maintenance Plan
FERC Procedures FERC’s Wetland and Waterbody Construction and Mitigation Procedures
GHG greenhouse gas
HAP hazardous air pollutants
Holyoke Holyoke Gas and Electric Department
HP horsepower
HP Replacement Project Compressor Station 261 Horsepower Replacement Project
ILSF isolated land subject to flooding
INGAA Interstate Natural Gas Association of America
IVW isolated vegetated wetland
LNG liquified natural gas
Looping Project Line 261B Pipeline Looping Project
LUWW land under waterbodies and waterways
MA DFW Massachusetts Division of Fisheries and Wildlife
MAOP maximum allowable operating pressure
MA PGP Massachusetts Programmatic General Permit
MassDEP Massachusetts Department of Environmental Protection
MassGIS Massachusetts Bureau of Geographic Information
MEPA Massachusetts Environmental Policy Act
MESA Massachusetts Endangered Species Act
ii
MGL Massachusetts General Law
MHC Massachusetts Historical Commission
MM million
MOVES Motor Vehicle Emissions Simulator
N/A not applicable
NAAQS National Ambient Air Quality Standards
National Register National Register of Historic Places
NEPA National Environmental Policy Act
NHESP Natural Heritage & Endangered Species Program
NMCPA Non-Major Comprehensive Plan Approval
NNSR nonattainment new source review
N2O nitrous oxide
NOx nitrogen oxides
NPS National Park Service
NRCS Natural Resources Conservation Service
NWI National Wetlands Inventory
O3 ozone
ORW outstanding resource water
OTR ozone transport region
PAL Public Archaeology Laboratory, Inc.
PAR permanent access roads
PCN Pre-Construction Notification
PHMSA Pipeline and Hazardous Materials Safety Administration
PM particulate matter
PM2.5 particulate matter with a diameter ≤ 2.5 microns
PM10 particulate matter with a diameter ≤ 10 microns
Projects 261 Upgrade Projects
iii
PSD prevention of significant deterioration
psi pounds per square inch
ROI region of influence
ROW right-of-way
SIL Significant Impact Level
SIP State Implementation Plan
SLR SLR International Corporation
SO2 sulfur dioxide
SPRP Spill Prevention Response Plan
SWCA SWCA Environmental Consultants
TAR temporary access road
TBD to be determined
Tennessee Tennessee Gas Pipeline Company, L.L.C.
TMDL total maximum daily load
Tribes federally recognized American Indian Tribes
TWS temporary workspace
UNT unnamed tributary
USACE U.S. Army Corps of Engineers
USDA U.S. Department of Agriculture
USEPA U.S. Environmental Protection Agency
USGS U.S. Geological Survey
VOC volatile organic compounds
WPA Wetlands Protection Act
WQC Water Quality Certification
iv
CONTENTS
Chapter 1 Summary............................................................................................................................ 1
1.1 Project Description .......................................................................................................................... 1
1.2 Permits, Approvals, and Consultations ............................................................................................ 2
1.3 Summary of Alternatives ................................................................................................................. 2
1.4 Summary of Impacts ........................................................................................................................ 3
1.5 Summary of Mitigation Measures ................................................................................................... 3
Chapter 2 Project Description ........................................................................................................... 5

2.1 Proposed Facilities ........................................................................................................................... 6
2.1.1 Purpose and Need ............................................................................................................... 6
2.1.2 Location and Description of Facilities ................................................................................ 6
2.1.2.1 Looping Project .......................................................................................................... 6
2.1.2.2 HP Replacement Project ............................................................................................. 7
2.2 Land Requirements .......................................................................................................................... 8
2.2.1 Looping Project................................................................................................................... 8
2.2.2 HP Replacement Project ................................................................................................... 10
2.3 Pipeline Construction Procedures .................................................................................................. 11
2.3.1 Standard Pipeline Construction Methods.......................................................................... 11
2.3.1.1 Marking the Corridor................................................................................................ 11
2.3.1.2 Erosion and Sediment Control.................................................................................. 12
2.3.1.3 Clearing, Grading, and Fencing................................................................................ 12
2.3.1.4 Trenching.................................................................................................................. 13
2.3.1.5 Pipe Stringing ........................................................................................................... 14
2.3.1.6 Pipe Bending ............................................................................................................ 14
2.3.1.7 Pipe Assembly and Welding .................................................................................... 14
2.3.1.8 Non-Destructive Testing and Weld Repair .............................................................. 14
2.3.1.9 Coating Field Welds, Inspection, and Repair ........................................................... 14
2.3.1.10 Pipe Preparation and Lowering-In.......................................................................... 15
2.3.1.11 Tie-Ins .................................................................................................................... 15
2.3.1.12 Backfilling and Grade Restoration ......................................................................... 15
2.3.1.13 Clean-up and Restoration ....................................................................................... 15
2.3.1.14 Hydrostatic Testing and Tie-Ins ............................................................................. 15
2.3.2 Specialized Pipeline Construction Procedures.................................................................. 16
2.3.2.1 Residential Areas ...................................................................................................... 16
2.3.2.2 Agricultural Lands .................................................................................................... 16
2.3.2.3 Road Crossings ......................................................................................................... 16
2.3.2.4 Trenchless Construction Methods ............................................................................ 16
2.3.2.5 Rock Removal .......................................................................................................... 17
2.3.2.6 Wetland Crossing Construction ................................................................................ 18
2.3.2.7 Waterbody Crossing Construction ........................................................................... 18
2.3.3 Construction Timeframe and Workforce .......................................................................... 19
2.3.4 Supervision and Inspection ............................................................................................... 19
2.4 Operations and Maintenance.......................................................................................................... 19
2.4.1 Cleared Areas .................................................................................................................... 20
2.5 Cumulative Impacts Methodology ................................................................................................. 21
2.5.1 Scope of Analysis ............................................................................................................. 21
v
2.5.2 Temporal and Geographic Distribution ............................................................................ 22

2.5.3 Activities Considered ........................................................................................................ 23
2.5.4 Analysis Summary ............................................................................................................ 28
2.6 Permits Required............................................................................................................................ 28
Chapter 3 Project Alternatives ........................................................................................................ 30

3.1 No-Action Alternative ................................................................................................................... 30
3.2 Energy Conservation/Energy Alternatives..................................................................................... 30
3.2.1 Energy Conservation......................................................................................................... 30
3.2.2 Energy Alternatives .......................................................................................................... 31
3.2.3 Efficiency Improvement Options...................................................................................... 31
3.3 System Alternatives ....................................................................................................................... 31
3.3.1 Modifications to Other Pipeline Systems ......................................................................... 32
3.3.2 Looping Project Alternatives ............................................................................................ 32
3.3.2.1 Compression Only Option ........................................................................................ 32
3.3.2.2 Lift and Relay Option ............................................................................................... 32
3.3.2.3 Uprating Option ........................................................................................................ 33
3.3.3 HP Replacement Project Alternatives ............................................................................... 33
3.3.3.1 Looping Only Option ............................................................................................... 33
3.3.3.2 Rewheel Compressors .............................................................................................. 34
3.3.3.3 Electric Driver Option .............................................................................................. 34
3.4 Proposed Projects Configuration Alternatives ............................................................................... 35
3.4.1 Looping Project Route Alternatives.................................................................................. 35
3.4.1.1 Internal Pipe Coating ................................................................................................ 36
3.4.1.2 Loop Diameter Option.............................................................................................. 36
3.4.1.3 Major Route Alternatives ......................................................................................... 36
3.4.1.4 Route Variations ....................................................................................................... 37
3.4.2 HP Replacement Project Site Options .............................................................................. 39
3.4.3 Contractor Yard Alternatives ............................................................................................ 39
3.5 Alternatives Summary ................................................................................................................... 40
Chapter 4 Environmental Analysis ................................................................................................. 41

4.1 Topography, Geology, and Soils ................................................................................................... 41
4.1.1 Geologic Resources .......................................................................................................... 41
4.1.1.1 Existing Environment ............................................................................................... 41
4.1.1.2 Assessment of Project Impacts ................................................................................. 43
4.1.1.3 Mitigation Measures ................................................................................................. 44
4.1.2 Soils .................................................................................................................................. 44
4.1.2.2 Assessment of Impacts ............................................................................................. 52
4.2 Surface and Groundwater Hydrology and Quality ........................................................................ 54
4.2.1 Groundwater Resources .................................................................................................... 54
4.2.2 Surface Water Resources .................................................................................................. 56
vi
4.2.3 Wetland Resources ........................................................................................................... 65

4.3 Air and Noise Quality .................................................................................................................... 71
4.3.1 Air ..................................................................................................................................... 71
4.3.2 Noise ................................................................................................................................. 79
4.4 Plant and Animal Species and Habitat ........................................................................................... 85
4.4.1 Vegetation ......................................................................................................................... 85
4.4.1.2 Impact Assessment ................................................................................................... 86
4.4.2 Wildlife ............................................................................................................................. 88
4.4.3 Threatened and Endangered Species ................................................................................ 92
4.5 Traffic, Transit, and Pedestrian and Bicycle Transportation ......................................................... 94
4.5.1 Existing Environment ....................................................................................................... 94
4.5.2 Assessment of Impacts...................................................................................................... 95
4.5.3 Mitigation Measures ......................................................................................................... 95
4.6 Scenic Qualities, Open Space and Recreational Resources ........................................................... 95
4.6.3 Mitigation Measures ......................................................................................................... 96
4.7 Historic and Archaeological Resources ......................................................................................... 96
4.7.1 Area of Potential Effects ................................................................................................... 96
4.7.1.1 APE for Archaeological Resources .......................................................................... 97
4.7.1.2 APE for Historic Architectural Properties ................................................................ 97
4.7.2 MHC Correspondence ...................................................................................................... 97
4.7.2.1 MHC Consultation ................................................................................................... 97
4.7.2.2 Tribal Communications and Outreach...................................................................... 97
4.7.3 Cultural Resource Investigations ...................................................................................... 98
4.7.3.1 Cumulative Impacts .................................................................................................. 99
4.8 Land Use ........................................................................................................................................ 99
4.8.2.1 Looping Project ...................................................................................................... 101
4.8.2.2 HP Replacement Project ......................................................................................... 102
4.8.2.3 Cumulative Impacts ................................................................................................ 102
4.8.3 Mitigation Measures ....................................................................................................... 103
vii
4.8.3.1 Looping Project ...................................................................................................... 103

4.9 Rare or Unique Features .............................................................................................................. 104
4.10 Tidelands......................................................................................................................... 104
Chapter 5 References Cited/Literature Cited .............................................................................. 105
Tables
Table 2-1. Proposed Permanent Facilities for the Looping Project .............................................................. 7
Table 2-2. Proposed Compressor Station 261 Modifications associated with the HP Replacement
Project ........................................................................................................................................ 8
Table 2-3. Summary of Land Requirements for the 261 Upgrade Projects in Massachusetts ...................... 8
Table 2-4. Analysis of Co-located Facilities with the Looping Project ...................................................... 10
Table 2-5. Tennessee Minimum Specifications for Depth of Cover (inches) ............................................. 13
Table 2-6. Hydrostatic Test Water Information for the 261 Upgrade Projects ........................................... 16
Table 2-7. Conventional Bore Crossings for the Looping Project .............................................................. 17
Table 2-8. Summary of Resources Analyzed for Cumulative Impacts ....................................................... 22
Table 2-9. Regions of Influence by Resource Type for the 261 Upgrade Projects..................................... 23
Table 2-10. Past, Present, and Reasonably Foreseeable Activities and Associated Resource Impacts
Considered in the Cumulative Impacts Analysis for the 261 Upgrade Projects ...................... 25
Table 2-11. Federal and State Approvals for the 261 Upgrade Projects ..................................................... 28
Table 3-1. Comparative Analysis of Minor Route Variations Incorporated into the Looping Project ....... 37
Table 4-1. Geologic Conditions in the Projects’ Areas............................................................................... 41
Table 4-2. Soils and Soil Characteristics Crossed by the 261 Upgrade Projects ........................................ 49
Table 4-3. Intermittent and Perennial Waterbodies Associated with the 261 Upgrade Projects ................ 58
Table 4-4. Wetlands Associated with the 261 Upgrade Projects ................................................................ 67
Table 4-5. Attainment Designations in the Area of the Projects................................................................. 72
Table 4-6. Construction GHG Emissions from 261 Upgrade Projects ....................................................... 73
Table 4-7. Emissions from Construction of the 261 Upgrade Projects ....................................................... 74
Table 4-8. Operational Emissions from Pipeline Facilities Associated with the Looping Project ............. 76
Table 4-9. Operational Emissions from HP Replacement Project .............................................................. 77
Table 4-10. Dispersion Modeling Results – HP Replacement Project ...................................................... 77
Table 4-11. Existing A-weighted Ambient Sound Levels at Property Line and Inhabited Buildings ....... 81
Table 4-12. A-weighted Sound Level Predictions at Property Line and Inhabited Buildings ................... 82
Table 4-13. Predicted Octave Band Sound Level Contribution of New Equipment ................................. 83
Table 4-14. Predicted Octave Band Sound Levels – New Equipment and Ambient ................................. 83
Table 4-15. Roadways Crossed by the 261 Upgrade Projects .................................................................... 95
Table 4-16. Special Land Uses within 1 mile of the 261 Upgrade Projects ............................................... 96
Table 4-17. Land Use Acreage Affected by Construction and Operation of the 261 Upgrade
Projects................................................................................................................................... 100
viii
Appendices
Appendix A. Figures
Figure 2-1 Project Location Map
Figure 3-1 to 3-4 Minor Route Variations
Figure 4-1 USDA NRCS Soil Map Units – Pipeline Facilities
Figure 4-2 USDA NRCS Soil Map Units – Compressor Station 261 Modifications
Appendix B FERC Plan and FERC Procedures

Appendix C Agency Correspondence
Appendix D Summary of EDR Report
Appendix E GHG Analysis
Appendix F Air Emissions Calculations
ix
Chapter 1 Summary
1.1 PROJECT DESCRIPTION

The proposed 261 Upgrade Projects (“Projects”) consist of (i) the Line 261B Pipeline Looping Project
(“Looping Project”), which involves approximately 2.1 miles of pipeline loop, and (ii) the Compressor
Station 261 Horsepower Replacement Project (“HP Replacement Project”), which involves equipment
upgrades at Tennessee Gas Pipeline Company, L.L.C.’s (“Tennessee”) existing Compressor Station 261
(“CS 261”). Both projects are located in Agawam, Massachusetts. Figure 2-1 in Appendix A depicts the
general location of the Projects’ components.
existing 8-inch-diameter 261BP-100 pipeline and/or Tennessee’s existing 10-inch-diameter 261B-100
pipeline, to the extent practicable. Where the pipeline loop will be installed adjacent to the 261B-100
pipeline, Tennessee proposes to remove an inactive 6-inch-diameter pipeline from this location 1 and
replace it with the 12-inch-diameter loop upgrade. The proposed HP Replacement Project involves the
replacement of two existing turbine compressor units with one new, cleaner-burning turbine compressor
unit and auxiliary facilities.
Massachusetts (“CMA”) and the Holyoke Gas and Electric Department (“Holyoke”). The Projects are
separate and distinct and will have independent utility to Tennessee’s customers; however, for
Massachusetts Environmental Policy Act (“MEPA”) review purposes, Tennessee is including both in this
Expanded Environmental Notification Form (“EENF”).
A separate project to serve CMA is the construction of a new meter station in Longmeadow,
Massachusetts. The Longmeadow Meter Station will provide a needed delivery point for CMA (the
nearest delivery points are in Agawam and East Longmeadow), specifically on the east side of the
Connecticut River. 2 The Longmeadow Meter Station will enhance system reliability to 55,000 existing
CMA customers and supports the ability of CMA to serve future customers. The Longmeadow Meter
Station is scheduled to be constructed beginning in June 2019 and placed into service in November 2019
(CMA requires this additional point of delivery to be operational by November 2019). The volume of
natural gas supplied to the proposed Longmeadow Meadow Station will come from Tennessee’s existing
mainline and is not influenced by the Looping Project or HP Replacement Project, each described above.
Tennessee provides this description of the new meter station for informational purposes only as the new
meter station does not trigger any MEPA review thresholds and has independent utility from the Looping
Project and HP Replacement Project, each described above. The Longmeadow Meter Station is separate
and distinct from the Projects submitted with this EENF (and Tennessee reserves all rights with respect to
this position); however, Tennessee includes this description to avoid any claim regarding segmentation.
1
Tennessee’s predecessor, Tennessee Gas Transmission Company, received authority from the Federal Power
Commission (the predecessor to the Federal Energy Regulatory Commission) in 1958 to construct and operate a new 10-inch
diameter pipeline to replace an existing 6-inch-diameter line. The 10-inch-diameter replacement line was relocated to a less
congested area than the 6-inch-diameter line and was constructed to increase transportation capacity to meet growing demands.
Tennessee Gas Transmission Co., Docket No. G-15265, 20 FPC 441 (1958).
2
Currently, CMA provides natural gas service to its existing customers on the east side of the Connecticut River by a
single pipe that crosses Memorial Street Bridge. If something were to happen to that single pipe, delivery of natural gas could be
impeded significantly. Adding a new delivery point will enhance reliability and redundancy as well as allowing bi-directional
flow east and west across the Memorial Street Bridge to improve operational flexibility for CMA. It will reduce the risk of a
disruption to CMA’s distribution system due to the current single source of supply for the City of Springfield and the surrounding
communities.
1
1.2 PERMITS, APPROVALS, AND CONSULTATIONS

The Projects are regulated by the Federal Energy Regulatory Commission (“FERC”). As such, Tennessee
intends to file an application for a Certificate of Public Convenience and Necessity under Section 7(c) of
the Natural Gas Act. As part of the application for the Projects, Tennessee will prepare an environmental
report that addresses environmental impacts and mitigation for the Projects’ activities.
Because the Projects require work in state-regulated wetland resource areas and buffer zones, a Notice of
Intent will be filed with the Agawam Conservation Commission, with copies submitted to the
Massachusetts Department of Environmental Protection (“MassDEP”). A Water Quality Certification
(“WQC”) Application will also be submitted to MassDEP as greater than 5,000 square feet of wetlands
will be temporarily impacted by the Projects. Pre-Construction Notification (“PCN”) will be submitted to
the U.S. Army Corps of Engineers (“USACE”) under the Massachusetts Programmatic General Permit
(“MA PGP”) for impacts to waters of the U.S. The Projects will also be reviewed by the FERC and the
USACE under Section 7 of the Endangered Species Act and Section 106 of the National Historic
Preservation Act of 1966, as amended (“NHPA”); Tennessee will coordinate with the U.S. Fish and
Wildlife Service (“USFWS”), Massachusetts Historical Commission (“MHC”), and American Indian
Tribes (“Tribes”), as applicable, throughout these review processes.
The Looping Project will require Project Review by the Natural Heritage and Endangered Species
Program (“NHESP”) due to work within a Priority Habitat of state-listed rare species; the Project Review
will determine whether a Conservation and Management Permit will be required. The HP Replacement
Project requires Non-major Comprehensive Plan Approval from MassDEP.
A list of necessary permits, licenses, and clearances related to the construction, installation, operation, and
maintenance of the Projects is provided in Table 2-11 of Section 2.7 of this narrative.
1.3 SUMMARY OF ALTERNATIVES

Tennessee reviewed construction, fuel source, system, and the No-Action alternatives, and determined
that the proposed Projects, as designed, represent the preferred alternative. If the proposed Projects are
not constructed to meet customer demand (i.e., the No-Action Alternative is selected), the market served
by the customers that have executed binding precedent agreements for all of the Projects’ capacity may
experience energy shortages in times of peak demand or users may revert to the consumption of
alternative fuels including oil. Use of alternative fuels to supply the energy needs of Tennessee’s natural
gas customers is not the best practicable alternative as compared to the use of cleaner-burning natural gas.
In addition, although energy conservation is a valuable measure as part of an overall energy plan, energy
conservation alone is not a solution to the current energy demand of consumers served by these Projects.
As discussed in Chapter 3, Tennessee conducted a detailed system alternatives analysis and route
analysis, including consideration of efficiency improvements, a lift and relay option, an uprating option,
and pipeline looping and compression options. The detailed system alternatives analysis allowed the
Projects’ designers to select the best configuration of the proposed facilities, including preferred routes
and siting for the proposed Looping Project, to meet the needs of the market. The HP Replacement
Project and 2.1-mile, 12-inch-diameter Looping Project were ultimately selected as the Preferred
Alternatives because they meet the customers’ objectives, allow for the use of existing pipeline corridors
and compressor station facilities, and minimize impacts to environmental resources and landowners.
2
1.4 SUMMARY OF IMPACTS

Construction of the Projects will affect a total of 36.91 acres of land, exceeding the MEPA thresholds
under 301 Code of Massachusetts Regulations (“CMR”) 11.03 for Land, requiring an ENF. Of the 36.91
acres of land affected during construction, 30.27 acres will be temporary impacts, 6.58 acres will be
permanently affected by the new pipeline easement, and 0.06 acre will be permanently altered due to
construction of a small building within a vegetated upland portion of the existing CS 261 yard.
Construction impacts will include soil disturbance and loss of vegetation during the construction period.
With the implementation of mitigation measures summarized in Section 1.5, permanent impacts to land
from the pipeline loop (6.58 acres) will be limited to permanent tree clearing from ongoing vegetation
management within the new permanent easement and the imposition of certain easement restrictions to
land use for landowners (e.g., prohibiting structures in the permanent easement for safety reasons).
Construction of the Projects will temporarily impact a total of 7.55 acres of wetlands (7.37 acres of
bordering vegetated wetland and 0.18 acre of isolated vegetated wetland) and 1,001 linear feet of bank,
exceeding the MEPA thresholds for Wetlands, Waterways and Tidelands requiring an ENF and
mandatory Environmental Impact Report (“EIR”). All temporary impacts to wetlands and waterbodies
from the Projects will be restored following construction. No wetland will be lost or filled by the
Projects, and no certified vernal pools will be impacted by the Projects.
1.5 SUMMARY OF MITIGATION MEASURES

Chapter 4 provides detailed information on mitigation measures proposed for the Projects for each
resource potentially affected. A summary of these measures includes the following:
• Approximately 73 percent of the proposed pipeline loop will be located within the existing
easement of Tennessee’s 261B-100 Line, and an additional 17 percent will be located within
other utility and roadway corridors or Tennessee’s existing CS 261 facility.
• The Projects will modify Tennessee’s existing compressor station facility rather than construct a
new greenfield facility.
• Tennessee will develop and adhere to a Project-specific Environmental Construction

Management Plan (“ECMP”) that will incorporate the FERC’s Upland Erosion Control,
Revegetation, and Maintenance Plan (“FERC Plan”; FERC, 2013a), Wetland and Waterbody
Construction and Mitigation Procedures (“FERC Procedures”; FERC, 2013b), and all applicable
plans, permits, and clearances, and specifies other best management practices (“BMPs”) that will
be used to avoid and minimize adverse environmental impacts.
• Tennessee will use specialized construction techniques and erosion control procedures to avoid
and minimize construction impacts, including the use of timber mats, installation of sediment
barriers, and flumed or dam and pump construction methods to minimize impacts to wetland
resource areas at stream crossings.
• Tennessee will employ an on-site Environmental Inspector (“EI”) to ensure compliance with the
Projects’ ECMP, which incorporates the FERC Plan and FERC Procedures, as well as federal,
state, and local environmental permit conditions.
• Tennessee will regrade and reseed all disturbed upland and wetland resource areas, except at new
permanent aboveground ancillary facilities.
3
• Tennessee will consult with NHESP to develop mitigation measures for crossing of priority
habitats of rare species.
• Tennessee will consult with MassDEP, USACE, and the Agawam Conservation Commission to
develop a mitigation plan for impacts to wetlands and waterbodies.
• Tennessee will consult with the MHC, FERC, and the Tribes to avoid or minimize any adverse
impacts to significant archaeological resources.
• Tennessee will limit construction to daylight hours, unless limited nighttime construction is
required due to site conditions, specialized construction techniques, and/or weather-related
events.
• Construction vehicles and equipment will be equipped with mufflers and will be maintained in
accordance with manufacturers’ recommendations to minimize air and noise impacts.
• The proposed Taurus 70 turbine will be equipped with custom inlet and exhaust silencers and
lube oil coolers, and Building D piping will be acoustically lagged to reduce the radiated noise
transmitted through the walls of the piping.
4
Chapter 2 Project Description

upgrades at Tennessee’s existing Compressor Station 261 (“CS 261”). Both Projects are located in
Agawam, Massachusetts. Figure 2-1 in Appendix A depicts the general location of the Projects’
components.
pipeline, Tennessee proposes to remove an inactive 6-inch-diameter pipeline from this location 3 and
Massachusetts (“CMA”) and the Holyoke Gas and Electric Department (“Holyoke”). The Projects are
separate and distinct and will have independent utility to Tennessee’s customers; however, for
Massachusetts Environmental Policy Act (“MEPA”) review purposes, Tennessee is including both in this
Expanded Environmental Notification Form (“EENF”).
A separate project to serve CMA is the construction of a new meter station in Longmeadow,
Massachusetts. The Longmeadow Meter Station will provide a needed delivery point for CMA (the
nearest delivery points are in Agawam and East Longmeadow), specifically on the east side of the
Connecticut River. 4 The Longmeadow Meter Station will enhance system reliability to 55,000 existing
CMA customers and supports the ability of CMA to serve future customers. The Longmeadow Meter
Station is scheduled to be constructed beginning in June 2019 and placed into service in November 2019
(CMA requires this additional point of delivery to be operational by November 2019). The volume of
natural gas supplied to the proposed Longmeadow Meadow Station will come from Tennessee’s existing
mainline and is not influenced by the Looping Project or HP Replacement Project, each described above.
Tennessee provides this description of the new meter station for informational purposes only as the new
meter station does not trigger any MEPA review thresholds and has independent utility from the Looping
Project and HP Replacement Project, each described above. The Longmeadow Meter Station is separate
and distinct from the Projects submitted with this EENF (and Tennessee reserves all rights with respect to
this position); however, Tennessee includes this description to avoid any claim regarding segmentation.
3
Tennessee’s predecessor, Tennessee Gas Transmission Company, received authority from the Federal Power
Commission (the predecessor to the FERC) in 1958 to construct and operate a new 10-inch diameter pipeline to replace an
existing 6-inch-diameter line. The 10-inch-diameter replacement line was relocated to a less congested area than the 6-inch-
diameter line and was constructed to increase transportation capacity to meet growing demands. Tennessee Gas Transmission
Co., Docket No. G-15265, 20 FPC 441 (1958).
4
Currently, CMA provides natural gas service to its existing customers on the east side of the Connecticut River by a
single pipe that crosses Memorial Street Bridge. If something were to happen to that single pipe, delivery of natural gas could be
impeded significantly. Adding a new delivery point will enhance reliability and redundancy as well as allowing bi-directional
flow east and west across the Memorial Street Bridge to improve operational flexibility for CMA. It will reduce the risk of a
disruption to CMA’s distribution system due to the current single source of supply for the City of Springfield and the surrounding
communities.
5
2.1 PROPOSED FACILITIES
2.1.1 Purpose and Need

Tennessee is an indirect wholly-owned subsidiary of Kinder Morgan, Inc. and a major transporter of
natural gas to local distribution companies and other end users in the northeast U.S. Tennessee plans to
construct the Looping Project and HP Replacement Project to upgrade its existing 261B-100
pipeline. These Projects are proposed in response to the request of Tennessee’s customers, CMA and
Holyoke. The Projects will ensure safe, reliable, and continuous natural gas service to (a) CMA’s Greater
Springfield Service Territory, which provides natural gas to approximately 106,000 customers in 16
municipalities, and (b) Holyoke’s approximately 10,000 customers. The Massachusetts Department of
Public Utilities (“DPU”) recognized the need for CMA’s additional capacity and recently approved
agreements, including Tennessee’s agreement, to support this need in Docket DPU 17-172 by an order
issued May 31, 2018.
The Looping Project, which includes 2.1 miles of 12-inch-diameter loop to be installed on the 261B-100
pipeline, would provide an additional 17,000 dekatherms per day (“Dth/d”) of capacity to transport
incremental natural gas requested by the customers to the existing CMA distribution system. The
Looping Project will provide multiple benefits. First, it will provide the needed additional transportation
capacity to support residential and commercial connections in the Greater Springfield Service
Territory. Second, it will increase the design delivery pressure to the system, which will further enhance
CMA’s ability to provide reliable service to its customers. Finally, it will enhance the reliability of the
261B-100 pipeline by providing the ability to maintain deliveries to the system in the event that the
looped section of the line is taken out of service for maintenance.
The HP Replacement Project involves the modernization of equipment at CS 261. The 10-inch 261B-100
pipeline and the aforementioned proposed loop begin at CS 261. The HP Replacement Project involves
removing two existing older units (a Solar Saturn installed in 1965 and a Solar Centaur installed in 1991)
and installing a new Solar Taurus 70 compressor unit. The new compressor unit is better designed to
meet the anticipated operational conditions at CS 261, including peak flow conditions, resulting in more
reliable service for Tennessee customers. This design will provide higher pressure into the 10-inch 261B-
100 pipeline, and will increase the operational reliability by providing approximately 30,800 Dth/d of
capacity at the nearest delivery point on CMA’s distribution system in Agawam.
In addition to meeting the customers’ needs, the HP Replacement Project will create 25,000 Dth/d of
incremental transportation capacity on Tennessee’s pipeline system to delivery points in Massachusetts.
Tennessee recognized the opportunity to better serve the regional need for natural gas by maximizing the
horsepower replacement within its existing infrastructure. This is a unique opportunity to not only meet
customers’ needs, but also to provide incremental capacity on a long-term basis into the already
constrained New England region. This region often experiences a shortage of gas transportation capacity,
especially in the winter during critical periods of peak heating demand, resulting in higher gas prices in
New England.
2.1.2 Location and Description of Facilities

2.1.2.1 Looping Project
The proposed Looping Project consists of approximately 2.1 miles of 12-inch-diameter pipeline loop in
Agawam, Massachusetts (see Figure 2-1 in Appendix A). The pipeline loop is designed for a maximum
6
allowable operating pressure (“MAOP”) of 700 pounds per square inch (“psi”) and will be constructed of
carbon steel. The incremental capacity created by the pipeline loop will be approximately 17,000 Dth/d.
The loop commences at Tennessee’s CS 261 in Agawam, Massachusetts. The loop proceeds for
approximately 0.3 miles through the CS 261 property before crossing Suffield Street. The loop then
proceeds north/northwest roughly parallel to Suffield Street for approximately 1.8 miles, crossing
Shoemaker Lane, Gold Street, and Silver Street, before terminating at its tie-in location north of Silver
Street. Tennessee has designed this route in a manner to avoid significant areas of residential
development, minimize the number of affected landowners, and minimize environmental impacts. To
accomplish this, the majority of the 2.1-mile pipeline loop upgrade would be located with Tennessee’s
existing pipeline corridors and would replace an existing abandoned 6-inch-diameter pipeline where
feasible. Where the proposed loop deviates from Tennessee’s existing pipeline corridors, the route is
intended to minimize impacts to residences and/or existing utility structures.
Appurtenant facilities associated with the Looping Project include pig launcher and receiver facilities, and
permanent access roads (“PAR”). A “pig” is a device used for cleaning and internal inspections of a
pipeline. Manifolds are installed at either end of a pipeline segment to propel the pig through the pipe.
Tennessee will install a pig launcher and tie-in piping at the commencement of the loop at Station 00+00,
on CS 261 property, and a pig receiver and tie-in piping on the northern terminus of the loop at Station
110+88. Three PARs are proposed to allow vehicle access to the right-of-way (“ROW”) during both
construction and operation; each PAR is located within an existing disturbed corridor.
The proposed permanent pipeline facilities are summarized in Table 2-1 below.
Table 2-1. Proposed Permanent Facilities for the Looping Project
Facility Loop Stationing Length or Area
12-inch-diameter pipeline loop upgrade 00+00 to 110+88 2.1 miles

Pig Launcher / Tie-in 00+00 Approximately 50 feet
PAR 1 46+65 266 linear feet
Pig Receiver / Tie-in 110+88 Approximately 50 feet
2.1.2.2 HP Replacement Project

The HP Replacement Project involves removing two existing older units (a Solar Saturn installed in 1965
and a Solar Centaur installed in 1991) and installing a new Solar Taurus 70 unit. The Project also
includes replacement of an existing older emergency generator with a new unit. Table 2-2 below
summarizes the existing permitted equipment along with the proposed changes. Other equipment
currently located at the facility will not change as part of this Project and are therefore not included in the
table below.
7
Table 2-2. Proposed Compressor Station 261 Modifications associated with the HP Replacement
Project
Change in ISO
Equipment Proposed Action
Horsepower (“HP”)
Solar Centaur H Turbine To be removed -5,490 HP

Solar Saturn T-1001 Turbine To be removed -1,199 HP
Waukesha Emergency Generator (natural gas) To be removed N/A
Solar Taurus 70 Turbine New +11,107 HP
Waukesha Emergency Generator (natural gas) New N/A
Total Horsepower Change +4,418 HP
New auxiliary facilities associated with the proposed upgrades will include an auxiliary building, cable
trays, suction header, blowdown silencer, and filter/separator.
2.2 LAND REQUIREMENTS

Table 2-3 provides a summary of land requirements for the Projects.
Table 2-3. Summary of Land Requirements for the 261 Upgrade Projects in Massachusetts
Land Affected During Land Affected During

Facility
Construction (acres)a Operation (acres)b
Looping Project
Pipeline Loop ROWc 19.91 5.51

ATWS 6.77 0.00
d
Pipe / Contractor Yard 3.30 0.00
Access Roads 2.07 1.07
Looping Project Total 32.05 6.58
HP Replacement Project
Compressor Station 261 Upgrades 4.86 0.06

HP Replacement Project Total 4.86 0.06e
261 UPGRADE PROJECTS TOTAL 36.91 6.64
a: Land Affected During Construction includes Land Affected During Operation.
b: Land Affected During Operation includes only the new permanent ROW that is in addition to the existing easement of Tennessee’s
existing pipelines. Further, it does not include proposed ROW across agricultural or open lands, which will revert to pre-existing
conditions after construction.
c: Includes land associated with removal of the abandoned 6-inch pipeline, which is entirely within the footprint of the of the pipeline loop.
d: Total acreage of Yard is 11.30 acres, of which 3.30 acres are in Massachusetts and 8.0 acres of which are in Connecticut.
e: Reflects land within the existing operational footprint of the station that will be impacted by the construction of a new building.
2.2.1 Looping Project

Typically, the land requirements for pipeline construction depend on the size of the pipeline to be
installed, topographic conditions, and other environmental and constructability factors. The proposed
standard construction ROW width for the Looping Project is 75 feet, which allows for the safe installation
8
of the pipeline facilities based on the terrain and land use types crossed by the Project. This construction
ROW width is based on guidelines for safe construction of similarly sized pipelines developed by the
Interstate Natural Gas Association of America (“INGAA”).
In addition to the 75-foot-wide typical construction ROW, the total construction work area will also
include additional temporary workspaces (“ATWS”), temporary and permanent access roads to allow
vehicular and equipment access to the ROW during construction and operation, and a pipe and contractor
yard to be used during construction for parking, pipe storage, and equipment laydown. ATWS are
additional workspaces typically required at road crossings, wetland and waterbody crossings, or other
locations where specialized construction techniques or staging may be necessary. The overall
construction workspace for the pipeline facilities in Massachusetts will total approximately 32.05 acres,
as identified in Table 2-3, which includes the 75-foot-wide construction ROW, ATWS, temporary access
roads (“TAR”), PARs, and the pipe/contractor yard, a portion of which lies in Connecticut, as discussed
below.
The land requirements for operation of the pipeline consist of the footprint of any appurtenant
aboveground facilities, as well as the maintained permanent pipeline easement required for safe operation
of the pipeline corridor. Where the pipeline loop overlaps with Tennessee’s existing permanent easement
the existing permanent easement will need to be expanded by an approximate 20-foot width to allow for
the safe operation and maintenance of the pipeline loop. Where the pipeline loop deviates from the
existing easement, a new 40-foot-wide permanent easement will be required for safe operation and
maintenance. Of the 32.05 acres of construction workspace required for the pipeline facilities,
approximately 5.51 acres will be maintained as new permanent easement and 1.07 acres will be used for
PARs, as identified in Table 2-3.
Appurtenant facilities associated with the Project will include a pig launcher, pig receiver, and crossover/
tie-in piping to be constructed by Tennessee. Tennessee is finalizing the design of these appurtenant
facilities; should additional land be required for the construction of these facilities outside the pipeline
loop construction workspaces, it will be provided to MEPA in the Environmental Impact Report (“EIR”).
Access to the pipeline corridor during construction will primarily be from existing public roadways.
However, Tennessee proposes to use seven access roads during construction; four of these access roads
are TARs that will be used during construction only and three will be PARs that will continue to be used
for vehicle access to the pipeline during operation. All are located within existing disturbed areas such as
farm roads, driveways/parking areas, or sewer easements. It is not anticipated that widening or roadway
improvements will be required for use of the access roads; however, minor tree trimming or selective tree
removal may be required to allow safe access for vehicles. Temporary equipment mats may be used
during construction on the access roads, where needed, to provide a stable surface for equipment or to
protect existing structures (e.g., sewer lines, paved surfaces, or culverts).
Tennessee has identified one location near the Looping Project that will serve as a contractor/pipe yard
for the temporary storage and laydown of pipe, materials, and equipment/vehicle parking during
construction. This 11.3-acre area, known as the “Hickory Street Yard,” was originally proposed and
approved as a contractor yard for Tennessee’s Connecticut Expansion Project. Approximately 3.3 acres
of the 11.3-acre yard are located in Massachusetts, while the remaining 8.0 acres is located in
Connecticut. The property is owned by Tennessee and has been used for agricultural purposes.
During the Looping Project planning phase, Tennessee evaluated potential routes, including co-location
of the proposed pipeline loop with other existing ROWs. Co-locating the loop with existing utility
corridors minimizes impacts on sensitive resources while also accommodating certain requirements that
are inherent in pipeline design. Approximately 1.5 miles (73 percent) of the 2.1-mile pipeline loop will
be co-located with (i.e., centerline will be located within) the existing permanent easement of Line 261B-
9
100. Areas where Tennessee was not able to locate the proposed loop within this easement were
primarily due to constructability issues (e.g., avoidance of transmission line poles or paved driveways) or
efforts to minimize impacts on residential development (e.g., a condominium development crossed by the
existing pipeline easement). In these locations, the route parallels or co-locates with transportation or
utility corridors, or is located within maintained lawn associated with the CS 261 property, to the extent
practicable. Table 2-4 provides a summary of existing ROWs that are abutting, overlapping, or located
within 200 feet of the Project ROW.
Table 2-4. Analysis of Co-located Facilities with the Looping Project
Length
Length
Begin End Adjacent Length Not Co-
Adjacent Facilities Overlapping
Station Station (within 200 feet) located (feet)
(feet)
(feet)
CS 261 00+00 13+00 1,290

Suffield Street 13+00 13+50 53
Line 261BP-100 / Suffield 13+50 21+90 849
Street
Line 261B-100 21+90 32+40 1,034
WMECO electric corridor 32+40 34+70 216
6-inch abandoned line 34+70 36+40 207
Line 261B-100 36+40 39+20 283
Shoemaker Lane 39+20 39+70 50
Line 261B-100 40+20 72+10 3,183
Line 261B-100 / Gold Street 72+10 73+50 63
Line 261B-100 73+50 105+00 3,231
Line 261B-100 / Silver Street 105+00 105+70 64
Line 261B-100 105+70 110+88 515
PROJECT TOTALS 9,906 1,132 0
Approximately 73 percent of the pipeline loop route will be located within the permanent easement of
Line 261B-100, an additional 17 percent will be co-located with other roadway and utility corridors and
Tennessee’s existing property at CS 261, and the remaining 10 percent is located adjacent to (within 200
feet of) these corridors.
2.2.2 HP Replacement Project

Upgrades to CS 261 are proposed entirely within the existing fenced-in facility boundaries. The majority
of the new facilities proposed at the site will be located within existing developed portions of the site,
including existing buildings, paved parking areas, or maintained lawn. However, a new auxiliary building
and its gravel driveway will be constructed on an adjacent previously disturbed, vegetated area on the site.
As identified in Table 2-3 above, the proposed workspace required for construction of the CS 261
upgrades is 4.86 acres. Permanent operational facilities are entirely within the existing fenced-in facility
boundaries. The only operational land use requirement will be limited to 0.06 acre associated with the
construction of the auxiliary building, which is proposed within the existing facility fenceline.
10
2.3 PIPELINE CONSTRUCTION PROCEDURES

The Projects’ facilities will be designed, constructed, tested, operated, and maintained to conform with
applicable federal, state, and local requirements, including U.S. Department of Transportation (“DOT”)
regulations at 49 Code of Federal Regulations (“CFR”) Part 192, “Transportation of Natural and Other
Gas by Pipeline: Minimum Federal Safety Standards” and FERC regulations at 18 CFR Section 380.15,
“Siting and Maintenance Requirements.” In addition, Tennessee will comply with the FERC Plan and the
FERC Procedures, which are provided for reference in Appendix B. Tennessee will also follow its Spill
Prevention and Response Procedures (“SPRP”), Unanticipated Discovery Plan for cultural resources, and
typical construction workspace layout drawings. All of these documents will be incorporated into
Tennessee’s Environmental Construction Management Plan (“ECMP”). The ECMP is intended to be a
working document that will incorporate the FERC Plan and FERC Procedures, as well as all applicable
plans, permits, and clearances, and specifies other best management practices (“BMPs”) that will be used
to avoid and minimize adverse environmental impacts; a preliminary ECMP will be prepared and
submitted to the applicable regulatory agencies with the permit applications.
2.3.1 Standard Pipeline Construction Methods

The general procedures for pipeline construction that will be followed for the Projects are described in
this section. Tennessee will use conventional techniques for buried pipeline construction and will follow
the requirements set forth in the FERC Plan and FERC Procedures, to ensure safe, stable, and reliable
transmission facilities consistent with FERC and DOT specifications. At a minimum, Tennessee will
perform the following procedures:
• Marking the corridor;
• Clearing and grading;
• Trenching;
• Stringing;
• Pipe preparation (bending, welding, non-destructive testing, weld coating, and coating repair) and
lowering in;
• Backfilling and rough grading;
• Hydrostatic testing and tie-ins; and
• Cleanup and final restoration.
The above-listed procedures will typically follow in the sequence listed. Areas requiring special
construction plans and techniques may include: road or utility crossings, waterbodies and wetlands,
unusual topographies such as unstable soils and trench conditions, residential or urban areas, agricultural
areas, areas requiring rock removal, and permanent recreational facilities.
2.3.1.1 Marking the Corridor

Land survey crews will mark the Projects’ limits of disturbance and centerline of Tennessee’s existing
pipelines with stakes prior to construction. The centerline will be marked at frequent intervals, as well as
at known crossings of foreign lines and utilities, at road crossings, and at points of inflection.
11
Additionally, avoidance areas including wetland boundaries, cultural resource sites, and rare species
habitat, as applicable, will be marked with appropriate fencing, signage, and /or flagging, based on
environmental and archaeology surveys and environmental permit conditions, prior to construction.
2.3.1.2 Erosion and Sediment Control

Tennessee will install temporary soil erosion and sediment control measures along the proposed
construction ROW, ATWS areas, access roads, and other work areas, as applicable, in accordance with
the Projects’ ECMP, which incorporates FERC Plan and FERC Procedures. Typically, staked straw bales
and/or silt fence barriers are positioned along the limit of wetland boundaries within the construction
workspace. To ensure that appropriate erosion and sediment control measures are maintained until the
construction workspace is fully stabilized, Tennessee will assign a fulltime EI to the Projects. The EI will
inspect all disturbed areas of the construction spread(s) (e.g., construction ROW, pipe storage yards,
temporary contractor yards) that have not been permanently stabilized in accordance with the following
schedule: 1) on a daily basis in areas of active construction; 2) on a weekly basis in areas with no
construction or equipment operation; and 3) within 24 hours of the end of a storm event that is 0.5 inch or
greater.
2.3.1.3 Clearing, Grading, and Fencing

The construction corridor will be cleared and graded to remove brush, trees, roots, and other obstructions
such as stumps. Non-woody vegetation may be mowed to ground level. Temporary fences and grates
will be installed as needed. No cleared material will be stored within wetland areas.
Tennessee anticipates disposal of trees cleared from the ROW using several different methods. Trees, if
suitable, may be taken off-site by the clearing contractor and used for timber. Trees may be chipped on-
site and removed. Chipped material that is not removed may be spread across the ROW within upland
areas in a manner that does not inhibit revegetation. Wood chips will not be left within agricultural lands,
wetlands, or within 50 feet of wetlands. Also, wood chips will not be stockpiled in a manner that they
could be transported into a wetland.
Should individual landowners wish to use the trees cleared from the ROW, the timber will be left and will
be neatly stacked at the edge of the ROW in areas identified by the EI prior to the commencement of
clearing activities and directly accessible to the landowner in accordance with individual landowner
agreements. Timber shall only be stacked along the ROW at the specific request of a landowner, under
the condition that it is in an already cleared upland area that will be accessible to the landowner without
disturbing the restored ROW. Timber not designated for other uses will be disposed of by Tennessee’s
contractor in accordance with applicable laws and regulations pertaining to timber transport and disposal,
as designed by the EI or contract agreement. Timber will not be stacked in drainage ways or left within
wetlands.
Tennessee will schedule grading activities to minimize the time between grading and the actual
installation of pipe. Access to the construction corridor will normally be obtained via public roads that
intersect the ROW. Permission will be obtained from landowners for the use/upgrade of access roads
across their property to the construction corridor. At the request of a landowner, Tennessee shall erect
temporary gates along access roads where necessary.
Grading of the construction workspace will allow for the movement of heavy equipment and the safe
passage of work crews. Grading will include removing rock outcrops, tree stumps, ridges, and
topographic irregularities. Generally, machinery will operate on one side of the trench (working side)
with excavated materials stockpiled on the other (non-working side).
12
As appropriate, the clearing and grading operations will incorporate special construction procedures to
minimize the amount of vegetation removed from stream banks and slopes, prevent undue disturbance of
the soil profile, restore the original contours of the natural ground, and prevent topsoil erosion. To
minimize impact to the soil profile on agricultural lands, up to 12 inches of topsoil will be segregated
from subsoil during trenching and will remain segregated during construction to avoid loss due to mixing
with subsoil material. Tennessee will utilize either full ROW topsoil segregation or ditch plus spoil side
topsoil segregation, as requested by the landowner, as required by applicable U.S. Department of
Agriculture (“USDA”) Natural Resources Conservation Service (“NRCS”) District, or as appropriate
based upon site-specific conditions. Upon completion of backfilling operations, the topsoil will be
properly replaced over the graded areas. Grading activities will be scheduled to minimize the time
between grading operations and the actual installation of pipe.
2.3.1.4 Trenching
In most areas characterized by normal soils, the trench for the pipeline is excavated by crawler-mounted,
trenching machines or track-mounted excavators. The trench generally will be approximately 16 inches
wider than the diameter of the pipe and of sufficient depth to allow for the minimum cover requirements
to the top of the pipe in accordance with DOT regulations pursuant to the Natural Gas Pipeline Safety Act
of 1968. Permitting requirements may dictate greater depth.
Except as depicted on site-specific plans, the depth of cover for the proposed pipeline loop will be in
accordance with Tennessee’s minimum specifications, as set forth in Table 2-5. Scour analysis and
potential for external damage may increase these depths. In actively cultivated agricultural lands,
Tennessee plans to install the pipeline with 48 inches of cover, except where rock prevents this depth. In
these cases, Tennessee’s minimum depth of cover will be used.
Table 2-5. Tennessee Minimum Specifications for Depth of Cover (inches)
Location a Normal Soil Consolidated Rock
DOT PHMSA Class 1 36 24

DOT PHMSA Class 2, 3, and 4 36 24
Land in Agriculture 48 24
Drainage ditches of public roads or railroad crossings 60 24
Navigable river, stream, or harbor 60 24
Minor stream crossings 60 24
a: As defined by DOT Pipeline and Hazardous Material Safety Administration (“PHMSA”) at 49 CFR 192.5.
Class 1: offshore areas and areas within 220 yards of a pipeline with occupancy.
Class 2: areas within 220 yards of a pipeline with >10 but <46 buildings intended for human occupancy.
Class 3: areas within 220 yards of a pipeline with >46 buildings intended for human occupancy and areas within 100
yards of either a building or a small, well defined outside area (such as a playground, recreation area, outdoor
theater, or other place of public assembly) that is occupied by 20 or more persons on at least five days a week for
10 weeks in any 12-month period.
Class 4: areas within 220 yards of a pipeline where buildings with four or more stories are prevalent.
Crossing of foreign pipelines will generally require the pipeline to be buried at greater depths, depending
upon the depth of the foreign pipeline. When crossing foreign pipelines, utilities, or other structures, a
minimum of 18 inches of clearance will be maintained between the proposed pipeline loop and the utility
or structure being crossed. Although not anticipated based on soil conditions, pipeline burial depths in
areas requiring special construction techniques through rock would be in accordance with DOT
requirements, 49 CFR Part 192. Prior to the commencement of construction activities, the “Dig-Safe”
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call system for Massachusetts, as well as the national “811” call system, will be contacted to have
underground utilities and foreign pipelines identified and marked. Trenching in the vicinity of these
foreign utilities will begin only after completing the appropriate notification procedures.
In accordance with the FERC Plan and FERC Procedures, Tennessee will employ measures to minimize
erosion during trenching operations and construction activities. Tennessee will also implement measures
to minimize the free flow of water into the trench and through the trench into waterbodies. Compacted
earth for temporary trench breakers and sandbags or foam for permanent trench breakers may be installed
within the trench to reduce erosion.
2.3.1.5 Pipe Stringing

The stringing operation involves moving the pipe into position along the prepared ROW. Pipe will be
delivered to the Projects’ pipeline storage areas typically by truck and will then be moved by truck from
the pipeline storage areas to the construction zone, where it will be placed along the ROW in a continuous
line in preparation for subsequent bending and set-up operations. Individual joints of pipe will be strung
along the ROW parallel to the centerline and arranged so they are easily accessible to construction
personnel. The amount of pipe necessary for stream or road crossings will be stockpiled in pipeline
storage areas adjacent to each crossing. Stringing activities will be coordinated in advance with the
trenching and pipe laying crews to minimize the potential impact to the resources.
2.3.1.6 Pipe Bending

The pipe will be delivered to the Projects’ sites in straight sections. However, bending of the pipe will be
required to allow the pipeline to follow natural grade and directional changes of the ROW. For this
purpose, prior to line-up and welding, selected joints will be field-bent by track-mounted hydraulic
bending machines. For larger horizontal changes of direction, manufactured bends may be used.
2.3.1.7 Pipe Assembly and Welding

Following stringing and bending, the joints of pipe will be placed on temporary cribbing supports
adjacent to the trench. The ends will be carefully aligned and welded together using multiple passes for a
full penetration weld. Only welders qualified in conformance with American Petroleum Institute (“API”)
Standard 1104 – Welding of Pipelines and Related Facilities will be permitted to perform welding on the
Projects. A Tennessee-approved welding inspector will conduct the welder qualification testing and
document all test results. A welder failing to meet acceptance criteria of Tennessee’s company standards
will be disqualified.
2.3.1.8 Non-Destructive Testing and Weld Repair

To ensure that the assembled pipe meets or exceeds the design strength requirements and to ensure weld
quality and integrity, the welds will be inspected visually and tested non-destructively using radiographic
(gamma ray) or another approved test method, in accordance with API 1104 Standard. Welds displaying
unacceptable defects will be repaired, or the welds will be cut out (removed) and new welds will be
installed and retested.
2.3.1.9 Coating Field Welds, Inspection, and Repair

Following welding, the field joints will be abrasively blasted and coated with a Tennessee-approved anti-
corrosion, below-grade, liquid epoxy coating. Prior to lowering the pipe into the trench, the coating on
the entire pipe section will be electronically and visually inspected and any damaged areas repaired.
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2.3.1.10 Pipe Preparation and Lowering-In

Once the pipeline has been welded together, coated, and inspected, the pipe is lowered into the trench.
The pipe will be supported on sandbags or support pillows at designated intervals along the trench, then
padded with native soils sifted to remove large stones. Trench dewatering may be required in certain
locations to prevent the pipe from floating and also to perform certain limited activities in the trench.
Tennessee will perform trench dewatering in accordance with the FERC Plan and FERC Procedures.
2.3.1.11 Tie-Ins
At select locations, such as waterbody crossings, road crossings, and terrain changes along the pipeline
system, the pipe will be lowered into the trench in segments. The segments will then be welded together
or tied-in prior to backfilling.
2.3.1.12 Backfilling and Grade Restoration

After lowering the pipe into the trench, the trench will be backfilled. Backfill consists of the material
originally excavated from the trench; however, in some cases, additional backfill from other sources may
be required. In areas where topsoil has been segregated, the subsoil will be placed in the trench first and
then the topsoil will be placed over the subsoil. Backfilling will occur to approximate grade. However, a
soil crown may be placed above the trench at the discretion of the Tennessee inspector to accommodate
any future soil settlement.
2.3.1.13 Clean-up and Restoration

After the completion of backfilling, disturbed areas will be graded, and any remaining debris will be
properly disposed of in compliance with federal, state, and local regulations. The construction corridor
will be protected through the implementation of erosion control measures including site-specific
contouring, permanent slope breakers, mulching, and reseeding or sodding with soil-holding vegetation.
Contouring will be accomplished using acceptable excess soils from construction. If sufficient soils are
not available, additional soil will be imported.
Tennessee will restore the construction workspace in accordance with the Project’s ECMP, which
incorporates the FERC Plan and FERC Procedures, applicable seed mix requirements from the NRCS, or
applicable agency recommendations and relevant landowner agreements.
2.3.1.14 Hydrostatic Testing and Tie-Ins

All new pipe will be tested hydrostatically in accordance with DOT’s regulations at 49 CFR Part 192
prior to being put in-service. The pipe will be filled with water obtained from municipal sources and
maintained at a test pressure and duration in compliance with Tennessee’s engineering standards and
applicable federal regulations. After the completion of a satisfactory test, the water will be transferred to
holding tanks, where it will be tested and disposed of at an appropriate off-site facility. Final tie-in
locations will be cleaned and restored after hydrostatic testing.
Hydrostatic testing procedures as described in Section VII of the FERC Procedures are incorporated in
the Projects’ ECMP. Table 2-6 summarizes the potential source, volume, and discharge procedures for
the Projects.
15
Table 2-6. Hydrostatic Test Water Information for the 261 Upgrade Projects
Quantity of Water
Facility Potential Source Method of Disposal
Required (gallons)
Looping Project Municipal 70,000 Transferred to holding tanks for

sampling and off-site disposal.
HP Replacement Project Municipal 40,000 Transferred to holding tanks for
sampling and off-site disposal.
2.3.2 Specialized Pipeline Construction Procedures

Dependent upon site conditions, Tennessee may implement the following special pipeline construction
methods in residential, agricultural, and environmentally sensitive areas.
2.3.2.1 Residential Areas

Tennessee has modified the route of the proposed pipeline loop to avoid construction activities on
residential land. Construction near residential areas will be done in a manner to ensure that all
construction activities minimize adverse impacts on adjacent residences and that cleanup is prompt and
thorough.
2.3.2.2 Agricultural Lands

To preserve soil productivity in agricultural lands, up to 12 inches of topsoil will be segregated and stored
separately from subsoil during construction. Tennessee will utilize full ROW topsoil segregation as
required by landowner agreements, as required by the NRCS District, or as appropriate based upon site-
specific conditions. Rock shall be removed from the top 12 inches (topsoil layer) or to the existing
subsoil horizon during initial cleanup to a level such that the construction ROW is similar to surrounding
areas. During the backfilling and restoration phases, topsoil will be replaced, and any stones
approximately greater than 4 inches in diameter uncovered during construction will be removed or
handled in accordance with individual landowner agreements. Any drain tiles damaged during
construction will be repaired or replaced, and a crop-monitoring program will be implemented to ensure
that crop productivity is restored to pre-construction conditions.
2.3.2.3 Road Crossings

Prior to construction, Tennessee will locate all existing underground utilities and make provisions for
traffic management in work areas as necessary. The majority of road crossings will be completed using
standard open cut or conventional boring methods. Conventional boring entails drilling a hole beneath
travel arteries through which the pipe will pass. No active or inactive railroad beds have been identified
along the pipeline loop route.
2.3.2.4 Trenchless Construction Methods

Trenchless construction methods may be used to construct pipelines in certain areas to minimize impacts
to resources such as major waterbodies, roadways, significant cultural resources, or other sensitive areas.
Using these techniques, the pipeline is installed below the resource using equipment staged at the resource
edge. For the Looping Project, the only trenchless construction technique proposed is conventional bore,
which is discussed below.
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2.3.2.4.1 CONVENTIONAL BORE

Conventional boring consists of creating a shaft/tunnel for a pipe or conduit to be installed to minimize
surface disturbance. This is accomplished by first excavating a bore pit and a receiving pit. The bore pit
is excavated to a depth slightly deeper than the depth of the associated trench and is graded such that the
bore will follow the proposed angle of the pipe. A boring machine is then lowered to the bottom of the
bore pit to tunnel using a cutting head mounted on an auger. The auger rotates through a bore casing,
both of which are pushed forward as the hole is cut. The pipeline is then installed through the bored hole
and welded to the adjacent pipeline. The typical workspace configurations required for boring operations
consists of staging areas (50-foot by 100-foot) for boring machine setup, cuttings/return settlement and
storage pits, pipe storage, entrance and exit pit spoil storage, and construction equipment necessary to
support the operation.
Major factors limiting the success of a boring operation include the crossing distance, subsurface soil and
geologic conditions, and existing topography. Boring operations typically occur over crossing distance of
50 to 60 feet. The maximum length a bore could achieve in ideal soil conditions typically does not
exceed 400 feet. Subsurface soil and geologic conditions must be conducive to establishing and
maintaining a safe bore pit excavation, as well as provide the capabilities for the boring equipment to
conduct a successful bore. Loose packed sediment, free of rock material, is preferred when conducting
boring operations. The topographic conditions at a site may also limit the use of this method, as preferred
locations are generally consistent with level or moderately convex terrain, such that the depth of the bore
pit does not present concerns relative to constructability or safety constraints. Most roads along the
proposed pipeline loop are expected to be crossed via conventional bore, as identified in Table 2-7 below.
Table 2-7. Conventional Bore Crossings for the Looping Project
Begin Station End Station Distance (feet) Resource Crossed
12+89 13+46 57 Suffield Street

29+49 40+00 51 Shoemaker Lane
105+34 105+95 61 Silver Street
2.3.2.5 Rock Removal

Rock encountered during trenching will be removed using one of the techniques detailed below. The
technique selected is dependent on relative hardness, fracture susceptibility, expected volume, and
location. Techniques may include:
• Conventional excavation with a backhoe;
• Ripping with a bulldozer followed by backhoe excavation;
• Hammering with a pointed backhoe attachment or a pneumatic rock hammer, followed by a

backhoe excavation;
• Blasting followed by backhoe excavation; or
• Blasting surface rock prior to excavation.
While some of the rock encountered during trenching will be rippable by conventional excavation
equipment, some of it may require blasting. All blasting activity will be performed according to strict
17
guidelines designed to control energy release. Proper safeguards will be taken to protect personnel and
property in the area. Suitable mats will be used as necessary to prevent scattering of rock and debris.
Tennessee will strictly adhere to all local, state, and federal regulations applicable to controlled blasting
and blast vibration limits with regard to structures and underground utilities while performing these
activities. Special care will be taken to monitor and assess blasting within 150 feet of dwellings and
private or public water supply wells.
Should blasting be anticipated in the Project area based on the results of desktop analysis of surficial
geology and/or geotechnical investigations, Tennessee will develop a Project-specific Blasting Plan that
establishes procedures and safety measures that Tennessee’s contractor will be required to adhere to while
implementing blasting activities along the pipeline ROW. Tennessee’s contractor will be required to
submit a detailed Blasting Specification Plan to Tennessee that is consistent with the provisions of the
Blasting Plan and Tennessee Construction Specifications. The contractor’s plan, when approved by
Tennessee, will be incorporated into the contractor’s scope of work.
Excess rock is defined as all rock that cannot be returned to the existing rock profile in the trench or
graded cuts or is not needed to restore the ROW surface to a condition comparable to that found adjacent
to the ROW. Excess rock will be hauled off the ROW and disposed of at an approved landfill or
recycling facility unless approved for use as slope stabilization, windrowing, or for some other use on the
construction work areas as approved by the landowner or land management agency.
2.3.2.6 Wetland Crossing Construction

Wetland locations along the pipeline loop segments are described in Section 4.2.3 of this narrative and
shown on the aerial map books (Attachment 2 of the ENF) and the Environmental Constraints Maps
(Attachment 3 of the ENF). Pipeline construction across wetlands will be performed in accordance with
the FERC Procedures, as set forth in the ECMP.
Tennessee will use one of the following methods for installing the pipeline within wetlands during
construction. The wetland impact summary table (Table 4-4 of Section 4.2.3.1) identifies the proposed
crossing technique for each wetland. The construction methods are:
• Conventional Wetland Construction
• Wetland Drag-section Method
These crossing techniques are described in detail in Section 4.2.3.2. The wetland summary table (Table
4-4) located in Section 4.2.3.1 identifies the proposed crossing technique for each wetland.
2.3.2.7 Waterbody Crossing Construction

Waterbody locations along the pipeline loop are described in Section 4.2.2 and shown on the aerial
alignment sheets. Pipeline construction across waterbodies will be performed in accordance with the
Project’s ECMP, which incorporates the FERC Procedures, and with applicable permit conditions. If any
crossings are required to take place outside of the specified timeframes, Tennessee will consult with the
applicable agencies to obtain concurrence to proceed with construction outside of the specified
timeframes. Tennessee will use one of the following methods for installation of the pipeline across
waterbodies:
• Conventional Trenching
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• Flume Crossing
• Dam and Pump
These waterbody crossing techniques are described in detail in Section 4.2.2.2. The waterbody summary
table (Table 4-3) located in Section 4.2.2.1 identifies the proposed crossing technique for each waterbody.
2.3.3 Construction Timeframe and Workforce

Construction of the Projects will commence after all necessary ROWs (on town-owned, state-owned or
privately owned lands) and permits/clearances have been acquired for the Project, and Tennessee has
received the Section 7(c) Certificate of Public Convenience and Necessity and Notice to Proceed from
FERC.
Construction of the Looping Project is planned to commence in March 2020 with tree clearing, followed
by pipeline installation starting in June 2020, pending receipt of all applicable permits. The planned in-
service date is November 2020. Tennessee expects that the pipeline loop will be constructed with a single
spread, consisting of approximately 40 to 60 personnel.
Construction of the HP Replacement Project is planned to commence in May 2020 with a planned in-
service date of November 2020. These modifications will require approximately 30 personnel at the peak
of construction.
2.3.4 Supervision and Inspection

Tennessee will use a minimum of one qualified, full-time EI during construction of the Projects. The EI’s
duties will be consistent with those contained in the Projects’ ECMP and will include ensuring
compliance with the ECMP, which incorporates the FERC Plan and FERC Procedures, Tennessee’s
environmental designs and specifications, and other environmental permits, authorizations, or
commitments. Tennessee conducts in-house environmental training to ensure that construction activities
will be in compliance with the requirements of applicable federal, state, and local environmental permits
and approvals and environmental requirements in landowner easement agreements. The level of training
will be commensurate with the type of duties of the Projects’ personnel.
2.4 OPERATIONS AND MAINTENANCE

The Projects will be owned, operated, and maintained by Tennessee. Tennessee will operate and maintain
the newly constructed pipeline loop in the same manner as it currently operates and maintains its major
interstate pipeline facilities, in accordance with the requirements of the FERC, DOT’s Pipeline and
Hazardous Material Safety Administration (“PHMSA”), pursuant to 49 CFR Part 192, and industry-
proven practices and techniques. The facilities will be operated and maintained in a manner such that
pipeline integrity is protected to ensure that a safe, continuous supply of natural gas reaches its ultimate
destination. Maintenance activities will include regularly scheduled gas-leak surveys and measures
necessary to repair any potential leaks. The latter may include repair or replacement of pipe segments.
All fence posts, signs, marker posts, aerial markers, and decals will be painted or replaced to ensure that
the pipeline locations will be visible from the air and ground. The pipeline will be patrolled on a routine
basis, and personnel well qualified to perform both emergency and routine maintenance on interstate
pipeline facilities will perform maintenance.
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The Projects’ facilities will be patrolled on a periodic basis, as are Tennessee’s existing facilities. This
will provide information on possible leaks, construction activities, erosion, exposed pipe, population
density, possible encroachment, and any other potential problems that may affect the safety and operation
of the pipeline. In addition, Tennessee is a participant in the “Dig Safe” system for utility companies in
Massachusetts, as well as the national “811” call system. Under either system, anyone planning
excavation activities must call a dedicated telephone number to alert all utility companies.
Representatives of the utility companies that may be affected then visit the site and mark their facilities so
that the excavation can proceed with relative certainty as to the location of all underground lines.
Other maintenance functions will include: 1) periodic seasonal mowing of the ROW in accordance with
the FERC mowing timing restrictions; 2) terrace repair, backfill replacement, and drain tile repair as
necessary; 3) periodic inspection of water crossings; and 4) maintenance of a supply of emergency pipe,
leak repair clamps, sleeves and other equipment needed for repair activities. Tennessee will not use
herbicides or pesticides within 100 feet of a wetland, waterbody, or water supply well unless approved by
applicable state and local agencies.
2.4.1 Cleared Areas

Following construction, vegetation within the full width of the permanent ROW will be maintained in a
low growing scrub-shrub or herbaceous state, except in wetlands and adjacent to perennial streams, where
maintenance clearing of woody vegetation will be limited. Crop production and grazing will be allowed
to continue in agricultural areas.
Tennessee will maintain a 50-foot-wide post-construction permanent ROW for the existing pipeline and
new loop in accordance with the Projects’ ECMP, which incorporates the FERC Plan and FERC
Procedures. Where the loop will be co-located with existing Tennessee easements, these 50 feet of
permanent ROW will consist of Tennessee’s existing 30-foot easement plus 20 feet of expanded
permanent easement; where the loop is not co-located with existing Tennessee easements, a new 40-foot
permanent easement is proposed. Maintaining a cleared ROW is necessary for the following reasons:
• Access for routine pipeline patrols and corrosion surveys;
• Access in the event that emergency repairs of the pipeline are needed;
• Visibility during aerial patrols; and
• To serve as a visual indicator to the public of an underground pipeline utility and easement.
Operational vegetation maintenance of Tennessee’s permanent ROW in uplands will be conducted on a

frequency of approximately once every three to five years to maintain in an herbaceous to low scrub-
shrub cover state. Tennessee may maintain a 10-foot corridor centered over the pipeline within both
uplands and wetlands to facilitate route patrols and emergency access.
Within wetlands, Tennessee will actively maintain only the 10-foot corridor centered over the pipeline,
allowing the balance of Tennessee’s permanent easement to revert back to its natural, pre-construction
vegetated cover state, except for selectively cutting and removing trees within 15 feet of the pipeline that
could damage the pipeline coating. No permanent loss of wetlands will occur due to the construction or
operation of the Projects, and the Projects will satisfy the No Net Loss of Wetlands standard.
Following construction of the pipeline facilities, areas used during construction for temporary workspace
(“TWS”) and ATWS will be restored to their pre-construction land use/land cover with no further
20
vegetation maintenance by Tennessee. Additionally, crop production will return to agricultural use
immediately following construction or the following growing season.
2.5 CUMULATIVE IMPACTS METHODOLOGY

MEPA regulations require that the Projects’ proponents provide an assessment of the potential cumulative
impacts of the Projects and any other project or other work or activity in the immediate surroundings and
region. Because the MEPA regulations provide little guidance on the methodology of cumulative impacts
assessments, Tennessee implemented the guidance provided by the FERC under their Guidance Manual
for Environmental Report Preparation (FERC 2017) and the Council on Environmental Quality’s
(“CEQ”) regulations under the National Environmental Policy Act (“NEPA”). The CEQ regulations
define cumulative impact as “the impact on the environment which results from the incremental impact of
the action [being studied] when added to other past, present, and reasonably foreseeable future actions.
Cumulative impacts can result from individually minor, but collectively significant, actions taking place
over a period of time” (40 CFR 1508.7 [2015]). This section describes the methodology implemented by
Tennessee. The analysis of cumulative impacts of the Projects are provided for each resource separately
in the Environmental Analysis Chapter of this EENF narrative (Chapter 4).
2.5.1 Scope of Analysis

The scope of the cumulative impacts analysis includes resources directly or indirectly affected by the
Projects. If the Projects result in no or negligible impacts on a resource, then the Projects will not
incrementally contribute to cumulative impacts. For the purposes of this analysis, a negligible impact
means that no apparent or measurable adverse impacts are expected. The Projects’ effects reflect the
successful implementation of the environmental protection and mitigation measures described for each
environmental resource and compliance with applicable federal, state, and local regulations and permit
requirements that minimize impacts. Where minor or greater unavoidable direct or indirect adverse
impacts occur, the resource was analyzed for the Projects’ incremental contributions to cumulative
impacts.
A summary of the resources analyzed and potentially affected by the Projects are identified in Table 2-8
below. For those resources that will be directly or indirectly impacted during construction or operation of
the Projects’ facilities, Tennessee assessed impacts on these resources to determine incremental
contributions to cumulative impacts. This assessment is provided for each resource separately within
Chapter 4.
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Table 2-8. Summary of Resources Analyzed for Cumulative Impacts
Resource ENF Section Looping Project HP Replacement Project
Geologic Resources 4.1.1 N/A N/A

Soils 4.1.2 Construction Construction
Groundwater 4.2.1 N/A N/A
Surface Water 4.2.2 Construction Construction
Wetlands 4.2.3 Construction / Operation Construction
Air 4.3.1 Construction Construction / Operation
Noise 4.3.2 Construction Construction / Operation
Vegetation 4.4.1 Construction / Operation N/A
Wildlife 4.4.2 Construction N/A
Threatened and Endangered Species 4.4.3 Construction / Operation N/A
Traffic, Transit, and Pedestrian and 4.5 N/A N/A
Bicycle Transportation
Scenic Qualities, Open Space, and 4.6 N/A N/A
Recreational Resources
Historic and Archaeological 4.7 Construction N/A
Resources
Land Use 4.8 Construction / Operation N/A
Rare or Unique Features 4.9 N/A N/A
Tidelands 4.10 N/A N/A
Notes: N/A – Not applicable; Projects’ impacts were not analyzed because direct and indirect impacts are negligible.
2.5.2 Temporal and Geographic Distribution

Cumulative impacts may occur when multiple activities have impacts on the same resources during the
same timeframe as the Projects. The region of influence (“ROI”) for potential cumulative impacts is the
physical space directly or indirectly affected by construction and operation of the Projects. The ROI for
each resource varies based on the potential for effects to extend beyond the area of direct impact. For
example, effects on air quality may extend several miles, while impacts on soil resources likely will not
extend beyond the construction workspaces. Table 2-9 below provides a description of the ROI for each
resource area potentially impacted by the Projects.
22
Table 2-9. Regions of Influence by Resource Type for the 261 Upgrade Projects
Resource ROI Type Description of ROI for Projects
Soils Workspace Construction and operation ROWs, ATWS,

access roads, and aboveground facility limit of
disturbance
Surface Water Hydrologic Unit Code 12 (“HUC12”) Connecticut River-Mill River to Freshwater
Brook (HUC12: 010802050102) in
Massachusetts
Wetlands HUC 12 Connecticut River-Mill River to Freshwater
Brook (HUC12: 010802050102) in
Massachusetts
Air Air Quality Control Region (“AQCR”) Hartford-New Haven-Springfield Interstate
AQCR
Noise Inhabited buildings 0.25-mile of construction workspaces along
pipeline route and within 1 mile of the CS 261
property line
Vegetation Ecoregion Connecticut River Valley (Ecoregion 59A) in
Massachusetts
Wildlife Ecoregion Connecticut River Valley (Ecoregion 59A) in
Massachusetts
T&E Species Ecoregion Connecticut River Valley (Ecoregion 59A) in
Massachusetts
Cultural Area of Potential Effect (“APE”) Construction and operation limit of
disturbance
Land Use Municipality Town of Agawam
2.5.3 Activities Considered

Cumulative impacts can result from individually minor but collectively significant activities expected to
occur in a similar location and during a similar period. The purpose of this analysis is to identify and
define cumulative impacts that would potentially result from the implementation of the proposed Projects
along with other projects in the vicinity that could affect the same resources in the same approximate
timeframe. Other projects considered in this analysis include past projects with ongoing impacts, recently
completed projects, and projects that are “reasonably foreseeable” future actions. To ensure that this
analysis focused on relevant projects and potentially significant impacts, the actions considered in the
cumulative impact analysis included projects that:
(1) Impact a resource potentially affected by construction or operation of the Projects, as identified in
Table 2-8 above;
(2) Impact a resource area within all or part of the same geographic area affected by the Projects,
which takes into account the resource being discussed within a region of influence where the
projects could contribute to cumulative impacts on that particular resource; and
(3) Impact a resource within all, or part of, the time span encompassed by the proposed or reasonably
expected construction or operation of the Projects.
Tennessee identified past, present, and reasonably foreseeable future activities in the region (“Activities”)
by consultation with municipal and regional county planning departments and by searching publicly
available information on projects under review at federal, state, and local agencies. The information
23
sources searched included permit applications, municipal meeting minutes, and websites. In addition,
letters of requests were sent to regional and town planning departments requesting information about
development activities within the vicinity of the Project facilities. Tennessee’s assessment focused on
Activities that have the potential to cause cumulative impacts (e.g., large infrastructure projects, industrial
facilities, large commercial facilities, and large residential subdivisions). Minor activities (e.g., single
family house lots, additions, small commercial developments, and minor roadway projects) were not
included in this analysis because impacts are expected to be negligible.
Table 2-10 below lists the Activities identified for consideration in the cumulative impacts analysis of the
Project, including the following information for each, if available:
• Activity type (energy, commercial/industrial, transportation, or large residential subdivision);
• Project name and sponsor/proponent;
• A brief description of the Activity;
• The location and distance from the nearest proposed Project facility;
• Quantitative impacts on specific resources, if available; and
• The current status and schedule of the Activity.
Publicly available information, including applications filed with federal and state agencies, professional
judgment, and desktop analysis provided quantitative and qualitative information on the magnitude and
nature of the impacts of past, present, and reasonably foreseeable future activities to determine the
potential for cumulative impacts on the resources affected.
24
Table 2-10. Past, Present, and Reasonably Foreseeable Activities and Associated Resource Impacts Considered in the Cumulative Impacts Analysis for the 261 Upgrade Projects
Project/ Proponent Project Description Location / Distance and Estimated Timeframe Resource Impacts a
Direction from Project
Workspaces
Soils Surface Wetlands Air Noise Veg Wildlife T&E Species Cultural Land Use
Water
ENERGY PROJECTS
TJA Solar / TJA Solar, LLC b Construction of a 4.9 MW 311 Shoemaker Lane, Unknown; currently seeking Construction Riverfront Buffer Zone Construction Construction Construction Construction N/A N/A 16.4 ac of ag land
ground mounted solar energy Agawam, MA municipal approvals (16.4 ac) Area only only and operation converted to
system on approximately 16.4 0.69 mile west of Station commercial/
acres (ac) of a 60.6-ac parcel. 41+00 industrial use
Longmeadow M&R Station / Construction of a meter station, 400 Shaker Rd., Construction start: June Construction TBD TBD Construction Construction Construction Construction N/A TBD Construction and
Tennessee Gas Pipeline c including two 8-inch taps on Longmeadow, MA 2019; construction and and operation and operation
mainlines 200-1 and 200-2; one 3.4 miles west of complete: November 2019 operation operation
4-inch and one 8-inch meter Compressor Station 261
with 12-inch headers and 8-inch
station piping; and access
driveway.
CT Loop of Connecticut Construction of 0.11 miles of Commences at Compressor Construction start: April 22, Construction Riverfront Construction Construction Construction Construction Construction N/A N/A Construction and
Expansion Project / Tennessee new 24-inch pipeline within or Station 261, Agawam, MA / 2017; (5.88 ac) area only (0.59 ac); and operation operation
Gas Pipeline d adjacent to the Tennessee 0 ft Construction complete: (0.54 ac) Operation
ROW in Agawam. Minor November 9, 2017 (0.32 ac)
modifications to Compressor
Station 261 in Agawam, MA.
ConEd Line Replacement / Con Replacement of 8,500 feet of Commences one mile north TBD Construction Construction Construction Construction Construction Construction Construction TBD N/A Construction
Edison e existing line with new pipe in of Station 110+88
Springfield, MA.
Alternate Backfeed / Columbia Construction of 6 miles of new Commences one mile north TBD Construction Construction Construction Construction Construction Construction Construction TBD TBD Construction and
Gas of Massachusetts e 12-inch pipeline between of Station 110+88 and operation and operation and operation
Agawam and Holyoke, MA. operation
Berkshire Gas f Construction of 19 miles of 12- Proposed route still in Project design is “still in its Construction TBD TBD Construction Construction Construction Construction TBD TBD Construction and
inch-diameter pipeline starting development, but would infancy” and and operation and Operation
at Tennessee’s 200-Line and pass through Hampden and operation operation
extending to the Northampton Hampshire Counties,
Meter Station. Project would through city/town streets.
include a new regulator station New / replacement
in Greenfield, MA and would aboveground facilities in
require Tennessee to replace its Greenfield and
Northampton Meter Station. Northampton, MA.
Westfield Reliability Project / Includes construction of a new Westfield, MA / 7.6 miles Construction start: 1st Construction Riverfront 34,490 sf Construction Construction Construction Construction Potential Yes N/A – existing utility
WMECO (Eversource) g 115-kV overhead transmission northwest of Station 110+88 quarter 2019 area only (temp mats); ROW
line in Westfield, MA; Construction complete: 4th 4,760 sf (tree
modifications at the Buck Pond quarter 2019 removal);
Substation; a new Switching 1,900 sf
Station; and modifications to the (perm fill)
existing 1512 Line.
3419 Road Building Project / Construction of permanent Ludlow, Wilbraham, & Construction start: 1st Construction 80 lf Bank 26,550 sf Construction Construction Construction Construction Potential Yes N/A – existing utility
WMECO (Eversource) h access roads along 12 miles of Hampden, MA / 9.1 miles quarter 2018 and and Operation ROW
overhead transmission lines. west of Compressor Station Construction complete: 4th Operation
261 quarter 2018
High Street to Westfield River / Replacement/updates to a line/ High Street to Westfield Unknown. Order of Construction Riverfront Buffer zone Construction Construction Construction Construction Conditional Unknown N/A – existing utility
Eversource i circuit including 19 new poles, 5 River, Agawam/ 2.2 miles Conditions issued by area only only “no take” ROW
replacement poles, and removal north of Station 110+88 Agawam Conservation from NHESP
of 7 poles. Commission 6/6/17
25
Project/ Proponent Project Description Location / Distance and Estimated Timeframe Resource Impacts a
Direction from Project
Workspaces
Soils Surface Wetlands Air Noise Veg Wildlife T&E Species Cultural Land Use
Water
Montague Solar Project / Construction of a 25-ac solar Millers Falls Rd & Lake Construction start: March Construction N/A N/A Construction Construction Construction Construction Yes (Eastern TBD Yes – conversion of
Eversource j farm. Pleasant Rd., Montague / 2017 and operation and box turtle) upland forest to
36 miles north of Station Construction complete: Dec (25 acres) operation commercial /
110+88 2017 industrial land use
COMMERCIAL/INDUSTRIAL DEVELOPMENTS
Chicopee Hotel Redevelopment Redevelopment of a 7.9-ac 357 Burnett Road, Construction start: Spring Construction N/A N/A Construction Construction N/A N/A N/A N/A N/A
/ Chicopee Inn, Inc. k previously developed parcel to Chicopee, MA / 8.6 miles 2017; Construction
include mixed commercial, northeast of Station 110+88. complete: Spring 2019
including hotel, restaurant, fast-
food restaurant, coffee shop
and gas station/convenience
store.
Westfield Turnpike Industrial Construction of a 75-ac Industrial Park Road, Construction start: July 1, Construction N/A N/A Construction Construction Construction Construction No Unknown Construction and
Park / Town of Westfield l industrial park. Westfield / 8.7 miles 2019; Construction and and operation and operation and operation –
northwest of Station 110+88 complete: July 1, 2027 operation operation conversion of
(75 acres) forested and
agricultural land to
industrial
RESIDENTIAL DEVELOPMENTS
Ace Precision Way/Ace Proposed 3-lot subdivision. 1123 Suffield Street, TBD; Project is in planning Construction Unknown; Unknown; Construction Construction Construction Construction No Unknown Unknown
Precision, Inc. m Agawam, MA / 230 feet east phase. No development and Intermittent BWW is and operation and
of TAR 2. plan has been presented to operation stream and present on operation
town. riverfront site
area to
Tarkill Brook
present on
site
TRANSPORTATION PROJECTS
Route 147 Highway & Reconstruction of the Morgan Suffield Street at Westfield Construction start: late 2017 Construction Riverfront N/A Construction Construction Unknown Unknown N/A Unknown N/A
Intersection Improvements and Sullivan Bridge (Suffield St.) River / 2.0 miles northeast area impacts
Morgan Sullivan Bridge over Westfield River, and of Station 110+88 only
Reconstruction / MassDOT n highway and intersection
improvements to Route 147.
Access Improvements to Improvements to improve safety Western Avenue in Construction start: Spring Construction N/A N/A Construction Construction Construction N/A N/A Unknown Construction and
Western Avenue – Central and access to/from Route 20 in Westfield / 8.3 miles 2018; construction and operation operation
Phase / City of Westfield o Westfield. northwest of Station complete: Fall 2020
110+88.
OTHER ACTIVITIES
Sewer Improvements / Construction of a new pumping M Street & Connecticut TBD; construction was Construction Construction Unknown Construction Construction Unknown Unknown Unknown Unknown N/A
Springfield Water and Sewer station in Springfield and River, Agawam, MA / originally anticipated Fall and and operation
Commission p installation of new piping Approximately 3 miles 2017 but the Project filings operation
connecting the pumping station northeast of Station 110+88 have been delayed multiple
to Bondi’s Island in Agawam. times as proponent
continues design.
Roberts Meadow Brook Stabilization of bank erosion Roberts Meadow Brook, Unknown Construction Construction N/A N/A N/A Construction Construction N/A Potential N/A
Channel Rehabilitation Project / areas along a 525 linear foot Northampton, MA / 20 miles and operation and operation
City of Northampton q section of Roberts Meadow north of Station 110+88 – 15,775
Brook in Northampton. square feet of
waters of the
U.S.
NOTES: TBD = To be Determined (still in design); N/A = Not Applicable (impacts are expected to be negligible).
a: Resource impacts in italics are speculative based on best professional judgment, since the Activity is still in design phase or more specific information on impacts was not available. Impacts in bold are located within the same ROI for that resource as the Projects.
SOURCES:
26
b: Agawam Conservation Commission. 2018. Agawam Conservation Commission Meeting Minutes of February 22, 2018. Last accessed on March 30, 2018 at http://www.agawam.ma.us/AgendaCenter/ViewFile/Minutes/_02222018-660.
c: Tennessee Gas Pipeline, L.L.C. Corporate knowledge.
d: Tennessee Gas Pipeline, L.L.C. 2015. Final Environmental Impact Report Filed under 301 CMR 11.00 Massachusetts Environmental Policy Act Regulations for the Connecticut Expansion Project, Agawam, Sandisfield and Tyringham, Massachusetts, EEA #15205, March 2, 2015.
e: Columbia Gas of Massachusetts. 2017. Columbia Gas of Massachusetts Plans Reliability Projects, November 7, 2017. Last accessed on March 30, 2018 at https://www.columbiagasma.com/en/about-us/newsroom/news/2017/11/07/columbia-gas-of-massachusetts-plans-reliability-projects.
f: MassLive.com. 2016. Berkshire Gas Proposes Major New Distribution Main to Lift Moratorium in Upper Pioneer Valley. Last accessed on March 30, 2018 at http://www.masslive.com/news/index.ssf/2016/10/berkshire_gas_proposes_major_n.html.
g: Beaton, M.A. 2018. Certificate of the Secretary of Energy and Environmental Affairs on the Environmental Notification Form, Westfield Reliability Project. EEA #15829. April 20, 2018.
h: Beaton, M.A. 2017. Certificate of the Secretary of Energy and Environmental Affairs on the Environmental Notification Form, 3419 Road Building Project. EEA #15698. June 23, 2017.
i: Agawam Conservation Commission. 2017. Agawam Conservation Commission Meeting Minutes of May 25, 2017. Last accessed on April 30, 2018 at http://www.agawam.ma.us/AgendaCenter/ViewFile/Minutes/_05252017-249.
j: Beaton, M.A. 2017. Certificate of the Secretary of Energy and Environmental Affairs on the Environmental Notification Form, Montague Solar Project, EEA# 15646. March 24, 2017.
k: Chicopee Hotel Redevelopment Environmental Notification Form. EEA#15625. Published in Environmental Monitor on December 21, 2016.
l: Westfield Turnpike Industrial Park. EEA #15845. Published in Environmental Monitor on April 11, 2018.
m: Agawam Planning Board. 2018. Agawam Planning Board Meeting Minutes of February 1, 2018. Last accessed on April 30, 2018 at https://www.agawam.ma.us/AgendaCenter/ViewFile/Minutes/_02012018-524.
n: Agawam Conservation Commission. 2017. Agawam Conservation Meeting Minutes of July 13, 2017. Last accessed on April 30, 2018 at http://www.agawam.ma.us/AgendaCenter/ViewFile/Minutes/_07132017-386.
o: Access Improvements to Western Avenue – Central Phase Environmental Notification Form. EEA #15835. Published in Environmental Monitor on March 21, 2018.
p: Agawam Conservation Commission. 2017. Agawam Conservation Meeting Minutes of April 13, 2017. Last accessed on May 30, 20
q: U.S. Army Corps of Engineers. 2017. Public Notice for CENAE-R File No. NAE-2016-1083. Published May 2, 2017.
27
2.5.4 Analysis Summary

For each resource potentially affected by the Projects’ facilities (summarized in Table 2-8), Tennessee
identified those Activities that potentially affect the same resource (identified in Table 2-10) and that are
located within the same ROI for that resource as the Projects (identified in Table 2-9). The analyses then
compare the incremental impacts of the Projects with the potential cumulative impacts of the past,
present, and reasonably foreseeable future activities considered. Cumulative impacts are discussed in
Chapter 3 for each resource potentially affected by the Projects.
2.6 PERMITS REQUIRED

Tennessee will obtain necessary permits, licenses, and clearances for the Projects. Tennessee will include
copies of relevant environmental permits and approvals in the construction bid packages and contracts,
and will incorporate those documents in the Projects’ ECMP. The contractor will be required to be
familiar with all permits and licenses obtained by Tennessee and will be required to comply with all the
requirements related to the construction of the Projects and to the restoration of any areas disturbed by the
construction of the Projects. Table 2-11 below provides a list of the permits, licenses, and clearances
identified for the Projects. Agency correspondence is provided in Appendix C.
Table 2-11. Federal and State Approvals for the 261 Upgrade Projects
Federal
Section 7(c) application under Federal Energy Regulatory Commission Anticipate submittal September 2018.
the Natural Gas Act
Section 404 MA GP U.S. Army Corps of Engineers New England Anticipate submittal August 2018.
District
Section 7 Clearance U.S. Fish and Wildlife Service To be initiated July 2018.
NPDES – Construction U.S. Environmental Protection Agency Exempt.
Section 106 Clearance MA Historical Commission Project Notification Form submitted
May 24, 2018; consultation ongoing.
CZM Consistency MA Coastal Zone Management Agency Not Applicable / not in coastal zone.
Massachusetts State
MEPA ENF Certificate Massachusetts Environmental Policy Act EENF filed herein.
MEPA EIR Certificate Massachusetts Environmental Policy Act Anticipate submittal of EIR 4th quarter
2018.
401 Water Quality Certification Massachusetts Department of Environmental Anticipate submittal September 2018
Protection
Order of Conditions under Agawam Conservation Commission / Anticipate submittal of Notice of Intent
Wetlands Protection Act Department of Environmental Protection July 2018.
MESA Project Review / MA Natural Heritage & Endangered Species Anticipate submittal of Project Review
Conservation & Management Program request with Notice of Intent July 2018.
Permit (Looping Project only)
Non-major Comprehensive Plan Massachusetts Department of Environmental Application submitted December 14,
Approval (HP Replacement Protection 2017; currently under review.
Project only)
Local
28
Road opening permits Agawam Department of Public Works Anticipate submittal prior to
construction.
Building Permit Approval Agawam Building Department Applicability to be determined.
29
Chapter 3 Project Alternatives

Tennessee has undertaken an extensive needs and alternatives analysis for the Projects. Tennessee’s
primary objective in performing this analysis was to identify options for the Projects that would satisfy
Tennessee’s requirement to meet its customers’ demand for natural gas transportation service, while
working to avoid or minimize potential adverse environmental impacts to the greatest extent practicable.
As discussed below, Tennessee evaluated pipeline routing options based on regional topography, potential
adverse environmental impacts, population density, existing land usage, and construction safety and
feasibility considerations, as well as different configurations of compression facilities.
3.1 NO-ACTION ALTERNATIVE

The “no-action” alternative for the Projects would avoid the temporary and permanent environmental
impacts associated with construction and operation of the currently proposed Projects. However, by not
constructing the Projects, Tennessee would be unable to provide the necessary natural gas transportation
service required to meet the expressed needs of its customers. Given the constrained pipeline capacity in
the northeast United States, other natural gas transmission companies would be required to increase their
capacity by constructing new facilities to meet the existing demand for the additional transportation
capacity. Such actions would only result in the transference of environmental impacts from one location
to another and would not reduce or eliminate such impacts. Given the much greater distance to other
natural gas transmission companies, the required infrastructure and resulting impacts would greatly
exceed that of Tennessee’s proposed Projects. If existing natural gas transmission systems are not
enhanced or expanded, energy shortages in times of peak demand may ensue, or users may revert to the
consumption of alternative fuels, which may include oil or propane. Natural gas continues to be the most
cost effective residential heating fuel and is 30-80% less expensive than other fuels, including propane,
heating oil, and electricity (Commonwealth of Massachusetts 2018). Utilization of natural gas as the
primary fuel offers the best alternative in terms of supply availability with the lowest environmental
impact among available alternative energy sources, particularly with regard to air quality impacts. The no-
action alternative was not found to be a feasible alternative for the Projects because that alternative would
not satisfy the purpose and need for the Projects and ultimately would result in other, more significant
impacts to the environment.
3.2 ENERGY CONSERVATION/ENERGY ALTERNATIVES
3.2.1 Energy Conservation

Reduction in the need for additional energy usage is the preferred option wherever possible.
Conservation of energy reduces the demand for the limited fossil fuel reserves. Energy conservation is
also advocated by both federal and state authorities in Massachusetts. The development and
implementation of additional conservation measures could have an effect on the demand for natural gas;
however, substantial new technology development and increased social and political support would be
needed before the magnitude of energy conservation needed to equal the Projects could be implemented
effectively. There remains an existing need for additional natural gas capacity that would be provided
with the construction of these Projects. Energy conservation alone is not a viable alternative to the
Projects in the immediate future.
30
3.2.2 Energy Alternatives

The use of alternative energy sources will not meet the stated purpose and need of the Projects’
customers, who have requested additional natural gas firm transportation capacity. The Projects’ purpose
and need is described in Section 2.1.1. Furthermore, any proposed energy alternative would require new
infrastructure to transport the energy to the required delivery point. This new infrastructure would be
expected to have a similar or greater environmental impact as the proposed Projects, which utilize
existing facilities and utility corridors to the extent practicable. It would not be feasible to use alternative
sources of energy to satisfy the need intended to be served by the Projects, such as other fossil fuels (i.e.,
coal and fuel oil), nuclear, solar, wind, hydroelectric power, geothermal, wood and other biomass, fuel
cells, and solar. These energy alternatives, whether alone or in combination, are not anticipated to
provide a timely, commercially viable, and environmentally preferable alternative to the Projects in the
near term.
3.2.3 Efficiency Improvement Options

Tennessee evaluated options for increased efficiency within its pipeline and compression systems to
determine if incremental capacity to transport natural gas volumes could be added through the
implementation of efficiency upgrades or modifications. While these options could be implemented to
achieve a limited amount of benefit, Tennessee determined that these measures alone would not be
sufficient to provide the required capacity to transport the volumes of natural gas required by the Projects’
customers.
3.3 SYSTEM ALTERNATIVES

System alternatives would make use of other existing, modified, or proposed natural gas pipeline systems
or facilities to meet the stated objectives of the proposed Projects. A viable system alternative would
make it unnecessary to construct all or part of the proposed Projects, and would involve the transportation
of all or a portion of the additional natural gas volumes by expansion of another existing pipeline system
or construction of a new pipeline system. Such modifications or additions would result in environmental
impact; however, the impact in all likelihood would be similar to, or greater than that associated with
construction of the proposed Projects.
Technical and feasible system alternatives were evaluated in terms of their ability to meet the Projects’
objectives, which were defined by the incremental level of firm transportation service contracted for by
the market, as described in Section 2.1.1. The facilities associated with the Projects are necessary to
provide the incremental firm transportation capacity for CMA and Holyoke on Tennessee’s existing
261B-100 pipeline.
31
Tennessee, because it currently operates an interstate natural gas pipeline system in the northeast,
evaluated its ability to supply the increased demand for natural gas transportation service in this area
using efficiencies afforded by its existing system. Additionally, Tennessee considered system alternatives
involving different configurations of pipeline looping and compression facilities within its own
transmission system, as well as efficiency improvements. These alternatives are described in the
following sections. Tennessee used the following evaluation criteria when selecting feasible alternatives
to the Projects:
• technical and economic feasibility and practicality;
• extent of environmental impacts; and
• ability to meet the Projects’ objective to provide additional incremental capacity to service
Tennessee’s customers’ need, given that alternative energy sources or conservation are not able to
satisfy this demand.
3.3.1 Modifications to Other Pipeline Systems

No pipeline systems owned and operated by other natural gas pipeline companies with the ability to
provide the requested natural gas volumes to CMA’s and/or Holyoke’s local distribution infrastructure
exist in the region. Therefore, any other natural gas transmission company would require a significant
investment in infrastructure to provide the requested natural gas to the customers, resulting in
significantly more environmental impact than the modest upgrade of Tennessee’s existing pipeline system
and compressor station.
3.3.2 Looping Project Alternatives

The Looping Project consists of the installation of 2.1 miles of 12-inch loop adjacent to Tennessee’s
pipeline, to the extent practicable. Tennessee evaluated three alternatives to avoid the need for looping:
(i) a compression only option, (ii) lifting the existing 10-inch and replacing (relaying) it with a larger
diameter pipe, and (iii) uprating the operating pressure of the existing 10-inch diameter line.
3.3.2.1 Compression Only Option

Prior to developing the proposed Looping Project, Tennessee initiated the proposed HP Replacement
Project at CS 261 to maximize capacity of the existing 10-inch diameter pipeline. Given that the
customers’ needed transportation capacity exceeds the transportation capacity that the HP Replacement
Project alone can provide, the Looping Project was developed. If the pipeline loop is not constructed, a
portion of the customers’ required transportation capacity would not be available. Based on this, the
Compression Only Option was not selected as a viable option and was not further considered.
3.3.2.2 Lift and Relay Option

The “lift and relay” option would involve replacing Tennessee’s existing 10-inch-diameter pipeline with a
larger diameter pipe, such as a 16-inch line. To construct the lift and relay option, Tennessee would need
to take the existing pipeline out of service for approximately two months during construction. Taking the
line out of service would require that a temporary liquefied natural gas (“LNG”) truck terminal be
constructed, and that LNG trucks be dispatched to the area on a 24-hour basis for the anticipated two-
month duration. In addition to the noise and emissions from the LNG trucks, the LNG regasification
32
facilities would create noise and emissions from regasifying the LNG. In addition, the construction
impact from the larger line would be similar to that of the proposed Looping Project. The customers
would also experience significantly higher costs given the greater cost of the LNG commodity, cost of
establishing a temporary truck terminal, trucking costs, and higher cost of a larger delivery line. Based on
these factors, lift and relay was not selected as a viable option and was not further considered.
3.3.2.3 Uprating Option

Uprating is a process that is used to increase the allowable operating pressure in a pipeline that is not
being used to its full design capability. This process would allow the existing infrastructure to transport
more natural gas and reduce the need to build additional pipeline facilities. Pipelines are designed to
operate at certain pressures based on the pipe steel yield strength, diameter, and wall thickness, which are
used to determine the maximum pressure a pipeline can withstand.
Uprating the existing 10-inch-diameter pipeline is not a technically feasible option to increase natural gas
firm capacity to meet the customers’ needs because, in this case, the pipeline material was not designed to
operate at the pressure that would be required to transport the requested natural gas capacity. The existing
10-inch-diameter pipeline has a MAOP of 700 psi, while a pressure of approximately 815 psi would be
required to achieve the same delivery pressures as the proposed Looping Project. Furthermore, the
pipeline is supplied from the discharge of existing CS 261, which operates a common discharge supplying
two mainlines and the 10-inch lateral, which all have an MAOP of 700 psi. Therefore, increasing the
discharge to the existing 10-inch pipeline cannot be achieved without also increasing the discharge
pressures to the other pipelines served by this common discharge, or constructing a sole purpose
compressor and yard piping to discharge only into the existing 10-inch-diameter pipeline, which would
have additional environmental impacts, expenses, and would create operational flexibility issues. Based
on this, the Uprating Option is not a viable option and was not further considered.
3.3.3 HP Replacement Project Alternatives

The HP Replacement Project consists of upgrades to Tennessee’s existing CS 261 to provide both
additional natural gas capacity and improved reliability to its customers, CMA and Holyoke. Tennessee
investigated three possible alternatives to the HP Replacement Project to meet the customers’ needs: (i) a
pipeline looping option; (ii) rewheeling the existing compressor units; and (iii) an electric driver option.
Each of these alternatives is discussed below.
3.3.3.1 Looping Only Option

Extending the proposed pipeline loop could be used to add natural gas capacity to a system in lieu of the
HP Replacement Project. In order to avoid the need for the HP Replacement Project, Tennessee
calculated that the proposed 2.1 miles of 12-inch-diameter loop would need to be extended by an
additional 2.2 miles, with 4.8 miles of 36-inch mainline loop also required. The 4.8 miles of 36-inch
mainline loop would likely have significant environmental and landowner impacts, and the extension of
the proposed 12-inch diameter loop would entail construction in several residential neighborhoods, with
additional environmental impacts and impacts to the landowners and community as compared to the
proposed HP Replacement Project, which is sited entirely within Tennessee’s existing CS 261 facility.
Further, the addition of a longer pipeline loop and mainline loop would not solve the reliability issue
related to the existing older compressor engines, or achieve the emissions and noise reductions associated
with the HP Replacement Project. For these reasons, the Looping Only Option was not deemed to be a
viable option and was not further considered.
33
3.3.3.2 Rewheel Compressors

Rewheeling is a process that can be used on compressor units to accommodate different process
conditions (e.g. increase the flow or pressure) within certain design and performance limits. However,
the age of the existing Saturn and Centaur compressor units at CS 261 limits the engineering options to
meet the design conditions needed to provide the additional natural gas capacity requested by Tennessee’s
customers. Further, the reliability issues related to the use of these existing older compressor engines
would remain. Rewheeling the older units would also not result in the emissions and noise reductions
anticipated with replacement by the new unit. For these reasons, rewheeling the existing compressors
was not deemed to be a viable option and was not further considered.
3.3.3.3 Electric Driver Option

Tennessee evaluated the use of electric motor-driven compression as opposed to the proposed natural gas
turbine driven compressor unit, and determined that it would replace two existing natural gas turbine
driven compressor units with a natural gas turbine compressor unit at CS 261 for the reasons provided
below:
• Although electric driven compression would eliminate certain stationary source emissions at CS
261, these emissions would simply be transferred to electric generation facilities in the area, the
majority of which utilize natural gas. An even worse emissions scenario occurs if an electric
motor driven compressor consumed electricity from the marginal electric supplier using coal, oil,
refuse, or wood fired generation. In New England, these sources accounted for 8.4 percent of the
generation fuel in 2017 and 11.3 percent through the first four months of 2018 (ISO-NE 2017).
• While reliability of the local electric transmission lines is good, electric supply is still vulnerable
and not as reliable as using natural gas for fuel. The supply of electricity for electric motor driven
compression is subject to power line outages (such as during storm events including ice) or black
or brown-outs due to power plant outages or general lack of generating capacity. Continued
retirement of nuclear, coal, and oil-fired capacity in New England is expected to further constrain
electricity supply (i.e., closure of Vermont Yankee, Brayton Point, and Pilgrim) (U.S. NRC 2017;
Finucane 2017; Abel and Ellement 2016). Peak natural gas usage (and thereby also compression
use) and peak electricity usage occur simultaneously for this region during cold winter weather,
further increasing the chances of loss of electric power exactly when the compression is most
needed.
• Mechanical problems with an electric motor drive can be much more complex and result in
extended downtime while the motor is repaired or replaced. Purchasing a spare standby motor is
not practical.
• Additional ancillary equipment (transformers, switchgear, breakers, etc.) would be required to

deliver power to an electric motor, which would result in additional environmental impacts.
• Electric driven compression would necessitate the construction of a new building and electric
substation within Tennessee’s existing CS 261 site. Given the existing facilities on the site, the
only location where these facilities could be located would be in the southwest portion of the site,
which has a large wetland system associated with Worthington Brook. This work would require a
substantial amount of wetland fill, likely requiring substantial approvals pursuant to the Wetlands
Protection Act. In contrast, Tennessee’s proposed HP Replacement Project will not require
construction beyond the existing developed portion of the site, and only minimal (0.03 acres),
temporary wetland disturbance during construction. Siting electric driven compression facilities
34
on an adjacent site (e.g., the Hickory Street Yard property) would require extensive tree clearing
within forested wetlands to route the necessary power lines to the site.
• Significantly higher capital cost to customers would be incurred from installing an electric drive
compressor unit ($43.6 million [“MM”]) as compared to the proposed natural gas driven Taurus
turbine ($22.9MM).
Fuel costs for electric driven compression are significantly higher compared to natural gas. Over 20
years, Tennessee estimates the additional fuel cost would amount to approximately $84MM in additional
costs for Massachusetts consumers. For these reasons, electric driven compression was not chosen as a
viable alternative and was not further considered.
3.4 PROPOSED PROJECTS CONFIGURATION

ALTERNATIVES
3.4.1 Looping Project Route Alternatives

Alternatives and variations to the route of the proposed pipeline loop were evaluated as part of the
planning and design process for the Looping Project. The alternatives analysis for the Project facilities
was based on environmental and land use impacts, as well as permanent easement acquisitions and overall
Project costs. Due to the length of the pipeline loop, there were no Major Route Alternatives (defined
below) evaluated. The following steps were used in the selection of the route variations discussed below:
• Determination of most cost effective technical solution;
• Development of routing criteria;
• Identification of potential routing variations;
• Collection of data relative to each option;
• Evaluation of potential environmental and land use impacts; and
• Evaluation of routing variations against routing criteria.
Existing information sources such as aerial photography, topographic maps from the USGS and National
Wetland Inventory (“NWI”) maps, and Massachusetts Bureau of Geographic Information (“MassGIS”)
data sources were used during the route variation identification and evaluation process. Because field
surveys were only completed for the proposed pipeline loop, this information was not included in the
evaluation process to ensure that the comparisons are equivalent between route variations.
The main determinants used to select the proposed route over the original route evaluated pertained to
minimizing the number of affected landowners, constructability issues, and Tennessee’s desire to limit the
extent of disruption on the communities potentially being affected during construction.
In evaluating options for the construction and operation of the proposed Looping Project, Tennessee
determined that given the existing pipeline, the proposed pipeline looping should be co-located with the
existing pipeline ROW to the maximum extent practicable, feasible, and as legally permitted. Co-locating
a new pipeline loop with an existing line is a preferred option as it minimizes the environmental impacts,
35
numbers of new affected landowners, constructability issues, and costs, as well as limits the extent of
disruption to the communities that would be affected during construction.
3.4.1.1 Internal Pipe Coating

Tennessee evaluated the installation of internally coated pipe as an energy saving alternative to determine
if the length of the pipeline loop could be reduced for the Looping Project. The use of internal pipeline
coating reduces the roughness of the pipe’s internal wall. A smooth internal wall reduces the resistance or
internal friction between the flowing gas stream and the wall of the pipe. Therefore, reducing internal
friction reduces energy loss and would reduce the required length of looping to transport a given quantity
of gas. Installation of internal pipeline coating reduces the overall pipeline construction footprint of 2.1
miles by just over 100 feet of pipeline looping in order to obtain the same hydraulic effect. However, on
a practical basis, Tennessee would still construct the 2.1 miles of loop to reach an accessible location to
construct and operate the tie-in to the existing 10-inch 261B-100 pipeline and a pig receiver. For this
reason, Tennessee elected not to use internal pipe coating for the Looping Project.
3.4.1.2 Loop Diameter Option

Tennessee also evaluated shorter pipeline loops of larger diameter, including 1.9 miles of 16-inch
diameter pipe. In order to terminate the loop at 1.9 miles, Tennessee would need to negotiate and reach
agreement with a landowner to convey approximately 1,000 square feet to site the tie-over and pig
receiver. Instead, Tennessee has reached voluntary agreement with the landowner at the termination of
the proposed 2.1-mile loop to utilize land that is currently being used for commercial activities. In
addition, given the modest reduction in length for a 16-inch diameter rather than 12-inch-diameter loop,
the capital costs are projected to be higher for the 16-inch-diameter loop alternative. This higher capital
cost would result in a higher transport rate for CMA and its customers. A 12-inch diameter loop is small
enough to allow Tennessee to maximize the use of its existing pipeline corridor, while being large enough
to efficiently transport the required volumes of natural gas. For these reasons, the 12-inch diameter loop
was determined to be the optimal size and the alternative loop diameter option was not chosen.
3.4.1.3 Major Route Alternatives

A Major Route Alternative is an alignment that has the potential to meet the Project objective but would
deviate significantly in both length and distance from the proposed pipeline loop. The physical start and
end points for the pipeline loop were determined through hydraulic modeling. Therefore, any major route
alternatives to this pipeline loop would consist of a new pipeline with the same start and end points as the
proposed pipeline.
As discussed above, in evaluating the routing options for the Looping Project, Tennessee determined that
the pipeline loop should be co-located within the existing pipeline ROW to the maximum extent
practicable, feasible, and as legally permitted. The use of co-location as a principle design element by
Tennessee is necessitated not only by Federal Energy Regulatory Commission guidelines that stress the
corridor concept, but also due to the existing land use characteristics in the area of the pipeline loop. The
utility corridor created by Tennessee’s existing pipeline minimizes further environmental impacts and
public disturbance, as well as construction costs. Locating pipeline facilities along the existing corridor
reduces the establishment of new corridors in previously undisturbed areas while limiting the number of
affected landowners. For these reasons, no Major Route Alternatives were considered for this Project and
looping the 261B-100 line was selected as the Preferred Route.
36
3.4.1.4 Route Variations

Route variations or deviations are typically the result of detailed field review and vary only slightly from
the proposed pipeline route. A route variation makes adjustments to the proposed pipeline route to
address landowner concerns or avoid specific features (e.g., sensitive habitat, wetlands, telephone pole,
and structures). The majority of the Looping Project is proposed to be co-located with Tennessee’s
existing pipeline system; therefore, these variations also considered which side of the ROW the new
pipeline would be located. Due to the linear nature of the Project, Tennessee’s preferred design criteria is
to locate the Looping Project on one side of the existing ROW and remain on that side to minimize cross-
overs that would otherwise complicate construction.
Because co-location was a principal design element of the Project, the proposed pipeline route considered
for the pipeline loop was one that is co-located for its entire length with the 261B-100 pipeline. However,
route variations were incorporated into the design at specific locations to reduce impacts to landowners,
avoid structures, and minimize environmental impacts. Four route variations were identified, evaluated,
and incorporated into the proposed Project, as summarized in Table 3-1 below and depicted in Figures 3-1
to 3-4 in Appendix A.
Table 3-1. Comparative Analysis of Minor Route Variations Incorporated into the Looping Project
Route Variation/Comparison Factor Original Route Proposed Routea Reason for Incorporation
Route Variation 1 (Station 5+44 to 21+90) Proposed route was adopted to avoid a
condominium complex crossed by the
Route Length (feet) 1,203 1,644 existing Line 261B-100. Tennessee also
Construction Land Requirements 1.8 2.9 evaluated another route variation in this
location that follows entirely along the
Operational Land Requirements 0.3 0.6 Berkshire Power pipeline. That variation
was not selected because it follows an
Land Uses Crossed (feet) internal driveway on the CS 261
- Upland Forest 323 737 property, and would therefore interfere
with Tennessee’s safe access to the
- Agricultural 0 0 facility.
- Open Upland 199 161
- Open Water 231 112
- Residential 450 0
- Industrial/Commercial 0 633
- Forested Wetlands 0 0
- Non-forested Wetlands 0 0
Waterbody Crossings (no.) 2 2
Residences within 100 feet of Centerline (no.) 8 (multi-family 1
buildings)
Distance to closest residential or commercial / 9 99
industrial building (feet)
37
Route Variation 2 (Station 32+25 to 40+80) This portion of the pipeline loop crosses
an overhead electric transmission line
Route Length (feet) 803 826 ROW. This route variation was adopted
Construction Land Requirements 1.4 1.4 to avoid a transmission structure located
in the path of the Original Route, by re-
Operational Land Requirements 0.0 0.1 routing it to the abandoned 6-inch line
corridor. It then deviates from the
Land Uses Crossed (feet) abandoned 6-inch corridor at the
- Upland Forest 0 184 crossing of Shoemaker Lane to provide
sufficient distance from the existing lines
- Agricultural 0 0 to safely conduct the road bore.
- Open Water 6 8
- Residential 0 0
- Forested Wetland 0 30
- Non-forested Wetland 0 5
Residences within 100 feet of Centerline (no.) 0 0
Route Variation 3 (Station 73+00 to 79+90) This route variation consists of a cross-
over of the pipeline loop from the west
Route Length (feet) 606 659 side of the Line 261B-100 easement to
Construction Land Requirements 1.0 1.1 the east side to avoid an existing
industrial building located less than 25
Operational Land Requirements 0.2 0.3 feet west of the existing Line 261B-100
centerline.
Land Uses Crossed (feet)
- Upland Forest 207 239
- Agricultural 0 0
- Open Upland 0 0
- Open Water 0 0
- Residential 0 0
38
Route Variation 4 (Station 104+52 to 110+88) This route variation consists of a cross-
over of the pipeline loop from the west
Route Length (feet) 626 638 side of the Line 261B-100 easement to
Construction Land Requirements 1.1 1.3 the east side to avoid electric
transmission line pole structures and
Operational Land Requirements 0 0 provide additional setback from an
electric substation.
Land Uses Crossed (feet)
- Upland Forest 0 0
- Agricultural 79 79
- Open Water 0 0
- Residential 0 0
a: Numbers shown may not agree with the numbers presented in other Chapters of this narrative. To facilitate an accurate comparison of all routes
considered, certain design features of the Proposed Route (e.g., ATWS and access roads) were not included and environmental comparison factors
were based only on desktop review. Data provided in other Chapters are based on the actual proposed Project footprint and include the results of field
surveys.
The proposed routing for the Looping Project minimizes impacts to the environment and/or residences
while optimizing Project constructability and economics. For Route Variation 1, the proposed route is
longer and, as such, would result in more construction and operational land impacts than the original route
that follows the 261B-100 pipeline; however, this variation was necessary to avoid direct impacts to a
condominium complex. For Route Variation 2, the proposed route deviates from the 261B-100 pipeline
to avoid transmission line structures and provide sufficient setbacks from the existing utility lines at the
Shoemaker Lane road bore. Finally, Route Variations 3 and 4 represent cross-overs of the proposed loop
from the east side of the 261B-100 pipeline to the west side that are proposed to avoid impacts to an
industrial building and transmission line structures, respectively.
3.4.2 HP Replacement Project Site Options

No alternative existing compressor station sites were considered for the HP Replacement Project. The
261B-100 pipeline begins at CS 261 and an existing building at the compressor station is suitable for the
replacement horsepower.
3.4.3 Contractor Yard Alternatives

No alternative contractor yards have been considered for these Projects. The proposed Hickory Street
Yard was previously approved as part of Tennessee’s completed Connecticut Expansion Project. It is an
existing open field that is located adjacent to the CS 261 property. As such, materials to be stored there
39
will be readily available for use during construction with minimal environmental or landowner impacts
required.
3.5 ALTERNATIVES SUMMARY

After review of all construction, fuel source, system, and the No-Action alternatives, it is evident that the
proposed Projects, as designed, represent the preferred alternative. If the proposed Projects are not
constructed to meet customer demand (i.e., the No-Action Alternative is selected), the market served by
the customers that have executed binding precedent agreements for all of the Projects’ capacity may
experience energy shortages in times of peak demand or users may revert to the consumption of
alternative fuels including oil. Use of alternative fuels to supply the energy needs of Tennessee’s natural
gas customers is not the best practicable alternative as compared to the use of cleaner-burning natural gas.
In addition, although energy conservation is a valuable measure as part of an overall energy plan, energy
conservation alone is not a solution to the current energy demand of consumers served by these Projects.
As discussed herein, Tennessee conducted a detailed system alternatives analysis and route analysis,
including consideration of efficiency improvements, a lift and relay option, an uprating option, and
pipeline looping and compression options. The detailed system alternatives analysis allowed the Projects’
designers to select the best configuration of the proposed facilities, including preferred routes and siting
for the proposed Looping Project, to meet the needs of the market. The HP Replacement Project and 2.1-
mile, 12-inch-diameter Looping Project were ultimately selected as the Preferred Alternatives because
they meet the customers’ objectives, allow for the use of existing pipeline corridors, and minimize
impacts to environmental resources and landowners.
40
Chapter 4 Environmental Analysis

This chapter provides a description and analysis of the existing environmental conditions of the Projects’
site, its immediate surroundings, and the region; an assessment of the negative and positive potential
environmental impacts of the Projects, including direct and indirect effects; the mitigation measures
designed to limit negative environmental impacts or to cause positive environmental impacts during
development and operation of the Projects; and the cumulative impacts of the Projects when taken into
consideration with the mitigation measures implemented and other projects in the immediate surroundings
and region. A discussion of the cumulative impact methodology applied to this analysis is provided in
Section 2.5.
4.1 TOPOGRAPHY, GEOLOGY, AND SOILS
4.1.1 Geologic Resources

4.1.1.1 Existing Environment
Table 4-1 summarizes the topographic and geologic conditions within the proposed Projects’ areas and
lists areas of shallow bedrock and other geologic hazards that would be traversed by the proposed pipeline
alignment.
Table 4-1. Geologic Conditions in the Projects’ Areas
Geology Geologic Hazards

Project
Component Physiographic Province / Geological Formation / Stationing of Shallow Stationing of Severe
Section Stratigraphic Unit Bedrock a Erosion Potential b
Looping Project New England Province / Portland Formation None 88+00 to 89+00
New England Upland
Section
HP Replacement New England Province / Portland Formation None None
Project New England Upland
Section
a: Areas of shallow bedrock are those with bedrock within five feet from the surface. See Table 4-2 for soil series information, including depth to
bedrock, for the soils crossed by the Project. Blasting may be necessary in these areas and will be carried out according to local, state, and federal
blasting regulations.
b: Area of soil that contain severe erosion potential. See Table 4-2 for soil series information, including erosion potential and erosion hazard, for the
soils crossed by the Project.
4.1.1.1.1 TOPOGRAPHY
The Projects’ areas are located within a lowlying area of the Connecticut River Valley. Topography
ranges from approximately 118 feet on southern end of pipeline loop at CS 261, slopes up gradually to a
high of 196 feet at a knoll between Tarkill Brook and Silver Street, then slopes back down to an elevation
of 157 feet on northern end of loop.
The Projects are located in the New England Upland Section of the New England Province, as defined by
Fenneman (1938). The undulating hilly topography of the New England Upland Section ranges in
elevation from below 1,000 feet to above 2,000 feet. Streams run in well-graded and rounded valleys,
and local relief ranges from a few hundred feet to 1,000 feet at the larger mountains in the section.
41
Glaciation has shaped the landscape of this region, with most of the surficial sediments found across New
England resulting from glaciation.
Within the New England Upland Section, the Projects are located in the Connecticut River Valley
ecoregion. The altitude of the Connecticut River Valley floor generally ranges from sea level to about
100 meters, except for narrow ridges of volcanic rock largely on the west side of the valley, which rise to
altitudes of about 180 to 300 meters. The bedrock is largely sandstone, shale, conglomerate, and volcanic
rocks of Jurassic and Triassic age. The borders of the valley in Massachusetts are easily defined on the
basis of bedrock lithology and topographic form (Denny 1982).
4.1.1.1.2 GEOLOGIC HAZARDS
Earthquakes
An earthquake is the vibration of the earth’s surface that follows a release of energy in the earth’s crust
due to fault fracture and movement. The cause of earthquakes in eastern North America is the forces
moving tectonic plates over the surface of the Earth. New England is located in the middle of the North
American plate. Therefore, New England’s earthquakes appear to be the result of the cracking of the
crustal rocks due to compression as the North American plate is being very slowly squeezed by global
plate movements (Commonwealth of Massachusetts 2013).
Because of the difficulty of identifying seismically active geological features in the Northeast, the level of
seismic hazard in the northeastern part of the United States is based primarily on the past record of
seismic activity (Kafka 2004). The USGS has produced a series of earthquake hazard maps for the
United States that show the amount of earthquake generated ground shaking that, over a specified period
of time, is predicted to have a specified chance of being exceeded. Ground shaking caused by
earthquakes is often expressed as a percentage of the force of gravity. As such, the Projects’ areas are
located within an area mapped as having a 2% chance that (at some point in the next 50 years), an
earthquake would occur with at least 8-10% of the force of gravity; damage due to an earthquake begins
at a level of ground shaking of approximately 10% of the force of gravity (USGS 2014). According to the
Commonwealth of Massachusetts’ 2013 State Hazard Mitigation Plan, the Projects’ areas are located
within a region where the 100-year earthquake event (i.e., an earthquake with a 1% chance that the
mapped ground motion levels will be exceeded in any given year) would have a modified Mercalli
Intensity of IV, which is a light earthquake with no damage (may feel like a passing truck)
(Commonwealth of Massachusetts 2013). A strong earthquake (Modified Mercalli of VI) is only likely to
occur in the Projects’ areas once every 2,500 years (0.04% chance of occurring in a given year); a
Mercalli intensity of VI is defined as one that would be felt by everyone, and may result in heavy
furniture moving, plaster falling off walls, and chimneys being slightly damaged, but is not sufficient to
cause damage to well-built buildings. Therefore, the risk of potential damage to the pipeline from seismic
ground accelerations is expected to be extremely low.
The closest earthquake recorded to the town of Agawam was a 3.7-magnitude earthquake that occurred in
1994 approximately 27 miles from Agawam center. The largest magnitude earthquake recorded in the
region was a 5.3-magnitude earthquake that occurred in 1983 approximately 156 miles from the center of
Agawam (city-data.com 2018).
Active Faults
A fault is a facture in the earth’s crust along which two blocks of the crust have slipped with respect to
each other. The Projects’ areas are located approximately 10 miles from nearest mapped fault line
(Commonwealth of Massachusetts 2013). However, unlike in the western portions of the United States,
42
where earthquakes align along known geologic faults, New England earthquake epicenters do not follow
the major mapped faults of the region, nor are they confined to particular geologic structures or terrains.
Landslides
Landslides occur when rock, sediments, soils, and debris move down steep slopes. Such gravity-inducted
flow is usually precipitated by heavy rains, erosion by rivers, earthquakes, or human activities (e.g.,
manmade structures or piles of rock or ore). Areas of unstable soils that may be susceptible to landslides
may be characterized by soils that shrink or swell with changes in moisture content and are located in
areas with steep relief. The Projects’ facilities will be located in a lowlying area in the Connecticut River
Valley. Mapping available from the Massachusetts Geological Survey indicates that the Projects’ areas
are located in a region of “Stable” soil stability, indicating that it has a very low relative slide ranking and
significant destabilizing factors would be required for instability (Mabee and Duncan 2013).
Shallow Bedrock / Blasting

Based on surficial geology mapping of the Projects’ areas available from MassGIS (2015), no areas of
abundant rock outcrops or shallow bedrock are crossed by the Projects. Further, the USDA-NRCS Web
Soil Survey did not identify any soil map units with a shallow depth to bedrock along the proposed
pipeline loop or in the area of the CS 261 upgrades (USDA-NRCS 2018a). Thus, no blasting is
anticipated to be required for construction of the Projects. However, a complete list of blasting locations
can only be accurately determined in the field during the construction process. Should areas be identified
during construction that can only be crossed with blasting, the mitigation measures identified in Section
4.1.1.3 below will be implemented.
4.1.1.1.3 MINERAL RESOURCES

Based on a review of the USGS topographic map (Figure 2-1) and MassGIS land use datalayers
(MassGIS 2005), one area of mining is located within 0.25-mile of the pipeline loop. Based on aerial
photography, the area appears to be an active sand and gravel operation, and is located approximately 400
feet west of the pipeline loop. The proposed Projects will not impact this area or its ability to continue to
utilize the mineral resources available on its site.
4.1.1.2 Assessment of Project Impacts

There are no impacts to geologic resources anticipated as a result of construction or operation of the
Projects. The potential for damage to the Project facilities due to geologic hazards is expected to be
negligible or nonexistent. Routine inspection of the pipeline and compression facilities will be conducted
to identify any potential problems that may develop. The potential for slope failure due to earthflow
along the proposed ROW would be minimized through specialized construction techniques and the use of
erosion control procedures outlined in the FERC Plan and FERC Procedures, which are incorporated into
Tennessee’s ECMP.
The proposed Projects are not expected to be affected by seismic activity due to the low probability and
low incidence/susceptibility of significant magnitude earthquakes in the Projects’ areas. Tennessee
anticipates the proposed pipeline looping and compressor station upgrades will not be affected by fault
movements. Tennessee will comply with all applicable federal DOT PHMSA regulations regarding pipe
wall thickness and strength, 49 CMR 192.
43
Blasting is not expected to be required during construction of the Projects’ facilities. In the unlikely event
that it is required, it would be conducted in compliance with all applicable federal, state, and local laws,
codes, and requirements.
4.1.1.3 Mitigation Measures

The potential for damage to the proposed facilities due to subsidence or other possible geologic hazards
would be minimized through routine inspection of the pipeline and compressor station. The potential for
slope failure due to earthflow along the proposed ROW would be minimized through specialized
construction techniques and the use of erosion control procedures outlined in the Project’s ECMP, which
incorporates the FERC Plan and FERC Procedures.
Should shallow bedrock be encountered during construction that cannot be removed by mechanical means
and blasting becomes necessary, Tennessee will obtain applicable state and municipal approvals. In
accordance with the Code of Massachusetts Regulations at 527 CMR 13, the entity conducting blasting
must hold a valid and current Massachusetts Blasters License issued by the State Fire Marshall’s Office.
Tennessee’s blasting specifications will meet or exceed all applicable federal, state, and local
requirements governing the use of explosions. In addition to detailed specification requirements, safety
and impact minimization precautions will include:
• Installation of blasting mats in congested areas, in shallow waterbodies, or near structures that
could be damaged by fly-rock;
• Posting warning signals, flags, and barricades;
• Following procedures for safe storage, handling, loading, firing, and disposal of explosive
materials;
• Manning adjacent pipelines at valves for emergency response; and
• Controlling excessive vibration by limiting the size of charges and using charge delays that
stagger each charge in a series of explosions.
4.1.2 Soils
4.1.2.1.1 LOOPING PROJECT
This section identifies and lists by mileposts the soils affected by the proposed Looping Project based on
USDA NRCS Soil Survey Information for Hampden County, Massachusetts (USDA-NRCS 2018a).
The pipeline loop crosses 16 different soil map units, which are identified by milepost in Table 4-2 and
Figure 4-1 in Appendix A. These soil types are described in alphabetical order below and characteristics
of soil series associated with the Project are summarized in Table 4-2. A brief description of each soil
association and series crossed by the Project is provided and based on the Official Soil Series
Descriptions prepared by the USDA-NRCS (2018b).
44
Agawam fine sandy loam, 0 to 3 percent slopes (275A)
The Agawam component makes up 85 percent of this map unit. Slopes are 0 to 3 percent. The Agawam
series consists of very deep, well drained soils formed in sandy, water deposited materials. They occur on
outwash terraces, and the parent material consists of coarse-loamy eolian deposits over sandy and
gravelly glaciofluvial deposits derived from gneiss, granite, schists, and/or phylite. Depth to a root
restrictive layer is 15 to 35 inches to strongly contrasting textural stratification. Water movement in the
most restrictive layer is moderately low to high. Available water storage is low (about 3.4 inches). Depth
to water table is more than 80 inches. The soil is not flooded or ponded. Nonirrigated land capability
classification is 2s. This soil is prime farmland soil and does not meet hydric criteria.
Amostown fine sandy loam, 0 to 6 percent slopes (258B)
The Amostown component and similar soils make up 80 percent of this map unit. Slopes are 0 to 6
percent. The Amostown series consists of very deep, moderately well drained soils formed in loamy
glacial outwash overlying lacustrine sediments. They are nearly level to gently sloping soils on terraces,
outwash plains, and deltas. The parent material consists of friable sandy glaciofluvial deposits over hard
silty glaciolacustrine deposits. Depth to a root restrictive layer is greater than 80 inches. Water
movement in the most restrictive layer is moderately low to moderately high. Available water storage to
a depth of 60 inches is high (about 9.4 inches). Depth to water table is 12 to 30 inches. Soils are not
flooded or ponded. Nonirrigated land capability classification is 2w. This soil is a prime farmland soil
and does not meet hydric criteria.
Buxton Variant silt loam, 0 to 8 percent slopes (729B)
The Buxton variant component makes up 85 percent of this map unit. Slopes are 0 to 8 percent. The
Buxton series consists of very deep, moderately well drained soils that formed in glaciolacustrine deposits
on coastal lowlands and river valleys. The parent material consists of soft coarse-silty glaciolacustrine
deposits derived from mica schist over hard clayey glaciolacustrine deposits derived from mica schist.
Depth to a root restrictive layer is 20 to 30 inches to strongly contrasting textural stratification. Water
movement in the most restrictive layer is very low to moderately high. Available water storage to a depth
of 60 inches is low (about 4.7 inches). Depth to water table is 18 to 36 inches. Soils are not flooded or
ponded. Nonirrigated land capability classification is 2e. This soil is a prime farmland soil and does not
meet hydric criteria.
Enosburg loamy sand, 0 to 3 percent slopes (731A)
The Enosburg component makes up 80 percent of this map unit. Slopes are 0 to 3 percent. The Enosburg
series consists of very deep, poorly drained soils that formed in sandy glaciofluvial or Aeolian deposits
underlain by loamy estuarine or glaciolacustrine deposits. They are on glacial lake plains and glacial
outwash areas. The parent material consists of friable sandy glaciofluvial deposits over soft loamy
glaciolacustrine deposits. Depth to a root restrictive layer is 16 to 34 inches to strongly contrasting
textural stratification. Water movement in the most restrictive layer is moderately low to moderately
high. Available water storage to a depth of 60 inches is very low (about 2.4 inches). Depth to water table
is 0 to 18 inches. Soils are not flooded or ponded. Nonirrigated land capability classification is 3w. This
soil meets hydric criteria, and is not a farmland soil.
Meckesville loam, 3 to 8 percent slopes (327B)
The Meckesville component makes up 80 percent of this map unit. Slopes are 3 to 8 percent. The
Meckesville series consists of very deep well drained soils formed in colluvium, glacial till, or
congeliturbate from red acid sandstone, siltstone, and shale. They are on the concave sideslopes of
45
upland ridges. The parent material consists of friable fine-loamy eolian deposits over dense silty
lodgment till derived from sandstone and shale. Depth to a root restrictive layer is 18 to 30 inches to
densic material. Water movement in the most restrictive layer is moderately high. Available water
storage to a depth of 60 inches is very low (about 2.8 inches). Depth to water table is 30 to 41 inches.
Soils are not flooded or ponded. Nonirrigated land capability classification is 2e. This soil is a prime
farmland soil and does not meet hydric criteria.
Meckesville loam, 8 to 15 percent slopes (327C)
congeliturbate from red acid sandstone, siltstone, and shale. They are on the concave sideslopes of
upland ridges. The parent material consists of friable fine-loamy eolian deposits over dense silty
lodgment till derived from sandstone and shale. Depth to a root restrictive layer is 18 to 30 inches to
densic material. Water movement in the most restrictive layer is moderately high. Available water
storage to a depth of 60 inches is very low (about 2.8 inches). Depth to water table is 30 to 41 inches.
Soils are not flooded or ponded. Nonirrigated land capability classification is 3e. This soil is classified as
farmland of statewide importance and does not meet hydric criteria.
Meckesville loam, 3 to 8 percent slopes, very stony (328B)
congeliturbate from red acid sandstone, siltstone, and shale. They are on the summits of upland ridges.
The parent material consists of friable fine-loamy eolian deposits over dense silty lodgment till derived
from sandstone and shale. Depth to a root restrictive layer is 18 to 30 inches to densic material. Water
movement in the most restrictive layer is moderately high. Available water storage to a depth of 60
inches is very low (about 2.4 inches). Depth to water table is 30 to 41 inches. Soils are not flooded or
ponded. Nonirrigated land capability classification is 6s. This soil is classified as farmland of statewide
importance and does not meet hydric criteria.
Merrimac fine sandy loam, 0 to 3 percent slopes (254A)
The Merrimac component makes up 85 percent of this map unit. Slopes are 0 to 3 percent. The
Merrimac series consists of very deep, somewhat excessively drained soils formed in outwash. They are
located on outwash terraces and plains and other glaciofluvial landforms. The parent material consists of
loamy glaciofluvial deposits derived from granite, schist, and gneiss over sandy and gravelly glaciofluvial
deposits derived from granite, schist, and gneiss. Depth to a root restrictive layer is more than 80 inches.
Water movement in the most limiting layer is moderately high to very high. Available water storage to a
depth of 60 inches is low (about 4.6 inches). Depth to water table is more than 80 inches. Soils are not
flooded or ponded. Nonirrigated land capability class is 2s. This soil is classified as prime farmland and
does not meet hydric criteria.
Merrimac fine sandy loam, 3 to 8 percent slopes (254B)
46
flooded or ponded. Nonirrigated land capability class is 2s. This soil is classified as prime farmland and
does not meet hydric criteria.
Merrimac fine sandy loam, 8 to 15 percent slopes (254C)
flooded or ponded. Nonirrigated land capability class is 2s. This soil is classified as farmland of
statewide importance and does not meet hydric criteria.
Paxton fine sandy loam, 3 to 8 percent (305B)
The Paxton component makes up 80 percent of this map unit. Slopes are 3 to 8 percent. The Paxton
series consists of well drained loamy soils formed in lodgment till. The soils are very deep to bedrock
and moderately deep to densic contact. They are located on hills, drumlins, till plains, and ground
moraines. The parent material consists of coarse-loamy lodgment till derived from gneiss, granite, and/or
schist. Depth to a root restrictive layer is 18 to 39 inches to densic material. Water movement in the most
limiting layer is very low to moderately low. Available water storage to a depth of 60 inches is low
(about 3.1 inches). Depth to water table is 18 to 37 inches. Soils are not flooded or ponded. Nonirrigated
land capability class is 2s. This soil is classified as prime farmland and does not meet hydric criteria.
Pollux fine sandy loam, 3 to 8 percent slopes (250B)
The Pollux component makes up 85 percent of this map unit. Slopes are 3 to 8 percent. The Pollux series
consists of very deep, well drained soils formed in loamy glacial outwash overlying glaciolacustrine
sediments. They are located on glaciofluvial plains or deltas. The parent material is friable coarse-loamy
glaciofluvial deposits over hard silty glaciolacustrine deposits derived from granite and gneiss. Depth to a
root restrictive layer is more than 80 inches. Water movement in the most limiting layer is moderately
low to moderately high. Available water storage to a depth of 60 inches is high (about 9.7 inches). Depth
to water table is more than 80 inches. Soils are not flooded or ponded. Nonirrigated land capability class
is 2e. This soil is classified as prime farmland and does not meet hydric criteria.
Scantic Variant silt loam, 0 to 3 percent slopes (736A)
The Scantic variant component makes up 80 percent of this map unit. Slopes are 0 to 3 percent. The
Scantic series consists of very deep, poorly drained soils formed in glaciolacustrine deposits on coastal
lowlands and river valleys. The parent material consists of soft silty and clayey glaciolacustrine deposits.
Depth to a root restrictive layer is 20 to 40 inches to strongly contrasting textural stratification. Water
movement in the most limiting layer is very low to moderately high. Available water storage to a depth
of 60 inches is low (about 4.7 inches). Depth to water table is 0 to 18 inches. Soils are not flooded or
ponded. Nonirrigated land capability class is 4w. This soil meets hydric criteria and is not a farmland
soil.
Wareham loamy sand, 0 to 3 percent slopes (32A)
The Wareham component makes up 80 percent of this map unit. Slopes are 0 to 3 percent. The Wareham
series consists of very deep, poorly drained sandy soils formed in outwash on plains, deltas, and terraces.
47
The parent material is loose sandy glaciofluvial deposits. Depth to a root restrictive layer is more than 80
inches. Water movement in the most limiting layer is high to very high. Available water storage to a
depth of 60 inches is low (about 4.7 inches). Depth to water table is 0 to 18 inches. Soils are not flooded
or ponded. Nonirrigated land capability class is 4w. This soil meets hydric criteria and is not a farmland
soil.
Windsor loamy sand, 3 to 8 percent slopes (255B)
The Windsor component makes up 85 percent of this map unit. Slopes are 3 to 8 percent. The Windsor
series consists of very deep, excessively drained soils formed in sandy outwash or eolian deposits. They
are located on glaciofluvial landforms. The parent material consists of loose sandy glaciofluvial deposits
derived from granite and/or loose sandy glaciofluvial deposits derived from schist and/or loose sandy
glaciofluvial deposits derived from gneiss. Depth to a root restrictive layer is more than 80 inches. Water
movement in the most limiting layer is moderately high to very high. Available water storage to a depth
of 60 inches is low (about 4.5 inches). Depth to water table is more than 80 inches. Soils are not flooded
or ponded. Nonirrigated land capability class is 2s. This soil is classified as farmland of statewide
importance and does not meet hydric criteria.
4.1.2.1.2 HP REPLACEMENT PROJECT

This section identifies and lists by mileposts the soils affected by the proposed HP Replacement Project
based on USDA NRCS Soil Survey Information for Hampden County, Massachusetts (USDA-NRCS
2018a).
The construction workspace associated with the HP Replacement Project will cross four different soil
map units, which are identified in Table 4-2 and Figure 4-2 in Appendix A. These soil types include:
Amostown fine sandy loam, 0 to 6 percent slopes (258B); Meckesville loam, 3 to 8 percent slopes
(327B); Meckesville loam, 8 to 15 percent slopes (327C); and Pollux fine sandy loam, 3 to 8 percent
slopes (250B). Descriptions of these soil series are provided in Section 4.1.2.1.1 above and are
summarized in Table 4-2.
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Table 4-2. Soils and Soil Characteristics Crossed by the 261 Upgrade Projects
Depth to
Distance Potential Depth to Seasonal
Map Erosion Rutting Capability Drainage Farmland
Map Unit Name Stationing Crossed Hydric Seedling Bedrock Mean High
Unit Potential a Hazard Class b Characteristics Class
(feet) Mortality (inches) Water Table
(inches)
Looping Project
250B Pollux fine sandy 0+00 to 125 Moderate Severe 2e Well drained No Low >60 >80 Prime
loam, 3-8% slopes 1+30
736A Scantic Variant silt 1+30 to 36 Slight Severe 4w Poorly drained Yes High >60 0-18 No
327C Meckesville loam, 8- 1+50 to 446 Moderate Severe 3e Well drained No Low >60 30-41 Statewide
15% slopes 6+10 importance
729B Buxton Variant silt 7+80 to 919 Moderate Severe 2e Moderately well No Low >60 18-36 Prime
loam, 0-8% slopes 16+80 drained
305B Paxton fine sandy 18+80 to 324 Moderate Moderate 2s Well drained No Low >60 18-37 Prime
731A Enosburg loamy 33+25 to 881 Slight Moderate 3w Poorly drained Yes High >60 0-18 No
sand, 0-3% slopes 42+25
258B Amostown fine sandy 42+25 to 138 Moderate Severe 2w Moderately well No Low >60 12-30 Prime
49
Depth to
(inches)
255B Windsor loamy sand, 43+25 to 634 Slight Moderate 2s Excessively No Moderate >60 >80 Statewide
3-8% slopes 49+70 drained importance
327B Meckesville loam, 3- 69+25 to 820 Moderate Severe 2e Well drained No Low >60 30-41 Prime
8% slopes 77+50
328B Meckesville loam, 3- 77+50 to 452 Moderate Severe 6s Well drained No Low >60 30-41 Statewide
8% slopes, very stony 82+10 importance
327B Meckesville loam, 3- 82+10 to 531 Moderate Severe 2e Well drained No Low >60 30-41 Prime
8% slopes 87+40
254C Merrimac fine sandy 87+40 to 156 Severe Moderate 2s Somewhat No Low >60 >80 Statewide
loam, 8-15% slopes 89+00 excessively importance
drained
258B Amostown fine sandy 89+00 to 145 Moderate Severe 2w Moderately well No Low >60 12-30 Prime
731A Enosburg loamy 90+50 to 278 Slight Moderate 3w Poorly drained Yes High >60 0-18 No
254A Merrimac fine sandy 93+25 to 483 Slight Moderate 2s Somewhat No Low >60 >80 Prime
loam, 0-3% slopes 98+00 excessively
drained
32A Wareham loamy 98+00 to 286 Slight Moderate 4w Poorly drained Yes High >60 0-18 No
254A Merrimac fine sandy 101+00 to 296 Slight Moderate 2s Somewhat No Low >60 >80 Prime
drained
254B Merrimac fine sandy 103+90 to 261 Moderate Moderate 2s Somewhat No Low >60 >80 Prime
drained
50
Depth to
(inches)
258B Amostown fine sandy N/A N/A Moderate Severe 2w Moderately well No Low >60 12-30 Prime
loam, 0-6% slopes drained
327B Meckesville loam, 3- N/A N/A Moderate Severe 2e Well drained No Low >60 30-41 Prime
8% slopes
327C Meckesville loam, 8- N/A N/A Moderate Severe 3e Well drained No Low >60 30-41 Statewide
15% slopes importance
250B Pollux fine sandy N/A N/A Moderate Severe 2e Well drained No Low >60 >80 Prime
loam, 3-8% slopes
a: The erosion potential for each of the soils was determined by reviewing the erosion hazard of soil loss after disturbance activities that expose the soil surface, as provided by the NRCS Web Soil Survey. The
NRCS has evaluated soils based on slope and soil erosion factor K.
• A rating of “slight” indicates that erosion is unlikely during ordinary climatic conditions.
• A rating of “moderate” indicates that some erosion is likely and that erosion control measures may be needed.
• A rating of “severe” indicates that erosion is very likely and that erosion control measures, including revegetation of bare areas, are advised.
• A rating of “very severe” indicates that significant erosion is expected, loss of soil productivity and off-site damage are likely, and erosion control measures are costly and generally impractical.
b: Capability class refers to the suitability of soils for most kinds of field crops. The soils are grouped according to their limitations for field crops, the risk of damage if they are used for crops, and the way they
respond to management. Soil Capability subclasses are designated by adding e, w, or s to the Capability Class designation. The letter “e” shows that the main hazard is the risk of erosion unless close-growing
plant cover is maintained; the letter “s” denotes that the soil is limited mainly because it is shallow, droughty or stony; the letter “w” indicates that water in or on the soil interferes with plant growth of cultivation.
• Capability Class 1: Soils have slight limitations that restrict their use.
• Capability Class 2: Soils have moderate limitations that reduce the choice of plants or that require special conservation practices, or both.
• Capability Class 3: Soils have severe limitations that reduce the choice of plants or that require very careful management, or both.
• Capability Class 4: Soils have very severe limitations that reduce the choice of plants or that require very careful management, or both.
• Capability Class 5: Soils are not likely to erode but have other limitations, impractical to remove, that limit their use.
• Capability Class 6: Soils have severe limitations that make them generally unsuitable for cultivation.
• Capability Class 7: Soils have very severe limitations that make them unsuitable for cultivation.
• Capability Class 8: Soils and miscellaneous areas have limitations that nearly preclude their use for commercial crop production.
51
4.1.2.2 Assessment of Impacts

Impacts will result from soil disturbance due to clearing, grading, trench excavation, and by heavy
machinery traveling along the ROW during pipeline construction, potential reduction of soil quality from
the intermixing of topsoil and subsoil, and the potential for soil settling or slumping. The soil resource
impacts will occur only during the construction period and/or post-construction monitoring period.
Depending on soil conditions, these impacts can include loss of excavated soil from water and wind
erosion, soil compaction from construction equipment, and mixing of wetland topsoil and subsoil.
Section 4.1.3.2 below addresses measures proposed to mitigate for these potential impacts to soils.
In general, as shown in Table 4-2, the potential for soil compaction in the Project area is moderate to
severe, based on the rutting hazards defined by the USDA NRCS (USDA-NRCS 2018a), and the loss of
excavated soil from water and wind erosion is expected to be slight to moderate.
Introduction of rock into topsoil in agricultural fields may result in reduction of soil quality, potential
difficulty in tilling, and damage to farm equipment. An examination of the soil survey information
showed that depth to bedrock is greater than 5 feet throughout the Project area; therefore the probability
of the introduction of rock into the topsoil is low. Approximately 400 linear feet of the proposed pipeline
loop will cross map unit 328B (Meckesville loam, 3-8% slopes, very stony). In this location, rock may be
encountered that could be introduced into topsoil; however, this area does not overlap agricultural fields.
The majority of the soils in the Project area have a high revegetation potential. The exception are the
three hydric soils crossed by the Project. These soils are expected to have high seedling mortality rates,
which typically requires a greater degree of management for successful revegetation.
Soil erosion is defined by the USDA NRCS as the breakdown, detachment, transport, and redistribution
of soil particles by forces of water, wind, or gravity (USDA-NRCS 2018c). Erosion is a natural process,
which over time may remove all or part of soils formed in the natural landscape. The process may be
accelerated by human activity, such as tillage, over-grazing, or timber harvesting. Soil susceptibility to
erosion is determined by many physical and environmental characteristics, including texture and
structure, topography and slope, surface roughness, vegetative cover, and climate. The USDA NRCS
rates potential erosion hazards for soils after disturbance activities that expose the soil surface. These
ratings are based on soil erosion factor K and slope. A rating of “severe” erosion potential indicates that
erosion is very likely and that erosion control measures, including revegetation of bare areas, are advised.
Erosion potential for the soils crossed by the pipeline loop are provided in Table 4-2. Approximately 150
feet of the proposed pipeline loop crosses a soil with severe erosion potential. Tennessee has developed
protective measures in those locations that have been identified as having severe erosion potential, as
described in Section 4.1.2.3.

Construction impacts will result from soil disturbance due to clearing, grading, trenching, and by
machinery operation. These impacts are entirely within disturbed portions of an existing compressor
station yard, will be temporary in nature, and will be mitigated in accordance with the measures outlined
in Section 4.1.2.3 below.
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4.1.2.2.3 CUMULATIVE IMPACTS

The ROI for soils impacts, as identified in Table 2-9, is the proposed construction workspaces of the
Projects. The only Activity identified to date within the same construction workspace as the proposed
Projects is Tennessee’s Connecticut Expansion Project, which includes minor modifications to CS 261
and the start of a pipeline loop within the compressor station yard. The Connecticut Expansion Project
has completed construction, and soils disturbed by construction have been restored. Therefore, no
cumulative impacts associated with the Projects together are anticipated.

To minimize potential soil impacts, Tennessee will construct the Projects in accordance with the FERC
Plan and FERC Procedures, which are incorporated into Tennessee’s ECMP. These documents identify
erosion control measures designed to reduce potential short-term and long-term impacts on soil and water
resources including installing slope breakers, temporary sediment barriers, and permanent trench
breakers; topsoil segregation in wetlands, agricultural lands, and residential lands; and the stabilization of
exposed soils through revegetation and mulching.
Additionally, Tennessee prescribes the use of erosion control devices and construction practices that will
minimize erosion during and after construction. During construction, erosion control structures,
temporary seeding and revegetation, and erosion control fabrics will be used. After construction is
complete, Tennessee will minimize further erosion by re-grading and restoring the disturbed areas.
Following restoration and clean up, Tennessee will monitor the disturbed areas to maintain erosion
control structures and repair any developing erosion.
In addition, the following are brief descriptions of some of the methods Tennessee will utilize during
construction to minimize impact upon soils:
• Minimize the quantity and duration of soil exposure;
• Protect critical areas by reducing the velocity of and redirecting runoff;
• Install and maintain erosion and sediment control measures;
• Reestablish vegetation as soon as possible following final grading; and
• Inspect the ROW and maintain erosion and sediment controls as necessary until final stabilization
is achieved.
The EI is responsible for ensuring that contractors implement and maintain erosion and sediment control
measures during construction. Erosion and sedimentation measures will be implemented through
construction of water bars diagonally across the ROW on slopes to reduce the velocity of stormwater
runoff. Water diverted by the water bars will be channeled to well-vegetated areas. Erosion control
barriers consisting of silt fences, hay/straw bales, and/or sandbags may be temporarily used in place of
water bars.
As a general practice, erosion control barriers will be installed immediately after soil disturbances in the
following areas:
• At water bar outlets if vegetation is incapable of filtering effectively;
• Between graded ROW and waterbody after clearing (along banks);
53
• Downslope of stockpiled soils near waterbodies and wetlands;
• At the base of slopes adjacent to road crossings, and at downslope boundaries of construction
areas where runoff is not controlled with a water bar; and
• In the ROW at boundaries between wetlands and adjacent disturbed uplands.
The ROW will generally be seeded within six working days of final grading, weather and soil conditions
permitting. Slopes steeper than 3:1 will be seeded immediately after final grading, weather and soil
conditions permitting. If there are adverse weather conditions, the ROW will be mulched in accordance
with local NRCS or other local soil conservation authority recommendations until reseeding can resume.
Stabilization of the soil will be necessary until vegetation is established. Temporary measures include
mulching, matting, or netting. If construction is completed 30 days or more before the seeding season for
perennial vegetation, upland areas adjacent to waterbodies will be mulched with three tons/acre of straw
at a minimum of 100 feet on either side.
In wetlands, the ROW will be seeded with a temporary annual seed mix prescribed in Tennessee’s ECMP
to stabilize the area until indigenous wetland species are re-established. Amendments such as fertilizer
and lime will not be permitted in wetlands unless otherwise stated.
4.2 SURFACE AND GROUNDWATER HYDROLOGY AND

QUALITY
This subsection provides information on groundwater and surface water resources in the vicinity of the
Projects including fisheries, wetlands and waterbodies. On behalf of Tennessee, SWCA Environmental
Consultants (“SWCA”) determined the nature and location of wetlands, surface waters, springs, wells,
groundwater hazards, and point and non-point pollution sources by performing field verification and
delineation surveys in November 2017 and May 2018 At the time of the May 2018 field delineation,
Tennessee had full survey access and completed delineations within all of the Projects’ workspaces.
4.2.1 Groundwater Resources

An aquifer is a geologic formation, group of formations, or part of a formation that contains sufficient
saturated permeable material to yield significant quantities of water to wells and springs. A principal
aquifer is defined as a regionally extensive aquifer or aquifer systems that has the potential to be used as a
source of potable water (USGS 2017). The Projects’ areas are mapped within the Early Mesozoic Basin
Aquifer, a sandstone aquifer that is a principal aquifer of the United States (Olcott 1995). The Early
Mesozoic basins are bounded by faults and are filled with thick sequences of sedimentary rocks of fluvial
and alluvial origin. Siltstones, mudstone, and local beds of dolomite and coals were deposited in lakes
and marshy areas with the basins as they are filled (USGS 2016). In the Projects’ areas, a large lake
known as Lake Hitchcock covered most of the Connecticut Valley lowlands in Massachusetts following
the retreat of the last glacial ice sheet, and left deposits of silt, clay, and fine sand up to 200 feet thick in
the lowlands areas. Sand and gravel beneath fine-grained lake deposits, known as buried outwash,
comprise the main aquifer of the Connecticut Valley lowlands and supplies most municipal wells
(Simcox 1992).
54
The U.S. Environmental Protection Agency (“USEPA”) administers the Sole Source Aquifer Program,
which is implemented across the entire country to protect groundwater aquifers that supply at least 50
percent of the drinking water consumed in the area overlying the aquifer. USEPA guidelines also require
that the area overlying the aquifer have no alternative drinking water sources that could physically,
legally, and economically supply water to all who depend on the aquifer for drinking water (USEPA
2018). Based on a review of available data from MassGIS, no USEPA-designated Sole Source Aquifers
are located within 0.25-mile of the Projects (MassGIS 1996).
Aquifers of high and medium yield are mapped by MassGIS; the nearest such aquifer is located
approximately 1.1 miles east of the proposed Projects’ route (MassGIS 2007). The Projects’ area are not
mapped within an area of high or medium aquifer yield, therefore yields from underlying aquifers in the
Projects’ areas are expected to be low.
4.2.1.1.1 GROUNDWATER HAZARDS

On behalf of Tennessee, SWCA conducted database research to identify, to the extent feasible, properties
within 0.25-mile of the Projects having the potential to impact the proposed workspace with oil and/or
hazardous materials. SWCA obtained a federal and state database search report from Environmental Data
Resources, Inc. (“EDR”) for sites within 0.25-mile of the Projects’ workspaces (EDR 2018). A list of
identified sites within 0.25-mile is presented in Appendix D.
Although several sites were identified by EDR, the majority of them have been sufficiently remediated,
are sufficient distance from the Projects’ workspaces, and/or are downgradient of the Projects, such that
no impact is anticipated. As shown in Appendix D, only two sites were identified that may continue to
pose a low potential for soil and groundwater impacts in the Projects’ areas.
4.2.1.1.2 PUBLIC AND PRIVATE WATER SUPPLY WELLS

Information on public and private water supply wells was requested from local planning and health
boards in February 2018, though no response has been received to date. The Town of Agawam purchases
its drinking water from the Springfield Water and Sewer Commission, which obtains its water from
surface water supplies located in Blandford and Granville, Massachusetts. No MassDEP Zone II
Wellhead Protection Areas or Interim Wellhead Protection Areas were identified within 1 mile of the
Projects.
Tennessee has not identified any private wells within 150 feet of any Projects’ workspaces to date.
Additional surveys, landowner discussions, and consultation with local officials are ongoing and any
additional information regarding water wells will be provided to MEPA, as needed.
At this time, no modifications to the pipeline alignment or compressor station workspaces are required
due to private water wells in the vicinity of the Project. The Project will not require use of public and/or
private water supply wells during construction or operation.

The proposed Project is not anticipated to impact groundwater quality and supply with the
implementation of the mitigation measures discussed in Section 4.2.1.3 below.
Tennessee does not anticipate any potential issues relative to hazardous materials during construction and
operation of the Project facilities. From information gathered to date, there appears to be low risk of
encountering impacted soils or groundwater during pipeline construction.
55

Tennessee proposes to implement construction practices designed to reduce and/or mitigate potential
impacts on groundwater during construction as detailed within the FERC Plan and FERC Procedures,
incorporated in the Project’s ECMP. Tennessee and its contractors will adhere to these practices related
to groundwater protection including specifications for trench breakers and dewatering as well as
restrictions on refueling and storage of hazardous substances. In the unlikely event that construction of
the proposed Projects temporarily impacts directly private or public well quality or yield, Tennessee will
provide alternative water sources or offer compensation to the well owner. Should permanent well
damage be sustained, Tennessee will either compensate the well owner or make arrangements for a new
well to be drilled.
Tennessee will contact affected landowners regarding the presence of private septic systems along the
proposed alignment. Septic systems located adjacent to the construction workspace will be identified on
residential construction plans to alert construction crews to the presence of the system and to avoid
inadvertent damage to the system that could lead to groundwater contamination.
All equipment used in construction of the pipeline will be refueled and lubricated within the limits of the
ROW at a minimum distance of 100 feet from all wetlands, waterbodies, and identified wells. Auxiliary
fuel tanks will be used to reduce the frequency of refueling operations, and refueling will not take place
within 400 feet of identified municipal or community water supplies including groundwater and surface
water, as per state requirements. The impact minimization measures will prevent the discharge of
hydraulic fluids or fuels from leaving the ROW and/or leaching into the groundwater.
Should any hazardous materials be encountered during construction of the Projects, Tennessee will
dispose of and/or mitigate for any hazardous materials uncovered in accordance with applicable federal
and state regulations. Additionally, Tennessee will implement the Project’s ECMP, which incorporates
the FERC Plan and FERC Procedures, during construction of the Projects’ facilities to minimize potential
disturbance of contaminated sediments. Should surface or subsurface contamination be encountered
during construction, it will be addressed and handled in accordance with federal, state, and local
requirements.
4.2.2 Surface Water Resources

The Projects lie within the Connecticut River Watershed. The total drainage area of the Connecticut
River Watershed is approximately 11,000 square miles (mi2), of which 2,728 mi2 are in Massachusetts.
The Connecticut River begins at Fourth Connecticut Lake in Chartierville, Quebec and flows 410 miles
through four U.S. states to Long Island Sound (Connecticut River Conservancy 2018). In Massachusetts,
the Connecticut River flows through both rural / agricultural areas as well as urban areas associated with
the City of Springfield and its suburbs. Nearly 80 percent of the Connecticut River Watershed is forested,
providing high quality timberland. More than 31 percent of the forestland in the watershed (23 percent of
all land in the watershed) is protected from development. Approximately 11 percent of the watershed is
developed for commercial or residential purposes, but this number is increasing due to urban sprawl (The
Trust for Public Land 2006).
Field surveys conducted in November 2017 and May 2018 identified all surface waters located within and
immediately adjacent to the Projects’ workspaces. Desktop review of USGS topographic maps, National
Hydrography Datasets, and MassDEP wetlands datalayers were used to identify surface waters outside the
56
Projects’ workspaces that may have Riverfront Area or Buffer Zones that extend into the Projects’ areas.
These desktop sources, as well as the USGS StreamStats program, were also used to determine flow
status of each surface water and categorize each as either intermittent or perennial. Of the seven streams
identified along the Projects’ alignment, four are perennial. Named streams in the Projects’ areas include
Worthington Brook, Tarkill Brook, and Threemile Brook. No open waterbodies (i.e., lakes or ponds)
were identified within the Projects’ workspaces. A summary of each surface water is provided in Table
4-3.
The Massachusetts Wetlands Protection Act (“WPA”) protects two resource areas associated with surface
waters – Bank and Land under Waterbodies and Waterways (“LUWW”). Bank is defined in the WPA
regulations at 310 CMR 10.54(2) as that portion of the land surface that normally abuts and confines
waterways and waterbodies, and extends from the mean annual low flow level to the mean annual flood
level or first observable break in slope, whichever is lower. For intermittent streams, the entire channel
below the “top of bank” line is the resource area Bank. LUWW is present in perennial streams only and
is defined in 301 CMR 10.56(2) as that area beneath a creek, river, stream, pond, or lake below the mean
annual low water level. The WPA regulates a 100-foot buffer zone from Bank and LUWW.
The WPA also protects the 100-year floodplain of surface waters as Bordering Land Subject to Flooding
(“BLSF”). Tennessee reviewed National Flood Insurance Program Flood Insurance Rate Maps issued by
the Federal Emergency Management Agency (“FEMA”) to identify proposed crossings of areas subject to
flooding and velocity zones. No portion of the Projects’ areas are located within the 100-year floodplain.
In addition to the protection provided by the Massachusetts WPA, the Massachusetts Rivers Protection
Act provides additional protection to land adjacent to perennial streams (riverfront area). The riverfront
area is “…a 200-foot wide corridor on each side of a perennial river or stream, measured from the mean
annual high-water line of the river.” Riverfront area associated with Worthington Brook, Tarkill Brook,
and an unnamed tributary (“UNT”) to Threemile Brook are crossed by the Looping Project. Previously
developed Riverfront area associated with Worthington Brook will be impacted by the HP Replacement
Project.
57
Table 4-3. Intermittent and Perennial Waterbodies Associated with the 261 Upgrade Projects
Waterbody Approx. Crossing Water Quality/Fishery Anticipated

Waterbody Name Source Flow Regime
ID Station Width (feet) a Classification b Crossing Method
Looping Project
MA1 Worthington Brook 7+00 SWCA Field Delineation Perennial 15 Class B / C Flume
MA2 UNT to Worthington Brook 0+00 SWCA Field Delineation Intermittent N/A Class B / C N/A – buffer zone
impacts only
MA3 UNT to Threemile Brook 93+50 SWCA Field Delineation Perennial 60 Class B / C Flume
MA4 Tarkill Brook 67+25 SWCA Field Delineation Perennial 13 Class B / W Flume and existing
culvert at PAR2
MA5 UNT to Fourmile Brook 38+50 SWCA Field Delineation Intermittent 8 Class B / C Flume with drag
section segment
MA6 Worthington Brook 17+75 SWCA Field Delineation Perennial 9 Class B / C Flume with drag
section segment
through abutting
wetlands
MA7 Tarkill Brook 67+00 SWCA Field Delineation Intermittent N/A Class B / W Existing culvert
(Access
Road)
MA1 Worthington Brook N/A SWCA Field Delineation Perennial N/A Class B / C N/A – Riverfront
area impacts only
N/A = Not applicable
UNT = unnamed tributary
a: Crossing width is defined as the Ordinary High Water Mark (OHWM) to OHWM width of the stream at the proposed centerline.
b: State Water Quality Classifications: all waterbodies are assumed to be Class B because they are in the watershed of the Connecticut River, which is classified as Class B pursuant to 314 CMR 4.00; State
Fishery Classifications: C = Coldwater Fisheries Resource; W = Warmwater Fisheries Resource based on correspondence with MA DFW (2018).
58
4.2.2.1.1 CONTAMINATED SEDIMENTS

Tennessee obtained a federal and state database search report to identify waterbodies affected by the
Projects with known or potentially contaminated sediments (EDR 2018). Additional information on the
EDR database search for the Projects is included in Section 4.2.1.1.1. No evidence of abandoned drums,
aboveground fuel pumps, unvegetated areas, or dumpsites that would be considered a result or source of
potential contamination were observed during field surveys.
4.2.2.1.2 PUBLIC WATERSHED AREAS

Review of the MassGIS Surface Water Protection Areas datalayer did not indicate any public watershed
areas occur within 0.25-mile of the Projects or within 3 miles downstream of any waterbody crossing. In
addition, no public or municipal water supply areas were identified within 0.25-mile of the Projects.
4.2.2.1.3 SENSITIVE SURFACE WATERS
Surface Water Quality Standards

In Massachusetts, surface waters are given a designation based on the following criteria:
• Class A: These waters include waters designated as a source of public water supply and their
tributaries. They are designated as excellent habitat for fish, other aquatic life, and wildlife,
including for their reproduction, migration, growth and other critical functions, and for primary
and secondary contact recreation, even if not allowed. These waters shall have excellent aesthetic
value and are protected as Outstanding Resource Waters (“ORWs”).
• Class B: These waters are designated as a habitat for fish, other aquatic life, and wildlife,
including for their reproduction, migration, growth and other critical functions, and for primary
and secondary recreation. Where designated in 314 CMR 4.06, they shall be suitable as a source
of public water supply with appropriate treatment. Class B waters are suitable for irrigation and
other agricultural uses and for compatible industrial cooling process uses. These waters shall
have consistently good aesthetic value.
• Class C: These waters are designated as a habitat for fish, other aquatic life and wildlife,
including for their reproduction, migration, growth and other critical functions, and for secondary
contact recreation. These waters shall be suitable for the irrigation of crops used for consumption
after cooking and for compatible industrial cooling and process uses. These waters shall have
good aesthetic value.
The streams crossed by the Projects’ workspaces are not designated as Class A or Class B waters
according to the Massachusetts Surface Water Quality Standards at 314 CMR 4.00, but are tributaries to
the Connecticut River, which is a Class B water and are therefore also presumed to be Class B waters.
Based on consultation with the MA Division of Fisheries and Wildlife (“MA DFW”), Worthington Brook
and Threemile Brook are classified as Coldwater Fishery Resources (see Appendix C for consultations).
Coldwater fisheries are defined in 314 CMR 4.00 as “Waters in which the mean of the maximum daily
temperature over a seven day period generally does not exceed 68 degrees Fahrenheit (20 degrees
Celsius) and, when other ecological factors are favorable (such as habitat), are capable of supporting a
year-round population of stenothermal aquatic life, such as trout (Salmonidae spp.).” Further, MA DFW
indicated that any stream that has not been sampled by MA DFW should be assumed to be a coldwater
fishery. Designated coldwater and warmwater fisheries are identified in Table 4-3 above.
59
303(d) Impaired Waters

Section 303(d) of the Clean Water Act and the implementing regulations at 40 CFR 130.7 require states to
identify those waterbodies that are not expected to meet state water quality standards after the
implementation of technology-based controls and to prioritize and schedule them for the development of
total maximum daily loads (“TMDLs”). A TMDL establishes the maximum amount of a pollutant that
may be introduced into a waterbody and still ensure attainment and maintenance of water quality
standards. A TMDL must also allocate that acceptable pollutant load among all potential sources. States
provide their 303(d) List of Impaired Waters to the USEPA for approval and categorize waterbodies into
one of the following five categories:
1.) Unimpaired and not threated for all designated uses;

2.) Unimpaired for some uses and not assessed for others;
3.) Insufficient information to make assessments for any uses;
4.) Impaired or threatened for one or more uses, but not requiring the calculation of a TMDL; and
5.) Impaired or threatened for one or more uses and requiring a TMDL.
In accordance with the most recently USEPA-approved Massachusetts Year 2014 Integrated List of
Waters (Massachusetts Division of Watershed Management 2015), none of the streams crossed by the
Projects are on the 303(d) List. However, the Project area is located within the watershed of Segment
MA34-05 of the Connecticut River, which is listed as a Category 5 water for the following impairments:
Escherichia coli, PCB in fish tissue, and total suspended solids.
Outstanding Resource Waters

The designation of ORW is applied to those waters with exceptional socio-economic, recreational,
ecological, and/or aesthetic values. ORWs have more stringent requirements than other waters because
the existing use is so exception or the perceived risk of harm is such that no lowering of water quality is
permissible. ORWs include certified vernal pool (“CVP”); all designated Class A Public Water Supplies;
and may include surface waters found in National Parks, State Forests and Parks, Areas of Critical
Environmental Concern (“ACEC”); and those protected by special legislation (Rojko et al. 1993).
Wetlands that border ORWs are designated as ORWs to the boundary of the wetland resource area.
Vernal Pools
Vernal pools are small, shallow ponds characterized by lack of fish and by periods of dryness. Vernal
pool habitat is extremely important to a variety of wildlife species including some amphibians that breed
exclusively in vernal pools, and other organisms such as fairy shrimp, which spend their entire life cycles
confined to vernal pool habitat. Many additional wildlife species utilize vernal pools for breeding,
feeding, and other important functions. CVPs are protected if they fall under the jurisdiction of the
Massachusetts Wetlands Protection Act regulations (310 CMR 10.00). No CVPs or mapped potential
vernal pools (“PVP”) are located within 0.5-mile of the Projects’ workspaces. In addition, no wetlands
that appear to function as vernal pools were identified during field surveys.
Wild and Scenic Rivers

The federal Wild and Scenic Rivers Act established a national system to identify outstanding values and
protect the free-flowing condition of rivers through a Wild & Scenic River nomination and designation
process that recognizes certain rivers as having “outstandingly remarkable” attributes. Massachusetts has
three national designated rivers: the Taunton River, the Westfield River, and the Sudbury/Assabet/
Concord Rivers. No designated Wild & Scenic Rivers are located within 0.5-mile of the Projects.
60
Chapter 91 Waterways
The Commonwealth of Massachusetts protects and promotes public use of its tidelands and other
waterways through Massachusetts General Law (“M.G.L.”) Chapter 91, the waterways licensing program,
which is administered by MassDEP. Through Chapter 91, the Commonwealth seeks to preserve and
protect the rights of the public, and to guarantee that private uses of tidelands and waterways serve a
proper public purpose. Chapter 91 regulates activities in the following areas: flowed tidelands; filled
tidelands; Great Ponds; and non-tidal navigable rivers and streams on which public funds have been
expended either upstream or downstream within the river basin. The placement of structures in non-tidal
rivers and streams that do not reduce the space available for navigation, such as buried pipelines, do not
require Chapter 91 authorization in accordance with 310 CMR 9.05(3)(g). However, applicants must
notify the MassDEP of their intent to perform such projects before undertaking them. No Chapter 91
waterways are crossed by the Projects.

The proposed pipeline loop will require five stream crossings, and the associated access roads will cross
one stream, as identified in Table 4-3 above. This work will involve temporary impacts to 1,001 linear
feet of Bank and 0.15 acre of LUWW. The Looping Project will also result in 4.2 acres of temporary
impacts and 1.6 acres of permanent impacts to Riverfront Area associated with perennial streams.
The CS 261 modifications will have no impact on Bank or LUWW. However, temporary construction
workspaces are required within 0.35 acre of previously developed Riverfront Area associated with the
existing compressor station facility.
The sections below described the construction methods and temporary and permanent impacts to surface
waters as a result of the proposed Projects.
4.2.2.2.1 WATERBODY CONSTRUCTION PROCEDURES

Tennessee will cross all waterbodies in accordance with the FERC Procedures, incorporated in the
Project’s ECMP, and applicable state and federal regulations and permit conditions. The proposed
construction procedures will ensure that potential impacts at all stream crossings are minimized. To limit
the time required for construction of a stream crossing, the ROW will be prepared on either side of the
stream prior to the actual crossing. Stream crossings will be perpendicular to the flow to the extent
practicable. Temporary erosion control measures will be installed as necessary to prevent downstream
impacts. If necessary, the pipe used for stream crossings will be weighted to prevent flotation.
After the completion of construction, streambeds will be restored to their pre-construction elevations and
grades. Spoil, debris, piping, construction materials, and any other obstructions resulting from or used
during construction of the pipeline will be removed to prevent interference with normal stream flow. Any
excavated material not used as backfill will be removed and disposed of in accordance with local, state,
and federal conditions. Following grading, all stream banks will be restored to pre-construction
conditions and in accordance with permit requirements.
Tennessee anticipates that all of the streams crossed by the pipeline loop will be crossed by either
conventional trenching (for minor streams with no discernible flow at the time of construction) or flume
crossing methods (for any stream crossing with discernible flow at the time of construction). However,
dam and pump is an alternative method that may be used, depending on site-specific conditions at the
time of construction. Additional descriptions of the construction procedures specific to these crossing
methods are described below.
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Conventional Trenching
Minor waterbodies (defined by FERC as those equal to or less than 10 feet wide) with no discernable flow
at the time of construction may be crossed using the conventional trenching method (i.e., bed and bank
disturbance with no stream flow bypass equipment installed). For conventional trench crossings, the
pipeline will be placed deep enough to meet the minimum cover requirement of 3 feet, provided rock is
not encountered. Consistent with the FERC Procedures, incorporated in the Project’s ECMP, Tennessee
plans to complete construction activities within 24 hours at minor conventional trench stream crossings.
The following additional stipulations apply to conventional trenching crossings:
• use of equipment operating in the waterbody will be limited to that needed to construct the
crossing;
• material excavated from the trench will be stockpiled in the construction ROW at least 10 feet
from the water’s edge or in ATWS (located at least 50 feet from the water’s edge, except where
the adjacent upland consists of cultivated or rotated cropland or other disturbed land);
• material excavated from the trench generally will be used as backfill, unless federal or state
permits specify otherwise;
• any excess material will be removed from the waterbody; and
• the stream bottom will be restored to its original contour.
Flumed Crossing
A flumed (dry) stream crossing redirects the water flow through one or more pipes to allow for the
trenching and pipe installation to occur in dry conditions. The number, length, and diameter of the pipes
are dependent on estimated stream flow for the stream being crossed. This method allows for drier
trenching, pipe installation, and restoration, while maintaining continuous downstream flow and passage
for aquatic organisms. Soil types must have characteristics that allow stable stream bank conditions, and
stream flow must be low enough for this method to be used successfully and safely. The flume pipe(s)
must be long enough to account for the potential for the ditch width to increase during excavation (due to
sloughing) and over-sized somewhat to accommodate the possibility of high flow conditions. An
effective seal must be created around the flume(s) at both the inlet and outlet ends, so water will not
penetrate and potentially compromise the channelized dam. Tennessee will implement the following
measures where the flumed crossing method is used:
• the flume pipe will be installed, after blasting (if necessary) but before any trenching;
• an effective seal will be created around the flume pipe with sand bags or an equivalent seal
mechanism;
• the flume pipe(s) will be aligned parallel with natural water flow to prevent scouring of the bank,
preventing erosion and sedimentation;
• the flume pipe will not be removed during trenching, pipe-laying, backfilling activities, or initial
streambed restoration efforts, except in rare conditions where a severe flow event causes
conditions that make it unsafe for the pipe to remain; and
• flume pipes and dams that are not associated with an equipment bridge will be removed as soon
as final cleanup of the stream bed and bank is complete.
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Dam and Pump

The dam and pump method may be used for stream crossings where pumps and hoses can adequately
transfer stream flow volumes from upstream of the work area to downstream of the work area, and there
are no concerns with preventing the passage of aquatic organisms. Tennessee will implement the
following measures where the dam and pump method is utilized:
• sufficient pump size, horsepower and hose capacity, including on-site backup pumps, will be used
to maintain downstream flows;
• coffer dams will be constructed with “clean” materials to prevent pollutants from entering the
waterbody (e.g., sandbags or clean gravel with plastic liner);
• water intakes will be suspended in the water column above the stream bed and will be screened to
reduce entrainment of aquatic organisms or particles that may clog the pump;
• pumps will be located within secondary containment structures to catch petroleum liquids and
prevent them from entering the waterbody during refueling or if a pump failure occurs;
• large volume and strong velocity discharges will use water dispersion structures placed at the
downstream discharge location to prevent streambed scour; and
• the coffer dam, pumps, and hoses will be monitored and maintained where necessary to ensure
proper operation for the duration of the waterbody crossing.
4.2.2.2.2 POTENTIAL IMPACTS TO FISHERIES AND WATER QUALITY

Construction of the proposed Projects may include temporary impacts to waterbodies crossed by the
pipeline loop alignments or located within the associated workspace. Temporary impacts to surface
waters include disturbance of stream banks, removal of bank vegetation, and in some instances
modification of flow during dry-crossing construction. Construction of the pipeline loop will require five
stream crossings of four streams (Worthington Brook will be crossed twice) during construction, resulting
in temporary impacts to Bank and LUWW. In addition, two streams are crossed by proposed PAR 2.
PAR 2 is located within an existing maintained sewer easement crossed by the streams via existing
culverts; no impacts to these existing stream culverts are anticipated.
Whenever construction occurs within a stream, there is a potential for impacts to fish habitat and water
quality. Downstream habitat alteration and increased suspended solids concentrations and sedimentation
may eliminate or degrade fish spawning and nursery areas, resulting in a temporary reduction in
reproductive potential. These impacts are typically temporary in nature as the sediments are flushed
during subsequent storm events, and aquatic communities re-colonize the affected area. The FERC Plan
and FERC Procedures will be implemented during construction, and include appropriate BMPs to avoid,
minimize, and mitigate for potential impacts during wetland and waterbody crossings. For the pipeline
loop, Tennessee plans to install flume pipes in all waterbodies with perceptible flow at the time of
construction to pass water across the disturbed areas and maintain downstream flow to further minimize
impacts to the stream and fishery resources, as opposed to using this method of crossing only for
designated fisheries. Dam and pump may be used for stream crossings where appropriate if necessitated
based on site-specific conditions at the time of construction. Once installation activities for the loop are
complete, all disturbed areas will be restored to pre-construction conditions and stabilized as necessary to
mitigate erosion and exposed soils and sedimentation to on- and off-site resource areas.
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Post-construction operational impacts to fisheries and water quality will be minimal. Restoration and
maintenance of the vegetation within the ROW will minimize the erosion potential relative to the stream.
Removal of mature streamside trees and vegetation at the pipeline crossing may temporarily reduce
shading of the stream, eliminate escape cover, and potentially result in a locally elevated water
temperature. Elevated water temperature may lead to a reduction in levels of dissolved oxygen and
influence fish survival and fitness. However, following construction of the Looping Project and
restoration/stabilization of the ROW, Tennessee will limit vegetation maintenance of the permanent ROW
to a 10-foot-wide corridor centered over the proposed new pipeline within wetlands and across
waterbodies except for selectively cutting trees that are located within 15 feet of the pipeline that are
greater than 15 feet in height. This will allow for the re-establishment of shrubby and herbaceous species
along the stream banks that will provide needed shading and crucial cover habitat to sufficiently maintain
coldwater fisheries habitat characteristics. Similarly, during ROW vegetation maintenance activities,
Tennessee will comply with the FERC Procedures, incorporated in the Project’s ECMP, and will leave
vegetation in place within 25 feet adjacent to a waterbody, as measured from the waterbody’s high water
mark, to allow for a riparian strip adjacent to waterbodies. Vegetation maintenance within this 25-foot
riparian strip will be limited to a 10-foot-wide corridor centered over the proposed pipeline centerline as
necessary for temporary equipment crossings and emergency access and the removal of trees located
within 15 feet of the pipeline that are greater than 15 feet in height.
No impact on fisheries is anticipated relative to the timing of construction. In accordance with the FERC
Procedures, incorporated in the Project’s ECMP, Tennessee has consulted with the MA DFW relative to
timing restrictions associated with sensitive fisheries (see Appendix C). Tennessee plans to construct the
crossing in compliance with the restrictions provided by the MA DFW, unless state permit conditions
relative to wetland and waterbody permits require more stringent timeframes for crossings.
Tennessee does not anticipate any potential concerns associated with contaminated sediments and surface
waters during construction and operation of the Projects’ facilities. If any contaminated sediments are
encountered during construction, Tennessee will dispose of or mitigate for them in accordance with
federal, state, and local requirements.
4.2.2.2.3 CUMULATIVE WATERBODY IMPACTS

The ROI for cumulative impacts on surface water (non-wetland waterbodies and waterways) and fisheries
is the HUC 12 area in Massachusetts in which the Projects’ facilities are located. As identified in Table
2-9, the HUC 12 of the Projects is the Connecticut River-Mill River to Freshwater Brook (HUC12:
010802050102). No permanent impacts to surface waters and/or fisheries will result from the Projects.
Potential temporary impacts to surface waters and/or fisheries as a result of the Projects take two primary
forms: (1) direct impacts from construction activities through waterbodies; and (2) indirect impacts from
nearby construction activities.
Because these potential impacts would both result in only short-term, localized increases in turbidity
levels and downstream sediment deposition in the waterbodies crossed, only those Activities occurring
during the same timeframe as the proposed Projects and within the same HUC 12 as the Projects would
be likely to have a cumulative impact.
A small number of Activities were identified in Table 2-10 that may impact waterbodies and are located
within the same HUC 12 as the proposed Projects. However, these Activities are not proposed during the
same timeframe as the Projects and therefore would not result in a cumulative impact. Further, like the
proposed Projects, any Activity would require permitting under the WPA for work within a waterbody,
work within 100 feet of a waterbody, and/or work within the 200-foot Riverfront Area of a perennial
stream. The requirements under the WPA would necessitate meeting the performance standards for work
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within these resource areas or buffer zones, which would include the use of appropriate erosion and
sedimentation controls and mitigation for permanent alterations. As a result of these requirements and the
lack of Activities proposed within the same HUC 12 during the same timeframe as the Projects,
cumulative impacts on surface waters resulting from construction erosion and sedimentation are not
anticipated.

Tennessee anticipates mitigating for potential impacts resulting from construction and operation through
adherence with the ECMP (which incorporates the FERC Procedures), as well as applicable permit
conditions. The Projects have been designed to avoid surface waterbodies to the maximum extent
practicable. Where temporary impacts to surface waterbodies cannot be avoided during construction,
Tennessee will restore these areas to pre-construction conditions upon completion of pipeline installation.
In addition to the measures described above for conventional trenching and flumed crossings, the
following measures to protect and minimize potential adverse impacts to streams will be implemented:
• expediting construction and limiting the amount of equipment and activities in waterbodies;
• coordinating construction activities to avoid high flow and spawning periods;
• installing erosion controls to prevent sediment and siltation from entering streams;
• constructing waterbody crossings perpendicular to the axis of the waterbody channel as
engineering and routing conditions allow;
• maintaining ambient downstream flow rates;
• removing construction material and structures from the waterbody after construction;
• restoring stream channels and bottoms to their original configurations and contours;
• permanently stabilizing stream banks and adjacent upland areas after construction;
• inspecting ROWs regularly during and after construction and repairing any erosion controls
and/or performing restoration, as needed, in a timely manner; and
• reducing the amount of clearing, and maintaining existing vegetation in place on streams banks to
the extent practicable.
4.2.3 Wetland Resources

In Massachusetts, wetlands are regulated by the MassDEP under the Massachusetts WPA (MGL c. 131 s.
40). The WPA defines Bordering Vegetated Wetlands (“BVW”) as “freshwater wetlands which border
on creeks, rivers, streams, ponds and lakes and includes wet meadows, marshes, swamps and bogs.
Bordering Vegetated Wetlands are areas where the soils are saturated and/or inundated such that they
support a predominance of wetland indicator plants.” Isolated vegetated wetlands (“IVW”) are not
regulated by the WPA, unless they are located within another resource area (e.g., BLSF or Riverfront
Area) or meet the definition of Isolated Land Subject to Flooding (“ILSF”), which is an isolated
depression or closed basin without an inlet or outlet that confines standing water to a volume of at least ¼
acre-feet at an average depth of 6 inches at least once a year. Wetlands meeting neither the BVW nor
ILSF definition may still be regulated by the USACE under Section 404 of the Clean Water Act.
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Field surveys conducted in November 2017 and May 2018 by SWCA identified wetlands located within
and immediately adjacent to the Projects’ workspaces. Desktop review of USGS topographic maps, NWI
datasets, and MassDEP wetlands datalayers, was used to identify wetlands outside the survey corridor that
may have Buffer Zone that extends onto the Projects’ workspaces. Wetlands adjacent to the Hickory
Street Yard were previously delineated as part of Tennessee’s Connecticut Expansion Project. Table 4-4
below provides a summary of the wetlands identified in the survey corridor during field surveys.
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Table 4-4. Wetlands Associated with the 261 Upgrade Projects
Crossing Wetland Acreage Affected

Wetland Approx. Wetland Wetland
Source Length Anticipated Crossing Method
ID Station Classification a Type b
(feet) Construction c Operation d
LOOPING PROJECT
A 6+50 SWCA Field Delineation PFO/PSS/PEM BVW 87 75-ft construction workspace with 0.15 0.02
drag section
B 1+00 SWCA Field Delineation PFO/PSS/PEM BVW 58 Variable width construction 0.17 0
workspace with drag section
C 0+75 SWCA Field Delineation PEM BVW 0 ATWS Workspace only 0.01 0
E 92+00 SWCA Field Delineation PFO/PEM BVW 457 75-ft construction workspace with 0.79 0.07
drag section
EA 98+00 SWCA Field Delineation PEM BVW 0 State buffer zone only 0 0
F 83+00 SWCA Field Delineation PEM IVW 167 75-ft construction workspace with 0.11 0
conventional wetland assembly
FA 87+25 SWCA Field Delineation PFO/PEM BVW 0 Workspace only 0.01 0
G 65+50 SWCA Field Delineation PFO BVW 0 Workspace only 0.05 0
GA 67+00 SWCA Field Delineation PFO BVW 0 Workspace only 0.02 0
H 64+50 SWCA Field Delineation PSS BVW 22 75-ft construction workspace with 0.05 0.01
J 41+00 SWCA Field Delineation PEM BVW 186 75-ft construction workspace with 0.23 0
K 60+00 SWCA Field Delineation PEM BVW 382 75-ft construction workspace with 0.73 0
L 52+00 SWCA Field Delineation PFO/PEM BVW 488 75-ft construction workspace with 0.95 0.28
M 48+50 SWCA Field Delineation PEM IVW 69 75-ft construction workspace with 0.07 0
N 27+00 SWCA Field Delineation PFO/PEM BVW 1,400 75-100-ft total construction 3.37 0.27
workspace with conventional
wetland assembly
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Crossing Wetland Acreage Affected

Wetland Approx. Wetland Wetland
Source Length Anticipated Crossing Method
ID Station Classification a Type b
(feet) Construction c Operation d
S 15+00 SWCA Field Delineation PFO BVW 362 75-125-ft total construction 0.82 0.23
workspace with conventional
wetland assembly and short drag
section near stream
V 67+00 SWCA Field Delineation PEM BVW 0 State buffer zone only 0 0
(access
road)
W 67+00 SWCA Field Delineation PFO BVW 0 State buffer zone only 0 0
(access
road)
WCT 1B N/A CT Expansion Field Delineation PSS BVW 0 State buffer zone only (contractor 0 0
yard)
WMA 1A N/A CT Expansion Field Delineation PFO BVW 0 State buffer zone only (contractor 0 0
yard)
WMA 1B N/A CT Expansion Field Delineation PFO BVW 0 State buffer zone only (contractor 0 0
yard)
LOOPING PROJECT TOTAL 7.53 0.88
HP REPLACEMENT PROJECT
B 1+00 SWCA Field Delineation PEM BVW 0 State buffer zone only 0 0
C N/A SWCA Field Delineation PEM BVW 0 Temporary workspace 0.02 0
T N/A SWCA Field Delineation PFO BVW 0 State buffer zone only 0 0
HP REPLACEMENT PROJECT TOTAL 0.02 0
a: Wetland classifications according to Cowardin et al 1979; PEM = palustrine emergent wetland; PSS = palustrine scrub-shrub wetland; PFO = palustrine forested wetland; POS =
palustrine open water
b: Per the Massachusetts Wetlands Protection Act (MGL Ch. 131 §40); BVW = bordering vegetated wetland; IVW = isolated vegetated wetland.
c: Construction acreage = permanent ROW and temporary workspaces
d: Permanent acreage = permanently maintained ROW through wetlands
* Wetland not crossed by pipeline; affected acreage refers to temporary workspace area.
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4.2.3.2.1 WETLAND CONSTRUCTION PROCEDURES
Tennessee will utilize one of the following two methods for crossing wetlands during construction:
• Conventional wetland construction
• Wetland drag-section construction
Table 4-4 above indicates the proposed crossing technique for each wetland. A description of each
crossing method is provided below.
Conventional Wetland Construction

Conventional wetland construction will be used for crossing wetlands with saturated soils or soils unable
to support construction equipment. Prior to crossing and movement of construction equipment through
these wetlands, the ROW will be stabilized using timber mats or corduroy roads to allow for a stable, safe
working condition.
Unless soils are saturated, Tennessee will segregate the top 12 inches of wetland soil over the trenchline.
Trench soil will be temporarily piled in a ridge along the pipeline trench. Gaps in the spoil pile will be
left at appropriate intervals to provide for natural circulation or drainage of water. While the trench is
dug, the pipeline will be assembled in a staging area located in an upland. After the pipeline is lowered
into the trench, wide track bulldozers or backhoes supported on swamp mats will be used for backfill,
final cleanup, and grading. This method will minimize the amount of equipment and travel in wetland
areas. If dry conditions exist within the wetland, the pipe fabrication will occur in the wetland and
Tennessee will implement normal cross-country construction practices.
Wetland Drag-Section Construction

The drag-section construction method in wetlands involves the trenching, installation and backfill of a
prefabricated length of pipe containing several segments all in one day. The trench is backfilled and/or
covered with steel plates or timber mats or protected by fencing at the end of each day after the pipe is
lowered in, as necessary to ensure safety.
4.2.3.2.2 TEMPORARY AND PERMANENT WETLAND IMPACTS
Looping Project
Temporary wetland impacts may include soil disturbance, temporary alteration of hydrology, and loss of
vegetation during construction. All wetlands will be substantially restored to their pre-construction
grades, contours, and draining patterns, and reseeded or replanted with native hydrophytic vegetation
species. Woody vegetation will be allowed to regenerate within the construction ROW except for a 10-
foot-wide area centered over the pipeline that will be maintained in an herbaceous/scrub-shrub state to
allow for inspection and maintenance of the pipeline once it is in service. In addition, trees within 15 feet
of the pipeline that are greater than 15 feet in height will be selectively cut and removed from the
permanent ROW.
Construction of the Project pipeline facilities will impact 7.53 acres of wetlands (7.35 acres of BVW and
0.18 acre of IVW). No permanent filling or loss of wetlands is proposed for the Looping Project.
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However, of the 7.53 acres of construction wetland impacts, approximately 0.88 acre of operational
impacts to wetlands will result from the permanent conversion of forested wetlands to a scrub-shrub or
emergent wetland vegetation cover type within the 30-foot corridor where trees may be selectively cut,
and the conversion of scrub-shrub wetlands to emergent wetland within the 10-foot maintenance corridor
centered over the pipeline.
The use of the proposed Hickory Street Yard and TARs will temporarily impact the 100-foot buffer zone
of BVWs. This work will be located within existing disturbed areas (e.g., maintained easements,
driveways, and open fields). Further, no indirect impacts to the associated wetlands are expected through
placement of erosion controls and other measures outlined in the Projects’ ECMP, which incorporate the
FERC Plan and FERC Procedures.
Construction workspace to install a new suction header at the compressor station will temporarily impact
0.02 acre of Wetland C, an emergent wetland associated with the compressor station’s site drainage
system. Following construction, this wetland will be restored to pre-construction grades, contours, and
drainage patters and will be reseeded or replanted with native hydrophytic vegetation species. No
permanent impacts, including permanent conversion or filling or loss of wetlands is proposed for the HP
Replacement Project.
Temporary and permanent work is also required as part of the HP Replacement Project within the state-
regulated 100-foot buffer zone of BVWs. However, this work will be limited to existing disturbed areas
consisting of maintained lawn and parking areas associated with the existing CS 261 yard. Indirect
impacts to the associated wetlands will be avoided by the placement of erosion controls and other BMPs.
4.2.3.2.3 CUMULATIVE WETLAND IMPACTS

The ROI of cumulative impacts on wetlands is the HUC 12 area in which the Projects’ facilities are
located. Activities that impact wetlands (identified in Table 2-10) within the ROI of the Projects could
contribute to cumulative impacts during construction. No permanent impacts to wetlands will result from
the Projects. Potential temporary impacts to wetlands from the Projects’ facilities take two primary
forms: (1) direct impacts from construction activities within wetlands; and (2) indirect impacts from
erosion and sedimentation from nearby construction workspaces.
Because wetlands temporarily impacted by construction will be restored and revegetated, impacts will be
short-term and localized. Only those Activities occurring during the same timeframe as the proposed
Projects and within the same HUC 12 as the Projects would be likely to have a cumulative impact. A
couple Activities were identified in Table 2-10 that may impact wetlands and are located within the same
HUC 12 as the proposed Projects. However, they are not proposed during the same timeframe as the
Projects and therefore would not result in a cumulative impact. Further, like the proposed Looping
Project and HP Replacement Project, any Activity would require permitting under the WPA for work
within a wetland or its buffer zone. The requirements under the WPA would necessitate meeting the
performance standards for work within these areas, which would include the use of appropriate erosion
and sedimentation controls and mitigation for permanent alterations. As a result of these requirements
and the lack of Activities proposed during the same timeframe as the proposed Projects, cumulative
impacts on wetlands resulting from construction erosion and sedimentation are not anticipated.
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All wetlands crossed by the pipeline loop or within the construction workspace will be protected by
adherence to the FERC Procedures, incorporated in the Projects’ ECMP. The FERC limits workspace
within wetlands to 75 feet in width unless topographic conditions or other safety concerns require
additional workspace.
In compliance with federal, state, and local regulatory permitting frameworks relative to wetland
protection, Tennessee will develop a wetland mitigation plan specific to the Projects prior to construction.
The mitigation plan(s) will detail measures to avoid, minimize, and mitigate for temporary and permanent
wetland impacts associated with the Projects. Mitigation for permanent wetland impacts will likely
consist of off-site wetland restoration and conservation. Tennessee will consult with the applicable
federal and state regulatory agencies for guidance during development of the proposed mitigation
measures and plans, and to incorporate specific recommendations of the agencies.
4.3 AIR AND NOISE QUALITY
4.3.1 Air
4.3.1.1.1 REGIONAL AIR QUALITY
Section 107 of the Clean Air Act (“CAA”) directs the USEPA to designate air quality control regions
(“AQCR”) for any interstate area or major intrastate area where communities share common air pollution
problems. An implementation plan is developed for each AQCR describing how ambient air quality
standards will be achieved and/or maintained. For each applicable pollutant and averaging period,
USEPA designates an area’s attainment status based on monitoring data from the region. Areas that meet
the National Ambient Air Quality Standards (“NAAQS”) are deemed “attainment areas.” Areas that do
not meet the NAAQS are termed “nonattainment areas.” Areas for which insufficient data are available
to determine attainment status are termed “unclassifiable areas.” Finally, areas formerly designated as
nonattainment that subsequently reached attainment are deemed “maintenance areas.” The attainment
status designations appear in 40 CFR 81. The attainment status of a region, in conjunction with project
emission rates or emissions increases, determines the regulatory review process for a new project.
The current attainment designations for Massachusetts are found in 40 CFR 81.322 and are listed in Table
4-5 for the areas of the Projects. The proposed Projects are located in the town of Agawam,
Massachusetts located in Hampden County, which is part of the Hartford-New Haven-Springfield
Interstate AQCR. This region is considered in attainment/unclassified status for all criteria pollutants.
However, the areas of the Projects must be treated as moderate ozone (“O3”) non-attainment for nitrogen
oxides (“NOX”) and volatile organic compounds (“VOC”) because Massachusetts is part of the Ozone
Transport Region (“OTR”).
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Table 4-5. Attainment Designations in the Area of the Projects
Pollutant a Attainment Status in Hampden County
Total Suspended Particulate Better than national standard

SO2 (1971) Better than national standard
SO2 (2010) Attainment / Unclassifiable (effective 4/9/2018)
CO Unclassifiable / Attainment
NO2 (1971) Unclassifiable / Attainment
NO2 (2010) Unclassifiable / Attainment
O3 (8-hr; 2008) Unclassifiable / Attainment
PM2.5 (1997, 2006, 2012) Unclassifiable / Attainment
Lead Unclassifiable / Attainment
a
SO2 = sulfur dioxide; CO = carbon monoxide; NO2 = nitrogen dioxide; O3 = ozone; PM2.5 = fine particulate matter with a diameter less than 2.5
microns
4.3.1.1.2 EXISTING COMPRESSOR STATION 261

CS 261 is an existing natural gas transmission facility on Tennessee’s interstate pipeline system serving
natural gas customers in the northeast. It was originally constructed in 1960 and, as reflected in the
permitting history of the station, upgrades have occurred several times since construction in order to
ensure that the station has appropriate equipment to address customers’ needs. Current station operations
are authorized under Operating Permit No. WE-13-020, issued April 16, 2014. The facility is staffed for
a single eight-hour daytime shift; however, the facility operates 24 hours per day. The station is also
continuously remotely monitored and controlled from Tennessee’s gas control facility in Houston, Texas,
ensuring safe and reliable operations for their customers and the general public. The station currently
consists of four natural gas-fired turbine driven compressors and two emergency generators. Natural gas
is used exclusively to fuel the four compressor turbines and one of the emergency generators. The second
emergency generator is diesel-fired. Depending upon natural gas demand, the four turbines may operate
simultaneously, independently, or not at all.
The existing CS 261 is an existing minor Prevention of Significant Deterioration (“PSD”) (40 CFR 52.21)
source and an existing major Nonattainment New Source Review (“NNSR”) (310 CMR 7.00, Appendix
A) source.

4.3.1.2.1 CONSTRUCTION IMPACTS
The Projects would result in short-term (lasting only for the duration of the construction period), highly
localized effects on air quality during construction, primarily from fugitive dust from land disturbance
(construction activities) and combustion emissions associated with the operation of the construction
equipment. No federal or state air permits will be required for these temporary air emissions.
Construction activities will result in the temporary generation of fugitive dust due to disturbance of the
surface and other dust generating actions. Indirect emissions during the construction period will be
associated with delivery vehicles and construction worker commuting. These emissions 1) will be
temporary and of limited duration; 2) will occur only as a result of construction activities; and 3) will not
significantly increase ambient pollutant concentrations.
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Greenhouse Gas Emissions

During the construction period, greenhouse gas (“GHG”) emissions will be emitted from diesel-fired non-
road construction equipment and diesel and gasoline-fired on-road construction and commuter vehicles.
Emissions can also occur when gas is vented as the new pipeline is tied into the existing pipeline. GHG
associated with construction are carbon dioxide (“CO2”), methane (“CH4”), and nitrous oxide (“N2O”)
from construction equipment and worker vehicle internal combustion engines. CH4 and CO2 may be
released from pipeline operations involved with the tie-in. This is a one-time event where emissions
associated with construction will not continue beyond the construction period. Emissions of GHGs are
typically expressed in terms of CO2 equivalents (“CO2e”), where the potential of each gas to increase
heating in the atmosphere is expressed as a multiple of the heating potential of CO2, or its global warming
potential.
During the commissioning process of the pipeline loop, CH4 and CO2 may be released from pipeline
operations involved with commissioning. These GHG emissions will result from purging the air out of
the new pipeline and filling it with natural gas. This is a necessary and important step to make sure that
the oxygen level inside of the pipeline meets safety thresholds. A safety valve will be opened to allow the
air to vent from the pipeline and small amounts of natural gas will vent to the atmosphere to ensure that
all of the air is removed prior to placing the pipeline into service. In addition, shortly after placing the
pipeline segments into service, Tennessee will run a pipeline inspection gauge through the pipeline to
clean impurities and check pipe wall integrity (known as “pigging”). These in-line inspection gauges
(known as “pigs”) are round cylindrical objects that are used to clean and inspect the inside of the pipeline
without having to remove individual sections of pipe. Emissions from in-line inspections are a result of
venting the pig launcher and pig receiver prior to opening hatches. Launchers and receivers are short
sections of pipe that protrude out of the ground to allow loading and unloading of the pigs. The loading
or removal of the inspection / maintenance will cause a small amount of natural gas to escape when the
launcher or receiver is vented prior to opening. These purging and inspection operations during
commissioning are one-time events where emissions will not continue beyond the construction period.
The GHG analysis for the Projects is provided in Appendix E. Table 4-6 provides a summary of the
calculated GHG emissions from the construction phases of the Projects. These emissions account for the
mitigation efforts detailed in Section 4.3.1.3.
Table 4-6. Construction GHG Emissions from 261 Upgrade Projects
Project Phase Frequency / GHG Emissions (tons)

Duration
CO2 CH4 N2O CO2e
LOOPING PROJECT
Construction Once / 2.33

2,227.66 0.07 0.10 2,261
months
Commissioning Once 0.0006 0.65 -- 22
HP REPLACEMENT PROJECT
Construction Once / 5 months 914.92 20.23 0.06 1,619

Commissioning Once 0.0005 0.59 -- 20
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Criteria Pollutants and General Conformity

The quantity of fugitive dust generated during construction depends on the size of the area disturbed and
the intensity of construction activity, as well as on the silt and moisture content of the soil, the wind
speed, and the speed, weight, and volume of vehicular traffic. Worst-case fugitive particulate matter
emissions for PM10 and PM2.5 were calculated based on USEPA AP-42 (a compilation of air pollutant
emission factors) recommended emission factors for heavy construction activities, along with estimates of
the extent and duration of active surface disturbance. The use of the heavy construction emission factor
from USEPA AP-42 is meant to be general and is used to cover a wide range of construction operations.
This emission factor may actually overestimate potential fugitive dust generated by the proposed
construction of the Project and, to be conservative, does not include mitigation measures outlined in the
fugitive dust control plan.
Exhaust emissions of NOX, CO, PM10, PM2.5, SO2, VOCs, and hazardous air pollutants (“HAP”) from
construction equipment and vehicle engines used during construction of the Projects were estimated based
on the anticipated types of non-road and on-road equipment and their levels of use. Emission factors for
diesel and gasoline on-road vehicles were obtained using USEPA’s Motor Vehicle Emission Simulator
(“MOVES”) model (USEPA 2014). Emission factors for diesel and gasoline non-road equipment engines
were obtained using USEPA’s NONROAD model documentation (USEPA 2008). Emission factors
applied to the Projects that use Tier 2 diesel engine standards are conservative (estimate higher emissions)
and do not reflect the potential of utilizing engines that meet more stringent emissions standards. Ultra-
low sulfur diesel fuel will be used for the non-road diesel vehicles and diesel equipment.
The estimated emissions for construction of the Projects’ facilities are summarized in Table 4-7. The
assumptions, data, and emission factors used to estimate emissions from construction activities are
provided in Appendix F.
Table 4-7. Emissions from Construction of the 261 Upgrade Projects
Emissions (tpy)
Phase 1
CO NOX VOC SO2 PM10 PM2.5 HAPs 2
Pipeline Loop 33.57 14.48 1.57 0.03 19.00 3.63 0.10
Compressor Station
7.47 6.25 0.69 0.01 2.75 0.79 0.04
261 Modifications
1 VOC – non-methane/ethane volatile organic compounds

2 HAPs – as aggregated total HAPs
Promulgated under 40 CFR Part 51 Subpart W, and 40 CFR Part 93 Subpart B, the General Conformity
Rule applies to all federal actions except for those related to transportation plans, programs, and projects.
The General Conformity Rule is used to determine if federal actions meet the requirements of the CAA
and the applicable state implementation plan (“SIP”) by ensuring that air emissions related to the action
do not cause or contribute to new violations of a NAAQS or increase the frequency or severity of any
existing violation of a NAAQS. A SIP is a compilation of a state’s air quality control plans and rules
approved by USEPA. The General Conformity Rule defines a federal action as any activity engaged in by
a department, agency, or instrumentality of the federal government or any activity that a department,
agency, or instrumentality of the federal government supports in any way or provides financial assistance
for, licenses, permits or approvals. The General Conformity Rule applies only to federal actions in
locations designated as nonattainment or maintenance areas for any criteria air pollutant NAAQS.
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A General Conformity determination is required for a federal action that is not classified as exempt and if
the total direct and indirect emissions of a NAAQS nonattainment/maintenance pollutant (or its
precursors) due to the action equal or exceed de-minimis emission thresholds established in the General
Conformity Rule. If emissions are less than these thresholds, the federal action is presumed to conform to
the SIP and a General Conformity determination is not required. The applicability thresholds vary,
depending on the severity of the nonattainment area. De-minimis emissions are total direct and indirect
emissions of a criteria pollutant caused by a federal action in a nonattainment or maintenance area at rates
less than the specified applicability thresholds.
As noted in Table 4-5, the area of the Projects is designated as in attainment or unclassifiable for all
criteria pollutants, with the exception that the area is treated as moderate non-attainment for ozone given
the location within the OTR. However, for General Conformity purposes, nonattainment designations
due solely to being part of the OTR are not applicable. Therefore, General Conformity does not apply to
these Projects. Nevertheless, the total construction emissions of NOx and VOC are less than the 50
ton/year General Conformity threshold for a serious non-attainment area.
4.3.1.2.2 OPERATIONAL IMPACTS
Looping Project
During normal operation of the pipeline, the release of very small amounts of natural gas containing CH4
and smaller amounts of VOCs, HAPs, and CO2 may occur from fugitive leaks. The location of fugitive
leaks is primarily limited to valves at either end of the new pipeline loop. The underground pipeline itself
is not expected to be a source of fugitive leaks. Even though the underground pipeline is not expected to
be a source of fugitive leaks during normal operation, fugitive emissions were still estimated using
standard emission factors from the INGAA GHG Emission Guidelines and the length of pipeline to
conservatively account for some level of fugitive leaks. Cathodically protected steel pipe will be used for
the pipeline loop to inhibit rust formation. The emissions quantified are the emissions being emitted each
year. As previously noted, the GHG emissions calculations are in Appendix E.
Other non-routine operations may occur for long-term maintenance procedures or unplanned blowdowns
of pipeline sections. Long-term maintenance consists of pipeline inspections and includes small releases
of gas when venting the pig launcher or receiver prior to opening the hatches. Blowdowns occur when a
section of pipe that is in service must be vented for safety purposes. Blowdowns may be required if there
is a need to perform unplanned maintenance repair on a section of pipeline. Blowdowns are performed to
reduce the pressure within the pipeline and release gas to safely perform any required repairs. There are
no planned blowdowns expected to occur along the pipeline loop. CH4 and CO2 emissions from in-line
inspections and blowdowns are sporadic in nature and are expected to occur infrequently. Ongoing in-
line inspection/maintenance of the new pipeline sections may occur once every 5–7 years or more and
blowdowns are expected to be an even rarer event as they only occur as a result of an unplanned response
to a discrete incident.
Table 4-8 lists the calculated emissions from the operation of the pipeline loop. These emissions account
for the mitigation efforts detailed in Section 4.3.1.3.
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Table 4-8. Operational Emissions from Pipeline Facilities Associated with the Looping Project
Project Phase Frequency Emissions (tons)
VOC 1 HAPs 2 GHG 3
Normal Operations Annual 0.00009 0.000001 0.6
Non-Routine Operations Once per 5-7 years / Sporadic & Infrequent / if needed 0.05 0.0007 301.5
1 VOC – non-methane/ethane volatile organic compounds.
2 HAPs – Hazardous Air Pollutants; as aggregated total HAPs
3 GHG – as CO2e.
There are no anticipated significant long-term effects on air quality associated with the operation of the
existing pipelines or the new pipeline loop. The Looping Project does not require any air plan approvals
from MassDEP.
The new compressor turbine and emergency generator will be fueled with natural gas. Operational air
emissions from these combustion sources will include NOx, VOCs, carbon monoxide CO, SO2, PM10,
PM2.5, HAPs, as well as GHGs. The compressor turbine will be equipped with Solar’s lean premix
technology, known as SoLoNOxTM. Compressor turbines with SoLoNOxTM use this technology to ensure
uniform air/fuel mixture and to limit NOx, CO, VOC, and HAP emissions. The turbine will also be
equipped with an oxidation catalyst to further control CO, VOC, and HAP emissions.
The emergency generator will be operated to provide electrical power in the event of unforeseeable
circumstances such as a power outage or voltage reduction, and for maintenance checks and readiness
testing as recommended by the manufacturer. There is no time limit on the use of this engine for
emergency purposes. The operation of the emergency generator will comply with all federal and state
requirements.
The estimated annual emissions for the operation of the compressor station are summarized in Table 4-9.
Based on the HP Replacement Project emissions, a Non-Major Comprehensive Plan Approval
(“NMCPA”) application was required to be submitted to MassDEP to obtain an air permit and
authorization for construction. The assumptions, data, and emission factors used to estimate emissions
are provided in the NMCPA air permit application submitted to MassDEP (Authorization ID #17-
AQ02/03F-000007-APP). Note that the NMCPA application is in the process of being revised and will
be resubmitted to MassDEP via their on-line filing system (ePlace). The revised NMCPA will reflect
changes to the project as well as to respond to an information request received on the original application
(MassDEP May 15, 2018 letter to Tennessee). Authorization of the emergency generator will be obtained
through the MassDEP’s Environmental Results Program (“ERP”). However, for air permit applicability
purposes, the generator emissions were included as part of the overall HP Replacement Project.
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Table 4-9. Operational Emissions from HP Replacement Project

Emissions (tpy)
Equipment CO SO2 PM10 PM2.5 VOC HAPs GHG 3
NOx 1 2
Solar Taurus 70 14.14 3.99 5.59 2.63 2.63 2.14 0.21 46,683
Emergency Generator 0.50 1.00 0.011 0.008 0.008 0.25 0.059 96
Total 14.64 4.99 5.60 2.64 2.64 2.39 0.26 46,779
Major Source Thresholds (PSD/NNSR) 25 250 250 250 250 25 -- --
1 VOC – non-methane/ethane volatile organic compounds.
2 HAPs – as aggregated total HAPs
3 GHG – as CO2e.
As required to support the air permit application, the air emissions associated with the operation of the
new compressor turbine and emergency generator were evaluated with dispersion modeling relative to the
NAAQS. The dispersion modeling, fully documented in the air permit application materials, was
conducted in accordance with MassDEP and USEPA requirements using USEPA’s AERMOD dispersion
model.
Following standard modeling procedure, the first step in modeling to demonstrate compliance with the
NAAQS was to determine the maximum ambient air quality impacts of the HP Replacement Project
sources for comparison to the USEPA Significant Impact Levels (“SILs”). Pollutants with modeled
concentrations less than the SILs do not require further analysis and demonstrate compliance with the
NAAQS. As shown in Table 4-10, the maximum modeled concentrations are below the SILs for all
pollutants and averaging periods. The NAAQS are included in the table for reference. Because the
modeled concentrations were below the SILs, the HP Replacement Project emissions comply with the
NAAQS without further analysis.
Table 4-10. Dispersion Modeling Results – HP Replacement Project

AERMOD Model Result SIL NAAQS
Pollutant Averaging Period
(µg/m³) (µg/m³) (µg/m³)
1-hour 2.66 7.5 188
NO2
Annual 0.17 1 100
1-hour 187.45 2000 40,000
CO
8-hour 19.51 500 10,000
PM10 24-hour 0.10 5 150
24-hour 0.09 1.2 35
PM2.5
Annual 0.01 0.3 12
1-hour 0.80 7.8 196
3-hour 0.68 25 1,300
SO2
24-hour 0.21 5 365
Annual 0.022 1 80
4.3.1.2.3 CUMULATIVE AIR IMPACTS
Construction
The majority of air emissions generated by construction activities from the Projects would be relatively
small (Table 4-7) and released at or near ground-level. In addition to the limited emissions, and area of
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potential impact, construction activities have relatively small potential to overlap the same timeframe as
other projects in the area given the various construction schedules, thus further limiting any potential
cumulative impacts. Therefore, any potential contribution of the proposed Projects’ construction air
emissions to the cumulative impacts with other projects would be temporary and minimal. Also, as
discussed in Section 4.3.1.1.1, Hampden County, which is part of the Hartford-New Haven-Springfield
Interstate AQCR is either in attainment or unclassified with respect to the NAAQS for all pollutants and
therefore, General Conformity does not apply to the Projects or the other potential projects in the region.
Operations
Operation of the Projects is not expected to substantially contribute to any cumulative impact to air
quality resulting from the other identified projects. The Projects’ operating emissions from non-permitted
sources will be minor and the potential emissions for the proposed permit modifications of the
compressor station are below major source thresholds. As documented in Section 4.3.1.2.2, dispersion
modeling was conducted for the HP Replacement Project to support the air permit application, to evaluate
the potential air quality impacts relative to the NAAQS. As shown in Table 4-10, the modeling results are
all below the USEPA SILs, which are similar to de minimis thresholds. When the modeled project air
impacts are below the SILs, the modeling demonstrates that the project impacts are minimal, and cannot
cause or contribute to an exceedance of a NAAQS.
Finally, the HP Replacement Project, as well as other proposed Activities identified in Table 2-10, are
subject to the requirements of the CAA and are required to be permitted under MassDEP and USEPA
regulations that protect air quality and are designed to maintain the current attainment status of all
regulated pollutants for Hampden County.

4.3.1.3.1 CONSTRUCTION MEASURES
Construction of the Projects will result in temporary increases in emissions of some pollutants.
Tennessee will apply mitigation measures during construction of the Projects to reduce the amount of
GHG emissions and the amount of tree removal.
During construction of the pipeline loop, Tennessee is planning to use a hot-tap methodology for
connecting the pipeline loop to Line 261B-100, which eliminates natural gas venting from the existing
natural gas pipeline. On- and off-road vehicles and engines used during construction of the Projects will
minimize emissions by utilizing vehicles adhering to the more stringent USEPA Tier 3 and 4 emissions
standards when available and practical. All diesel construction vehicles will operate with ultra-low sulfur
diesel fuel. Tennessee will comply with Massachusetts state law related to engine idling time.
Tennessee will also require its contractors to comply with BMPs discussed in the FERC Plan and FERC
Procedures (incorporated in the Projects’ ECMP) related to air quality during construction, including dust
suppression. Fugitive dust emissions will be mitigated, as necessary, by spraying water to dampen the
surfaces of dry work areas.
For the commissioning phase of the Projects, Tennessee plans to pressure test the pipeline loop and
compressor station piping using hydrostatic testing that eliminates the need to use, and then vent, natural
gas to pressure test the pipes. Emissions from purging and in-line inspections of the pipeline and
compressor equipment are minimal enough to make any control attempt impractical.
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Given these mitigation measures, Tennessee believes fugitive dust and engine emissions, and the potential
impacts from these emissions, will be minor during construction of the Projects.
4.3.1.3.2 OPERATIONAL MEASURES
Looping Project
For the normal operation of the pipeline loop, cathodic protected steel pipes will be installed to inhibit
rust, regular inspections will check for potential leaks, and all practical efforts will be made to fix leaks
expeditiously to limit the amount of natural gas vented into the atmosphere. Locations of potential leaks
are expected to be primarily limited to valves at either end of the new pipeline loop.
For non-routine operations, in-line inspection emissions will only occur approximately once every 5–7
years. Since just a very small amount of natural gas is lost during the in-line inspections from the pig
launcher and receiver, it is not economically feasible to recover. Blowdown emissions would only occur
due to unplanned discrete incidents. In the unlikely event of a blowdown, emission controls could not be
implemented due to timing constraints. Emissions calculated assume the worst case scenario where the
entire length of the pipeline loop will be required to be vented.
Operational impacts will be mitigated by using natural gas as the sole fuel in all new combustion
equipment and implementing appropriate controls on the new combustion turbine, which will include
low-NOx combustors to limit NOx emissions and an oxidation catalyst to reduce CO, VOC, and organic
HAP emissions.
The HP Replacement Project will also employ good combustion practices and perform manufacturer and
vendor recommended operational and maintenance activities on the combustion equipment.
4.3.2 Noise
This section provides an overview of applicable noise regulations, an assessment of existing noise levels
at nearby inhabited buildings, a noise impact evaluation at nearby inhabited buildings, and a summary of
noise mitigation measures to be implemented during the construction and operation phases of the
Projects.
The commonly accepted unit of noise measurement is the decibel (“dB”). Because the human ear is not
uniformly sensitive to all noise frequencies, the A-weighted frequency scale (often denoted as “dBA”),
within the noise level measurement, weights frequencies to correspond with the sensitivity of the human
ear.
MassDEP has a noise policy that limits the sound levels from new equipment to no more than 10 dBA
above ambient sound levels at the property line and the nearest inhabited buildings. MassDEP defines
ambient as “the lowest one-hour background A-weighted sound pressure level that is exceeded 90 percent
of the time measured during equipment operating hours” (MassDEP 1990). The level exceeded 90
percent of the time is commonly referred to as the L90. For continuously operating equipment, MassDEP
recommends establishing the background level based on seven consecutive days of continuous monitoring
at the site. Thus, the noise generated by the Project will need to comply with this limit.
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MassDEP will also not approve new equipment if it will generate a “Pure Tone” condition. MassDEP
defines Pure Tone as a sound level spectrum in which any octave band center frequency sound pressure
level exceeds the adjacent sound pressure levels by 3 decibels or more.

Because operational impacts will primarily be from the proposed HP Replacement Project, noise studies
were focused on the existing environment around CS 261, located off Suffield Street in Agawam,
Hampden County, Massachusetts. The area surrounding the existing CS 261 consists of both rural and
residential areas. Inhabited buildings identified for the HP Replacement Project include nearby
residential areas, the Longbrook Estates condominium complex to the north of CS 261, and the nearest
residence along Suffield Street to the west of the station.
CS 261 currently consists of the following five compressor units, which are housed in four buildings:
• A Solar Centaur 50 turbine (Unit 5A) housed in Building A;

• An electric motor driven reciprocating compressor (Unit 4A) also housed in Building A;
• A Solar Saturn turbine (Unit 1B) housed in Building B;
• A Solar Centaur 40 turbine (Unit 1C) housed in Building C; and
• A Solar Centaur H turbine (Unit 1D) housed in Building D.
A baseline sound level survey at CS 261 was conducted by SLR International Corporation (“SLR”)
between October 5, 2017 and October 13, 2017.
Sound level equipment used during the survey included the following instruments:
• Larson Davis Model 831 SLM; Type 1; s/n 1708, 2443; and
• Brüel and Kjӕr Calibrator; s/n 2022566.
Windscreens were used on the measurement microphones, and the sound level meters were field-
calibrated before and after measurement intervals. All instrumentation had current laboratory
certification. Sound levels were measured using the slow meter response and A-weighting, and were
measured in 1/3- and 1/1-octave bands. Sound levels were recorded in 10-second sampling periods
averaged over 1-hour.
Two locations along the station’s property line were continuously monitored during the survey:
• A location on the north property line of the station, approximately 40 feet south of the
Longbrook Estates condominium complex; and
• A location on the west property line of the station, approximately 400 feet from the nearest house
west of the station.
These sampling locations were selected because they are nearest to the inhabited buildings that are most
affected by noise from Building D in each direction. There are no inhabited buildings south or east of the
station, and the inhabited buildings southwest and southeast of the station are farther away and less
affected by noise from Building D than the inhabited buildings to the north and west.
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Environmental noise sources present at the sampling locations included construction noise in the
southwest part of the site, traffic, birds, and insects. A summary of the weather conditions during the
survey is provided below.
• Dates: October 5–13, 2017

• Temperature: 36°F - 81°F
• Relative Humidity: 39% - 100%
• Wind Direction: Variable
• Wind Speed: 0–15 mph
• Sky Conditions: Clear to Overcast
• Ground Conditions: Dry to Damp
Table 4-11 provides a summary of the distances from Building D to the sampling locations and nearest
residences, as well as their existing ambient sound levels.
Table 4-11. Existing A-weighted Ambient Sound Levels at Property Line and Inhabited Buildings
Distance from Building D to Existing Ambient

Location Property Line or Nearest Inhabited
Building (feet) Sound Level (dBA L90)
North Property Line 560 33.5

West Property Line 760 35.1
North Residence 600 33.5
West Residence 1,150 35.1

Noise impacts associated with construction activities will be temporary and will result primarily from
heavy construction equipment and machinery. Noise levels will vary throughout construction depending
on the phase of the work, number and locations of operating equipment, distance of the noise receptor
from the noise source, atmospheric conditions, and any intervening topography or barriers (e.g., walls,
buildings, and vegetation).
The highest sound levels during construction are expected to occur during the early earthmoving and
installation of the compressor/associated equipment phases of the project. Equipment that may be
operating during these phases would include bulldozers, graders, dump trucks, cranes, forklifts,
generators, etc.
Looping Project
Operational impacts for the pipeline loop will primarily consist of ongoing maintenance activities, such as
trucks driving through for inspections, checking for leaks, and conducting vegetation management
activities. These impacts are currently performed on the existing Line 261B and are therefore expected to
be negligible.
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The significant operational sound sources at the station will consist of the following:
• Noise from the turbine exhaust, including the exhaust outlet and noise radiated from the exhaust
ductwork, expansion joins, and silencer shell;
• Noise from the turbine inlet air system, including the inlet opening and noise radiated from the
silencer/ductwork shell and any duct joints;
• Noise from the turbine/compressor casing that penetrates the building and building ventilation
openings;
• Noise from the lube oil cooler; and
• Noise radiating by aboveground station piping.
A three dimensional computer noise model was constructed to analyze the noise contributions expected
from the proposed compressor station configuration. This model was developed using CadnaA, version
2018, build 161.4801, a commercial noise modeling package developed by DataKustik GmbH.
Table 4-12 below provides a summary of the existing ambient sound levels at each measurement location
(“ML”), the predicted sound level contribution of the new equipment, and a predicted increase over the
existing condition. As indicated on the table, the increase in sound levels at the property line and
inhabited buildings will be less than 10 decibels. Thus, the Project will be in compliance with the
MassDEP noise policy.
Table 4-12. A-weighted Sound Level Predictions at Property Line and Inhabited Buildings
Distance from Increase

Existing Estimated New
Building D to Over
Ambient Contribution of Equipment
Location Description Property Line or Existing
Sound Level New Equipment and Ambient
Nearest Inhabited Ambient
Building (feet) (dBA L90) (dBA) (dBA)
(dBA)
ML1 North Property Line 560 33.5 40.7 41.5 8.0

ML2 West Property Line 760 35.1 43.3 43.9 8.8
1 North Residence 600 33.5 40.5 41.3 7.8
2 West Residence 1,150 35.1 41.0 42.0 6.9
Table 4-13 below shows the predicted octave band sound level contribution of the new equipment at the
station at both the property line measurement locations and at the nearest residences. As shown on the
table, there are no octave bands in which the sound levels exceed both adjacent octave band levels by
three or more decibels. Thus, the new equipment is not expected to cause a “Pure Tone” condition as
defined by MassDEP.
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Table 4-13. Predicted Octave Band Sound Level Contribution of New Equipment
Spectral Sound Pressure Level at Octave Band Center Frequency dB at Hertz

Overall
Location Desc.
dBA
31.5 63 125 250 500 1k 2k 4k 8k 16k
North
ML1 40.7 63.1 57.7 47.7 39.6 34.6 33.7 32.2 30.5 17.6 -
Property Line
West
ML2 43.3 58.0 52.4 43.4 36.2 32.6 38.7 39.2 26.9 -4.3 -
Property Line
North
1 40.5 62.9 57.5 47.5 39.5 34.5 33.5 31.9 30.2 16.8 -
Residence
West
2 41.0 55.8 50.2 40.9 33.9 30.3 36.5 36.9 23.1 -15.5 -
Residence
Table 4-14 below shows the total predicted octave band sound level contribution with the new equipment
in operation, including the ambient sound levels. These levels are the energy sum of the existing ambient
sound levels and the predicted new equipment sound levels shown in Table 4-13. These levels are a
prediction of the expected overall sound levels with the new station equipment in operation.
Table 4-14. Predicted Octave Band Sound Levels – New Equipment and Ambient
Spectral Sound Pressure Level at Octave Band Center Frequency dB at Hertz

Overall
Location Desc.
dBA
31.5 63 125 250 500 1k 2k 4k 8k 16k
At North
ML1 41.5 63.2 58.0 48.3 40.2 35.6 34.0 32.5 32.1 22.2 23.4
Property Line
At West
ML2 43.9 58.4 53.8 45.5 38.2 35.8 39.0 39.3 29.4 20.0 22.8
Property Line
At North
1 41.3 63.0 57.8 48.1 40.1 35.5 33.8 32.2 31.9 21.9 23.4
Residence
At West
2 42.0 56.4 52.4 44.1 36.9 34.9 36.9 37.1 27.7 20.0 22.8
Residence
4.3.2.2.3 CUMULATIVE NOISE IMPACTS

The ROI for cumulative noise impacts is any inhabited buildings within 0.25-mile of the construction
workspace and within 1 mile of the CS 261 property line. Noise impacts resulting from the Projects will
include: (1) construction-related noise for both the Looping Project and the HP Replacement Project; and
(2) operational noise for the HP Replacement Project only.
Construction-related noise would only result in a cumulative impact with Activities proposed during the
same timeframe as the Projects and at inhabited buildings within 0.25-mile of the Projects. As
summarized in Table 2-10, the only Activity identified that could result in noise impacts during
construction to the same inhabited buildings as the Projects is the Ace Precision Way 3-lot residential
subdivision; however, this Activity is currently in the planning and design stage, and no information on
whether construction will overlap with the Projects is available. Regardless, any cumulative impacts to
inhabited buildings would be short-term, minor, and limited to daytime hours to the extent practicable.
Operational noise would only result in a cumulative impact with permanent noise-generating facilities at
inhabited buildings within 1 mile of the HP Replacement Project. The only such Activity identified was
the TJA Solar Project. Solar invertors may create operational noise; however, these noise impacts are
83
typically minor and are limited to daytime hours. Therefore, no significant cumulative noise impacts
from the operation of the two projects together are anticipated.

4.3.2.3.1 CONSTRUCTION MEASURES
The following measures will be taken to mitigate the noise impacts during the construction phase of the
project:
• Construction activities will be restricted to daylight hours, unless limited nighttime construction
is required due to site conditions, specialized construction techniques, and/or weather-related
events;
• Vehicles and equipment will be equipped with mufflers; and
• Vehicles and equipment will be maintained in accordance with manufacturers’ recommendations.
Given the existing noise character of the area and the implementation of the above mitigation measures, it
is not anticipated that noise levels during the construction phase of the project will be disruptive to nearby
inhabited buildings.
4.3.2.3.2 OPERATIONAL MEASURES
Looping Project
Once constructed, the pipeline loop will be located entirely underground and will not generate noise.
The new turbine-driven centrifugal compressor will include the following equipment:
• Turbine inlet and exhaust openings;

• Turbine lube oil cooler; and
• Station suction and discharge piping and suction separators.
The following noise control treatments will be utilized to mitigate operational noise impacts:
• A custom exhaust silencer will be equipped on the proposed Taurus 70 turbine;

• A custom inlet silencer will be equipped on the proposed Taurus 70 turbine, and will preferably
be located inside of the compressor building;
• A custom lube oil cooler will be designed; and
• Building D piping will be acoustically lagged to reduce the radiated noise transmitted through the
walls of the piping.
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4.4 PLANT AND ANIMAL SPECIES AND HABITAT
4.4.1 Vegetation
The Projects are located in the Connecticut River Valley ecoregion of Massachusetts (Ecoregion 59A).
The Connecticut River Valley is characterized by rich soils, mild climate, and low rolling topography.
The valley floor is primarily cropland and developed land. Central hardwoods and transition hardwood
forests cover the ridges (NHESP 2010).
The Projects are proposed to be located within or adjacent to existing Tennessee natural gas pipeline
ROW and CS 261 property to the maximum extent practicable, thereby minimizing alteration of
undisturbed areas and avoiding the additional fragmentation of contiguous areas. The general cover types
crossed by the Projects include open upland, open wetlands, agricultural land, commercial/industrial land,
forested upland, and forested wetland.
4.4.1.1.1 OPEN UPLAND

Open uplands are crossed by the pipeline loop and generally include maintained utility easements. The
open upland communities are dominated by multiflora rose (Rosa multiflora), Morrow’s honeysuckle
(Lonicera morrowii), goldenrods (Solidago and Euthamia spp.), white bedstraw (Galium mollugo),
grasses, bitter dock (Rumex obtusifolius), and Allegheny blackberry (Rubus allegheniensis).
4.4.1.1.2 OPEN WETLAND

Open wetlands are crossed by the Looping and HP Replacement Projects and include emergent marsh and
scrub-shrub wetlands. These wetlands are free of trees because they either are within a maintained utility
easement or have sufficient hydrology to inhibit tree growth. The emergent marshes are dominated by
goldenrods, purple loosestrife (Lythrum salicaria), reed canary grass (Phalaris arundinacea), broad-leaf
cattail (Typha latifolia), soft rush (Juncus effusus), fringed sedge (Carex crinita), bulrushes (Scirpus
spp.), Japanese stiltgrass (Microstegium vimineum), and sensitive fern (Onoclea sensibilis). Where scrub-
shrub wetlands occur, they include the species above mixed with silky dogwood (Cornus amomum),
speckled alder (Alnus rugosa), nannyberry (Viburnum lentago), and red maple (Acer rubrum) saplings.
4.4.1.1.3 AGRICULTURAL LAND

Agricultural lands crossed by the Looping Project include active cropland, hayfields, and pastureland for
grazing livestock. Those agricultural lands that are not in active crop production are generally dominated
by maintained or grazed grasses, white clover (Trifolium repens), goldenrods, great plantain (Plantago
major), and common dandelion (Taraxacum officinale).
4.4.1.1.4 COMMERCIAL/INDUSTRIAL LAND

Commercial/industrial lands crossed by the Looping and HP Replacement Projects consist of buildings,
paved parking lots, landscaped areas, and maintained lawn.
4.4.1.1.5 FORESTED UPLAND
Forested uplands are crossed by the Looping Project and are located outside of the existing maintained
Line 261B-100 easement. These forested uplands may be classified as an oak-hemlock-white pine forest.
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The canopy and shrub/sapling layers are dominated by northern red oak (Quercus rubra), white oak (Q.
alba), post oak (Q. stellata), eastern hemlock (Tsuga canadenisis), eastern white pine (Pinus strobus),
gray birch (Betula populifolia), black birch (B. lenta), and American beech (Fagus grandifolia). The
understory is sparse and dominated by tree saplings.
4.4.1.1.6 FORESTED WETLAND

Forested wetlands are crossed by the Looping Project and are located in low-lying areas outside of the
existing maintained Line 261B-100 easement. The forested wetlands in the Project area are primarily red
maple swamps dominated by red maple and pin oak (Q. palustris) with glossy false buckthorn (Frangula
alnus) in the shrub layer and cinnamon fern (Osmunda cinnamomea) and soft rush (Juncus effusus) in the
herb layer.
4.4.1.1.7 VEGETATIVE COMMUNITIES OF SPECIAL CONCERN

No NHESP Priority Natural Communities, MA DFW Interior Forests, or ACECs are crossed or located
within 0.25-mile of the Projects.
4.4.1.2 Impact Assessment

Areas that are already vegetated with grasses or early successional species will be restored after
construction has been completed. Impacts to these vegetation communities, including open upland, open
wetland and agricultural land, will be short-term and are expected to regenerate after one to two growing
seasons.
Long-term impacts are limited to forested areas during operation of the proposed pipeline loop. The
siting of the pipeline loop alignment along a previously disturbed and maintained pipeline corridor was
the preferred alternative as it reduces the clearing of forested areas during construction and minimizes the
potential for habitat fragmentation. However, unavoidable temporary impacts to 2.17 acres of forested
upland and 2.51 acres of forested wetland will occur as a result of construction. In areas where
workspace within forested areas is unavoidable, they will be cleared, and standard erosion control/cover
species will be planted after construction is completed. Temporary workspace that was identified as
forest during the field surveys will be allowed to revert to forest; however, succession back to forested
habitat may take up to 50 years to regenerate in the temporary ROW to near preconstruction conditions.
Permanent impacts will occur to 2.17 acres of forested upland and 0.85 acre of forested wetland as a
result of vegetation management within the permanent easement, which will permanently convert these
vegetative communities to open upland or open wetland types.

Modifications at CS 261 will result in temporary impacts to mowed lawn and an emergent wetland
drainage feature within the station yard. All temporary construction workspaces will be restored after
construction has been completed. Permanent vegetation impacts will be limited to approximately 2,470
square feet of a vegetated slope on the CS 261 yard that will be permanently altered by the footprint of the
proposed auxiliary building.
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The ROI for cumulative impacts on vegetation is the ecoregion in Massachusetts in which the Projects’
facilities are located, the Connecticut River Valley Ecoregion. Table 2-10 summarizes those Activities
that overlap the Project’s ROI and could include cumulative impacts to vegetation.
Vegetation impacts resulting from construction of the Projects are expected to take the following forms:
(1) direct temporary impacts from vegetation clearing during construction; and (2) indirect impacts, such
as the spread of invasive species, from land disturbance activities. The Projects’ proposed mitigation
measures, described in Section 4.4.1.3 below, will mitigate for construction-related impacts including
restoration of vegetated areas. With the implementation of these mitigation measures, cumulative impacts
on vegetation resulting from construction are expected to be minor.
Permanent vegetation impacts resulting from the Projects would include the permanent conversion of
forested communities to non-forested types and scrub-shrub wetlands to emergent wetlands within
portions of the new permanent easement of the Looping Project. Like the Project, the Activities identified
in Table 2-10 would require mitigation for wetland impacts under the WPA, 401 WQC, and/or USACE
404 permits needed for these Activities. Therefore, no cumulative impact on wetland vegetation
communities are anticipated within the ecoregion. However, although efforts have been made to
minimize permanent tree clearing through co-location, loss of forested upland resulting from the Looping
Project together with these Activities will result in a cumulative impact on forested uplands within the
ecoregion. These cumulative impacts on forested uplands are typical of a region experiencing growth and
urban sprawl, such as that being experienced in the Greater Springfield Service Territory / Pioneer Valley.

Tennessee will protect and minimize potential adverse impacts to vegetation using the procedures
outlined below.
4.4.1.3.1 CLEARING
Tennessee has minimized the acreage of clearing that will be required by co-locating the Projects within
their existing easements, other utility and roadway easements, and/or their CS 261 facility to the extent
practicable, feasible, and legally permissible. Prior to the commencement of any clearing activities, all
workspace limits will be clearly marked to endure that no clearing occurs beyond these boundaries. All
wetland boundaries will also be delineated and clearly marked prior to clearing so that all Project
personnel and inspectors will know where these sensitive environmental resources are located and where
specialized mitigation measures and techniques must be implemented. Any trees that are to be saved
shall be adequately marked (e.g., flagging and/or construction fencing) before tree clearing begins.
When pruning is necessary to clear the ROW, pruning cuts will be made as follows: (1) cuts will be
smooth; (2) branch collars will not be cut (i.e., cuts should be made immediately in front of the branch
collar); (3) large, heavy branches will be precut on the underside to prevent splitting or peeling of bark;
and (4) climbing spurs will not be used for tree climbing.
All woody vegetation cleared as part of the installation and construction of the Projects will be chipped
and hauled off-site. Some amount of chips may be left on the ROW, with EI approval, if it does not
inhibit revegetation. Chips will not be left in agricultural lands, wetlands, or within 50 feet of wetlands.
Chips will not be stockpiled in such a manner that they may be transported into a wetland or agricultural
land.
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Within wetlands, no rubber tire equipment will be permitted unless it will not damage the root systems
and its use is approved by the on-site EI. Excessive traffic from rubber-tired clearing equipment, such as
skidders, on saturated soils can result in soil compaction and damage to existing root systems. To
mitigate potential damage to root systems from clearing operations, the EI would determine whether or
not rubber-tired equipment would damage root systems by surveying the wetland ahead of clearing
equipment for degree of saturation. Where wetlands are saturated and root damage is likely, clearing will
be done manually or will be completed with equipment operating on timber mats. If the wetland must be
crossed by rubber-tired equipment to access the remainder of the ROW, a travel land of timber mats will
be installed to facilitate access along the ROW. Bulldozers will not be used for clearing in wetlands.
Trees and brush will be cut at ground level by hydroaxes, tree shears, grinders, or chain saws. Within
wetlands, stumps will be left in place, except on the trenchline or unless the removal is necessary to
ensure worker safety. Stumps may be ground to a suitable height for safety reasons.
4.4.1.3.2 TOPSOIL SEGREGATION

Tennessee proposes topsoil segregation and reuse in certain areas to improve the success of revegetation
by preserving the soil seed bank, organic material, and nutrients present in the topsoil. In accordance with
the FERC Plan, as incorporated into the Project ECMP, topsoil will be stripped from the full work area, or
from the trench and subsoil storage area in active or rotated crop and pasturelands, residential areas,
hayfields, or other areas at the landowner or land manager’s request. In accordance with the FERC
Procedures, as incorporated into the Project ECMP, topsoil will be segregated in wetlands except where
soils are saturated or frozen or in areas of standing water. These segregation techniques do not apply to
wetlands within actively cultivated or rotated croplands.
4.4.1.3.3 RESTORATION
Following trenching, lowering-in of the pipeline loop, and backfilling, Tennessee will restore the original
contours and flow regimes to the extent practical, with the exception of unnatural features and unstable
grades. In consultation with NRCS, the ROW will be seeded with an erosion control seed mixture to
stabilize the area until indigenous species can become re-established. If weather conditions limit the
effectiveness of the reseeding efforts, at the discretion of the EI and as allowed by all applicable permits,
the ROW may be mulched to minimize erosion until conditions are suitable for reseeding. No fertilizer or
lime will be used in wetlands unless specified by the NRCS and approved by the applicable regulatory
agencies.
Restoration of wetland vegetation will be in accordance with permit conditions and in consultation with
the various regulatory authorities, including the Agawam Conservation Commission, MassDEP, and
USACE.
4.4.2 Wildlife
Wildlife habitat types in the Project area have been identified based on preliminary field surveys, review
of available resource materials, and interpretation of aerial photographs. For the purposes of this report,
the wildlife habitats along the pipeline loop route and at the existing CS 261 are representative of the
vegetation community structure described in Section 4.4.1 above, the composition of the terrestrial and
wetland habitats present, and the Project ecoregion and nearby land uses. These habitat types include
forested upland, forested wetland, open uplands (early successional scrub-shrub and herbaceous
vegetation cover), open wetlands (both emergent and scrub-shrub communities), agricultural, and
commercial/industrial habitats.
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Existing plant communities, as well as aspects of the physical environment (climate, microclimate,
hydrology, geology, etc.) will influence the wildlife species that are present in a particular habitat. This
section describes the major wildlife habitat types and wildlife species associated with vegetative cover
and community types present in the Projects’ areas (see Section 4.4.1.1 for description of plant
communities in the Projects’ areas).

The open upland habitat types in the Projects’ areas generally include existing maintained utility
corridors. These areas have been disturbed by periodic vegetation maintenance work. These utility
corridors may provide edge habitat and migratory corridors for wildlife, as well as providing needed
grassland and early successional habitat for many wildlife species, including grassland birds. Grasslands,
old fields, and brushy areas can be used as foraging and nesting habitat by mammals and songbirds.
Shrublands provide sources of food and nesting sites for various birds, as well as cover for invertebrates,
reptiles, and amphibians. Species such as the eastern cottontail (Sylvilagus floridanus), gray squirrel
(Sciurus carolinensis), opossum (Didelphis virginiana), raccoon (Procyon lotor), and red fox (Vulpes
vulpes) utilize these types of habitats.
4.4.2.1.2 OPEN WETLAND

Open wetlands include emergent marshes and scrub-shrub swamps. Emergent marshes are characterized
by a variety of grasses, sedges, and rushes and scrub-shrub swamps include those species along with
shrubs and saplings. These wetland communities are often associated with areas containing standing
water for extended periods of time or areas that are maintained in an emergent state by regular vegetation
maintenance (e.g., utility corridors). Many of the open wetlands in the Projects’ areas are dominated by
invasive species, including purple loosestrife, reed canary grass, and Japanese stiltgrass, and therefore
represent low quality wildlife habitat. Common species of birds associated with emergent wetlands
include red-winged blackbird (Agelaius phoeniceus) and great blue heron (Ardea herodias). Common
mammals associated with this habitat type include star-nosed mole (Condylura cristata) and muskrat
(Ondatra zibethicus). White-tailed deer (Odocoileus virginianus) capitalize on the abundance of grasses
and forbs. A large variety of amphibians and reptiles are also commonly found within these areas, for
example bullfrog (Rana catesbeiana), common snapping turtle (Chelydra serpentina), painted turtle
(Chrysemys picta), and pickerel frog (Lithobates palustris).

Agricultural lands in the Projects’ areas include active cropland, pasture for grazing livestock, and
hayfields. Although these areas generally provide poor to moderate cover habitat, they often provide
forage and nesting for a number of species such as European starlings (Sturnus vulgaris) and mourning
doves (Zenaida macroura). Pastures also provide grazing habitat for species such as the white-tailed
deer.
4.4.2.1.4 COMMERCIAL/INDUSTRIAL
Portions of the pipeline loop will cross commercial/industrial land associated with businesses adjacent to
the proposed pipeline loop, public roadways, and the existing CS 261. In addition, the modifications to
CS 261 will be sited on land that is currently in commercial/industrial use. These developed lands
provide low quality wildlife habitat. Species present in landscaped and lawn areas associated with these
properties may include grey squirrels and common songbirds that are tolerant of human activity, such as
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American robins (Turdus migratorius), mockingbirds (Mimus polyglottos), American crow (Corvus
brachyrhynchos), and house sparrows (Passer domesticus). Occasional visitors to these areas may also
include raccoons and striped skunk (Mephitis mephitis).
4.4.2.1.5 FORESTED UPLAND

The oak-hickory-white pine forests crossed by the Looping Project may provide habitat for a variety of
wildlife species. Tree cavities and large woody material provided by upland forests provide den sites
and/or cover for a variety of bird, mammal, amphibians and reptiles. Acorns and beech nuts provide an
important source of wildlife food. There is a large suite of neotropical migratory birds that may be found
here, including 15–16 warbler species, Eastern wood-pewee (Contopus virensi), and great-crested
flycatcher (Miarchus crinitus) (Swain and Kearsley 2001). Large mammals may include white-tailed
deer, coyote (Canis latrans), red fox, and fisher (Martes pennanti). Common small mammals may
include shrews (Sorex spp.), white-footed mouse (Peromyscus leucopus), and red squirrels
(Tamiasciourus hudsonicus). A variety of snakes and terrestrial amphibians and turtles may also be
present in these areas.
4.4.2.1.6 FORESTED WETLAND

Forested wetlands are dominated by woody vegetation that can reach approximately 20 feet tall or taller
and normally includes an overstory of trees, and understory of young trees or shrubs, and an herbaceous
layer. These areas provide a diverse assemblage of vegetation and an abundance of food and water
sources for wildlife. The forested wetland canopy species in the Projects’ areas are typically dominated
by red maple. These wetlands are important for providing food, shelter, migratory and wintering areas,
and breeding areas for wildlife species, including American toad (Bufo americanus), northern spring
peeper (Pseudacris crucifer), and gray treefrog (Hyla versicolor).

It is anticipated that vegetation clearing will cause a temporary impact as a result of habitat loss and
general disturbance from construction activities. Wildlife will vacate a selected breeding/wintering
location and expend energy finding an alternate location. However, disruption of habitat will be
temporary in nature, and the individuals will be able to utilize the area in subsequent seasons, post-
construction.
Long-term impacts to wildlife habitat due to construction and operation of the proposed Projects will be
limited to clearing of upland and wetland forests required for temporary workspace and new permanent
easement. To the extent practicable, feasible, and legally permissible, Tennessee has routed the pipeline
loop to follow existing utility ROWs (and thus follow existing forest edges) thereby minimizing the
acreage of forest lands crossed and the relatively greater impacts that would be associated with clearing
an entirely new ROW through a contiguously forested area. Areas cleared for temporary workspace and
for pipeline construction will quickly regenerate and provide additional open land habitat (i.e., scrub-
shrub and old-field). These areas will not be maintained post-construction and will revert back to forested
habitat over time, much like land that has been previously cut during timber harvesting operations. Areas
of early successional habitat that are impacted by construction will naturally re-vegetate within one to two
growing seasons to their pre-construction condition and cover type.
The wildlife populations that use the Projects’ areas will not be permanently adversely affected by the
proposed pipeline loop. While temporary impacts to food, cover, and water sources may occur, none of
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the species located within the Projects’ areas are specialized in such a way that construction of the
pipeline will inhibit the overall fitness or reproductive output of the populations as a whole. Most species
are not dependent on the ROW or transitional areas to provide all their habitat requirements. Many of the
mammal, bird, reptile, and amphibian species are adaptive to changing habitat conditions and possess the
capability to expand or shift their home ranges temporarily to find alternative sources of food, water, and
shelter until the ROW habitats become re-established (DeGraaf et al. 1992).

Temporary and permanent impacts to wildlife from the modifications to CS 261 are expected to be
negligible. The proposed modifications to the CS 261 will be located within the existing fenceline of the
compressor station and within or adjacent to developed portions of the site that provide minimal wildlife
habitat value.

The ROI for cumulative impacts on wildlife is the ecoregion in which the Projects’ facilities are located,
the Connecticut River Valley ecoregion. By siting the pipeline loop within or adjacent to existing utility
or transportation corridors, modifying existing aboveground facilities, and revegetating all temporary
construction workspaces following construction, the Projects are expected to have negligible permanent
impacts on wildlife. Temporary direct or indirect impacts on resident wildlife may result from
construction activities associated with the Projects’ facilities. Direct impacts may include injury/mortality
from active construction, while indirect impacts can result from temporary displacement or behavioral
changes due to construction noise and activity.
Table 2-10 summarizes the Activities that overlap the Project’s ROI and that could contribute to
cumulative impacts to wildlife. Because impacts to wildlife resulting from the Projects are expected to be
temporary, generally limited to the construction phase, only those Activities with construction that
overlaps with construction of the Looping Project would result in a cumulative impact to wildlife. As
depicted in Table 2-10, the only Activity identified that may impact wildlife during the same timeframe
and in the same ROI as the Projects is the proposed Westfield Turnpike Industrial Park in Westfield,
Massachusetts. However, these impacts are expected to be of short duration and no long-term cumulative
impacts on wildlife will result.

Tennessee and its contractors will strive to minimize impacts to wildlife by adhering to the FERC Plan
and FERC Procedures, as adopted in the Project ECMP, and expediting construction to the greatest extent
possible. Tennessee proposes to clear the ROW during the winter of 2019/2020 to minimize impacts to
breeding birds. Additional timing restrictions on vegetation clearing may be implemented by state
agencies based upon the final results and impact assessments for rare, threatened, and endangered species,
as discussed in Section 4.4.3 below. These timing restrictions would likely be limited to specific areas
identified as suitable habitat for rare species within the Projects’ workspaces.
Conversion of forest and scrub-shrub habitats will be minimized through co-location of the Projects with
Tennessee’s existing pipeline ROWs, other utility and roadway corridors, and Tennessee’s existing CS
261 facility. Further, the construction and operational ROW will be of the smallest width practical,
particularly in wetlands, given the site-specific conditions. Re-vegetation will occur after construction
has been completed, and the areas of impact will be monitored until final site stabilization has been
achieved.
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4.4.3 Threatened and Endangered Species

4.4.3.1.1 STATE-LISTED SPECIES
State-listed rare species and their habitat are protected under the Massachusetts Endangered Species Act
(“MESA”) (M.G.L. c. 131A) and, where their habitat occurs within wetlands, by the Massachusetts
Wetlands Protection Act. MESA protects rare species and their habitats by prohibiting the “Take” of any
plant or animal species listed as endangered, threatened, or special concern. The Massachusetts NHESP
administers MESA by requiring projects within mapped rare species habitats to undergo project review
and, if a Take is anticipated, to obtain a Conservation & Management Permit that will require mitigation
sufficient to result in a net benefit to the species.
Approximately 0.66-mile of the proposed pipeline loop crosses a mapped Priority Habitat of Rare Species
(PH 780). On November 21, 2017, Tennessee submitted a Request for State-Listed Species Information
to the NHESP. Tennessee received a response from NHESP dated December 27, 2017 indicating that PH
780 provides habitat for the eastern box turtle (Terrapene carolina), a state-listed reptile of special
concern, and the eastern wormsnake (Carphophis amoenus), a state-listed threatened reptile (see Agency
Consultations in Appendix C). A second Priority Habitat (PH 805), which is mapped habitat for the
eastern box turtle, is located adjacent to the proposed workspace at the pipeline loop terminus but will not
be impacted by the Projects.
No state-listed rare species habitats are mapped at CS 261.
Eastern Box Turtle

The eastern box turtle is a small, terrestrial turtle that inhabits many types of habitats, including both dry
and moist woodlands, brushy fields, thickets, marsh edges, bogs, swales, fens, stream banks, and well-
drained bottomland. Eastern box turtles hibernate from late October or November to mid-March or April
in upland forests, a few inches under the soil surface. They become active in the spring and females lay
eggs in June or early July. Nesting areas are often in open uplands, typically early successional fields,
meadows, utility ROWs, woodland openings, roadsides, mulch piles, lawns, or abandoned gravel pits
(NHESP 2015a).
Eastern Wormsnake
Eastern wormsnakes are small, non-venomous snakes that have been documented in only five
Massachusetts towns, all within Hampden County. The eastern wormsnake prefers moist, non-saturated,
sandy soil and woody debris. It occurs in deciduous hardwood forest, mixed pine-hardwoods, pine forest,
and early successional fields, and are often found in edge habitats near woodland and wetland borders or
woodland/grassland edges. They are a fossorial snake, spending most of the year underground. They
emerge from overwintering in the spring, and mate in May. Females lay eggs under decaying woody
debris or rocks from mid-June through July. Hatchlings emerge in August or September (NHESP 2015b).
4.4.3.1.2 FEDERALLY LISTED SPECIES

Section 7 of the federal ESA (16 United States Code [“U.S.C.”] §§ 1531-1543) requires each federal
agency to ensure that an action authorized, funded, or carried out by the agency does not jeopardize the
continued existence of federally-listed threatened or endangered species, or result in the destruction or
adverse modification of the designated critical habitat for any federally-listed threatened or endangered
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species. FERC, as the lead agency in the review of the proposed Projects, consults and/or confers with
the U.S. Fish and Wildlife Service (“USFWS”) to determine whether any federally listed species or
species proposed for federal listing, or their designated critical habitat may occur in the Projects’ areas,
and to determine the Projects’ potential effects on these species and/or critical habitats.
Tennessee reviewed the USFWS New England Field Office’s online project review process, and
determined that the northern long-eared bat (Myotis septentrionalis) has the potential to occur in the
Project area. Based on mapping from NHESP, no known maternity roost trees occur within 150 feet of
the Projects and no known hibernacula occur within 0.25-mile of the Projects. The Projects therefore
comply with the northern long-eared bat 4(d) Rule; under the 4(d) Rule, an incidental take as a result of
tree clearing activities is not prohibited. Tennessee will coordinate with the USFWS New England Field
Office to confirm that the Projects would not cause a prohibited incidental take.

Approximately 7.65 acres of total construction workspace is required for installation of the pipeline loop
within PH 780. Construction activities will result in the temporary loss of available habitat for these
species and, in the absence of mitigation, could result in physical injury or mortality to individuals as a
result of earth movement activities and construction equipment travel. Loss of available habitat is,
however, expected to be temporary in nature and limited to the duration of construction. Mitigation
measures proposed to protect these species during construction and minimize or avoid a “Take” of a state-
listed species are discussed in Section 4.4.3.3 below.

The eastern box turtle and eastern wormsnake utilize a variety of habitats, including utility ROWs. Thus,
conversion of forested land to open land as a result of vegetation maintenance in the new permanent
easement is not expected to result in a permanent loss of habitat for either species. Measures to be
implemented during vegetation management and operation and maintenance of the pipeline are discussed
in Section 4.4.3.3.

The ROI for cumulative impacts to threatened and endangered species is the ecoregion in which the
Projects occur, the Connecticut River Valley ecoregion. A cumulative impact would only occur in
conjunction with Activities in the same ROI that also impact the same species. Activities within rare
species habitat in Massachusetts must be reviewed by NHESP, which cannot allow a project to proceed if
it will have an adverse impact on a state-listed species. All projects must either receive a “Conditional
no-take” or a Conservation and Management Permit, which is issued only if the project has a net benefit
to the species. This regulatory review process is designed to ensure that no cumulative impacts to state-
listed species will occur in Massachusetts.
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Tennessee is currently in the process of consulting with NHESP regarding mitigation measures for work
in state-listed species habitat and whether a Conservation and Management Plan will be required. At this
time, Tennessee anticipates that mitigation will include the following measures, at a minimum:
• Pre-construction field surveys for eastern box turtles and eastern wormsnakes, in accordance with
protocols approved by NHESP.
• Pre-construction population monitoring of eastern box turtles and eastern wormsnakes using
radiotelemetry for at least one active season (April 1 to October 31) prior to tree clearing in
November 2019, followed by monitoring April to May 2020 prior to pipeline installation in June
2020.
• Use of appropriate exclusion fencing and pre-construction sweeps of active tree clearing /
construction areas to identify and re-locate individuals out of the construction area.
• Development of a contractor training program to educate all construction personnel on species

life history, identification, and protection protocols.
• Submittal of written reports of findings to NHESP.
• All work will be conducted under a valid Scientific Collection Permit by wildlife biologists with
experience with these species.
• Conducting operational ROW vegetation management and operations and maintenance in

accordance with NHESP-approved plans and the FERC Plan and FERC Procedures, as
incorporated into the Project ECMP.
• Minimization of long-term habitat impacts by co-location of pipeline loop with existing utility
and roadway ROWs and the existing CS 261.
• Additional mitigation, which may include the preservation of habitat, developed in consultation
with NHESP.
4.5 TRAFFIC, TRANSIT, AND PEDESTRIAN AND BICYCLE

TRANSPORTATION
4.5.1 Existing Environment

A total of four public roadways will be crossed by the proposed pipeline loop. Table 4-15 below provides
a list of the roadways crossed by the Projects, their ownership, and Tennessee’s proposed crossing
method.
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Table 4-15. Roadways Crossed by the 261 Upgrade Projects
Road Name Approximate Stationing Road Type Crossing Method
Suffield Street (Route 75) 12+89 to 13+46 Municipal road Conventional bore
Shoemaker Lane 19+49 to 40+00 Municipal road Conventional bore
Gold Street 72+87 to 73+08 Municipal road Open cut
Silver Street 105+34 to 105+95 Municipal road Conventional bore
Impacts to transportation will result only from construction activities across roadways, as identified in
Table 4-15 above, and minor increases in roadway use from construction vehicles. No new permanent
employees will be required as a result of the operations of the Projects. Therefore, there will be no
increased demands on local transportation requiring mitigation during operation of the Projects’ facilities.
4.5.2 Assessment of Impacts

The roadways crossed by the proposed pipeline loop will either be open-cut or conventional bore to install
the pipeline, depending on site-specific conditions. Potential temporary impacts associated with roadway
crossings include disruption of traffic flows, identification and construction around existing underground
utilities such as water and sewer lines, and maintenance of emergency vehicle access. There will be no
permanent effects on existing use of the roadways crossed by the Projects.
4.5.3 Mitigation Measures

Roadway crossings will be conducted to minimize impacts to traffic during construction. Traffic lanes
and residential access will be maintained except for the temporary periods essential for pipeline
installation. Tennessee will incorporate measures to ensure that construction of activities will not prevent
the passage of fire and emergency vehicles, including the creation of temporary travel lanes during
construction or the placement of steel plate bridges to allow continued traffic flow during open trenching.
When necessary, Tennessee will employ a police detail to ensure traffic flow and safety of pedestrians
and vehicles during construction.
4.6 SCENIC QUALITIES, OPEN SPACE AND

RECREATIONAL RESOURCES

Tennessee reviewed landowner information and online references and data layers to determine whether
the Projects will cross scenic resources, open space areas, or recreational resources. Resources that were
considered scenic or recreational included National Forests, lands administered by federal agencies such
as Indian reservations or designated wilderness areas, ACEC, open space lands, state agricultural
preservation areas, state scenic landscapes, mapped trails, National Park Service (“NPS”) scenic trails,
scenic roads, wild and scenic rivers, nature preserves, wildlife management areas, registered natural
landmarks, state parks and public natural resource lands (e.g., parks, forests, reserves, conservation lands)
protected under Article 97.
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No distinctive or noteworthy scenic landscapes are crossed directly by the Projects. One recreational
resource, a private golf course, is directly adjacent to the Projects. Resources identified in proximity to the
Projects are shown in Table 4-16.
Table 4-16. Special Land Uses within 1 mile of the 261 Upgrade Projects
Resource Type Approx. Stationing Distance from Direction from

Nearest Workspace Centerline
Crestview Country Club &

Golf course 0+00 to 30+20 adjacent West
Golf Course
James Clark School Playground 45+00 to 62+00 0.16 mile East
Veterans Memorial Cemetery Cemetery 54+00 to 70+00 0.26 mile East
Agricultural Preservation
Agricultural land 54+00 to 69+90 0.07 mile West
Restriction
Agricultural Preservation
Agricultural land 54+00 to 69+90 0.07 mile West
Restriction
West Springfield Fish & Private hunting and
106+00 to end 0.04 mile West
Game Club fishing club
Silver Lake Open space 111+00 to end 0.07 mile Northeast
Perry Lane Park Town park 111+00 to end 0.67 mile Northeast

No permanent impacts associated with installation of the pipeline loop are proposed to open space or
scenic or recreational resources. The scenic qualities of nearby resources are not anticipated due to the
proposed co-location of the pipeline loop with the existing pipeline ROW.

Tennessee proposes to co-locate the pipeline loop within or adjacent to previously existing pipeline,
roadway, and other utility corridors to mitigate for potential visual impacts on nearby scenic and natural
resources. Temporary visual impacts of limited duration will be mitigated through restoration practices to
revegetate the ROW in a timely manner.
4.7 HISTORIC AND ARCHAEOLOGICAL RESOURCES
4.7.1 Area of Potential Effects

The area of potential effect (“APE”) is the “geographic area or areas within which an undertaking may
directly or indirectly cause changes in the character of or use of historic properties, if any such properties
exist” (36 CFR 800.16(d)). The APE is defined based upon the potential for effect, which may differ for
aboveground resources (historic structures and landscapes) and subsurface resources (archaeological
sites). The APE may include all areas where ground disturbances are proposed, where land use may
change, or any locations from which the undertaking may be visible.
96
4.7.1.1 APE for Archaeological Resources

For archaeological resources, the APE was defined as any areas of ground disturbance for the Project
facilities including proposed pipeline trench, associated temporary workspaces, pipe yards, and access
roads. The archaeological surveys encompass all areas where ground disturbances are currently proposed
or where land use (i.e., traffic patterns and drainages) may change. The APE for the Looping Project
corresponds with a 20-foot buffer around all proposed construction workspace, and the APE for the HP
Replacement Project is limited to the area within the fence line at existing CS 261. For ancillary facilities
such as pipe yards and access roads, the APE limits vary based upon the acreage required at each.
4.7.1.2 APE for Historic Architectural Properties

The historic architectural properties survey will be conducted within a study area established to account
for all potential direct or indirect effects of the Projects. The study area will comprise of a linear corridor
extending 150 feet from either side of the pipeline centerline (300 feet total width) and areas surrounding
workspaces and access roads. Based on the nature of the potential impacts of the Projects and the results
of fieldwork conducted to identify historic properties, the study area as defined above comprises the
recommended APE for historic architectural resources.
4.7.2 MHC Correspondence

Following FERC guidelines, Tennessee provided notification of the Projects to the Massachusetts
Historical Commission (“MHC”), interested cultural resource stakeholders, Tribes, and affiliated Tribal
Historic Preservation Officers (“THPOs”) who have historically expressed an interest in ancestral lands
located in central-southern Massachusetts along the Connecticut River Valley.
4.7.2.1 MHC Consultation

On behalf of Tennessee, The Public Archaeology Laboratory, Inc. (“PAL”) provided a Projects’
introduction package to the MHC on May 24, 2018, consisting of an initial outreach letter, Project
Notification Form, cultural resources due diligence review, and a technical proposal for an intensive
(locational) archaeological survey for the Project. On June 13, 2018, the Massachusetts State
Archaeologist issued a permit to PAL to perform the survey. The cultural resources fieldwork will be
conducted in June/July 2018 and the results will be submitted to the MHC to continue consultation
throughout the Section 106 process.
4.7.2.2 Tribal Communications and Outreach

Tennessee initiated communications with federally recognized American Indian Tribes (“Tribes”) through
introductory meetings to introduce the Projects and the Projects’ teams, and to initiate communications
prior to agency consultation. Written communication with Tribes and the Massachusetts Commission on
Indian Affairs was initiated to provide an opportunity to identify concerns about properties of traditional
religious or cultural significance that may be affected by the Project. The letter clearly stated that the
FERC, not Tennessee or PAL, is responsible for government-to-government consultations with
Tribes. The notification letter provided contact information for cultural resource staff at the FERC and
provided an anticipated schedule for PAL archaeological fieldwork activities. Further, in addition to
sending tribal representatives paper copies of the notification letters, Tennessee also submitted electronic
copies of the technical proposal for archaeological survey and cultural resource due diligence to the tribal
contacts via email.
97
On May 31, 2018 Tennessee, with PAL, met with the Tribes to provide information on the Projects and
solicit information on areas of interest/concern, and brief them on the archaeological survey plan.
Tennessee invited the Tribes to participate in the archaeological field work activities. Additionally,
regular communications will be made with tribal contacts, providing information on upcoming and
ongoing fieldwork activities. Tennessee and PAL will continue to communicate with the Tribes
throughout the Section 106 process. The following Tribes have been notified for this Project:
Federally Recognized American Indian Tribes

• Delaware Nation of Oklahoma
• Delaware Tribe of Indians
• Mashantucket Pequot Tribal Nation
• Mashpee Wampanoag Tribe
• Mohegan Indian Tribe
• Narragansett Indian Tribe
• Stockbridge-Munsee Community Band of Mohican Indians;
• Wampanoag Tribe of Gay Head (Aquinnah)
State Tribal Organization

• Massachusetts Commission in Indian Affairs
4.7.3 Cultural Resource Investigations

PAL conducted the cultural resources due diligence review to provide information about known
archaeological sites within one-half mile and known aboveground historic architectural resources and
historic districts within one-quarter mile of the Projects. As such, the study area for archaeological sites
encompasses one-half mile on either side of the Projects for a total width of one mile; for aboveground
resources, the study area encompasses one-quarter mile on either side of the Projects for a total width of
one-half mile.
Twelve resources were identified within the Projects’ defined study area: eleven archaeological sites and
one historic architectural property. None of the identified resources are currently listed in the National
Register of Historic Places (“National Register”). To date, the one historic architectural property and
three archaeological sites have not been evaluated for potential to be listed in the National Register; the
historic architectural property is listed in the MHC’s Inventory of Historic and Archaeological Assets of
the Commonwealth (“Inventory”). Of the remaining eight resources that have been evaluated, two have
been recommended as potentially eligible and six have been recommended as not eligible for listing in the
National Register.
The cultural resources sensitivity assessment was conducted within a 300-foot-wide corridor that
encompasses the pipeline centerline and potential workspaces. Approximately 36 percent of the corridor
was assessed as having moderate archaeological sensitivity, and approximately 64 percent of the corridor
was assessed as having low archaeological sensitivity. No areas were assessed with high archaeological
sensitivity.
In June/July 2018, PAL conducted archaeological and historic architectural properties surveys within the
APEs for each Project to identify cultural resources that may be potentially eligible for listing in the
National Register. Tennessee will continue to coordinate with the Tribes to determine if the APEs contain
any properties of traditional religious or cultural significance that may be affected.
98
4.7.3.1 Cumulative Impacts

The ROI for cumulative impacts to cultural resources is the APEs in which the Projects occur. The APEs
are defined above in Section 4.7.1. No Activities were identified in Table 2-10 that will impact cultural
resources within the APEs for the Projects. Therefore, no cumulative impacts are anticipated.
4.8 LAND USE

Characterization of land use in the Projects’ areas was completed using information gathered from field
surveys conducted in November 2017 and May 2018, interpretation of aerial photographs of the Project
area, and from MassGIS land use datalayers. Land use types along the proposed pipeline route divided
into the following classifications: commercial/industrial; open upland; wetlands; upland forest; residential
land; open water; and agricultural land.

Table 4-17 below quantifies impacts to the various land use classifications crossed by the Projects.
99
Table 4-17. Land Use Acreage Affected by Construction and Operation of the 261 Upgrade Projects
Commercial
Open Upland Residential Agricultural
/ Industrial Wetlandsc Open Waterf Total
Uplandb Forestd Lande Landg
Landa
Construction h
Construction
Construction
Construction
Construction
Construction
Construction
Construction
Operation i
Operation
Operation
Operation
Operation
Operation
Operation
Operation
Workspace Type/ Facility
Looping Project
Pipeline Loop ROW 4.07 2.46 4.04 0 6.60 0.88 3.35 2.17 0 0 0.14 0 1.71 0 19.91 5.51
ATWS 1.98 0 2.42 0 0.92 0 0.45 0 0 0 0 0 1.00 0 6.77 0
Hickory Street Yard j 0 0 3.30 0 0 0 0 0 0 0 0 0 0 0 3.30 0
Access Roads k 1.00 0.00 1.07 1.07 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 2.07 1.07
LOOPING PROJECT TOTAL: 7.05 2.46 10.83 1.07 7.52 0.88 3.80 2.17 0.00 0.00 0.14 0.00 2.71 0.00 32.05 6.58
Compressor Station 261
4.86 0.06 0 0 0 0 0 0 0 0 0 0 0 0 4.86 0.06
Upgrades
NOTES: *Sums may not equal addends due to rounding. Areas less than 0.01 acre are included in the sum as a six decimal digit.
a: Commercial / Industrial Land – Manufacturing or industrial plants, paved areas, landfills, mines, quarries, electric power and natural gas utility aboveground facilities,
developed areas, railroads and railroad yards, and commercial or retail facilities.
b: Open Upland – Utility rights-of-way, open fields, vacant land, herbaceous and scrub-shrub uplands and non-forested lands.
c: Wetlands – Palustrine emergent, palustrine forested, and estuarine intertidal emergent wetlands.
d: Upland Forest – Forested area, not including forested wetlands.
e: Residential Land – Existing developed residential areas. This may include large developments low, medium, and high-density residential neighborhoods, urban/suburban
residential, multi-family residences, ethnic villages, residentially zoned areas that have been developed, or short segments of the route at road crossings with homes near
the route alignment.
f: Open Water – Surface waters identified during field surveys. All Project workspace areas have been field surveyed.
g: Agriculture – Cultivated or rotated cropland, orchards, vineyards, or hay fields.
h: Includes land to be used for construction, including any land that would be retained for operation of the new facilities.
i: Includes new permanent easement
j: Total acreage of Hickory Street Yard is 11.3 acres, 3.3 acres of which are in Massachusetts and 8.0 acres of which are in Connecticut.
k: PAR 2 is located within a maintained sewer line easement (open upland) that passes through forested upland. Although selective tree trimming and removal may be
required where necessary to allow safe vehicle passage, widening of the utility corridor, necessitating tree clearing, is not proposed. Therefore, land use has been
categorized as open upland.
100

The primary impacts to existing land uses from the proposed pipeline loop will be associated with
clearing and widening the existing ROW through forested areas and may include displacement,
inconveniences, and encumbrances. As detailed in Table 4-17, a combined total of approximately 32.05
acres in Massachusetts will be utilized for temporary workspace, ATWS, access, or contractor yard
during construction. Upon completion of construction, a total of 5.51 acres will be maintained as new
permanent ROW, of which approximately 2.17 acres forested upland and 0.88 acre of forested or scrub-
shrub wetland will be permanently maintained in an herbaceous/scrub-shrub state. To ensure operational
safety and to allow for routine maintenance of the facilities, no trees or structures will be allowed within
the permanent ROW. Permanent access roads will utilize 1.07 acres of open upland for operational
access to the permanent ROW. Land used as temporary workspace, ATWS, and temporary access roads
will revert to pre-construction condition. The following provides a brief description of the impacts
associated with the various land use types crossed by the Projects.
Commercial/industrial land includes electric power or gas utility stations, manufacturing or industrial
plants, landfills, mines, quarries, commercial or retail facilities, and roads. A total of 7.05 acres of
commercial/industrial land will be impacted during construction. Of this area, approximately 2.46 acres
will remain as permanent easement. Although land use within the permanent easement through
commercial/industrial areas will be allowed to revert to existing conditions, the use of this area will be
restricted by the terms of the easement (e.g., limiting construction of new structures) and is therefore
considered to be a permanent land use impact.

Open land includes non-forested lands, such as those used for open space or utility ROWs.
Approximately 10.83 acres of open upland will be impacted during construction, and this total is
dominated by the temporary and permanent workspace area co-located within Tennessee’s existing
pipeline ROWs. Because open uplands within the permanent ROW will be allowed to revert to existing
conditions, no permanent (operational) land use changes will occur from the proposed pipeline; however,
1.07 acres will be utilized for the proposed new permanent access roads.
4.8.2.1.3 WETLANDS
Wetlands include palustrine forested, scrub-shrub, and emergent wetland vegetation community types.
Approximately 7.52 acres of wetlands will be temporarily impacted during construction. Of this,
approximately 0.88 acre of forested and scrub-shrub wetlands will be permanently converted to scrub-
shrub or emergent types by vegetation maintenance within the new permanent easement; however, despite
these vegetation community conversions, these areas will still function as wetlands and their land use will
therefore remain unchanged. Wetlands and their impacts are further described in Section 4.2.3.

Agricultural lands are defined as cultivated or rotated cropland, orchards, vineyards, pasture lands, or hay
fields. Approximately 2.71 acres of agricultural land, consisting of active cropland, pasture lands, and
hayfields, will be temporarily altered during the construction of the pipeline loop. Because agricultural
lands within the permanent ROW will revert to existing conditions, and will continue to be used for crops,
grazing, or hay following construction, no permanent (operational) land use changes will occur.
101
The pipeline loop crosses no known organic farms. Tennessee has not identified any agricultural drain
tiles or irrigation systems along the proposed route to date. Should Tennessee identify drain tiles or
irrigation systems prior to or during construction, they will implement appropriate measures to avoid or
mitigate for any damage in consultation with the landowner and in accordance with the FERC Plan, as
adopted by the Project ECMP.
4.8.2.1.5 UPLAND FOREST

Forest/woodland includes wooded lands not used for specific commercial purposes, consisting of
deciduous and coniferous types, including both forested wetlands and uplands. The pipeline loop will
impact a total of 3.80 acres of forested uplands during construction. Of this area, approximately 2.17
acres will be permanently converted to open upland as a result of vegetation maintenance in the new
permanent easement.
4.8.2.1.6 RESIDENTIAL
The pipeline loop has been specifically routed to avoid impacts to residential properties.
4.8.2.2 HP Replacement Project

The proposed modifications to CS 261 will be sited entirely within the existing facility yard. No
permanent expansion of the facility fenceline is required to accommodate the new equipment.
Approximately 0.06 acre of a vegetated slope on this property will be permanently altered for the new
auxiliary building; however, no long-term direct or indirect impacts to the continued use of this property
as commercial/industrial land use will result from the proposed modifications.
4.8.2.3 Cumulative Impacts

The ROI for cumulative impacts to land use is the municipality in which the Projects occur. Table 2-10
summarizes the Activities that overlap the Project’s ROI and that could contribute to cumulative impacts
to land use.
Cumulative impacts would occur from similar permanent changes in land use within the municipality,
such as loss of agricultural lands or forest lands. The only permanent long-term land use impact that will
result from the Projects is the conversion of forested land to herbaceous/scrub-shrub types within the
permanent easement of the Looping Project, and easement restrictions on the expansion of certain
commercial/industrial structures within the new permanent easement. As discussed in the cumulative
impacts analysis for vegetation, Section 4.4.1.2.3, no long-term cumulative impacts to forested wetlands
are anticipated due to the requirements of the WPA, 401 WQC, and/or USACE 404 permits, which would
require appropriate mitigation. However, although efforts have been made to minimize permanent tree
clearing through co-location, the Looping Project will contribute to a cumulative impact on forested
uplands in Agawam. These cumulative impacts are typical of a region experiencing growth and urban
sprawl, such as that being experienced in Agawam and the Greater Springfield Service Territory.
102

Impact minimization measures used in commercial/industrial areas include timing of construction to
avoid peak use periods, maintaining access to businesses at all times, and expediting construction through
these areas. Tennessee will coordinate directly with affected commercial/industrial landowners on an
individual basis to further reduce potential adverse impacts.

Co-location of the proposed pipeline loop with Tennessee’s existing pipeline ROW allows for Tennessee
to minimize impacts to forest land along the pipeline route. Tennessee will follow the FERC Plan and
FERC Procedures as well as its ECMP and applicable landowner requirements to restore the construction
workspace and temporary impacts.
4.8.3.1.3 WETLANDS
Mitigation measures for work within wetlands are discussed in Section 4.2.3.3.
4.8.3.1.4 UPLAND FOREST

The primary impact minimization measure to reduce the impacts of the Projects on forestland consists of
co-location with Tennessee’s existing pipeline ROW, which will limit the extent of forest clearing
required for construction and operation of the facilities. Additionally, Tennessee has located ATWS areas
outside of forested land where possible to further reduce adverse impacts.
4.8.3.1.5 RESIDENTIAL LAND

The pipeline loop has been specifically routed to avoid direct impacts to residential properties. Where the
construction workspace comes within 50 feet of residences, Tennessee will adopt the following
provisions:
• Mature trees and landscaping within the construction work area will not be removed unless
necessary for safe operation of construction equipment, or as specified in landowner agreements;
• The edge of the construction work area will be fenced for a distance of 100 feet on either side of
the residence for safety and to ensure that construction equipment and materials remain within the
construction work area;
• All lawn areas and landscaping will be restored immediately following cleanup operations, or as
specified in landowner agreements; and
• If seasonal or other weather conditions prevent compliance with these time frames, temporary
erosion controls will be maintained and monitored until conditions allow completion of
restoration.
103

Tennessee will reduce any adverse impacts to agricultural land by implementing the FERC Plan and
FERC Procedures. Tennessee will work with landowners in these areas to ensure that proper restoration
of any impacted agricultural area occurs, including topsoil segregation, stone removal, and compliance
with reseeding specifications. Tennessee will protect active livestock pasture land during construction
through the installation of temporary fencing, the use of alternative locations to cross the construction
corridor, and/or alternate feeding arrangements, as negotiated with the landowner.
4.9 RARE OR UNIQUE FEATURES

Rare or unique features include environmental or social conditions of the Projects’ sites and its immediate
surroundings that any increase in environmental impacts, however small or gradual, may result in an
unusual or disproportionate effect on environmental resources or quality or public health. The Projects’
areas are relatively typical of the region in regards to environmental and social conditions. No rare or
unique features were identified from field surveys or desktop review of aerial photographs, MassGIS
datalayers, and other sources.
4.10 TIDELANDS
No tidelands are located in or near the Projects. The Projects are located at an inland Massachusetts site,
approximately 70 miles from the nearest coastal zone and over 74 miles from the nearest mapped area of
tidelands jurisdiction (MassGIS 2011).
104
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107
APPENDIX A
Figures
Looping Project
Existing CS 261
.
!
Hickory Street
Pipeyard
Pipeline Centerline
Line 261B Pipeline
Looping Project Limit
of Work
Compressor Station
261 Horsepower
Replacement Project
Limit of Work
Hickory Street Pipe
Yard
CHICOPEE WILBRAHAM
WESTFIELD WEST
Data Source: USGS Topo Map SPRINGFIELD
SPRINGFIELD
Figure 2-1. Massachusetts AGAWAM HAMPDEN
261 Upgrade Projects SOUTHWICK EAST
LONGMEADOW
USGS 7.5-Minute LONGMEADOW
Topographic Quadrangle SUFFIELD

GRANBY SOMERS
ENFIELD
Connecticut
¯
EAST
Hampden County, MA, Town of Agawam GRANBY
EAST WINDSOR
WINDSOR LOCKS
Hartford County, CT, Town of Suffield
0 1,000 2,000 Latitude 42.034717° N
14 Jun 2018 Feet Longitude -72.633895° W
736A
327C
250B
258B
340C 250B
731A
340B
736A
729B
729B
258B
Massachusetts
Connecticut
28A
9
9
82C
25B
82B
36B
40A
28A
25B
77C
82B
87B
.
! Station
87B
Proposed Centerline
9
Existing Pipelines
Limit of Work
Proposed Access
Roads
NRCS Soil Map Unit
CHICOPEE WILBRAHAM
Figure 4.1. Data Source: Web Soil Survey, WESTFIELD WEST
SPRINGFIELD
SPRINGFIELD
261 Upgrade Project USDA NRCS Massachusetts AGAWAM HAMPDEN
USDA NRCS Soil Map Units SOUTHWICK EAST
LONGMEADOW
Sheet 1 of 6 LONGMEADOW
SUFFIELD
GRANBY SOMERS
ENFIELD
EAST Connecticut
Hampden County, MA
¯
GRANBY
WINDSOR LOCKS EAST WINDSOR
Town of Agawam
0 150 300 Latitude 42.046761° N
08 Jun 2018 Feet
SWCA Project No.: 045687.00 Longitude -72.637315° W
. 24+00
!
250A
729B 22+00
.
! 305C
254B
305B
731A
. 20+00
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. 18+00
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258B
. 16+00
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.
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.
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327C
729B
250B
729B
.
! Station 250B
340C 258B
Proposed Centerline
Existing Pipelines
Limit of Work
Proposed Access 340B 736A
Roads
729B
NRCS Soil Map Unit 729B

736A 729B
CHICOPEE WILBRAHAM
SPRINGFIELD
SPRINGFIELD
LONGMEADOW
SUFFIELD
GRANBY SOMERS
ENFIELD
EAST Connecticut
Hampden County, MA
¯
GRANBY
Town of Agawam
0 150 300 Latitude 42.046761° N
08 Jun 2018 Feet
250C 250A
258B 729B 736A 258B
327D
.
!
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255B
.
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258B
.
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.
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.
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8A
736A
.
!
.
! Station 305C
736A 327C
Proposed Centerline
Existing Pipelines 250A

.
!
Limit of Work 729B
Proposed Access
Roads
250C
NRCS Soil Map Unit
729B .
! 254B 254D
CHICOPEE WILBRAHAM
SPRINGFIELD
SPRINGFIELD
LONGMEADOW
SUFFIELD
GRANBY SOMERS
ENFIELD
EAST Connecticut
Hampden County, MA
¯
GRANBY
Town of Agawam
0 150 300 Latitude 42.046761° N
08 Jun 2018 Feet
.
!
32A 328B
255B
731A
255B
327B .
! 731A 327B
255B 255B
.
!
.
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.
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.
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.
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.
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.
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254C
258B
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729B .
!
.
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327B
Proposed Centerline .
!
250C
Existing Pipelines
255A 254B
Limit of Work
Proposed Access .
!
Roads 255B
258B 327D
254A NRCS Soil Map Unit 255B
255B 258B 258B
CHICOPEE WILBRAHAM
SPRINGFIELD
SPRINGFIELD
LONGMEADOW
SUFFIELD
GRANBY SOMERS
ENFIELD
EAST Connecticut
Hampden County, MA
¯
GRANBY
Town of Agawam
0 150 300 Latitude 42.046761° N
08 Jun 2018 Feet
253C .
!
600
32A
254B 254A
.
! 254A
32A
254A
.
!
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.
!
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.
!
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.
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.
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600
255B
.
! 255C
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.
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.
!
.
! Station
Proposed Centerline
32A
Existing Pipelines .
! 731A
255B
Limit of Work
255B 327B
Proposed Access 731A
Roads
.
!
NRCS Soil Map Unit
736A
CHICOPEE WILBRAHAM
SPRINGFIELD
SPRINGFIELD
LONGMEADOW
SUFFIELD
GRANBY SOMERS
ENFIELD
EAST Connecticut
Hampden County, MA
¯
GRANBY
Town of Agawam
0 150 300 Latitude 42.046761° N
08 Jun 2018 Feet
254C
255B
258B 254A
254C
1
718A
275A 254B
.
!
.
!
.
!
253C
.
!
254B
254A
.
!
254A
.
! Station 32A
.
!
Proposed Centerline
Existing600
Pipelines
Limit of Work
.
!
Proposed Access
Roads
254A
NRCS Soil Map Unit
.
!
CHICOPEE WILBRAHAM
SPRINGFIELD
SPRINGFIELD
LONGMEADOW
SUFFIELD
GRANBY SOMERS
ENFIELD
EAST Connecticut
Hampden County, MA
¯
GRANBY
Town of Agawam
0 150 300 Latitude 42.046761° N
08 Jun 2018 Feet
Massachusetts
Connecticut
¯
! 25+00 LONG BROO
K ESTATE
S
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Figure 1. Minor Route WESTFIELD

WEST SPRINGFIELD
SPRINGFIELD
Variation 1
! Station
Looping
Existing Pipeline Centerline AGAWAM
Project SOUTHWICK
Agawam, MA Proposed Pipeline Centerline LONGMEADOW
Stream
¯
Wetland
Data Sources: Office of Geographic 0 25 50 100
Information (MassGIS), Tennessee
Feet
Gass Pipeline LLC
44+00
!
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40+00 SOUTH STREET

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KER LANE
SHOEMA
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WEST SPRINGFIELD
SPRINGFIELD
Variation 2
! Station
Looping
Project SOUTHWICK
Stream
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Wetland
Feet
Gass Pipeline LLC
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GOLD
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WEST SPRINGFIELD
SPRINGFIELD
Variation 3
! Station
Looping
Project SOUTHWICK
Stream
¯
Wetland
Feet
Gass Pipeline LLC
110+88
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SILVER
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Figure 4. Minor Route

WEST SPRINGFIELD
SPRINGFIELD
WESTFIELD
Variation 4
! Station
Looping
Project SOUTHWICK
Stream
¯
Wetland
Feet
Gass Pipeline LLC
APPENDIX B
FERC Plan and FERC Procedures
UPLAND EROSION CONTROL, REVEGETATION, AND
MAINTENANCE PLAN
MAY 2013 VERSION

UPLAND EROSION CONTROL, REVEGETATION, AND
MAINTENANCE PLAN
TABLE OF CONTENTS
I. APPLICABILITY ..................................................................................................................... 1
II. SUPERVISION AND INSPECTION ..................................................................................... 2
A. ENVIRONMENTAL INSPECTION ............................................................. 2
B. RESPONSIBILITIES OF ENVIRONMENTAL INSPECTORS .................. 2
III. PRECONSTRUCTION PLANNING .................................................................................... 4
A. CONSTRUCTION WORK AREAS .............................................................. 4
B. DRAIN TILE AND IRRIGATION SYSTEMS ............................................. 4
C. GRAZING DEFERMENT.............................................................................. 5
D. ROAD CROSSINGS AND ACCESS POINTS ............................................. 5
E. DISPOSAL PLANNING ................................................................................ 5
F. AGENCY COORDINATION ........................................................................ 5
G. SPILL PREVENTION AND RESPONSE PROCEDURES ......................... 6
H. RESIDENTIAL CONSTRUCTION............................................................... 6
I. WINTER CONSTRUCTION PLANS ........................................................... 6
IV. INSTALLATION ................................................................................................................... 7
A. APPROVED AREAS OF DISTURBANCE.................................................. 7
B. TOPSOIL SEGREGATION ........................................................................... 8
C. DRAIN TILES ................................................................................................. 9
D. IRRIGATION .................................................................................................. 9
E. ROAD CROSSINGS AND ACCESS POINTS ............................................. 9
F. TEMPORARY EROSION CONTROL ......................................................... 9
1. Temporary Slope Breakers .............................................................................. 9
2. Temporary Trench Plugs ............................................................................... 10
3. Sediment Barriers .......................................................................................... 10
4. Mulch ............................................................................................................. 11
V. RESTORATION ................................................................................................................... 12
A. CLEANUP ..................................................................................................... 12
B. PERMANENT EROSION CONTROL DEVICES ..................................... 13
1. Trench Breakers............................................................................................. 13
2. Permanent Slope Breakers ............................................................................ 14
C. SOIL COMPACTION MITIGATION ......................................................... 14
D. REVEGETATION ........................................................................................ 15
1. General ........................................................................................................... 15
2. Soil Additives ................................................................................................ 15
3. Seeding Requirements ................................................................................... 15
VI. OFF-ROAD VEHICLE CONTROL ................................................................................... 16
VII. POST-CONSTRUCTION ACTIVITIES AND REPORTING ......................................... 17
A. MONITORING AND MAINTENANCE .................................................... 17
B. REPORTING................................................................................................. 18
i MAY 2013 VERSION
UPLAND EROSION CONTROL, REVEGETATION,
AND MAINTENANCE PLAN (PLAN)
I. APPLICABILITY
A. The intent of this Plan is to assist project sponsors by identifying baseline mitigation
measures for minimizing erosion and enhancing revegetation. Project sponsors shall
specify in their applications for a new FERC authorization and in prior notice and
advance notice filings, any individual measures in this Plan they consider
unnecessary, technically infeasible, or unsuitable due to local conditions and fully
describe any alternative measures they would use. Project sponsors shall also explain
how those alternative measures would achieve a comparable level of mitigation.
Once a project is authorized, project sponsors can request further changes as

variances to the measures in this Plan (or the applicant’s approved plan). The
Director of the Office of Energy Projects (Director) will consider approval of
variances upon the project sponsor’s written request, if the Director agrees that a
variance:
1. provides equal or better environmental protection;
2. is necessary because a portion of this Plan is infeasible or unworkable based

on project-specific conditions; or
3. is specifically required in writing by another federal, state, or Native

American land management agency for the portion of the project on its land
or under its jurisdiction.
Sponsors of projects planned for construction under the automatic authorization

provisions in the FERC’s regulations must receive written approval for any variances
in advance of construction.
Project-related impacts on wetland and waterbody systems are addressed in the

staff’s Wetland and Waterbody Construction and Mitigation Procedures
(Procedures).
1 MAY 2013 VERSION

II. SUPERVISION AND INSPECTION
A. ENVIRONMENTAL INSPECTION
1. At least one Environmental Inspector is required for each construction spread

during construction and restoration (as defined by section V). The number
and experience of Environmental Inspectors assigned to each construction
spread shall be appropriate for the length of the construction spread and the
number/significance of resources affected.
2. Environmental Inspectors shall have peer status with all other activity
inspectors.
3. Environmental Inspectors shall have the authority to stop activities that

violate the environmental conditions of the FERC’s Orders, stipulations of
other environmental permits or approvals, or landowner easement
agreements; and to order appropriate corrective action.
B. RESPONSIBILITIES OF ENVIRONMENTAL INSPECTORS
At a minimum, the Environmental Inspector(s) shall be responsible for:
1. Inspecting construction activities for compliance with the requirements of this

Plan, the Procedures, the environmental conditions of the FERC’s Orders, the
mitigation measures proposed by the project sponsor (as approved and/or
modified by the Order), other environmental permits and approvals, and
environmental requirements in landowner easement agreements.
2. Identifying, documenting, and overseeing corrective actions, as necessary to

bring an activity back into compliance;
3. Verifying that the limits of authorized construction work areas and locations
of access roads are visibly marked before clearing, and maintained throughout
construction;
4. Verifying the location of signs and highly visible flagging marking the
boundaries of sensitive resource areas, waterbodies, wetlands, or areas with
special requirements along the construction work area;
5. Identifying erosion/sediment control and soil stabilization needs in all areas;
6. Ensuring that the design of slope breakers will not cause erosion or direct
water into sensitive environmental resource areas, including cultural resource
sites, wetlands, waterbodies, and sensitive species habitats;
2 MAY 2013 VERSION

7. Verifying that dewatering activities are properly monitored and do not result
in the deposition of sand, silt, and/or sediment into sensitive environmental
resource areas, including wetlands, waterbodies, cultural resource sites, and
sensitive species habitats; stopping dewatering activities if such deposition is
occurring and ensuring the design of the discharge is changed to prevent
reoccurrence; and verifying that dewatering structures are removed after
completion of dewatering activities;
8. Ensuring that subsoil and topsoil are tested in agricultural and residential
areas to measure compaction and determine the need for corrective action;
9. Advising the Chief Construction Inspector when environmental conditions

(such as wet weather or frozen soils) make it advisable to restrict or delay
construction activities to avoid topsoil mixing or excessive compaction;
10. Ensuring restoration of contours and topsoil;
11. Verifying that the soils imported for agricultural or residential use are
certified as free of noxious weeds and soil pests, unless otherwise approved
by the landowner;
12. Ensuring that erosion control devices are properly installed to prevent
sediment flow into sensitive environmental resource areas (e.g., wetlands,
waterbodies, cultural resource sites, and sensitive species habitats) and onto
roads, and determining the need for additional erosion control devices;
13. Inspecting and ensuring the maintenance of temporary erosion control

measures at least:
a. on a daily basis in areas of active construction or equipment

operation;
b. on a weekly basis in areas with no construction or equipment

operation; and
c. within 24 hours of each 0.5 inch of rainfall;
14. Ensuring the repair of all ineffective temporary erosion control measures
within 24 hours of identification, or as soon as conditions allow if compliance
with this time frame would result in greater environmental impacts;
15. Keeping records of compliance with the environmental conditions of the

FERC’s Orders, and the mitigation measures proposed by the project sponsor
in the application submitted to the FERC, and other federal or state
environmental permits during active construction and restoration;
3 MAY 2013 VERSION
16. Identifying areas that should be given special attention to ensure stabilization
and restoration after the construction phase; and
17. Verifying that locations for any disposal of excess construction materials for
beneficial reuse comply with section III.E.
III. PRECONSTRUCTION PLANNING
The project sponsor shall do the following before construction:
A. CONSTRUCTION WORK AREAS
1. Identify all construction work areas (e.g., construction right-of-way, extra

work space areas, pipe storage and contractor yards, borrow and disposal
areas, access roads) that would be needed for safe construction. The project
sponsor must ensure that appropriate cultural resources and biological
surveys are conducted, as determined necessary by the appropriate federal and
state agencies.
2. Project sponsors are encouraged to consider expanding any required cultural

resources and endangered species surveys in anticipation of the need for
activities outside of authorized work areas.
3. Plan construction sequencing to limit the amount and duration of open trench
sections, as necessary, to prevent excessive erosion or sediment flow into
sensitive environmental resource areas.
B. DRAIN TILE AND IRRIGATION SYSTEMS
1. Attempt to locate existing drain tiles and irrigation systems.
2. Contact landowners and local soil conservation authorities to determine the

locations of future drain tiles that are likely to be installed within 3 years of
the authorized construction.
3. Develop procedures for constructing through drain-tiled areas, maintaining

irrigation systems during construction, and repairing drain tiles and irrigation
systems after construction.
4. Engage qualified drain tile specialists, as needed to conduct or monitor

repairs to drain tile systems affected by construction. Use drain tile
specialists from the project area, if available.
4 MAY 2013 VERSION

C. GRAZING DEFERMENT
Develop grazing deferment plans with willing landowners, grazing permittees, and
land management agencies to minimize grazing disturbance of revegetation efforts.
D. ROAD CROSSINGS AND ACCESS POINTS
Plan for safe and accessible conditions at all roadway crossings and access points
during construction and restoration.
E. DISPOSAL PLANNING
Determine methods and locations for the regular collection, containment, and
disposal of excess construction materials and debris (e.g., timber, slash, mats,
garbage, drill cuttings and fluids, excess rock) throughout the construction process.
Disposal of materials for beneficial reuse must not result in adverse environmental
impact and is subject to compliance with all applicable survey, landowner or land
management agency approval, and permit requirements.
F. AGENCY COORDINATION
The project sponsor must coordinate with the appropriate local, state, and federal
agencies as outlined in this Plan and/or required by the FERC’s Orders.
1. Obtain written recommendations from the local soil conservation authorities

or land management agencies regarding permanent erosion control and
revegetation specifications.
2. Develop specific procedures in coordination with the appropriate agencies to

prevent the introduction or spread of invasive species, noxious weeds, and
soil pests resulting from construction and restoration activities.
3. Develop specific procedures in coordination with the appropriate agencies

and landowners, as necessary, to allow for livestock and wildlife movement
and protection during construction.
4. Develop specific blasting procedures in coordination with the appropriate

agencies that address pre- and post-blast inspections; advanced public
notification; and mitigation measures for building foundations, groundwater
wells, and springs. Use appropriate methods (e.g., blasting mats) to prevent
damage to nearby structures and to prevent debris from entering sensitive
environmental resource areas.
5 MAY 2013 VERSION

G. SPILL PREVENTION AND RESPONSE PROCEDURES
The project sponsor shall develop project-specific Spill Prevention and Response
Procedures, as specified in section IV of the staff's Procedures. A copy must be filed
with the Secretary of the FERC (Secretary) prior to construction and made available
in the field on each construction spread. The filing requirement does not apply to
projects constructed under the automatic authorization provisions in the FERC’s
regulations.
H. RESIDENTIAL CONSTRUCTION
For all properties with residences located within 50 feet of construction work areas,
project sponsors shall: avoid removal of mature trees and landscaping within the
construction work area unless necessary for safe operation of construction
equipment, or as specified in landowner agreements; fence the edge of the
construction work area for a distance of 100 feet on either side of the residence; and
restore all lawn areas and landscaping immediately following clean up operations, or
as specified in landowner agreements. If seasonal or other weather conditions
prevent compliance with these time frames, maintain and monitor temporary erosion
controls (sediment barriers and mulch) until conditions allow completion of
restoration.
I. WINTER CONSTRUCTION PLANS
If construction is planned to occur during winter weather conditions, project sponsors

shall develop and file a project-specific winter construction plan with the FERC
application. This filing requirement does not apply to projects constructed under the
automatic authorization provisions of the FERC’s regulations.
The plan shall address:
1. winter construction procedures (e.g., snow handling and removal, access road
construction and maintenance, soil handling under saturated or frozen
conditions, topsoil stripping);
2. stabilization and monitoring procedures if ground conditions will delay

restoration until the following spring (e.g., mulching and erosion controls,
inspection and reporting, stormwater control during spring thaw conditions);
and
3. final restoration procedures (e.g., subsidence and compaction repair, topsoil

replacement, seeding).
6 MAY 2013 VERSION

IV. INSTALLATION
A. APPROVED AREAS OF DISTURBANCE
1. Project-related ground disturbance shall be limited to the construction right-

of-way, extra work space areas, pipe storage yards, borrow and disposal areas,
access roads, and other areas approved in the FERC’s Orders. Any project-
related ground disturbing activities outside these areas will require prior
Director approval. This requirement does not apply to activities needed to
comply with the Plan and Procedures (i.e., slope breakers, energy-dissipating
devices, dewatering structures, drain tile system repairs) or minor field
realignments and workspace shifts per landowner needs and requirements that
do not affect other landowners or sensitive environmental resource areas. All
construction or restoration activities outside of authorized areas are subject to
all applicable survey and permit requirements, and landowner easement
agreements.
2. The construction right-of-way width for a project shall not exceed 75 feet or
that described in the FERC application unless otherwise modified by a FERC
Order. However, in limited, non-wetland areas, this construction right-of-
way width may be expanded by up to 25 feet without Director approval to
accommodate full construction right-of-way topsoil segregation and to ensure
safe construction where topographic conditions (e.g., side-slopes) or soil
limitations require it. Twenty-five feet of extra construction right-of-way
width may also be used in limited, non-wetland or non-forested areas for
truck turn-arounds where no reasonable alternative access exists.
Project use of these additional limited areas is subject to landowner or land

management agency approval and compliance with all applicable survey and
permit requirements. When additional areas are used, each one shall be
identified and the need explained in the weekly or biweekly construction
reports to the FERC, if required. The following material shall be included in
the reports:
a. the location of each additional area by station number and reference to

previously filed alignment sheets, or updated alignment sheets
showing the additional areas;
b. identification of the filing at FERC containing evidence that the

additional areas were previously surveyed; and
7 MAY 2013 VERSION

c. a statement that landowner approval has been obtained and is
available in project files.
Prior written approval of the Director is required when the authorized

construction right-of-way width would be expanded by more than 25 feet.
B. TOPSOIL SEGREGATION
1. Unless the landowner or land management agency specifically approves

otherwise, prevent the mixing of topsoil with subsoil by stripping topsoil
from either the full work area or from the trench and subsoil storage area
(ditch plus spoil side method) in:
a. cultivated or rotated croplands, and managed pastures;
b. residential areas;
c. hayfields; and
d. other areas at the landowner’s or land managing agency’s request.
2. In residential areas, importation of topsoil is an acceptable alternative to

topsoil segregation.
3. Where topsoil segregation is required, the project sponsor must:
a. segregate at least 12 inches of topsoil in deep soils (more than 12

inches of topsoil); and
b. make every effort to segregate the entire topsoil layer in soils with less
than 12 inches of topsoil.
4. Maintain separation of salvaged topsoil and subsoil throughout all

construction activities.
5. Segregated topsoil may not be used for padding the pipe, constructing
temporary slope breakers or trench plugs, improving or maintaining roads, or
as a fill material.
6. Stabilize topsoil piles and minimize loss due to wind and water erosion with
use of sediment barriers, mulch, temporary seeding, tackifiers, or functional
equivalents, where necessary.
8 MAY 2013 VERSION

C. DRAIN TILES
1. Mark locations of drain tiles damaged during construction.
2. Probe all drainage tile systems within the area of disturbance to check for
damage.
3. Repair damaged drain tiles to their original or better condition. Do not use
filter-covered drain tiles unless the local soil conservation authorities and the
landowner agree. Use qualified specialists for testing and repairs.
4. For new pipelines in areas where drain tiles exist or are planned, ensure that
the depth of cover over the pipeline is sufficient to avoid interference with
drain tile systems. For adjacent pipeline loops in agricultural areas, install the
new pipeline with at least the same depth of cover as the existing pipeline(s).
D. IRRIGATION
Maintain water flow in crop irrigation systems, unless shutoff is coordinated with
affected parties.
E. ROAD CROSSINGS AND ACCESS POINTS
1. Maintain safe and accessible conditions at all road crossings and access
points during construction.
2. If crushed stone access pads are used in residential or agricultural areas, place
the stone on synthetic fabric to facilitate removal.
3. Minimize the use of tracked equipment on public roadways. Remove any soil
or gravel spilled or tracked onto roadways daily or more frequent as necessary
to maintain safe road conditions. Repair any damages to roadway surfaces,
shoulders, and bar ditches.
F. TEMPORARY EROSION CONTROL
Install temporary erosion controls immediately after initial disturbance of the soil.
Temporary erosion controls must be properly maintained throughout construction (on
a daily basis) and reinstalled as necessary (such as after backfilling of the trench)
until replaced by permanent erosion controls or restoration is complete.
1. Temporary Slope Breakers
a. Temporary slope breakers are intended to reduce runoff velocity and

divert water off the construction right-of-way. Temporary slope
9 MAY 2013 VERSION
breakers may be constructed of materials such as soil, silt fence,
staked hay or straw bales, or sand bags.
b. Install temporary slope breakers on all disturbed areas, as necessary to

avoid excessive erosion. Temporary slope breakers must be installed
on slopes greater than 5 percent where the base of the slope is less
than 50 feet from waterbody, wetland, and road crossings at the
following spacing (closer spacing shall be used if necessary):
Slope (%) Spacing (feet)

5 - 15 300
>15 - 30 200
>30 100
c. Direct the outfall of each temporary slope breaker to a stable, well

vegetated area or construct an energy-dissipating device at the end of
the slope breaker and off the construction right-of-way.
d. Position the outfall of each temporary slope breaker to prevent

sediment discharge into wetlands, waterbodies, or other sensitive
environmental resource areas.
2. Temporary Trench Plugs
Temporary trench plugs are intended to segment a continuous open trench

prior to backfill.
a. Temporary trench plugs may consist of unexcavated portions of the

trench, compacted subsoil, sandbags, or some functional equivalent.
b. Position temporary trench plugs, as necessary, to reduce trenchline

erosion and minimize the volume and velocity of trench water flow at
the base of slopes.
3. Sediment Barriers
Sediment barriers are intended to stop the flow of sediments and to prevent
the deposition of sediments beyond approved workspaces or into sensitive
resources.
a. Sediment barriers may be constructed of materials such as silt fence,

staked hay or straw bales, compacted earth (e.g., driveable berms
across travelways), sand bags, or other appropriate materials.
10 MAY 2013 VERSION

b. At a minimum, install and maintain temporary sediment barriers
across the entire construction right-of-way at the base of slopes greater
than 5 percent where the base of the slope is less than 50 feet from a
waterbody, wetland, or road crossing until revegetation is successful
as defined in this Plan. Leave adequate room between the base of the
slope and the sediment barrier to accommodate ponding of water and
sediment deposition.
c. Where wetlands or waterbodies are adjacent to and downslope of

construction work areas, install sediment barriers along the edge of
these areas, as necessary to prevent sediment flow into the wetland or
waterbody.
4. Mulch
a. Apply mulch on all slopes (except in cultivated cropland) concurrent

with or immediately after seeding, where necessary to stabilize the soil
surface and to reduce wind and water erosion. Spread mulch
uniformly over the area to cover at least 75 percent of the ground
surface at a rate of 2 tons/acre of straw or its equivalent, unless the
local soil conservation authority, landowner, or land managing agency
approves otherwise in writing.
b. Mulch can consist of weed-free straw or hay, wood fiber hydromulch,

erosion control fabric, or some functional equivalent.
c. Mulch all disturbed upland areas (except cultivated cropland) before

seeding if:
(1) final grading and installation of permanent erosion control

measures will not be completed in an area within 20 days after
the trench in that area is backfilled (10 days in residential
areas), as required in section V.A.1; or
(2) construction or restoration activity is interrupted for extended

periods, such as when seeding cannot be completed due to
seeding period restrictions.
d. If mulching before seeding, increase mulch application on all slopes

within 100 feet of waterbodies and wetlands to a rate of 3 tons/acre of
straw or equivalent.
e. If wood chips are used as mulch, do not use more than 1 ton/acre and
add the equivalent of 11 lbs/acre available nitrogen (at least 50 percent
of which is slow release).
11 MAY 2013 VERSION
f. Ensure that mulch is adequately anchored to minimize loss due to
wind and water.
g. When anchoring with liquid mulch binders, use rates recommended by

the manufacturer. Do not use liquid mulch binders within 100 feet of
wetlands or waterbodies, except where the product is certified
environmentally non-toxic by the appropriate state or federal agency
or independent standards-setting organization.
h. Do not use synthetic monofilament mesh/netted erosion control

materials in areas designated as sensitive wildlife habitat, unless the
product is specifically designed to minimize harm to wildlife. Anchor
erosion control fabric with staples or other appropriate devices.
V. RESTORATION
A. CLEANUP
1. Commence cleanup operations immediately following backfill operations.

Complete final grading, topsoil replacement, and installation of permanent
erosion control structures within 20 days after backfilling the trench (10 days
in residential areas). If seasonal or other weather conditions prevent
compliance with these time frames, maintain temporary erosion controls (i.e.,
temporary slope breakers, sediment barriers, and mulch) until conditions
allow completion of cleanup.
If construction or restoration unexpectedly continues into the winter season

when conditions could delay successful decompaction, topsoil replacement,
or seeding until the following spring, file with the Secretary for the review
and written approval of the Director, a winter construction plan (as specified
in section III.I). This filing requirement does not apply to projects constructed
under the automatic authorization provisions of the FERC’s regulations.
2. A travel lane may be left open temporarily to allow access by construction

traffic if the temporary erosion control structures are installed as specified in
section IV.F. and inspected and maintained as specified in sections II.B.12
through 14. When access is no longer required the travel lane must be
removed and the right-of-way restored.
3. Rock excavated from the trench may be used to backfill the trench only to the
top of the existing bedrock profile. Rock that is not returned to the trench
shall be considered construction debris, unless approved for use as mulch or
for some other use on the construction work areas by the landowner or land
managing agency.
12 MAY 2013 VERSION
4. Remove excess rock from at least the top 12 inches of soil in all cultivated or
rotated cropland, managed pastures, hayfields, and residential areas, as well as
other areas at the landowner’s request. The size, density, and distribution of
rock on the construction work area shall be similar to adjacent areas not
disturbed by construction. The landowner or land management agency may
approve other provisions in writing.
5. Grade the construction right-of-way to restore pre-construction contours and

leave the soil in the proper condition for planting.
6. Remove construction debris from all construction work areas unless the
landowner or land managing agency approves leaving materials onsite for
beneficial reuse, stabilization, or habitat restoration.
7. Remove temporary sediment barriers when replaced by permanent erosion

control measures or when revegetation is successful.
B. PERMANENT EROSION CONTROL DEVICES
1. Trench Breakers
a. Trench breakers are intended to slow the flow of subsurface water

along the trench. Trench breakers may be constructed of materials
such as sand bags or polyurethane foam. Do not use topsoil in trench
breakers.
b. An engineer or similarly qualified professional shall determine the

need for and spacing of trench breakers. Otherwise, trench breakers
shall be installed at the same spacing as and upslope of permanent
slope breakers.
c. In agricultural fields and residential areas where slope breakers are not
typically required, install trench breakers at the same spacing as if
permanent slope breakers were required.
d. At a minimum, install a trench breaker at the base of slopes greater

than 5 percent where the base of the slope is less than 50 feet from a
waterbody or wetland and where needed to avoid draining a waterbody
or wetland. Install trench breakers at wetland boundaries, as specified
in the Procedures. Do not install trench breakers within a wetland.
13 MAY 2013 VERSION

2. Permanent Slope Breakers
a. Permanent slope breakers are intended to reduce runoff velocity,

divert water off the construction right-of-way, and prevent sediment
deposition into sensitive resources. Permanent slope breakers may be
constructed of materials such as soil, stone, or some functional
equivalent.
b. Construct and maintain permanent slope breakers in all areas, except

cultivated areas and lawns, unless requested by the landowner, using
spacing recommendations obtained from the local soil conservation
authority or land managing agency.
In the absence of written recommendations, use the following spacing

unless closer spacing is necessary to avoid excessive erosion on the
construction right-of-way:
Slope (%) Spacing (feet)

5 - 15 300
>15 - 30 200
>30 100
c. Construct slope breakers to divert surface flow to a stable area without

causing water to pool or erode behind the breaker. In the absence of a
stable area, construct appropriate energy-dissipating devices at the end
of the breaker.
d. Slope breakers may extend slightly (about 4 feet) beyond the edge of
the construction right-of-way to effectively drain water off the
disturbed area. Where slope breakers extend beyond the edge of the
construction right-of-way, they are subject to compliance with all
applicable survey requirements.
C. SOIL COMPACTION MITIGATION
1. Test topsoil and subsoil for compaction at regular intervals in agricultural and
residential areas disturbed by construction activities. Conduct tests on the
same soil type under similar moisture conditions in undisturbed areas to
approximate preconstruction conditions. Use penetrometers or other
appropriate devices to conduct tests.
2. Plow severely compacted agricultural areas with a paraplow or other deep

tillage implement. In areas where topsoil has been segregated, plow the
subsoil before replacing the segregated topsoil.
14 MAY 2013 VERSION

If subsequent construction and cleanup activities result in further compaction,
conduct additional tilling.
3. Perform appropriate soil compaction mitigation in severely compacted

residential areas.
D. REVEGETATION
1. General
a. The project sponsor is responsible for ensuring successful revegetation

of soils disturbed by project-related activities, except as noted in
section V.D.1.b.
b. Restore all turf, ornamental shrubs, and specialized landscaping in

accordance with the landowner’s request, or compensate the
landowner. Restoration work must be performed by personnel
familiar with local horticultural and turf establishment practices.
2. Soil Additives
Fertilize and add soil pH modifiers in accordance with written

recommendations obtained from the local soil conservation authority, land
management agencies, or landowner. Incorporate recommended soil pH
modifier and fertilizer into the top 2 inches of soil as soon as practicable after
application.
3. Seeding Requirements
a. Prepare a seedbed in disturbed areas to a depth of 3 to 4 inches using

appropriate equipment to provide a firm seedbed. When
hydroseeding, scarify the seedbed to facilitate lodging and germination
of seed.
b. Seed disturbed areas in accordance with written recommendations for

seed mixes, rates, and dates obtained from the local soil conservation
authority or the request of the landowner or land management agency.
Seeding is not required in cultivated croplands unless requested by the
landowner.
c. Perform seeding of permanent vegetation within the recommended

seeding dates. If seeding cannot be done within those dates, use
appropriate temporary erosion control measures discussed in section
IV.F and perform seeding of permanent vegetation at the beginning of
the next recommended seeding season. Dormant seeding or temporary
15 MAY 2013 VERSION
seeding of annual species may also be used, if necessary, to establish
cover, as approved by the Environmental Inspector. Lawns may be
seeded on a schedule established with the landowner.
d. In the absence of written recommendations from the local soil

conservation authorities, seed all disturbed soils within 6 working
days of final grading, weather and soil conditions permitting, subject
to the specifications in section V.D.3.a through V.D.3.c.
e. Base seeding rates on Pure Live Seed. Use seed within 12 months of
seed testing.
f. Treat legume seed with an inoculant specific to the species using the
manufacturer’s recommended rate of inoculant appropriate for the
seeding method (broadcast, drill, or hydro).
g. In the absence of written recommendations from the local soil

conservation authorities, landowner, or land managing agency to the
contrary, a seed drill equipped with a cultipacker is preferred for seed
application.
Broadcast or hydroseeding can be used in lieu of drilling at double the

recommended seeding rates. Where seed is broadcast, firm the
seedbed with a cultipacker or roller after seeding. In rocky soils or
where site conditions may limit the effectiveness of this equipment,
other alternatives may be appropriate (e.g., use of a chain drag) to
lightly cover seed after application, as approved by the Environmental
Inspector.
VI. OFF-ROAD VEHICLE CONTROL
To each owner or manager of forested lands, offer to install and maintain measures to
control unauthorized vehicle access to the right-of-way. These measures may include:
A. signs;
B. fences with locking gates;
C. slash and timber barriers, pipe barriers, or a line of boulders across the right-of-way;
and
D. conifers or other appropriate trees or shrubs across the right-of-way.
16 MAY 2013 VERSION

VII. POST-CONSTRUCTION ACTIVITIES AND REPORTING
A. MONITORING AND MAINTENANCE
1. Conduct follow-up inspections of all disturbed areas, as necessary, to

determine the success of revegetation and address landowner concerns. At a
minimum, conduct inspections after the first and second growing seasons.
2. Revegetation in non-agricultural areas shall be considered successful if upon

visual survey the density and cover of non-nuisance vegetation are similar in
density and cover to adjacent undisturbed lands. In agricultural areas,
revegetation shall be considered successful when upon visual survey, crop
growth and vigor are similar to adjacent undisturbed portions of the same
field, unless the easement agreement specifies otherwise.
Continue revegetation efforts until revegetation is successful.
3. Monitor and correct problems with drainage and irrigation systems resulting
from pipeline construction in agricultural areas until restoration is successful.
4. Restoration shall be considered successful if the right-of-way surface

condition is similar to adjacent undisturbed lands, construction debris is
removed (unless otherwise approved by the landowner or land managing
agency per section V.A.6), revegetation is successful, and proper drainage has
been restored.
5. Routine vegetation mowing or clearing over the full width of the permanent
right-of-way in uplands shall not be done more frequently than every 3 years.
However, to facilitate periodic corrosion/leak surveys, a corridor not
exceeding 10 feet in width centered on the pipeline may be cleared at a
frequency necessary to maintain the 10-foot corridor in an herbaceous state.
In no case shall routine vegetation mowing or clearing occur during the
migratory bird nesting season between April 15 and August 1 of any year
unless specifically approved in writing by the responsible land management
agency or the U.S. Fish and Wildlife Service.
6. Efforts to control unauthorized off-road vehicle use, in cooperation with the

landowner, shall continue throughout the life of the project. Maintain signs,
gates, and permanent access roads as necessary.
17 MAY 2013 VERSION

B. REPORTING
1. The project sponsor shall maintain records that identify by milepost:
a. method of application, application rate, and type of fertilizer, pH

modifying agent, seed, and mulch used;
b. acreage treated;
c. dates of backfilling and seeding;
d. names of landowners requesting special seeding treatment and a

description of the follow-up actions;
e. the location of any subsurface drainage repairs or improvements made

during restoration; and
f. any problem areas and how they were addressed.
2. The project sponsor shall file with the Secretary quarterly activity reports
documenting the results of follow-up inspections required by section VII.A.1;
any problem areas, including those identified by the landowner; and
corrective actions taken for at least 2 years following construction.
The requirement to file quarterly activity reports with the Secretary does not
apply to projects constructed under the automatic authorization, prior notice,
or advanced notice provisions in the FERC’s regulations.
18 MAY 2013 VERSION

WETLAND AND WATERBODY CONSTRUCTION AND
MITIGATION PROCEDURES
MAY 2013 VERSION

WETLAND AND WATERBODY CONSTRUCTION AND
MITIGATION PROCEDURES
TABLE OF CONTENTS
I. APPLICABILITY ................................................................................................................ 1
II. PRECONSTRUCTION FILING ......................................................................................... 2
III. ENVIRONMENTAL INSPECTORS ................................................................................. 3
IV. PRECONSTRUCTION PLANNING ................................................................................. 3
V. WATERBODY CROSSINGS ............................................................................................ 5

A. NOTIFICATION PROCEDURES AND PERMITS ........................................... 5
B. INSTALLATION .................................................................................................. 5
1. Time Window for Construction ............................................................................ 5
2. Extra Work Areas .................................................................................................. 5
3. General Crossing Procedures ................................................................................ 6
4. Spoil Pile Placement and Control ......................................................................... 7
5. Equipment Bridges ................................................................................................ 7
6. Dry-Ditch Crossing Methods ................................................................................ 8
7. Crossings of Minor Waterbodies .......................................................................... 9
8. Crossings of Intermediate Waterbodies .............................................................. 10
9. Crossings of Major Waterbodies ........................................................................ 10
10. Temporary Erosion and Sediment Control ......................................................... 10
11. Trench Dewatering .............................................................................................. 11
C. RESTORATION ................................................................................................. 11
D. POST-CONSTRUCTION MAINTENANCE.................................................... 12
VI. WETLAND CROSSINGS ................................................................................................ 13

A. GENERAL .......................................................................................................... 13
B. INSTALLATION ................................................................................................ 14
1. Extra Work Areas and Access Roads ................................................................. 14
2. Crossing Procedures ............................................................................................ 15
3. Temporary Sediment Control.............................................................................. 16
4. Trench Dewatering .............................................................................................. 17
C. RESTORATION ................................................................................................. 17
D. POST-CONSTRUCTION MAINTENANCE AND REPORTING .................. 18
VII. HYDROSTATIC TESTING ............................................................................................. 19

A. NOTIFICATION PROCEDURES AND PERMITS ......................................... 19
B. GENERAL .......................................................................................................... 19
C. INTAKE SOURCE AND RATE........................................................................ 19
D. DISCHARGE LOCATION, METHOD, AND RATE ...................................... 20
i MAY 2013 VERSION

WETLAND AND WATERBODY
CONSTRUCTION AND MITIGATION PROCEDURES (PROCEDURES)
I. APPLICABILITY
A. The intent of these Procedures is to assist project sponsors by identifying baseline

mitigation measures for minimizing the extent and duration of project-related
disturbance on wetlands and waterbodies. Project sponsors shall specify in their
applications for a new FERC authorization, and in prior notice and advance notice
filings, any individual measures in these Procedures they consider unnecessary,
technically infeasible, or unsuitable due to local conditions and fully describe any
alternative measures they would use. Project sponsors shall also explain how those
alternative measures would achieve a comparable level of mitigation.
Once a project is authorized, project sponsors can request further changes as

variances to the measures in these Procedures (or the applicant’s approved
procedures). The Director of the Office of Energy Projects (Director) will consider
approval of variances upon the project sponsor’s written request, if the Director
agrees that a variance:
1. provides equal or better environmental protection;
2. is necessary because a portion of these Procedures is infeasible or unworkable

based on project-specific conditions; or
3. is specifically required in writing by another federal, state, or Native

American land management agency for the portion of the project on its land
or under its jurisdiction.
Sponsors of projects planned for construction under the automatic authorization

provisions in the FERC’s regulations must receive written approval for any variances
in advance of construction.
Project-related impacts on non-wetland areas are addressed in the staff’s Upland

Erosion Control, Revegetation, and Maintenance Plan (Plan).
1 MAY 2013 VERSION

B. DEFINITIONS
1. “Waterbody” includes any natural or artificial stream, river, or drainage with

perceptible flow at the time of crossing, and other permanent waterbodies
such as ponds and lakes:
a. “minor waterbody” includes all waterbodies less than or equal to 10

feet wide at the water’s edge at the time of crossing;
b. “intermediate waterbody” includes all waterbodies greater than 10 feet

wide but less than or equal to 100 feet wide at the water’s edge at the
time of crossing; and
c. “major waterbody” includes all waterbodies greater than 100 feet wide
at the water’s edge at the time of crossing.
2. “Wetland” includes any area that is not in actively cultivated or rotated

cropland and that satisfies the requirements of the current federal
methodology for identifying and delineating wetlands.
II. PRECONSTRUCTION FILING
A. The following information must be filed with the Secretary of the FERC (Secretary)
prior to the beginning of construction, for the review and written approval by the
Director:
1. site-specific justifications for extra work areas that would be closer than 50
feet from a waterbody or wetland; and
2. site-specific justifications for the use of a construction right-of-way greater

than 75-feet-wide in wetlands.
B. The following information must be filed with the Secretary prior to the beginning of
construction. These filing requirements do not apply to projects constructed under
the automatic authorization provisions in the FERC’s regulations:
1. Spill Prevention and Response Procedures specified in section IV.A;
2. a schedule identifying when trenching or blasting will occur within each

waterbody greater than 10 feet wide, within any designated coldwater fishery,
and within any waterbody identified as habitat for federally-listed threatened
or endangered species. The project sponsor will revise the schedule as
necessary to provide FERC staff at least 14 days advance notice. Changes
within this last 14-day period must provide for at least 48 hours advance
notice;
2 MAY 2013 VERSION

3. plans for horizontal directional drills (HDD) under wetlands or waterbodies,
specified in section V.B.6.d;
4. site-specific plans for major waterbody crossings, described in section V.B.9;
5. a wetland delineation report as described in section VI.A.1, if applicable; and
6. the hydrostatic testing information specified in section VII.B.3.
III. ENVIRONMENTAL INSPECTORS
A. At least one Environmental Inspector having knowledge of the wetland and

waterbody conditions in the project area is required for each construction spread.
The number and experience of Environmental Inspectors assigned to each
construction spread shall be appropriate for the length of the construction spread and
the number/significance of resources affected.
B. The Environmental Inspector’s responsibilities are outlined in the Upland Erosion

Control, Revegetation, and Maintenance Plan (Plan).
IV. PRECONSTRUCTION PLANNING
A. The project sponsor shall develop project-specific Spill Prevention and Response
Procedures that meet applicable requirements of state and federal agencies. A copy
must be filed with the Secretary prior to construction and made available in the field
on each construction spread. This filing requirement does not apply to projects
constructed under the automatic authorization provisions in the FERC’s regulations.
1. It shall be the responsibility of the project sponsor and its contractors to

structure their operations in a manner that reduces the risk of spills or the
accidental exposure of fuels or hazardous materials to waterbodies or
wetlands. The project sponsor and its contractors must, at a minimum, ensure
that:
a. all employees handling fuels and other hazardous materials are

properly trained;
b. all equipment is in good operating order and inspected on a regular

basis;
c. fuel trucks transporting fuel to on-site equipment travel only on

approved access roads;
d. all equipment is parked overnight and/or fueled at least 100 feet from
a waterbody or in an upland area at least 100 feet from a wetland
boundary. These activities can occur closer only if the Environmental
Inspector determines that there is no reasonable alternative, and the
3 MAY 2013 VERSION

project sponsor and its contractors have taken appropriate steps
(including secondary containment structures) to prevent spills and
provide for prompt cleanup in the event of a spill;
e. hazardous materials, including chemicals, fuels, and lubricating oils,

are not stored within 100 feet of a wetland, waterbody, or designated
municipal watershed area, unless the location is designated for such
use by an appropriate governmental authority. This applies to storage
of these materials and does not apply to normal operation or use of
equipment in these areas;
f. concrete coating activities are not performed within 100 feet of a

wetland or waterbody boundary, unless the location is an existing
industrial site designated for such use. These activities can occur
closer only if the Environmental Inspector determines that there is no
reasonable alternative, and the project sponsor and its contractors
have taken appropriate steps (including secondary containment
structures) to prevent spills and provide for prompt cleanup in the
event of a spill;
g. pumps operating within 100 feet of a waterbody or wetland boundary

utilize appropriate secondary containment systems to prevent spills;
and
h. bulk storage of hazardous materials, including chemicals, fuels, and

lubricating oils have appropriate secondary containment systems to
prevent spills.
2. The project sponsor and its contractors must structure their operations in a
manner that provides for the prompt and effective cleanup of spills of fuel
and other hazardous materials. At a minimum, the project sponsor and its
contractors must:
a. ensure that each construction crew (including cleanup crews) has on

hand sufficient supplies of absorbent and barrier materials to allow the
rapid containment and recovery of spilled materials and knows the
procedure for reporting spills and unanticipated discoveries of
contamination;
b. ensure that each construction crew has on hand sufficient tools and
material to stop leaks;
c. know the contact names and telephone numbers for all local, state,
and federal agencies (including, if necessary, the U. S. Coast Guard
and the National Response Center) that must be notified of a spill; and
4 MAY 2013 VERSION

d. follow the requirements of those agencies in cleaning up the spill, in
excavating and disposing of soils or other materials contaminated by a
spill, and in collecting and disposing of waste generated during spill
cleanup.
B. AGENCY COORDINATION
The project sponsor must coordinate with the appropriate local, state, and federal
agencies as outlined in these Procedures and in the FERC’s Orders.
V. WATERBODY CROSSINGS
A. NOTIFICATION PROCEDURES AND PERMITS
1. Apply to the U.S. Army Corps of Engineers (COE), or its delegated agency,
for the appropriate wetland and waterbody crossing permits.
2. Provide written notification to authorities responsible for potable surface

water supply intakes located within 3 miles downstream of the crossing at
least 1 week before beginning work in the waterbody, or as otherwise
specified by that authority.
3. Apply for state-issued waterbody crossing permits and obtain individual or

generic section 401 water quality certification or waiver.
4. Notify appropriate federal and state authorities at least 48 hours before

beginning trenching or blasting within the waterbody, or as specified in
applicable permits.
B. INSTALLATION
1. Time Window for Construction
Unless expressly permitted or further restricted by the appropriate federal or

state agency in writing on a site-specific basis, instream work, except that
required to install or remove equipment bridges, must occur during the
following time windows:
a. coldwater fisheries - June 1 through September 30; and
b. coolwater and warmwater fisheries - June 1 through November 30.
2. Extra Work Areas
a. Locate all extra work areas (such as staging areas and additional spoil
storage areas) at least 50 feet away from water’s edge, except where
5 MAY 2013 VERSION

the adjacent upland consists of cultivated or rotated cropland or other
disturbed land.
b. The project sponsor shall file with the Secretary for review and
written approval by the Director, site-specific justification for each
extra work area with a less than 50-foot setback from the water’s
edge, except where the adjacent upland consists of cultivated or
rotated cropland or other disturbed land. The justification must
specify the conditions that will not permit a 50-foot setback and
measures to ensure the waterbody is adequately protected.
c. Limit the size of extra work areas to the minimum needed to construct
the waterbody crossing.
3. General Crossing Procedures
a. Comply with the COE, or its delegated agency, permit terms and
conditions.
b. Construct crossings as close to perpendicular to the axis of the

waterbody channel as engineering and routing conditions permit.
c. Where pipelines parallel a waterbody, maintain at least 15 feet of

undisturbed vegetation between the waterbody (and any adjacent
wetland) and the construction right-of-way, except where maintaining
this offset will result in greater environmental impact.
d. Where waterbodies meander or have multiple channels, route the

pipeline to minimize the number of waterbody crossings.
e. Maintain adequate waterbody flow rates to protect aquatic life, and

prevent the interruption of existing downstream uses.
f. Waterbody buffers (e.g., extra work area setbacks, refueling

restrictions) must be clearly marked in the field with signs and/or
highly visible flagging until construction-related ground disturbing
activities are complete.
g. Crossing of waterbodies when they are dry or frozen and not flowing
may proceed using standard upland construction techniques in
accordance with the Plan, provided that the Environmental Inspector
verifies that water is unlikely to flow between initial disturbance and
final stabilization of the feature. In the event of perceptible flow, the
project sponsor must comply with all applicable Procedure
requirements for “waterbodies” as defined in section I.B.1.
6 MAY 2013 VERSION

4. Spoil Pile Placement and Control
a. All spoil from minor and intermediate waterbody crossings, and

upland spoil from major waterbody crossings, must be placed in the
construction right-of-way at least 10 feet from the water’s edge or in
additional extra work areas as described in section V.B.2.
b. Use sediment barriers to prevent the flow of spoil or silt-laden water

into any waterbody.
5. Equipment Bridges
a. Only clearing equipment and equipment necessary for installation of

equipment bridges may cross waterbodies prior to bridge installation.
Limit the number of such crossings of each waterbody to one per
piece of clearing equipment.
b. Construct and maintain equipment bridges to allow unrestricted flow

and to prevent soil from entering the waterbody. Examples of such
bridges include:
(1) equipment pads and culvert(s);

(2) equipment pads or railroad car bridges without culverts;
(3) clean rock fill and culvert(s); and
(4) flexi-float or portable bridges.
Additional options for equipment bridges may be utilized that achieve

the performance objectives noted above. Do not use soil to construct
or stabilize equipment bridges.
c. Design and maintain each equipment bridge to withstand and pass the
highest flow expected to occur while the bridge is in place. Align
culverts to prevent bank erosion or streambed scour. If necessary,
install energy dissipating devices downstream of the culverts.
d. Design and maintain equipment bridges to prevent soil from entering

the waterbody.
e. Remove temporary equipment bridges as soon as practicable after

permanent seeding.
f. If there will be more than 1 month between final cleanup and the
beginning of permanent seeding and reasonable alternative access to
the right-of-way is available, remove temporary equipment bridges as
soon as practicable after final cleanup.
7 MAY 2013 VERSION

g. Obtain any necessary approval from the COE, or the appropriate state
agency for permanent bridges.
6. Dry-Ditch Crossing Methods
a. Unless approved otherwise by the appropriate federal or state agency,

install the pipeline using one of the dry-ditch methods outlined below
for crossings of waterbodies up to 30 feet wide (at the water’s edge at
the time of construction) that are state-designated as either coldwater
or significant coolwater or warmwater fisheries, or federally-
designated as critical habitat.
b. Dam and Pump
(1) The dam-and-pump method may be used without prior

approval for crossings of waterbodies where pumps can
adequately transfer streamflow volumes around the work area,
and there are no concerns about sensitive species passage.
(2) Implementation of the dam-and-pump crossing method must

meet the following performance criteria:
(i) use sufficient pumps, including on-site backup pumps,

to maintain downstream flows;
(ii) construct dams with materials that prevent sediment
and other pollutants from entering the waterbody (e.g.,
sandbags or clean gravel with plastic liner);
(iii) screen pump intakes to minimize entrainment of fish;
(iv) prevent streambed scour at pump discharge; and
(v) continuously monitor the dam and pumps to ensure
proper operation throughout the waterbody crossing.
c. Flume Crossing
The flume crossing method requires implementation of the following

steps:
(1) install flume pipe after blasting (if necessary), but before any
trenching;
(2) use sand bag or sand bag and plastic sheeting diversion
structure or equivalent to develop an effective seal and to
divert stream flow through the flume pipe (some modifications
to the stream bottom may be required to achieve an effective
seal);
8 MAY 2013 VERSION

(3) properly align flume pipe(s) to prevent bank erosion and
streambed scour;
(4) do not remove flume pipe during trenching, pipelaying, or

backfilling activities, or initial streambed restoration efforts;
and
(5) remove all flume pipes and dams that are not also part of the
equipment bridge as soon as final cleanup of the stream bed
and bank is complete.
d. Horizontal Directional Drill
For each waterbody or wetland that would be crossed using the HDD
method, file with the Secretary for the review and written approval by
the Director, a plan that includes:
(1) site-specific construction diagrams that show the location of

mud pits, pipe assembly areas, and all areas to be disturbed or
cleared for construction;
(2) justification that disturbed areas are limited to the minimum

needed to construct the crossing;
(3) identification of any aboveground disturbance or clearing

between the HDD entry and exit workspaces during
construction;
(4) a description of how an inadvertent release of drilling mud

would be contained and cleaned up; and
(5) a contingency plan for crossing the waterbody or wetland in

the event the HDD is unsuccessful and how the abandoned
drill hole would be sealed, if necessary.
The requirement to file HDD plans does not apply to projects

constructed under the automatic authorization provisions in the
FERC’s regulations.
7. Crossings of Minor Waterbodies
Where a dry-ditch crossing is not required, minor waterbodies may be crossed

using the open-cut crossing method, with the following restrictions:
a. except for blasting and other rock breaking measures, complete

instream construction activities (including trenching, pipe installation,
backfill, and restoration of the streambed contours) within 24 hours.
9 MAY 2013 VERSION

Streambanks and unconsolidated streambeds may require additional
restoration after this period;
b. limit use of equipment operating in the waterbody to that needed to

construct the crossing; and
c. equipment bridges are not required at minor waterbodies that do not

have a state-designated fishery classification or protected status (e.g.,
agricultural or intermittent drainage ditches). However, if an
equipment bridge is used it must be constructed as described in
section V.B.5.
8. Crossings of Intermediate Waterbodies
Where a dry-ditch crossing is not required, intermediate waterbodies may be

crossed using the open-cut crossing method, with the following restrictions:
a. complete instream construction activities (not including blasting and

other rock breaking measures) within 48 hours, unless site-specific
conditions make completion within 48 hours infeasible;
b. limit use of equipment operating in the waterbody to that needed to

construct the crossing; and
c. all other construction equipment must cross on an equipment bridge

as specified in section V.B.5.
9. Crossings of Major Waterbodies
Before construction, the project sponsor shall file with the Secretary for the
review and written approval by the Director a detailed, site-specific
construction plan and scaled drawings identifying all areas to be disturbed by
construction for each major waterbody crossing (the scaled drawings are not
required for any offshore portions of pipeline projects). This plan must be
developed in consultation with the appropriate state and federal agencies and
shall include extra work areas, spoil storage areas, sediment control
structures, etc., as well as mitigation for navigational issues. The requirement
to file major waterbody crossing plans does not apply to projects constructed
under the automatic authorization provisions of the FERC’s regulations.
The Environmental Inspector may adjust the final placement of the erosion
and sediment control structures in the field to maximize effectiveness.
10. Temporary Erosion and Sediment Control
Install sediment barriers (as defined in section IV.F.3.a of the Plan)

immediately after initial disturbance of the waterbody or adjacent upland.
10 MAY 2013 VERSION

Sediment barriers must be properly maintained throughout construction and
reinstalled as necessary (such as after backfilling of the trench) until replaced
by permanent erosion controls or restoration of adjacent upland areas is
complete. Temporary erosion and sediment control measures are addressed
in more detail in the Plan; however, the following specific measures must be
implemented at stream crossings:
a. install sediment barriers across the entire construction right-of-way at

all waterbody crossings, where necessary to prevent the flow of
sediments into the waterbody. Removable sediment barriers (or
driveable berms) must be installed across the travel lane. These
removable sediment barriers can be removed during the construction
day, but must be re-installed after construction has stopped for the day
and/or when heavy precipitation is imminent;
b. where waterbodies are adjacent to the construction right-of-way and

the right-of-way slopes toward the waterbody, install sediment
barriers along the edge of the construction right-of-way as necessary
to contain spoil within the construction right-of-way and prevent
sediment flow into the waterbody; and
c. use temporary trench plugs at all waterbody crossings, as necessary, to

prevent diversion of water into upland portions of the pipeline trench
and to keep any accumulated trench water out of the waterbody.
11. Trench Dewatering
Dewater the trench (either on or off the construction right-of-way) in a

manner that does not cause erosion and does not result in silt-laden water
flowing into any waterbody. Remove the dewatering structures as soon as
practicable after the completion of dewatering activities.
C. RESTORATION
1. Use clean gravel or native cobbles for the upper 1 foot of trench backfill in all
waterbodies that contain coldwater fisheries.
2. For open-cut crossings, stabilize waterbody banks and install temporary

sediment barriers within 24 hours of completing instream construction
activities. For dry-ditch crossings, complete streambed and bank stabilization
before returning flow to the waterbody channel.
3. Return all waterbody banks to preconstruction contours or to a stable angle of

repose as approved by the Environmental Inspector.
4. Install erosion control fabric or a functional equivalent on waterbody banks at

the time of final bank recontouring. Do not use synthetic monofilament
11 MAY 2013 VERSION

mesh/netted erosion control materials in areas designated as sensitive wildlife
habitat unless the product is specifically designed to minimize harm to
wildlife. Anchor erosion control fabric with staples or other appropriate
devices.
5. Application of riprap for bank stabilization must comply with COE, or its
delegated agency, permit terms and conditions.
6. Unless otherwise specified by state permit, limit the use of riprap to areas
where flow conditions preclude effective vegetative stabilization techniques
such as seeding and erosion control fabric.
7. Revegetate disturbed riparian areas with native species of conservation

grasses, legumes, and woody species, similar in density to adjacent
undisturbed lands.
8. Install a permanent slope breaker across the construction right-of-way at the

base of slopes greater than 5 percent that are less than 50 feet from the
waterbody, or as needed to prevent sediment transport into the waterbody. In
addition, install sediment barriers as outlined in the Plan.
In some areas, with the approval of the Environmental Inspector, an earthen

berm may be suitable as a sediment barrier adjacent to the waterbody.
9. Sections V.C.3 through V.C.7 above also apply to those perennial or

intermittent streams not flowing at the time of construction.
D. POST-CONSTRUCTION MAINTENANCE
1. Limit routine vegetation mowing or clearing adjacent to waterbodies to allow

a riparian strip at least 25 feet wide, as measured from the waterbody’s mean
high water mark, to permanently revegetate with native plant species across
the entire construction right-of-way. However, to facilitate periodic
corrosion/leak surveys, a corridor centered on the pipeline and up to 10 feet
wide may be cleared at a frequency necessary to maintain the 10-foot corridor
in an herbaceous state. In addition, trees that are located within 15 feet of the
pipeline that have roots that could compromise the integrity of the pipeline
coating may be cut and removed from the permanent right-of-way. Do not
conduct any routine vegetation mowing or clearing in riparian areas that are
between HDD entry and exit points.
2. Do not use herbicides or pesticides in or within 100 feet of a waterbody

except as allowed by the appropriate land management or state agency.
3. Time of year restrictions specified in section VII.A.5 of the Plan (April 15 –

August 1 of any year) apply to routine mowing and clearing of riparian areas.
12 MAY 2013 VERSION

VI. WETLAND CROSSINGS
A. GENERAL
1. The project sponsor shall conduct a wetland delineation using the current
federal methodology and file a wetland delineation report with the Secretary
before construction. The requirement to file a wetland delineation report
does not apply to projects constructed under the automatic authorization
provisions in the FERC’s regulations.
This report shall identify:
a. by milepost all wetlands that would be affected;
b. the National Wetlands Inventory (NWI) classification for each

wetland;
c. the crossing length of each wetland in feet; and
d. the area of permanent and temporary disturbance that would occur in

each wetland by NWI classification type.
The requirements outlined in this section do not apply to wetlands in actively

cultivated or rotated cropland. Standard upland protective measures,
including workspace and topsoiling requirements, apply to these agricultural
wetlands.
2. Route the pipeline to avoid wetland areas to the maximum extent possible. If
a wetland cannot be avoided or crossed by following an existing right-of-way,
route the new pipeline in a manner that minimizes disturbance to wetlands.
Where looping an existing pipeline, overlap the existing pipeline right-of-way
with the new construction right-of-way. In addition, locate the loop line no
more than 25 feet away from the existing pipeline unless site-specific
constraints would adversely affect the stability of the existing pipeline.
3. Limit the width of the construction right-of-way to 75 feet or less. Prior

written approval of the Director is required where topographic conditions or
soil limitations require that the construction right-of-way width within the
boundaries of a federally delineated wetland be expanded beyond 75 feet.
Early in the planning process the project sponsor is encouraged to identify
site-specific areas where excessively wide trenches could occur and/or where
spoil piles could be difficult to maintain because existing soils lack adequate
unconfined compressive strength.
4. Wetland boundaries and buffers must be clearly marked in the field with
signs and/or highly visible flagging until construction-related ground
disturbing activities are complete.
13 MAY 2013 VERSION

5. Implement the measures of sections V and VI in the event a waterbody
crossing is located within or adjacent to a wetland crossing. If all measures
of sections V and VI cannot be met, the project sponsor must file with the
Secretary a site-specific crossing plan for review and written approval by the
Director before construction. This crossing plan shall address at a minimum:
a. spoil control;
b. equipment bridges;
c. restoration of waterbody banks and wetland hydrology;
d. timing of the waterbody crossing;
e. method of crossing; and
f. size and location of all extra work areas.
6. Do not locate aboveground facilities in any wetland, except where the

location of such facilities outside of wetlands would prohibit compliance with
U.S. Department of Transportation regulations.
B. INSTALLATION
1. Extra Work Areas and Access Roads
a. Locate all extra work areas (such as staging areas and additional spoil
storage areas) at least 50 feet away from wetland boundaries, except
where the adjacent upland consists of cultivated or rotated cropland or
other disturbed land.
b. The project sponsor shall file with the Secretary for review and
written approval by the Director, site-specific justification for each
extra work area with a less than 50-foot setback from wetland
boundaries, except where adjacent upland consists of cultivated or
rotated cropland or other disturbed land. The justification must
specify the site-specific conditions that will not permit a 50-foot
setback and measures to ensure the wetland is adequately protected.
c. The construction right-of-way may be used for access when the

wetland soil is firm enough to avoid rutting or the construction right-
of-way has been appropriately stabilized to avoid rutting (e.g., with
timber riprap, prefabricated equipment mats, or terra mats).
In wetlands that cannot be appropriately stabilized, all construction

equipment other than that needed to install the wetland crossing shall
14 MAY 2013 VERSION

use access roads located in upland areas. Where access roads in
upland areas do not provide reasonable access, limit all other
construction equipment to one pass through the wetland using the
construction right-of-way.
d. The only access roads, other than the construction right-of-way, that
can be used in wetlands are those existing roads that can be used with
no modifications or improvements, other than routine repair, and no
impact on the wetland.
2. Crossing Procedures
a. Comply with COE, or its delegated agency, permit terms and

conditions.
b. Assemble the pipeline in an upland area unless the wetland is dry

enough to adequately support skids and pipe.
c. Use “push-pull” or “float” techniques to place the pipe in the trench

where water and other site conditions allow.
d. Minimize the length of time that topsoil is segregated and the trench is
open. Do not trench the wetland until the pipeline is assembled and
ready for lowering in.
e. Limit construction equipment operating in wetland areas to that

needed to clear the construction right-of-way, dig the trench, fabricate
and install the pipeline, backfill the trench, and restore the
construction right-of-way.
f. Cut vegetation just above ground level, leaving existing root systems
in place, and remove it from the wetland for disposal.
The project sponsor can burn woody debris in wetlands, if approved

by the COE and in accordance with state and local regulations,
ensuring that all remaining woody debris is removed for disposal.
g. Limit pulling of tree stumps and grading activities to directly over the
trenchline. Do not grade or remove stumps or root systems from the
rest of the construction right-of-way in wetlands unless the Chief
Inspector and Environmental Inspector determine that safety-related
construction constraints require grading or the removal of tree stumps
from under the working side of the construction right-of-way.
h. Segregate the top 1 foot of topsoil from the area disturbed by

trenching, except in areas where standing water is present or soils are
15 MAY 2013 VERSION

saturated. Immediately after backfilling is complete, restore the
segregated topsoil to its original location.
i. Do not use rock, soil imported from outside the wetland, tree stumps,
or brush riprap to support equipment on the construction right-of-way.
j. If standing water or saturated soils are present, or if construction

equipment causes ruts or mixing of the topsoil and subsoil in
wetlands, use low-ground-weight construction equipment, or operate
normal equipment on timber riprap, prefabricated equipment mats, or
terra mats.
k. Remove all project-related material used to support equipment on the

construction right-of-way upon completion of construction.
3. Temporary Sediment Control
Install sediment barriers (as defined in section IV.F.3.a of the Plan)

immediately after initial disturbance of the wetland or adjacent upland.
Sediment barriers must be properly maintained throughout construction and
reinstalled as necessary (such as after backfilling of the trench). Except as
noted below in section VI.B.3.c, maintain sediment barriers until replaced by
permanent erosion controls or restoration of adjacent upland areas is
complete. Temporary erosion and sediment control measures are addressed in
more detail in the Plan.
a. Install sediment barriers across the entire construction right-of-way

immediately upslope of the wetland boundary at all wetland crossings
where necessary to prevent sediment flow into the wetland.
b. Where wetlands are adjacent to the construction right-of-way and the

right-of-way slopes toward the wetland, install sediment barriers
along the edge of the construction right-of-way as necessary to contain
spoil within the construction right-of-way and prevent sediment flow
into the wetland.
c. Install sediment barriers along the edge of the construction right-of-

way as necessary to contain spoil and sediment within the
construction right-of-way through wetlands. Remove these sediment
barriers during right-of-way cleanup.
16 MAY 2013 VERSION

4. Trench Dewatering
Dewater the trench (either on or off the construction right-of-way) in a

manner that does not cause erosion and does not result in silt-laden water
flowing into any wetland. Remove the dewatering structures as soon as
practicable after the completion of dewatering activities.
C. RESTORATION
1. Where the pipeline trench may drain a wetland, construct trench breakers at
the wetland boundaries and/or seal the trench bottom as necessary to maintain
the original wetland hydrology.
2. Restore pre-construction wetland contours to maintain the original wetland

hydrology.
3. For each wetland crossed, install a trench breaker at the base of slopes near
the boundary between the wetland and adjacent upland areas. Install a
permanent slope breaker across the construction right-of-way at the base of
slopes greater than 5 percent where the base of the slope is less than 50 feet
from the wetland, or as needed to prevent sediment transport into the wetland.
In addition, install sediment barriers as outlined in the Plan. In some areas,
with the approval of the Environmental Inspector, an earthen berm may be
suitable as a sediment barrier adjacent to the wetland.
4. Do not use fertilizer, lime, or mulch unless required in writing by the

appropriate federal or state agency.
5. Consult with the appropriate federal or state agencies to develop a project-

specific wetland restoration plan. The restoration plan shall include measures
for re-establishing herbaceous and/or woody species, controlling the invasion
and spread of invasive species and noxious weeds (e.g., purple loosestrife and
phragmites), and monitoring the success of the revegetation and weed control
efforts. Provide this plan to the FERC staff upon request.
6. Until a project-specific wetland restoration plan is developed and/or

implemented, temporarily revegetate the construction right-of-way with
annual ryegrass at a rate of 40 pounds/acre (unless standing water is present).
7. Ensure that all disturbed areas successfully revegetate with wetland

herbaceous and/or woody plant species.
8. Remove temporary sediment barriers located at the boundary between

wetland and adjacent upland areas after revegetation and stabilization of
adjacent upland areas are judged to be successful as specified in section
VII.A.4 of the Plan.
17 MAY 2013 VERSION

D. POST-CONSTRUCTION MAINTENANCE AND REPORTING
1. Do not conduct routine vegetation mowing or clearing over the full width of
the permanent right-of-way in wetlands. However, to facilitate periodic
corrosion/leak surveys, a corridor centered on the pipeline and up to 10 feet
wide may be cleared at a frequency necessary to maintain the 10-foot corridor
in an herbaceous state. In addition, trees within 15 feet of the pipeline with
roots that could compromise the integrity of pipeline coating may be
selectively cut and removed from the permanent right-of-way. Do not
conduct any routine vegetation mowing or clearing in wetlands that are
between HDD entry and exit points.
2. Do not use herbicides or pesticides in or within 100 feet of a wetland, except

as allowed by the appropriate federal or state agency.
3. Time of year restrictions specified in section VII.A.5 of the Plan (April 15 –

August 1 of any year) apply to routine mowing and clearing of wetland areas.
4. Monitor and record the success of wetland revegetation annually until

wetland revegetation is successful.
5. Wetland revegetation shall be considered successful if all of the following

criteria are satisfied:
a. the affected wetland satisfies the current federal definition for a

wetland (i.e., soils, hydrology, and vegetation);
b. vegetation is at least 80 percent of either the cover documented for the

wetland prior to construction, or at least 80 percent of the cover in
adjacent wetland areas that were not disturbed by construction;
c. if natural rather than active revegetation was used, the plant species
composition is consistent with early successional wetland plant
communities in the affected ecoregion; and
d. invasive species and noxious weeds are absent, unless they are
abundant in adjacent areas that were not disturbed by construction.
6. Within 3 years after construction, file a report with the Secretary identifying
the status of the wetland revegetation efforts and documenting success as
defined in section VI.D.5, above. The requirement to file wetland restoration
reports with the Secretary does not apply to projects constructed under the
automatic authorization, prior notice, or advance notice provisions in the
FERC’s regulations.
For any wetland where revegetation is not successful at the end of 3 years
after construction, develop and implement (in consultation with a
18 MAY 2013 VERSION

professional wetland ecologist) a remedial revegetation plan to actively
revegetate wetlands. Continue revegetation efforts and file a report annually
documenting progress in these wetlands until wetland revegetation is
successful.
VII. HYDROSTATIC TESTING
A. NOTIFICATION PROCEDURES AND PERMITS
1. Apply for state-issued water withdrawal permits, as required.
2. Apply for National Pollutant Discharge Elimination System (NPDES) or

state-issued discharge permits, as required.
3. Notify appropriate state agencies of intent to use specific sources at least 48

hours before testing activities unless they waive this requirement in writing.
B. GENERAL
1. Perform 100 percent radiographic inspection of all pipeline section welds or

hydrotest the pipeline sections, before installation under waterbodies or
wetlands.
2. If pumps used for hydrostatic testing are within 100 feet of any waterbody or
wetland, address secondary containment and refueling of these pumps in the
project’s Spill Prevention and Response Procedures.
3. The project sponsor shall file with the Secretary before construction a list
identifying the location of all waterbodies proposed for use as a hydrostatic
test water source or discharge location. This filing requirement does not
apply to projects constructed under the automatic authorization provisions of
the FERC’s regulations.
C. INTAKE SOURCE AND RATE
1. Screen the intake hose to minimize the potential for entrainment of fish.
2. Do not use state-designated exceptional value waters, waterbodies which

provide habitat for federally listed threatened or endangered species, or
waterbodies designated as public water supplies, unless appropriate federal,
state, and/or local permitting agencies grant written permission.
3. Maintain adequate flow rates to protect aquatic life, provide for all waterbody
uses, and provide for downstream withdrawals of water by existing users.
4. Locate hydrostatic test manifolds outside wetlands and riparian areas to the
maximum extent practicable.
19 MAY 2013 VERSION

D. DISCHARGE LOCATION, METHOD, AND RATE
1. Regulate discharge rate, use energy dissipation device(s), and install sediment
barriers, as necessary, to prevent erosion, streambed scour, suspension of
sediments, or excessive streamflow.
2. Do not discharge into state-designated exceptional value waters, waterbodies

which provide habitat for federally listed threatened or endangered species, or
waterbodies designated as public water supplies, unless appropriate federal,
state, and local permitting agencies grant written permission.
20 MAY 2013 VERSION

APPENDIX C
Agency Correspondence
January 23, 2018
Ms. Christine Clarke, State Conservationist

USDA NRCS - Massachusetts
451 West Street
Amherst, MA 01002-2953
RE: Tennessee Gas Pipeline Company, L.L.C.

Line 261B Pipeline Looping Project
Via Electronic Mail
Dear Ms. Clarke:
Tennessee Gas Pipeline Company, L.L.C. (Tennessee), a Kinder Morgan company, is planning to
upgrade its Line 261B natural gas pipeline system. This would include a looping upgrade of 2.1 miles of
existing pipeline system in Agawam, Massachusetts (Project). The proposed pipeline loop upgrade would
be a 12-inch pipeline installed adjacent to Tennessee’s existing 8-inch, 261BP-100 pipeline and 10-inch,
261B-100 pipelines to the greatest extent possible. Where the loop upgrade is adjacent to the 10-inch
261B-100 pipeline, Tennessee proposes to remove an abandoned 6-inch-diameter pipeline where it exists
in this location and replace it with the 12-inch loop upgrade.
An Environmental Report, required as part of the Federal Energy Regulatory Commission (FERC)
Section 7(c) Blanket Certificate Prior Notice process, is currently being prepared for the Project. As part
of the FERC National Environmental Policy Act review, it is necessary to obtain recommendations from
the NRCS on regionally appropriate seed mixes for restoration activities. In addition, it is necessary to
identify whether the proposed Project will cross any of the following sensitive environmental areas:
• Conservation Reserve Enhancement Program (CREP) or Wetland Reserves Program (WRP)

lands
• Land currently in use for agriculture
• Land with agricultural restrictions, specialty crops, or grazing allotments
• Soils with severe erosion potential, poor re-vegetation potential, or high susceptibility to
compaction
• Prime farmlands soils or soils of statewide importance
• Areas with noxious weed concerns
Tennessee respectfully requests that the NRCS review its records relative to any of the above-referenced
areas and provide written comments pertaining to the identified resources. We have enclosed for your
Page 2
review a USGS location map depicting the proposed Project locations. If you have any questions
regarding this request, please contact me at either (713) 420-6723 or via e-mail at
debi_mccartney@kindermorgan.com.
Very truly yours,
TENNESSEE GAS PIPELINE COMPANY, L.L.C.
______________________________
Deborah J. McCartney
Senior Permitting and Compliance Specialist
KINDER MORGAN
713-420-6723 (office)
832-691-6125 (cell)
c: R. Weissman, SWCA
Proposed Pipeline
Existing TGP System
Data Source: Office of Geographic WESTFIELD

WEST SPRINGFIELD
SPRINGFIELD
Information (MassGIS)
Figure 1. Site Locus Map
USGS Topographic Quadrangle Images
Looping Project SOUTHWICK
AGAWAM
Tennesse Gas Pipeline USGS West Springfield Quadrangle LONGMEADOW

Agawam, MA

0 1,000 2,000
Feet
¯ Latitude 42.04863° N
Longitude 72.6377° W
From: Akin, Thomas - NRCS, Amherst, MA
To: Debi_McCartney@kindermorgan.com
Cc: Rebecca Weissman; Clarke, Christine - NRCS, Amherst, MA; Thibodeau, Rita - NRCS, Greenfield, MA; Snyder,
Vince - NRCS, Amherst, MA; Nicholson, Theodore - NRCS, Amherst, MA; Wright, Dan - NRCS, Amherst, MA
Subject: RE: Line 261B Pipeline Looping Project - Information Request
Date: Friday, February 2, 2018 10:43:56 AM
Attachments: image001.png
MA NRCS Letter to Kinder Morgan Tennessee Gas Co Agawam 261B Pipeline Lo.._.pdf
Critical_Area_Planting-Code_342_MA_Native_Plants_Reference_Guide_Version3_2001.pdf
Dear Ms. McCartney,
On behalf of Christine Clarke, State Conservationist, please find attached our response to your letter
of January 23, 2018.
Hard copies of the correspondence and attachment will go out with today’s mail.
If you have any questions please contact me at your convenience.
Best regards, Tom Akin
THOMAS J AKIN | State Resource Conservationist | USDA Natural Resources Conservation Service | 451 West Street,
Amherst, MA 01002
thomas.akin@ma.usda.gov | Phone: 413-253-4365 | Cell: 413-835-1278 | Fax:
RA.NRCS.MAAMH.efax7666@ma.usda.gov OR 1-855-596-7666 |
Helping People Help the Land | USDA is an equal opportunity employer, provider, and lender.
If you manage land, please consider signing up for Conservation Client Gateway, at
http://www.nrcs.usda.gov/wps/portal/nrcs/main/national/cgate/
From: Rebecca Weissman [mailto:Rebecca.Weissman@swca.com]

Sent: Tuesday, January 23, 2018 10:03 AM
To: Thibodeau, Rita - NRCS, Greenfield, MA <Rita.Thibodeau@ma.usda.gov>
Cc: McCartney, Debi <Debi_McCartney@kindermorgan.com>
Subject: Line 261B Pipeline Looping Project - Information Request
Ms. Thibodeau,
On behalf of Tennessee Gas Pipeline Company, L.L.C., SWCA Environmental Consultants is providing
you with the attached information request for the Line 261B Pipeline Looping Project. A description
of the Project, the nature of the information requested, and a general location map are included in
the attachment. If you have any questions about this request, please do not hesitate to contact Debi
McCartney at 713-420-6723 or debi_mccartney@kindermorgan.com. Thank you.
Rebecca Weissman, PWS

Project Manager / Sr. Wetland Scientist

15 Research Drive
Amherst, MA 01002
P 339.203.7045
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Natural Resources Conservation Service
451 West Street, Amherst, MA 01002 | 413-253-4350 | fax 855-596-7666 | www.ma.nrcs.usda.gov
February 1, 2018
Ms. Deborah J. McCartney

Senior Permitting/Compliance Specialist
Kinder Morgan
Houston, TX 77002
RE: Tennessee Gas Pipeline Company, LLC—Line 261B Pipeline Looping Project
Dear Ms. McCartney,
Thank you for your correspondence of January 23, 2018.
Regarding your request for locally appropriate seed mixes for vegetation restoration activities
post-construction, I have enclosed the Massachusetts NRCS Conservation Practice, “Critical
Area Planting—Code 342 Specification Guide.”
NRCS Massachusetts does not hold any permanent conservation easements along the projected
route of the above mentioned pipeline project. Soils data for the project area may be obtained
from our national “Web Soil Survey” located at:
https://websoilsurvey.sc.egov.usda.gov/App/HomePage.htm.
If you have any questions, please contact me by phone at 413-253-4351 or by email at

christine.clarke@ma.usda.gov .
Sincerely,
Christine S. Clarke
State Conservationist
Attachment: Critical Area Planting—Code 342, Specification Guide
Cc: Daniel Wright, Assistant State Conservationist for Program, NRCS MA

Thomas Akin, State Resource Conservationist, NRCS MA
USDA is an equal opportunity provider, employer, and lender.

Critical Area Planting Specifications 342-1
NATURAL RESOURCES CONSERVATION SERVICE

SPECIFICATION GUIDELINES
CRITICAL AREA PLANTING
(Code 342)
GENERAL SPECIFICATIONS stripping depth shall be used, depending on the

Plans and specifications for establishment and particular soil.
maintenance of a critical area planting shall be Fill material shall be free of brush, rubbish, timber,
prepared for each site or management unit logs, stumps, and other vegetative matter in
according to the USDA, NRCS-MA Conservation amounts that is detrimental to constructing stable
Practice Standard, Critical Area Planting (342), fills.
Criteria, Considerations, and Operation and
Maintenance. They shall be recorded on All disturbed areas shall be left with a generally
specification sheets, job sheets, narrative smooth finish and shall be protected from erosion.
statements in conservation plans, or other Provisions shall be made to safely conduct surface
acceptable documentation. water to storm drains or suitable watercourses and
When this practice is used to specify the vegetative to prevent surface runoff from damaging cut faces
component of another practice (e.g., grassed and fill slopes.
waterway, filter strip, pond, etc.), plans and In areas having a high water table, subsurface
specifications shall meet the requirements of both drainage shall be provided to intercept seepage that
standards to achieve the intended purpose of the would adversely affect slope stability, building
practice. The completed work shall be checked and foundations, or create undesirable wetness.
documented to verify that the practice was
completed according to the drawings and Adjoining properties shall be protected from
specifications of both standards. Documentation sedimentation associated with excavation and
shall be in accordance with the section “Supporting filling operations.
Data and Documentation” in both standards. Fill shall not be placed adjacent to the bank of a
stream or channel, unless provisions are made to
protect the hydraulic, biological, aesthetic and other
GRADING PLAN environmental functions of the stream.
The grading plan and practice installation shall be
based upon adequate topographic surveys and
investigations. The plan shall show the location, SOIL AMENDMENTS
slope, cut, fill, and finish elevation of the surfaces Soil tests shall be used to determine the optimum
to be graded. The plan shall also include auxiliary recommendations for both lime and fertilizer. At a
practices for safe disposal of runoff water, slope minimum, soil samples taken for nutrient and pH
stabilization, erosion control, and drainage. analysis shall be from the soil layer that will be
Practices such as waterways, ditches, diversions, used as the surface layer (top 4 to 6 inches) for
grade stabilization structures, retaining walls and seeding.
subsurface drains shall be included where
necessary. Soil analysis shall be performed by a soil testing
laboratory that has been accredited by the North
American Proficiency Testing Program, preferably
SITE PREPARATION Land Grant University soil testing laboratories from
Timber, logs, brush, rocks, stumps and vegetative Massachusetts, Connecticut, New York and
matter that will interfere with the grading operation Vermont.
or affect the planned stability of fill areas shall be
removed and disposed of according to the plan. Lime
Topsoil shall be stripped and stockpiled in amounts Lime shall be applied to achieve a soil pH of 6.0 if
necessary to complete finish grading of all exposed legumes are included in a planting, and 5.5 if only
areas requiring topsoil. A minimum 4-inch grasses are used.
NRCS, MA
September 2001
Lime materials shall be ground limestone (hydrated All fertilizer shall be uniform in composition, free-
or burnt lime may be substituted) that contains at flowing, and suitable for application by approved
least 50% total oxides (calcium plus magnesium equipment. Fertilizers shall be delivered to the site
oxide). Pulverized limestone shall be ground to fully labeled according to applicable state fertilizer
such a fineness that at least 50% will pass through a laws, and shall bear the name, trade name, or
100-mesh sieve and at least 98% will pass through trademark and warranty of the producer. Slow-
a 20-mesh sieve. Pulverized limestone applied at release forms of nitrogen shall be used when
rates greater than 50 pounds per 1,000 square feet feasible to provide nitrogen over a longer period of
(or greater than 1 ton per acre) shall be time.
incorporated into the upper 4 to 6 inches of the soil.
Pulverized limestone may also be included in a Organic Amendments
hydroseeding slurry. Apply manure and compost at a rate based on a
nutrient analysis of that material and the soil test
When a soil test is not feasible, lime shall be results. Organic amendments to sites shall be
applied according to the rates specified as follows: recommended only after an evaluation of any
Limestone potential water quality hazards. Organic
Application Rate amendments shall be incorporated to the extent
Soil Texture practical into the upper 4 to 6 inches of the soil
Tons/Acre Lbs./1,000 SF
with a disk, springtooth harrow, or other suitable
Clay, clay loam, and equipment.
3 135
highly organic soil
Topsoil
Sandy loam, loam,
2 90 Topsoil shall be added to a site when needed to
silt loam
improve the soil medium for plant establishment
Loamy sand, sand 1 45 and growth. The use of topsoil shall be limited to
slopes that are 2:1 or flatter.
Fertilizer Exposed soils shall be topsoiled if they have one or
Fertilizer shall be applied to prepared seedbeds as more of the following limiting factors:
needed, based on soil test results. Fertilizer applied 1. Very shallow to bedrock or other restrictive
without a soil test may result in an inefficient layer (e.g., the subsoil is less than 6 inches
quantity of nutrients for plant establishment or deep);
could result in over application of nutrients leading
to potential water quality problems. If the site 2. Extremely acidic (pH less than 5.0); or,
conditions involve B-horizon soil and no topsoil, 3. Extremely salty (conductivity greater than 500
use one of the following recommendations, in lieu parts per million, or 4.0 millisiemens per
of a soil test: centimeter).
! Cool Season Seed Mix: Apply 10-20-20 Topsoil shall also be used when assurance of
analysis fertilizer at a rate of 500 lbs./acre, with improved vegetative growth is desired.
40% of the nitrogen to be in an organic or slow
release form. Incorporate into the top 2-3 Topsoil Quality
inches of soil. If legumes are more than 20% Topsoil shall be friable and loamy, free of debris,
of the mix, reduce nitrogen to 30 lbs./acre. stones, or other materials larger than 1.5 inches in
diameter. It shall be free of any known viable seeds
! Warm Season Seed Mix: Apply a 0-10-10 or plant parts of objectionable weeds such as
analysis fertilizer at a rate of 600 lbs./acre. Johnsongrass, shattercane, thistle, multiflora rose,
Incorporate into the top 2-3 inches of soil. For or others as specified.
sterile, droughty sites add a slow release
nitrogen after emergence of grass in late spring Topsoil shall contain no toxic substance that may
at the rate of 30 lbs./acre. If the mix includes be harmful to plant growth. Soluble salts shall not
more than 20% legumes, use 20 lbs./acre of be excessive (concentration greater than 500 parts
nitrogen. On finer textured soils with high per million). A pH range of 5.5 to 7.5 is required.
weed pressure, delay application of nitrogen If pH is less than 5.5, lime shall be applied and
until the second year. incorporated with the topsoil to adjust the pH to
between 5.5 and 7.5. A pH of 6.5 is ideal. Topsoil
NRCS, MA
September 2001
hauled in from off-site shall have a minimum Slopes 3:1 or steeper

organic matter content of 1% by weight, based on Scarify the soil surface with a bulldozer, heavy
soil test results. chain, hand tools or other equipment that will
Topsoil Application loosen the soil 0.5 to 1 inch deep. After the soil is
Before topsoiling, the exposed subsoil shall be loosened, it shall not be worked completely smooth,
tested for pH. Where the subsoil is highly acidic but left in a somewhat roughened condition. The
(< 4.0), ground limestone shall be added at the rate final surface preparation shall be on the general
of 4 to 8 tons per acre (200 to 400 pounds per 1,000 contour.
square feet). Lime shall be distributed uniformly
and worked into the subsoil as previously described SEEDING
in the section concerning Soil Amendments.
Seed Quality and Treatment
Immediately before spreading topsoil, the subsoil
All seed shall be labeled and meet the requirements
shall be loosened by disking or scarifying to
of the Massachusetts Seed Law. Refer to Table 7
provide a good bond for the topsoil. Where the
for minimum germination and purity requirements.
slope of the site is flatter than 3:1, loosen the
Seed shall have had a germination test within 12
subsoil to a minimum average depth of 2 inches.
months prior to the date of sowing. Use of certified
On steeper slopes (up to 2:1), loosen the subsoil to
seed is preferred. Seed shall be kept cool and dry
a depth of 0.5 to 1 inch, or use a bulldozer to track
until planted.
up and down slope to create horizontal check slots
that will prevent topsoil from sliding down the Species with seed lots greater than 50% hard seed
slope. shall be dehulled and/or scarified and planted no
later than 60 days after scarification.
Topsoil shall only be handled when it is dry enough
to work (less than field capacity) without damaging Endophytes
soil structure. Topsoil shall not be spread when it Grass seed (perennial ryegrass, fine fescues, and
is partly frozen or muddy, or on frozen slopes tall fescue) enhanced with endophytes, a naturally
covered with ice or snow. occurring fungus, shall only be used when
Topsoil shall be uniformly applied in a 5 to 8 inch establishing a managed turf grass, such as a lawn,
layer, and lightly compacted to a minimum athletic field, or recreation area. The endophytes
thickness of 4 inches. Subsoil with a pH of 4.0 or protect the grass from insect and disease damage
less, or containing iron sulfide, shall be covered but are potentially harmful to wildlife if the seed or
with a minimum depth of 12 inches of topsoil. plant is eaten. Conservation seedings should be
made with low (< 5%) or endophyte-free grass
Topsoil placed on slopes greater than 5% shall be cultivars. Refer to Table 8 for guidance on
promptly limed and fertilized (if needed), seeded, selecting the appropriate cultivar.
mulched, and tracked with suitable equipment.
Grasses that have fluffy seeds shall be planted
using specialized seed drills. Alternatively, beards
SEEDBED PREPARATION or awns shall be mechanically removed from such
Seedbed preparation shall be done when the soil is seeds to facilitate movement through conventional
moist, but not wet. Lime, fertilizer, and other soil seeding equipment.
amendments shall be evenly applied where needed Legume seeds shall be inoculated with the proper,
on the site, as described above. Either dry or wet viable Rhizobium bacteria before planting.
application methods may be suitable. Inoculant shall be kept as cool as possible until
used and shall not be used later than the date
Slopes flatter than 3:1 indicated on the package. When hydroseeding, use
four times the recommended inoculant rate.
Seedbed preparation shall consist of working the
soil to a depth of 3 to 5 inches with a disk or similar
equipment. Continue tillage until a reasonably Seeding Methods
uniform seedbed is prepared. Apply seed uniformly by hand, cyclone seeder,
drill, cultipacker-seeder, or hydroseeder. The
preferred method of seeding is by drilling or
NRCS, MA
September 2001
cultipacker-seeder method, because these methods toward the end of the listed planting dates for
optimize seed to soil contact. Seeding operations permanent seedings, or when conditions are
shall be done on the contour, to the extent feasible. expected to be less than optimal, select an
appropriate nurse crop from Table 1 and plant with
Drill the permanent seeding mix. Companion seedings
A grass drill (not a grain drill) or cultipacker-type of small-seeded grasses shall not exceed 5% (by
seeder shall be used to plant grass seed. Grasses weight) of the overall permanent seeding mixture.
shall not be planted more than 1/4 to 1/2-inch deep. Companion seedings of small grains such as barley,
If the drill does not have a packer attachment, a wheat, oats, or cereal rye shall be sown at one-third
packer/roller shall be trailed behind the drill. the rates listed in Table 1.
Where practical, seed shall be applied in two
directions perpendicular to each other. Apply one- Oats are the recommended nurse crop for warm-
half the seeding rate in each direction. season grasses. Do not use cereal rye as a nurse
crop for warm-season grasses because it will inhibit
Broadcast their germination and growth.
Seed may be broadcast by using a cyclone or When a temporary or permanent seeding cannot be
whirlwind seeder, or by hand. If spread by hand, completed because of weather conditions or time of
small or light-seeded species such as redtop or year, mulch only (no seeding) shall be applied as a
bluestem may be mixed with filler (e.g., sawdust, temporary cover when soil stabilization is needed.
rice) to achieve an even distribution. Seed shall be Refer to the Mulching section of this standard for
applied in two directions, each perpendicular to one application rates and methods.
another. One–half the seeding rate shall be applied
in each direction. Seed shall be incorporated 1/8 to
1/4-inch deep by raking or dragging, cultipacking, Permanent Seeding
or tracking with heavy machinery. Raked areas Permanent herbaceous vegetation shall be designed
shall be rolled with a weighted roller to provide to achieve a minimum stand density of 85 percent
good seed to soil contact. ground cover within one year.
Hydroseeding Grasses and Legumes
This method is best suited for steep, inaccessible Grasses and legumes suitable for erosion control in
areas where use of a drill or other mechanized Massachusetts are described in Tables 3 and 4.
equipment is not feasible. Hydroseeding shall be
done in two separate operations with seed and Seed Mixes
fertilizer applied in the first pass, and mulch To establish permanent cover, select grass and
applied in the second pass. Do not use burnt or legume mixes according to the guidelines listed in
hydrated lime when hydroseeding. If legume Tables 5 and 6.
inoculant is used, seeding shall be accomplished
within 3 to 4 hours after slurry is mixed, or a fresh Planting Dates
supply of inoculant shall be added. If possible after Use Figure 1 and Table 2 to determine the
seeding, the area shall be tracked with heavy recommended planting dates for selected mixes.
machinery such as a bulldozer to improve seed to
Supplemental Watering
soil contact.
If soil moisture is deficient, supply new seedings
with adequate water (a minimum of 1/4-inch twice
Temporary Seeding a day) until vegetation is well established. This is
When the period of soil exposure is more than two especially necessary when seedings are made in
months but less than twelve months, a temporary abnormally dry or hot weather or on droughty soils.
seeding (usually an annual grass) shall be used to
provide short-term cover on disturbed areas. See
MULCHING
Table 1 for recommended plant species and
planting rates. Mulch shall consist of natural and/or artificial non-
toxic materials, such as coconut fibers, wood
Temporary seedings shall be planted as a nurse shavings, straw, hay, bark chips, plastic, or fabric
crop with a permanent seeding mixture when of sufficient thickness and durability to achieve the
rapidly growing cover is needed. When seeding intended effect for the required time period.
NRCS, MA
September 2001
Tackifiers, emulsions, netting, pinning, or other protection and allow adequate light penetration for
methods of anchoring mulch shall be sufficiently seedling germination. Straw or hay shall not be
durable to maintain mulch in place until it is no chopped or finely broken during application.
longer needed.
On sites where mulch is exposed to displacement
Mulch shall be used where needed to accomplish by wind and water, it shall be anchored
one or more of the following purposes: immediately after placement. One of the following
methods shall be used, depending on the size of the
Provide temporary erosion control when
area, steepness of slope, and costs.
!
seeding must be delayed until the proper
planting dates, or until plantings become well Mulch Netting.
established; Cover mulch with degradable plastic, jute, or cotton
! Conserve soil moisture to aid seed germination netting. Staple the netting in place using wire
and plant survival; staples;
! Reduce weed growth in planted areas; Crimper.
! Reduce surface compaction or crusting, and Use a tractor-drawn mulch anchoring coulter
improve water infiltration. (crimper) to cut mulch into the soil surface, so as to
anchor part of the mulch and leave part standing
All newly planted areas that are subject to erosion upright. Follow the general contours of the site
shall be mulched. If dense ground cover is already when crimping mulch. Crimping operations are
present after planting (e.g., there is a previously limited to areas accessible by tractor;
seeded nurse crop sufficient to control soil erosion),
then this mulching requirement shall be considered Liquid Mulch-Binders.
met. Use one of the following:
Organic and Vegetable-Based Binders.
Soil Stabilization Matting Mix with water and apply to mulch to form an
Soil stabilization matting shall have a uniform insoluble polymer gel binder. Use at rates and
thickness and distribution of natural or under weather conditions as recommended by the
biodegradable synthetic fibers or cords that freely manufacturer. These mulch binders shall be
allow penetration by water and plant seedlings. physiologically harmless and not impede the
Matting shall resist decay for a minimum of 6 germination and growth of desired vegetation;
months and a maximum of 12 months. Matting Synthetic Binders.
shall not contain any harmful chemicals or other
materials that may leach into the soil, or reduce the Mix with water and apply to mulch to form an
germination and establishment of seedlings. insoluble high polymer synthetic binder. Use at
rates and under weather conditions as
Matting products shall be applied on seeded areas recommended by the manufacturer.
and shall be secured to the soil surface according to
the manufacturer's instructions. Soil stabilization
matting is especially applicable where high water Wood Fiber or Paper Fiber Mulch
velocities are expected. Mulch made from wood, paper, or plant fibers shall
be applied at the rate of 2,000 pounds per acre, or
as recommended by the product manufacturer.
Straw or Hay Mulch Mulch shall not contain any germination or growth
Straw or hay shall be applied at the rate of 2 tons inhibiting materials. It may be applied by
per acre (90 pounds per 1,000 square feet) hydroseeder, but shall not be mixed in the tank with
immediately following seeding. Straw and hay seed. Use shall be limited to flatter slopes and
shall be unweathered and free of any known viable during optimum seeding periods in the spring and
seeds of objectionable weeds such as Johnsongrass, fall. Do not use on steep slopes or in concentrated
shattercane, thistle, or others as specified. flow areas.
Spread mulch uniformly by hand or by mechanical
methods so that approximately 85% of the soil
surface is covered. This will provide erosion
NRCS, MA
September 2001
Pelletized Mulch Sod shall not be harvested or transplanted when the

Dry pellets of compressed and extruded paper moisture content (excessively wet or dry) may
and/or wood fiber products shall be applied by adversely affect its survival.
hand or mechanical spreader at the rate of 60 to 75
pounds per 1,000 square feet, in accordance with Planting Dates
the manufacturer's recommendations. Pelletized
Use Figure 1 and Table 2 to determine the
mulch may contain co-polymers, tackifiers,
appropriate planting dates for sod.
fertilizers, and coloring agents. Apply 1/4 to 1/2-
inch of water after spreading pelletized mulch to The optimum planting period is in early fall,
activate and expand the mulch and to provide followed by the spring planting period. Sod may be
sufficient soil coverage. This mulch material is planted during the summer if supplemental
especially applicable for small lawns or renovation watering will be provided until the sod is well
areas where weed-free mulch is desirable, or straw established. The fall planting season is limited by
mulch and tackifiers are not practical. the amount of time the sod has to develop roots
before the ground freezes. Newly sodded areas
usually need 4 to 6 weeks before the sod is
Bark Mulch sufficiently rooted. Similarly, the spring planting
Shredded hardwood bark mulch or bark chips shall season is limited by the high temperatures and
be applied to a depth of 2 to 3 inches around drought of summer, unless supplemental water will
plantings of trees, shrubs, groundcovers, and vines. be provided.
Bark mulch and chips shall be well-aged, and shall
be applied to provide at least 85% ground cover of
the site. Shredded hardwood bark mulch, rather Installation
than bark chips, shall be used on steeper slopes Prior to sodding, the soil surface shall be cleared of
because it is less subject to movement by water. roots, brush, trash, debris, and other objects that
would interfere with planting. Based on a soil test,
lime and fertilizer shall be evenly applied as
SOD needed, and mixed into the top 3 inches of soil.
Sod Quality and Treatment The site shall then be raked smooth in preparation
Sod used shall be state certified sod which is at for laying the sod.
least one year old but not older than 3 years. During periods of high temperature, the soil shall
Commonly available sod types include Kentucky be lightly watered immediately prior to laying the
Bluegrass blends, and Tall Fescue/Kentucky sod. Sod strips shall be laid lengthwise on the
Bluegrass mixes. contour, never up and down the slope, starting at
Sod shall be machine cut to uniform thickness of the bottom of the slope and working up. On steep
3/4-inch, plus or minus 1/4-inch, at the time of slopes, the use of ladders will facilitate the work
cutting. Measurement of thickness shall exclude and prevent damage to the sod.
top growth or thatch. Sod strips shall be laid in staggered rows, with
Standard size sections of sod shall be strong enough joints butted tightly together to prevent voids. Sod
to support their own weight and retain their shape shall be rolled or tamped immediately following
when suspended vertically with a firm grasp of the placement to insure solid contact of root mat and
upper 10% of the section. soil surface. Sod strips shall not be overlapped.
Individual pieces of sod shall be cut to the On slopes greater than 3:1, sod shall be secured to
supplier's width and length. Maximum allowable the soil surface with wooden pegs or wire staples.
deviation from standard widths and lengths shall be Where surface water cannot be diverted from
no more than 5%. flowing over the face of a sodded slope, a capping
Sod shall be harvested, delivered, and installed strip of heavy jute or plastic netting, properly
within a period of 36 hours. Sod not transplanted secured, shall be installed along the crown of the
within this period shall be inspected and approved slope and edges to provide extra protection against
prior to its installation. lifting and undercutting of sod. The same
technique shall be used to anchor sod in water-
carrying channels and other critical areas. Wire
NRCS, MA
September 2001
staples shall be used to anchor netting in channel Planting Dates

work. Use Figure 1 and Table 2 to determine the
appropriate planting dates for the different types of
Supplemental Watering plant materials.
Immediately following installation, sod shall be
watered until moisture penetrates the soil layer Installation
beneath the sod to a depth of 4 inches. Maintain Soil shall be prepared by incorporating 2 inches of
optimum moisture for at least 2 weeks by lightly compost or peat moss into the upper 8 inches of
watering the sod on a regular (usually daily) basis, soil. If needed based on a soil test, lime and
unless sufficient rainfall has occurred. Do not fertilizer shall also be incorporated into the soil. In
allow the sod to dry out completely. After the sod the absence of a soil test for very small sites (e.g.,
begins to take root, reduce the frequency of in home landscaping areas), fertilizer may be added
watering and increase the amount of water applied at the rate of 3 pounds of
per watering. This encourages the development of 5-10-10 grade fertilizer (or equivalent) per 100
a deep root system and ultimately reduces the square feet.
amount of water needed.
Install the plants at a spacing that is based on their
present size, expected rate of growth, and how
GROUNDCOVERS quickly a complete cover is desired. In general,
On sites where grass is difficult to grow or spacing shall be one plant for every 1 to 4 square
maintain, other perennial groundcovers may be feet, using a staggered spacing between rows.
used to control erosion. Groundcovers are low-
The entire planted slope shall be covered with a
growing herbaceous plants, vines, and creeping
mulch that will provide sufficient erosion control
shrubs that spread quickly to form a dense cover.
during the establishment period. Refer to the
These plants should not be expected to provide
"Mulching" section of these guidelines for
erosion control or prevent soil slippage on sites that
application rates and methods.
are inherently unstable due to soil texture,
structure, water movement, or excessive slope.
TREES AND SHRUBS
Selection of Plant Species If trees and shrubs will be used on a critical area,
the soil surface shall be stabilized with mulch or
Low-maintenance groundcovers are available to
with a low-growing herbaceous planting to control
suit a variety of conditions, especially for small
erosion until the woody plants are large enough to
areas around homes and commercial buildings.
serve that purpose.
These plants generally require more care than turf
during the initial establishment period, but may Refer to Table 7, "Species for Tree and Shrub
require less care after establishment. Plantings in Massachusetts", for a selected list of
native tree and shrub species that may be used.
Species recommendations may be found by
Other trees and shrubs that are native, or are
consulting publications in the "References" section
introduced and are non-invasive, may also be
of these guidelines. Be cautious of using species
suitable.
that have aggressive growth habits and may spread
beyond the planted area, especially if the planting is For selection and use of trees and shrubs as part of
near a neighboring property or a natural area such a soil bioengineering system for upland slopes,
as a shoreline or woodland. Species such as refer to Chapter 18 of the Engineering Field
English Ivy (Hedera helix) and Periwinkle (Vinca Handbook.
minor) tend to grow rapidly once established, and
should not be used except under well-contained
conditions.
NRCS, MA
September 2001
OPERATION AND MAINTENANCE Lime according to soil test recommendations at

least once every five years.
General Requirements for All Plantings
Corrective actions shall be taken as needed to
replace destroyed plant material or dislodged Groundcovers
mulching material. Reshape the soil surface and
replant areas where prolonged slope instability is Use a soil test analysis to determine the need for
present. Where vegetative efforts have failed, lime and fertilizer. Spread 2 to 3 inches of organic
reassess the need for structural measures to mulch such as shredded hardwood bark or bark
complement vegetative measures. chips to reduce evaporation of moisture from the
soil and help reduce invasion by weeds.
Invasions by undesirable plants shall be controlled Use hand tools to remove weeds from between
by pulling, mowing, or spraying with a selective plants. Some perennial weeds, such as thistle and
herbicide. Where wildlife habitat is a concern, do dandelion, are difficult to remove by hand weeding,
not mow during the primary nesting season (April and may require spot treatment with a nonselective
15 to July 15). Noxious weeds shall be controlled broadleaf herbicide. Care must be taken to avoid
as required by state law. herbicide contact with the desired groundcovers or
vines, because they are susceptible to being killed
Inspect for insects and diseases, and if an incidence or severely damaged by nonselective herbicides.
threatens stand survival, take corrective action to Follow all label directions when using herbicides.
bring the pest under control.
Trees and Shrubs
Grasses and Legumes Follow the maintenance recommendations in the
During the establishment period, plantings shall be Massachusetts Job Sheet for Trees and Shrubs.
monitored for germination success, water stress,
pest problems, and damage by erosion. After one SUPPORTING DATA AND
full year from planting, all areas with less than 85% DOCUMENTATION
plant cover shall be replanted according to the
following recommendations: The following is a list of the minimum data and
documentation to be recorded in the case file:
1. If the stand provides less than 40% ground 1. Completed copy of the appropriate Job Sheet(s)
cover, reestablish following the original or other specifications, and management plans.
seedbed preparation, lime, fertilizer, and The following items shall be addressed, as
seeding recommendations; appropriate:
2. If the stand provides 40 to 84% ground cover, a. Method of site preparation and type of
overseed and fertilize using one-half the seedbed preparation;
original rate. On small areas, reseeding may be b. Conservation Practice Code to be seeded,
accomplished by broadcasting and lightly or type of problem site;
raking the seed. For larger areas, use of a grass
drill or cultipacker-seeder is preferable. c. Species and rates to be seeded/planted;
d. Seeding/planting dates;
Spring seedings may require an application of
fertilizer between September 1 and October 15, at e. Rate and type of soil amendments to be
least every two years, according to soil test applied;
recommendations. Mixtures dominated by legumes f. Rate and type of mulch and anchoring
may only need topdressing once every three years methods.
according to soil test recommendations.
2. Field location and extent of planting in acres,
If a slow release form of nitrogen (such as ureaform and assistance notes. Also note the location of
or Osmocote ) was used, a follow-up topdressing of the planting on the conservation plan map.
nitrogen may not be necessary for several years.
NRCS, MA
September 2001
REFERENCES
Kerrigan, Jack. Ground Covers for the Home Russ, Karen, and Bob Polomski, 1999. Vines.
Landscape. Ohio State University Cooperative Clemson University Cooperative Extension
Extension Service, Horticulture and Crop Service, Home and Garden Information Center,
Science, Fact Sheet HYG-1050-97. Available Publication HGIC 1101. Available on-line:
http://hgic.clemson.edu/factsheets/HGIC1101.htm
on-line: http://www.ohioline.ag.ohio-state.edu/hyg-
fact/1000/1050.html
Rutgers Cooperative Extension Service. Turfgrass
Kluepfel, Marjan, and Bob Polomski, 1999. Seed Selection for Home Lawns. FS684. 1995.
Groundcovers. Clemson University Cooperative Cook College, Rutgers University.
Extension Service, Home and Garden
Information Center, Publication HGIC 1100. Rutgers Cooperative Extension Service.Fine
Available on-line: Fescues:Low Maintenance Species for Turf.
http://hgic.clemson.edu/factsheets/HGIC1100.htm
FS688.1996.Cook College, Rutgers University.
Marrotte, Edmond. University of Connecticut, Rutgers Cooperative Extension Service. New

Cooperative Extension Service. Lawn Jersey Seed Standards for Sod Certification
Construction and Maintenance. FS6738. 1997. Cook College, Rutgers University.
Maryland Seeding Association, 1999. MSA Rutgers Cooperative Extension Service. Managing
Guideline Specifications 1999 (MSA-GS-99). Soil pH for Turfgrasses FS635. 1994. Cook
Available on-line: http://www.marylandseeding.org College, Rutgers University.
Pennsylvania State University, College of Rutgers Cooperative Extension Service.

Agricultural Sciences. The Agronomy Guide, Sodding:Steps to an Instant Lawn.FS104. 2000.
1999-2000. Available on-line: Cook College, Rutgers University.
http://agguide.agronomy.psu.edu/
University of Rhode Island, Cooperative Extension
Pennucci, Annamarie and Langille, Alan. An Service. GreenShare Factsheet: Selection of
Evaluation of Turfgrass Species and Varieties: Turfgrasses. 1999.
Fine Fescues. 1999. Maine Agricultural and
Forest Experiment Station.University of Maine. USDA, Agricultural Marketing Service and Seed
Misc. Report 413. Regulatory and Testing Branch, 2000. State
Noxious-Weed Seed Requirements Recognized in
Relf, Diane, and Bonnie Appleton, 2000. Selecting the Administration of the Federal Seed Act.
Landscape Plants: Ground Covers. Virginia Available on-line:
http://www.ams.usda.gov/lsg/seed/seed_pub.htm
Cooperative Extension Service, Environmental
Horticulture, Publication 426. Available on-line:
http://www.ext.vt.edu/pubs/envirohort/426-609/426-
USDA, Natural Resources Conservation Service,
609.html
Engineering Field Handbook, Chapter 18, Soil
Bioengineering for Upland Slope Protection and
Roberts, John and Seavey, David. Low Erosion Reduction.
Maintenance Turfgrass for Landscapes and
Commercial Agriculture. 1993. University of
New Hampshire, Cooperative Extension Service.
NRCS, MA
September 2001
Critical Area Planting Specifications, 342-10
FIGURE 1: USDA Plant Hardiness Zones for Massachusetts
NRCS, MA
September 2001
TABLE 1: Temporary Seeding for Site Stabilization
Recommended Seeding Dates

Seeding Rate 1/ Seeding
by Plant Hardiness Zone 3/
Depth
Plant Species (inches)
lbs/ac lbs./ 2/
1,000 sf 4b & 5a 5b 6a, 6b, & 7a
Cool-Season Grasses
Annual Ryegrass
Apr 1 to May 31 Mar 15 to May 31 Mar 1 to May 31
Lolium perenne 40 1.0 0.5
Aug 1 to Sept. 1 Aug 1 to Sept. 15 Aug 15 to Sept 30
ssp. multiflorum
Oats Apr 1 to July 1 Mar 15 to Jun 15 Mar 1 to Jun 1
86 2.0 1.0
Avena sativa Aug 1 to Sep 30 Aug 1 to Oct 15 Aug 15 to Sept 30
Cereal Rye
112 2.8 1.0 Aug 15 to Oct 15 Sept 1 to Nov 1 Sept 1 to Nov 15
Secale cereale
Warm-Season Grass
Foxtail Millet
30 0.7 0.5 Jun 1 to Jul 31 May 1 to Jul 31 May 1 to Aug 15
Setaria italica
TABLE 1 NOTES:
1. Seeding rates for the warm-season grasses are in pounds of Pure Live Seed (PLS). Actual planting rates shall be
adjusted to reflect percent seed germination and purity, as tested. No adjustments are necessary for the cool-season
grasses.
Seeding rates listed above are for temporary seedings, when planted alone. When planted as a nurse crop with
permanent seed mixes, use 1/3 the seeding rate listed above for barley, oats, wheat, and cereal rye. For smaller-
seeded grasses (annual ryegrass, pearl millet, foxtail millet), do not exceed more than 5% (by weight) of the overall
permanent seeding mix.
Oats are the recommended nurse crop for warm-season grasses. Do not use cereal rye with warm-season grasses; it
has been shown to have allelopathic properties that inhibit the germination and growth of warm-season grasses.
2. For sandy soils, plant seeds at twice the depth listed above.
3. The planting dates listed are averages for each Zone, and may require adjustment to reflect local conditions,
especially near the boundaries of the zone.
NRCS, MA
September 2001
TABLE 2: Recommended Planting Dates for Permanent Cover

Massachusetts 1/
Plant Hardiness Zones
Type of Plant Material
4b & 5a 5b 6a, 6b, & 7a
Cool-Season Apr. 1 to May 31 Apr.1 to May 15 Mar. 15 to May 15
Seed Mixes Aug 1 to Sep 10 Aug 1 to Oct 15 Aug 15 to Oct 31
Grasses Warm-Season/ Mar.15 to Jun.15
Apr. 1 to May 15 Apr. 1 to May 31 (May 1 to May 31)*
& Cool-Season
(Jun 1 to Jun 15)* (May 1 to Jun 15)*
Seed Mixes Nov 1 to Dec. 31!
Legumes
Apr. 1 to May 31 Apr.1 to May 15 Mar. 15 to May 15
Cool-Season Sod (Jun 1 to Aug 15)* (May 1 to Sep 1)* (May 1 to Sep 15)*
Aug. 15 to Oct 1 Sept.1 to Oct 15 Sept 15 to Oct.30
Apr.1 to May 31 Apr. 1 to May 15 Mar.15 to May 15
Seeds
Aug.15 to Sept.15 Sept.1 to Oct.15 Sept.15 to Oct.30
Bare-Root Apr 1 to May 31 Mar 15 to May 30 Feb 15 to May 30
Forbs Seedlings Jun 1 to Jun 30* May 15 to Jun 30* May 1 to Jun 30*
Same as bare-root Same as bare-root Same as bare-root
Containerized
except: except: except:
Stock
Sept.1 to Oct.15* Sept.15 to Nov.1* Sept.15 to Nov.1*
TABLE 2 NOTES:
1. The planting dates listed are averages for each zone. These dates may require adjustment to reflect local conditions,
especially near the boundaries of the zones. When seeding toward the end of the listed planting dates, or when
conditions are expected to be less than optimal, select an appropriate nurse crop from Table 1 and plant with the
permanent seeding mix. (See Table 1, Note 1 for more information.)
2. !Additional planting dates for the Cape and Islands, dependent on annual rainfall and temperature trends.
Recommend adding a nurse crop, as noted above, if planting during this period.
3. *Additional planting dates during which supplemental watering may be needed to ensure plant establishment.
NRCS, MA
September 2001
TABLE 3. Grasses & Legumes For Erosion Control in Massachusetts

Species Characteristics
Plant
Common Name Scientific Name Native Season Environmental
Type*
Tolerance*
Beachgrass, American Ammophila breviligulata Yes Cool S,D M,G
Bentgrass,Creeping Agrostis stolonifera Yes Cool F,W
var. palustris M,P,G,
R
Bluegrass, Canada Poa compressa No Cool D,S,s,W S,P,G,R
Bluegrass, Kentucky Poa pratensis No Cool S S,P,G,R
Bluestem, Big Andropogon gerardii Yes Warm D,S L,P,G,B
Bluestem, Little Schizachryrium scoparium Yes Warm D,S
M,P,G,
B
Bromegrass, Smooth Bromus inermis No Cool D,F,S,w
M,P,G,
R
Bromegrass, Fringed Bromus, ciliatus Yes Cool S,s,w
M,P,G,
R
Broomsedge Andropogon virginicus Yes Warm D,S
M,P,G,
B
Bushclover, Hairy Lespedeza hirta Yes Warm S L.P
Bushclover, Round Head Lespedza capitata Yes Warm D,S L,P
Cordgrass, Freshwater Spatina pectinata Yes Cool F,Na,S,W M,P,G
Cordgrass, Saltmeadow Spartina patens Yes Warm F,Na,S,W S,P,G
Cordgrass, Smooth Spartina alterniflora Yes Warm F,Na,S,W L,P,G
Cut Grass, Rice Leersia oryzoides Yes Cool F,S,W M,P,G
Deertongue Grass Dicanthelium clandestinum Yes Warm D,S,W S,P,G,R
Dropseed, Poverty Sporobolus vaginiflorus Yes Warm D,S
S,A,G,
B
Fescue, Red Festuca rubra Yes Cool F,S,w
M,P,G,
R
Flatpea Lathyrus sylvestris No Cool D,S,W P,HV
Groundnut Apios americana Yes Cool F,S,s P,HV
Indiangrass, Yellow Sorghastrum nutans Yes Warm D,F,S L,P,G,B
Lovegrass, Tumble Eragrostis spectabilis Yes Warm D,S S,P,G,B
Manna Grass, Canada Glyceria canadensis Yes Cool W M,G
Manna Grass, Fowl Glyceria striata Yes Cool W M,G
Meadow Grass, Fowl Poa palustris Yes Cool S,W M,P,G
Pea, Beach Lathyrus japonicus Yes Cool D,S,Na P,HV,R
Red Top Agrostis alba No Cool D,S,W,F
M,P,G,
R
Reed Grass, Blue Joint Calamagrostis canadensis Yes Cool F,S,W L,P,G
Ryegrass, Perennial Lolium perenne No Cool W M,P,G,
B
NRCS, MA
September 2001
Rye, Canada Wild Elymus canadensis Yes Cool D,S,s,Na L,P,G,R

Rye, Riverbank Wild Elymus riparius Yes Cool F,s,w
M,P,G,
R
Rye, Virginia Wild Elymus virginicus Yes Cool F,S,s
M,P,G,
R
Switchgrass Panicum virgatum Yes Warm D,F,Na,S,W L,P,G,R
Trefoil, Showy-Tick Desmodium canadense Yes Cool D,S L,P
Wood Reed, Stout Cinna arundinacea Yes Cool s,W L,P,G
*See legend on following page
Table 3 Legend
Environmental Plant Type

Tolerance
D Drought L Large (> 4 ft.)
F Flood M Medium (< 4 ft.)
Na Salt S Small (< 2 ft.)
S Full Sun HV Herbaceous Vine
s Shade A Annual
W Wet Soil P Perennial
G Grass
R Rhizomotous
B Bunch
Prepared By NRCS - Amherst.

Native Plant List from Massachusetts NHESP, B.Sori and P.Somers
Environmental Tolerance and Plant Type adapted from “Landscape Restoration Handbook”, Lewis Publishers
NRCS, MA
September 2001
TABLE 4. Grasses And Legumes For Critical Area Planting

In Massachusetts
Plant Name Plant Characteristics Uses and Establishment Notes
American Beachgrass " Native to Massachusetts, in fact " Tolerant of droughty sands, full
(Ammophila breviligulata) the ‘Cape’ variety available sun
from nurseries, is the native " Intolerant of foot and vehicular
strain traffic
" Extensively rhizomatous in " Established by planting dormant
sandy soils and readily grows stems (culms) , 2-3 per planting
up through new deposition unit on 12”-18” centers
layers (dunes) " Useful as initial vegetative cover
" 3’ mature height on dunes and other sandy sites, to
" Adapted to coastal dunes be later inter-planted with native
" Cool Season woody shrubs
Bentgrass, Creeping/Marsh " Native to Massachusetts " Tolerant of wet soils and flooding
(Agrostis stolonifera " Rhizomotous perennial " Seed in mixes at 1lb./acre rate
Var. palustris) " Sod forming (4.5 millon seeds/pound)
" Adapted to wet meadows, " Suitable for waterways and ditch
shores and coastal marshes, or pond banks
FACW, Cool Season
Bluegrass, Canada " Introduced to Massachusetts " Useful on dry, low fertility soils
(Poa compressa) " Rhizomotous perennial " Tolerant of drought, full sun,
" Open sod forming shade and wet soil
" 2’ mature height, FACU " slow starter
" Cool Season " Use in mixes only
Bluegrass, Kentucky " Introduced to Massachusetts " Grows best on well-drained fertile
(Poa pratensis) " Rhizomotous perennial soil with pH 5.5-7.0
" Turf forming " Avoid acid soils
" 3’ mature height, FACU " Useful in lawn-type mixes
" Cool season " Tolerant of moist or dry sites
Bluestem, Big " Both are Native to " Tolerates medium to low fertility
(Andropogon gerardii) Massachusetts soil with pH 5.0-7.5
" Perennial bunchgrasses, with " Seed at 2 to 5 lbs. per acre in a
Bluestem, Little dense root systems mix and 5 to 10 lbs. per acre when
(Schizachryrium scoparium) " Big (7’ height), Little (3’ seeded alone
height) " Useful for stabilizing sand and
" Big (FAC), Little (FACU-) gravel pits, road sides and mine
" Both are Warm Season spoil
" Adapted to hot, dry, sunny sites " slow to germinate the first year
in sandy, loamy or silt soils " Seed in early spring with a native
grass drill. Roll or cultipack
Bromegrass, Smooth " Introduced to Massachusetts " Tolerant of heat, drought and
(Bromus inermis) " Rhizomotous perennial periodic flooding
" Forms coarse dense sod " Prefers fertile soils with pH 5.5-
" Adapted to diverse types of 8.0
soils, but not wet soils " Suited for waterways,channels,
" 3 - 4’ mature height, pond banks where soils do not
" Cool Season remain wet.
NRCS, MA
September 2001
TABLE 4, cont.
Bromegrass, Fringed " Native to Massachusetts " Tolerant of full sun or partial
(Bromus ciliatus) " Rhizomotous perennial shade
" FACW " Good species for moist soils
" 1 - 5’ mature height " Suitable for waterways and pond
" Cool Season banks
Broom-Sedge " Native to Massachusetts " Adapted to dry, open sites with a
(Andropogon virginicus) " Perennial bunchgrass variety of soil types
" FACU " Suited for general erosion control
" 2’ - 5’ mature height, FACU where an eastern prairie
" Warm Season appearance is desired
Bushclover, Hairy " Native to Massachusetts " Open, sandy, sterile sites
(Lespedeza hirta) " Erect perennial " Use in mixes with native, warm
" Warm Season season grasses.
Bushclover, Round Head " Native to Massachusetts " Roadsides, sandy, dry sites
(Lespedeza capitata) " Erect perennial " Useful in mixes with native, warm
" Warm Season season grasses
Cordgrass, Freshwater " Native to Massachusetts " Tolerant to flooding, and salt
(Spartina pectinata) " OBL " Suited to wet soil in eastern
" 2’ - 7’ mature height prairie applications
" Adapted to upland edge of salt " Suitable for streambank or
marshes where soil is relatively wetland stabilization
dry
" Warm Season
Cut Grass, Rice " Native to Massachusetts " Tolerant of saturated soils, full
(Leersia oryzoides) " OBL sun and flooding
" 2 - 5’ mature height " Suited for waterways,
" Cool Season pond/ditch/stream banks
stabilization
Deertongue Grass " Native to Massachusetts " Best grass for acid soil sites
(Dicanthelium " Perennial, spreads slowly by " Tolerant of low fertility sites
clandestinum) seed and rhizomes " Use for cover of erodible sandy
" Up to 3’ mature height areas such as road/ditch banks and
" FAC+ sand and gravel borrow areas.
" Adaptation: dry to moist sites " Seed in mixes at rate of 5-10
with full sun to partial shade lbs./ac.
" Warm Season " Seed with other native warm
season species or with perennial
ryegrass
Dropseed, Poverty " Native to Massachusetts " Tolerant of dry sites with full sun
(Sporobolus vaginiflorus) " Annual bunchgrass and low fertility
" 1’ - 2’ mature height UPL " Suitable as a native nurse crop for
" Shallow root system warm season mixes
" Warm Season " Adapted to dry roadside sites
NRCS, MA
September 2001
TABLE 4, cont.
Fescue, Red " Festuca rubra is a species " Valuable for its shade tolerance
native to Massachusetts " Suited for close growing cover in
Creeping Red Fescue " Short perennial with round, mixes; seed at rate of 10-40
(Festuca rubra var rubra) wiry basal leaves lbs.per acre depending on use
" Creeping Red Fescue tends to " Adapted to a wide variety of soil
Chewings Red Fescue grow in tufts on low fertility types; tolerant of dry and very
(Festuca rubra commutata) sites, but spreads by rhizomes moist sites
in more fertile soils. Chewings " Suited for low maintenance areas,
is a true bunch type general purpose turf or in mixes
" FACU for wood roads, landings,
" Cool Season roadbanks etc.
" Adapted to full or partial shade
Flatpea " Introduced to Massachusetts " Adapted to a variety of sites from

(Lathyrus sylvestris) " Deep-rooted perennial dry to moist.
" Long, climbing, vine-like stems " Slow to germinate
" Established stand resist " Seed alone (with perennial
encroachment by other plants ryegrass) for utility rights-of-way
Groundnut " Native to Massachusetts " Moist soils
(Apios americana) " Climbing vine, 1-3 m in length " Use in mixes for pond and
" From rhizome streambanks
Indiangrass " Native, Perennial, Warm " Grows best in fertile loam
(Sorghastrum nutans) Season Bunchgrass. " Has a light and fluffy seed.Use a
" 3’ - 5’ mature height native grass drill designed for
chaffy seed.
" Seed at 2-5 lbs. per acre in a mix
or 5-10 lbs./ac. alone
Lovegrass, Tumble " Native, Perennial, Warm " Suited to Dry sites with Full Sun
(Eragrostis spectabilis) Season Bunchgrass. " Purplish-pink appearance in
" 12”-18” height, UPL flower (late summer)
" Low maintenance
Manna Grass, Canada " Native, Perennial, Cool Season " Suited to very wet sites
(Glyceria canadensis) " 2’-3’ height, " Good for initial wetland cover
" OBL
Manna Grass, Fowl " Native, Perennial, Cool Season " Suited to very wet sites
(Glyceria striata) " 2’-3’ height, " Low maintenance
" OBL
Meadow Grass, Fowl " Native, perennial, Cool " Suited to very wet sites with full
(Poa palustris) Season sun
" Spreads by rhizomes " Use in waterways, ditches and
" 3’ height, FACW pond/stream banks
Pea, Beach " Native to Coastal " Adapted to beach/dune sites
(Lathyrus japonicus) Massachusetts " Seeded in moist, inter-dune areas
" Perennial with rhizomes
NRCS, MA
September 2001
TABLE 4, cont.
Red Top " Introduced to Massachusetts " Suited to full sun, wet or dry sites
(Agrostis alba) " Cool Season, spreading, " Seed at 1 lb/ac. or less in mixes
perennial grass " Suited to pH 4.0-7.5
" FACW " Suited in mixes for waterways,
road banks, diversions or critical
areas
Reed Grass, Blue Joint " Native, Cool Season, Perennial " Adapted to wet sites with full sun
(Calamagrostis canadensis) " 4-5’ height, Spreads by " Tolerates flooded conditions
rhizomes " Suited for waterways, ditches,
" FACW+ pond/stream banks
Rush, Path " Native, perennial " Adapted to full or partial sun
(Juncus tenuis) " 12” height " Tolerant of flooding , wet soils
" FAC- and compacted soils
" Suited for cover of access road
surfaces
Switchgrass " Native to Massachusetts " Adapted to a wide range of sites:
(Panicum virgatum) " Warm Season, Bunchgrass " Dry, Moist, Wet, Full Sun or
" 3 -5’ height, FAC Partial Sun
" Provides excellent nesting and " Tolerant of salt
fall and winter wildlife cover " Seed at 5 - 10 lbs. PLS per acre in
" Expect 1-2 yrs. for mix or 15 lbs. PLS per acre alone
establishment " Suited to pH of 4.5-7.5
Ryegrass, Perennial " Introduced to Massachusetts " Best in moist soils and has fair
(Lolium perenne) " Cool Season drought tolerance
" Fast Growing, Short lived " Seed in mixes at rate of 10
perennial lbs./acre
" 2’ mature height, FACU-
Trefoil, Showy-Tick " Native to Massachusetts " Adapted to dry open sites
(Desmodium canadense) " Has taproot and 4-20 dm height
Wild Rye, Canada " Native, Cool Season perennial " suited to dry-moist sites with full
(Elymus candensis) Bunchgrass sun or partial shade
" -6 height, FACU+ " Seed in mixes at 5 lbs./acre
" Good wildlife food and cover
Wild Rye, Riverbank " Native, Cool Season, Perennial " Suited to moist to wet sites with
(Elymus riparius) Bunchgrass partial shade
" 3-5’ height, FACW " Tolerates flooding
Wild Rye, Virginia " Native, Cool Season, Perennial " Suited to wet sites but can tolerate
(Elymus virginicus) Bunchgrass drought. Can tolerate shade.
" 4-5’ height, FACW- " Good initial grass for seeding
" Good wildlife food and cover newly established wetlands
Wood Reed, Stout " Native, Cool Season, Perennial " Adapted to interior woodland and
(Cinna arundinacea) " 5’ height woodland borders
" FACW " Tolerant of shade
NRCS, MA
September 2001
TABLE 5: Recommended Permanent Seeding Mixtures by Purpose

Massachusetts Seeding Mix No.
Purpose of the Planting
1 2 3 4 5 6 7 8 9 10 11
Steep Slopes, Roadsides ! ! ! ! ! ! ! !
Sand and Gravel Pits, Sanitary Landfills ! ! ! ! ! ! ! !
Mine Spoil, Dredged Material, and Spoil Banks ! ! ! ! ! ! ! !
Utility Rights-of-Way ! ! ! ! ! ! !
Dikes and Dams ! ! ! ! !
Berms, Low Embankments (not on Ponds) ! ! ! ! ! ! ! ! !
Pond and Channel Banks, Streambanks ! ! ! ! ! !
Grassed Waterways, Diversions, Terraces, Spillways ! ! ! ! ! !
Bottom of Drainage Ditches, Swales, Detention Basins ! ! ! ! ! !
Field Borders, Filter Strips, Contour Buffer Strips ! ! ! ! ! ! ! ! ! !
TABLE 5 NOTES:
!Recommended best mix for this purpose.
! Alternative mix, depending on site conditions.
NRCS, MA
September 2001
TABLE 6: Permanent Herbaceous Seeding Mixtures
Recommended Seeding Rate 1/ Soil Max.

Mix Cultivars Maint. Remarks
lbs./ac. lbs./ Drainage Height
Level 3/
(Endophyte free) 1000 sq .ft. Class 2/ (feet)
WARM-SEASON/COOL-SEASON GRASS MIXES

1. Switchgrass Panicum virgatum Blackwell, Carthage, 10 0.23 Good sand stabilizing mixture using
Cave-in-Rock, or all native species.
Shelter If little bluestem is used, mix needs to
Little (seacoast) bluestem Aldous, Blaze, or coastal 3 0.07 be seeded with a specialized native
ecotype grass drill.
Schizachyrium scoparium (var. littoralis)
Canada Wildrye Elymus canadensis Common 5 0.11 Canada wildrye is a quick establishing,
short-lived companion grass.
OPTIONAL: E - MW 3-4 C-D
Purple lovegrass Eragrostis spectablis Common 2 0.05 Purple lovegrass seed may be difficult
to obtain commercially.
PLUS TWO OF THE FOLLOWING LEGUMES:
Partridge Pea Chamaecrista fasciculata Common 4 0.09 Partridge pea is a reseeding annual with
good wildlife value. All the legumes
Beach pea Lathyrus japonicus Common 2 0.05 are adapted to coastal conditions.
Wild Indigo Baptisia tinctoria Common 2 0.05 Beach pea seed may be difficult to
obtain.
2. Big Bluestem Andropogon gerardii Niagara 3 0.07 Eastern prairie mixture using all
species native to Massachusetts.
Indiangrass Sorghastrum nutans Rumsey 3 0.07
The indiangrass and bluestems have
Little Bluestem Schizachyrium scoparium Aldous or 4 0.09 fluffy seeds. Plant with a specialized
Blaze native seed drill.
Switchgrass Panicum virgatum Blackwell, Carthage, 5 0.11 On highly erodible sites, include a
Cave-in-Rock, or temporary (annual) grass at 1/3 the rate
Shelter E - MW 5-8 C-D specified in the table, for quick cover.
PLUS ONE OR MORE LEGUMES:
Partridge Pea Chamaecrista fasciculata Common 4 0.09 All the legumes are perennials except
partridge pea, which is a reseeding
Bushclover Lespedeza capitata/hirta Common 2 0.05 annual.
Wild Indigo Baptisia tinctoria Common 2 0.05
All are adapted to droughty soils. Tick
Showy Tick-Trefoil Desmodium canadense Common 1 0.02 trefoil is also adapted to finer-textured
soils.
NRCS, MA
September 2001

Level 3/
3. SELECT THREE GRASSES: Dredge disposal mix. Excellent for
excessively droughty and low pH
Deertongue Dicanthelium clandestinum Tioga 10 0.23 (4.0) soils
Broomsedge Andropogon virginicus Common 3 0.07
If broomsedge is used, a specializd seed
Redtop Agrostis gigantea Streaker, Fireball 1 0.02 drill is needed for fluffy seed.
PLUS: Sheep Fescue Festuca ovina OR Azay, Covar 15 0.34 E - MW 2-4 C-D
Sheep fescue, Canada wild rye, and
Redtop are cool-season companion
Canada Wild Rye Elymus canadensis Common 5 0.11 grasses that will provide immediate
cover for erosion protection.
PLUS: Flatpea Lathyrus sylvestris And/Or Lathco 10 0.23
Flatpea is tolerant of low pH (4.0)
Partridge pea Chamaecrista fasciculata Common 4 0.09 Partridge pea is tolerant to pH 5.0
4. Deertongue Dicanthelium clandestinum OR Tioga 10 0.23 Grassed waterway/Streambank mix
(Good mix for variable soil moisture
Switchgrass Panicum virgatum Blackwell, Carthage, 10 0.23 conditions.)
Shelter, Cave-in-Rock
And: Creeping Red Fescue Festuca rubra Ensylva, Longfellow, 20 0.46 Use switchgrass in grassed waterways.
var. rubra Pennlawn
W-P 2-3 C-D Creeping red fescue provides a quick,
Select One of the Following: low growing cover.
Virginia Wild Rye Elymus virginicus Common 5 0.11
Riparian Wild Rye Elymus riparus Common 5 0.11 Use Virginia or Riparian wild rye on
moist, shady sites; Canada wild rye on
Canada Wild Rye Elymus canadensis Common 5 0.11 droughty sites.
COOL-SEASON GRASS MIXES

5. Creeping Red Fescue Festuca rubra Ensylva, Longfellow, 15 0.34 Traditional grassed waterway mix.
var. rubra Pennlawn
Perennial Ryegrass Lolium perenne OR Blazer II, Pennfine 10 0.23 Use redtop on acid soils (<5.5)
Redtop Agrostis gigantea Streaker, Fireball 1 0.02 W-P 2-3 C-D
And: Alsike clover Trifolium hybridum Common 2 0.05 Alsike clover is adapted to wet soils.
NRCS, MA
September 2001

Level 3/
(CONT.)
6. Orchardgrass Dactylis glomerata OR Any forage variety 10 0.23 Good mix for utility rights of way.
Use orchardgrass if wildlife forage is

Hard Fescue Festuca trachyphylla Biljart, Scaldis, Spartan, 20 0.46 desired.
And: Tornament
MW-SWP 1-2 C-D
Perennial Ryegrass Lolium perenne OR Blazer (II), Pennfine 10 0.23
Use redtop for wetter and lower pH
Redtop Agrostis gigantea Streaker, Fireball 1 0.02 soils.
Plus: Flatpea Lathyrus sylvestris Lathco 15 0.34 Flatpea suppresses woody vegetation
7. Virginia/Riparian Wild Rye Common 5 0.11 Riparian area mix
Elymus virginicus/riparius Good native species mix for shady,
moist conditions (forested floodplain)
Bottlebrush grass Elymus hystrix Common 2 0.05
SWP-P 2-3 D
(Optional):
Wood reedgrass, Fringed bromegrass
Wood reedgrass Cinna arundinacea Common 1 0.02
and Groundnut seed may be difficult
Fringed bromegrass Bromus ciliatus Common 1 0.02
to obtain.
Groundnut Apios americana Common
8. Canada bluejoint Calamagrostis canadensis Common 2 0.05 All native grass mix for waterways,
ditches, and pond banks.
Fowl Meadowgrass Poa palustris Common 2 0.05 SWP-P 3-4 D
Seed may be difficult to obtain.
Creeping bentgrass Agrostis stolonifera Common 1 0.02
9. Canada wildrye Elymus canadensis OR Common 3 0.07 Successional mix. Use to provide
quick, non-aggressive cover that
Virginia wildrye Elymus virginicus Common 3 0.07 allows indigenous vegetation to
Perennial ryegrass Or Common 5 0.11 volunteer.
Redtop Agrostis gigantea Streaker, Fireball 1 0.02 Use Canada wildrye and redtop in
W - SP 2-3 C-D droughty soils.
Plus: (optional)
Partridge pea Chamaecrista fasciculata OR Common 2 0.05 Use partridge pea on dry sites and tick
trefoil on moist sites.
Tick trefoil Desmodium canadense Common 1 0.02
NRCS, MA
September 2001

Level 3/

10. Chewings Fescue Recommended NE turf- 15 0.34 Erosion Control/Wildflower mix
Festuca rubra ssp.commutata types 4/
Attractive mix of fine fescues and
wildflowers for low maintenance
Hard Fescue Festuca trachyphylla Recommended NE turf- 15 0.34
conditions. Once well-established, the
types 4/
grasses may tend to outcompete the
Sheep Fescue Festuca ovina Recommended NE turf- 15 0.34 wildflowers.
types 4/
PLUS WILDFLOWER MIX:

Black-eyed Susan Rudbeckia hirta Common 2 0.05
E - MW 2-3 C-D
Lance-leaved Coreopsis Common 2 0.05 Hydroseeding is not recommended for
Coreopsis lanceolata this mix if wildflowers are used.
(They have very small seeds.)
Purple Coneflower Echinacea purpurea Common 2 0.05
Partridge Pea Chamaecrista fasciculata Common 5 0.11
11. Alkali Saltgrass Puccinellia distans Fults or Salty 20 0.46 Saline (salt) adapted mix
Alkaligrass will persist only under

Creeping Red Fescue Festuca rubra Dawson, Ensylva, 15 0.34
saline conditions.
var. rubra Longfellow, Pennlawn,
Perennial ryegrass Lolium perenne Pennfine 5 0.11 W-P 2-3 B-D Use the 'Dawson' variety of creeping
red fescue in saline conditions.
OPTIONAL ADDITION
Creeping Bentgrass Agrostis stolonifera Seaside, Southshore 2 0.05 Add bentgrass for wet, saline
conditions.
NRCS, MA
September 2001
TABLE 6 NOTES:
1. Seeding rates for the warm-season grasses are in pounds of Pure Live Seed (PLS). Actual planting rates shall be adjusted to reflect percent
seed germination and purity, as tested. No adjustments are necessary for the cool-season grasses, legumes, or wildflowers. All legume seeds
shall be inoculated before planting with the appropriate Rhizobium bacteria.
2. Soil Drainage Class (refer to the county soil survey for further information):
E - Excessively Drained
W - Well Drained
MW - Moderately Well Drained
SP - Somewhat Poorly Drained
P - Poorly Drained
3. Maintenance Level:
A - Intensive mowing (every 2 - 4 days), fertilization, lime, insect and weed control, and watering (examples: high maintenance lawns and
athletic fields).
B - Frequent mowing (every 4 - 7 days), occasional fertilization, lime, pest control, and watering (examples: residential, school, and
commercial lawns).
C - Periodic mowing (every 7 - 14 days), occasional fertilization and lime (examples: residential lawns, parks).
D - Infrequent or no mowing, fertilization, or lime after the first year of establishment (examples: wildlife areas, roadsides, steep banks)
7. Recommended cultivars for New England. Refer to University of Massachusetts, Connecticut, or Rhode Island’s Cooperative Extension
Service Turfgrass Fact Sheets.
NRCS, MA
September 2001
TABLE 7: Quality of Seed 1/.

Minimum Minimum Minimum Minimum
Species Seed Seed Species Seed Seed
Purity Germination Purity Germination
(%) (%) (%) (%)
COOL-SEASON GRASSES WARM-SEASON GRASSES
Alkali saltgrass 85 80 Bluestem, Big 60 60
Barley Little Bluestem,

98 85 Broomsedge 55 60
Bentgrass, Creeping 95 85 Deertongue 95 75

Bluegrass, Canada 90 80 Indiangrass 60 60
Bluegrass, Kentucky 97 80 Lovegrass, Purple -- --
Bluejoint, Canada 85 70 Millet, Foxtail 98 80
Bromegrass, Fringed 85 70 Switchgrass 95 75
Bromegrass, Smooth 95 85 LEGUMES/FORBS

Cordgrass, Freshwater 85 70 Beach pea -- --
Dropseed, Poverty -- -- Bushclover 80 50
Fescue, Creeping Red,
Hard, Chewings, Sheep 97 85 Clover, Alsike 99 85
Meadowgrass, Fowl 90 70 Flatpea 98 75

Oats 98 85 Groundnut -- --
Orchardgrass 90 80 Pea, Partridge 98 70
Redtop 92 80 Tick trefoil 90 70
Rye, Cereal 98 85 Wild Indigo -- --
Ryegrass, Annual or
Perennial 97 85
Wheat 98 85
Wild Rye, Canada, VA,
Riparian 85 70
Wood Reedgrass -- --
FOOTNOTE: 1/. All seed shall comply with the Massachusetts, Connecticut, or Rhode Island State Seed Law.
NRCS, MA
September 2001
TABLE 8. Endophyte Levels of Turfgrass Cultivars

% Endophyte Content in Seed*
Perennial Ryegrass
Variety Hi Lo Perennial Ryegrass, cont.
Mod. Mod.
Yorklown III 97
Variety Hi Lo
Palmer II 97
Mod. Mod.
Gen-90 97
Hi Lo
Express 97
Advent 97 Pennfine 01
Seville 06 Fine Fescue
Dandy 96
Variety Hi Lo
Duet 93
Mod. Mod.
ManhattanII 93
Hi Lo
PreludeII 93
RepellII 92 Jamestown II 100
Assure 92 Reliant 100
Pleasure 92 Warwick 96
Target 92 Southport 94
Riviera 91 SR-5000 92
Gettysburg 91 SR-3000 64
Pennant 91 Rainbow 63
Legacy 90 Valda 47
4 Del. Dwarf 90 Bridgeport 26
Pimacle 90
Repell 89 Tall Fescue
SR 4200 89 Variety Hi Lo
Commander 88 Mod. Mod.
Regal 88 Hi Lo
Saturn 85
Titan 98
Competitor 71
Shenandoa 86
Accolade 70
Mesa 70
Equal 68
Tribute 58
Calypso 66
Aguara 50
Citation II 59
Arid 48
Stallion 58
Normark 99 42
Caliente 54
Rebel Jr. 37
Premier 50
Trident 28
Entrar 47
Rebel II 28
Prestige 43
Winchester 24
Derby Supreme 38
Taurus 18
Lindsay 37
Apache 18
Charger 34
Finelawn I 16
Envy 30
Sundance 14
Rodeo II 27
Thoroughbred 14
Essence 20
Murietta 14
Fiesta II 15
Bonanza 12
Cowboy II 12
Chieftain 06
Danilo 06
Hubbard 87 04
Ovation 05
Finelawn 5GL 02
Loretta 04
Zero endophyte in other varieties.
Allegro 01 NOTE: The data are from Rutgers University and were
Gator 01 obtained from seed lots submitted to the National Turfgrass
Danaro 01 Evaluation Program. Seed lots may contain lower percentages
NRCS, MA
September 2001
of seeds with viable endophytes because of loss of viability

during seed storage. (Source: Dr. Richard Hurley.)
NRCS, MA
September 2001
January 23, 2018
Mr. Ralph Taylor, District Fish and Wildlife Supervisor

MA Division of Fish and Wildlife – CT Valley District
341 East Street
Belchertown, MA 01007

Dear Mr. Taylor:
Tennessee Gas Pipeline Company, L.L.C. (Tennessee), a Kinder Morgan company, is planning to upgrade
its Line 261B natural gas pipeline system. This would include a looping upgrade of 2.1 miles of existing
pipeline system in Agawam, Massachusetts (Project). The proposed pipeline loop upgrade would be a 12-
inch pipeline installed adjacent to Tennessee’s existing 8-inch, 261BP-100 pipeline and 10-inch, 261B-100
pipelines to the greatest extent possible. Where the loop upgrade is adjacent to the 10-inch 261B-100
pipeline, Tennessee proposes to remove an abandoned 6-inch-diameter pipeline where it exists in this
location and replace it with the 12-inch loop upgrade.
An Environmental Report, required as part of the Federal Energy Regulatory Commission (FERC) Section
7(c) Blanket Certificate Prior Notice process, is currently being prepared for the Project. As part of the
FERC National Environmental Policy Act review, it is necessary to identify the following:
• fishery types (coldwater vs. warm water) of each surface waterbody crossed by the proposed Project
• any sensitive fisheries or fisheries of special concern crossed by the Project
• any applicable construction timing restrictions for in-stream work
Tennessee respectfully requests that the MassWildlife – CT Valley District review its records relative to
any of the above-referenced areas and provide written comments pertaining to the identified resources. We
have enclosed for your review a USGS location map depicting the proposed Project locations. If you have
any questions regarding this request, please contact me at either (713) 420-6723 or via e-mail at
debi_mccartney@kindermorgan.com.
Very truly yours,
______________________________
KINDER MORGAN
713-420-6723 (office)
832-691-6125 (cell)
Proposed Pipeline
Existing TGP System

WEST SPRINGFIELD
SPRINGFIELD
AGAWAM

Agawam, MA

0 1,000 2,000
Feet
From: McCartney, Debi
To: Rebecca Weissman
Subject: FW: Line 261B Pipeline Looping Project, Agawam, MA
Date: Thursday, March 15, 2018 3:51:14 PM
Attachments: Fisheries Section BMPs.pdf
georef_pipeline.zip
Letter from Kinder Morgan.pdf
Kinder Morgan 261B.pdf
FYI
Debi
From: Slater, Caleb (FWE) [mailto:Caleb.Slater@MassMail.State.MA.US]

Sent: Thursday, March 15, 2018 2:49 PM
To: McCartney, Debi
Cc: Keleher, Brian (FWE)
Subject: Line 261B Pipeline Looping Project, Agawam, MA
[This email message was received from the Internet and came from outside of Kinder Morgan]
Please see attached (Kinder Morgan 261B) in regard to your request for fishery resource information
for the Line 261B Looping Project, Agawam, MA.
Caleb Slater, PhD

Anadromous Fish Project Leader
Massachusetts Division of Fisheries and Wildlife
1 Rabbit Hill Road, Westborough, MA 01581
p: (508) 389-6331 | e: Caleb.Slater@state.ma.us
mass.gov/masswildlife | facebook.com/masswildlife
March 15, 2018
Kinder Morgan
Huston, Texas 77002
Debi_mccartney@kindermorgan.com

Dear Ms. McCartney:
In a letter to MassWildlife dated January 23, 2018 you requested information regarding potential impacts to fishery
resources of your “Line 261B Pipeline looping project” in Agawam, MA. Below you will find an overview of the current
data available as well as commentary regarding its implications.
The proposed project crosses five streams, all in the Connecticut River watershed (Figure 1). MassWildlife has existing
fisheries survey data for three of the five streams: Worthington Brook, Tarkill Brook, and Three Mile Brook. We currently
have no data available for the other two impacted streams: Unnamed Tributary of Three Mile Brook, and Unnamed
Tributary of Worthington Brook.
Worthington Brook (Saris ID 3417450) has been sampled once, in July 2002. The sample documented the
following species: American Eel, Bluegill, Blacknose Dace, Bluntnose Minnow, Eastern Brook Trout, Largemouth
Bass, Pumpkinseed, and White Sucker. Worthington Brook is classified as a Coldwater Fisheries Resource.
Tarkill Brook (Saris ID 3417500) has been sampled once, in July 2002. The sample documented the following
species: Blacknose Dace, Golden Shiner, and White Sucker.
Three Mile Brook (Saris ID 3417425) has been sampled once, in July 2002. The sample documented the following
species: American Eel, Bluegill, Blacknose Dace, Brown Trout, Eastern Brook Trout, Fallfish, Largemouth Bass,
Tessellated Darter, White Sucker, and Yellow Perch. Three Mile Brook is classified as a Coldwater Fisheries
Resource.
According to MA 321 CMR 5.0 (https://www.mass.gov/regulations/321-CMR-500-coldwater-fish-resources) “a

Coldwater Fish Resource (CFR) is a waterbody (stream, river, or tributary thereto) where reproducing Coldwater Fish use
such waters to meet one or more of their life history requirements. CFRs are particularly sensitive habitats. Changes in
land and water use can reduce the ability of these waters to support trout and other kinds of coldwater fish.” Eastern
Brook Trout and Brown Trout are the coldwater fish species of concern that were documented in Worthington and
Three Mile Brooks.
As a matter of protocol- the un-sampled streams should also be considered Coldwater Fishery Resources until sampling
(using MassWildlife protocols) proves otherwise.
Additionally, other species documented; American Eel, White Sucker, Blacknose Dace, Tessellated Darter, Eastern Brook
Trout, and Fallfish are listed as species of greatest conservation need in the Massachusetts Statewide action plan.
https://www.mass.gov/service-details/state-wildlife-action-plan-swap
Please review attached: Fisheries Environmental Review Best Management Practices for information on how to best
avoid impacts to fishery resources during the project.
Please contact me if you have any questions.
Caleb Slater, PhD
Anadromous Fish Project Leader

Figure 1: Pipeline map with impacted waters
Fisheries Section, Environmental Review Best Management Practices
Best management practices for erosion and sedimentation control must be adhered to for all
phases of construction to minimize potential impacts to the fisheries resources. Traditional hay
and/or straw bales should be avoided in favor of fiber rolls. To the greatest extent practicable, all
in stream work should be conducted during low flow periods throughout the year. Times of year
when stream flow is high due to extended rain and/or snow melt events should be avoided. If at
any time during construction fish may become isolated, the Division should be notified to
determine if salvage operations are desired and/or feasible. If dewatering is required at any point
during construction, heated or sediment laden water should not be allowed to enter the brook
directly. If the projects results in the replacement of existing culverts, the culvert replacement
should meet the replacement recommendations found in the “Massachusetts River and Stream
Crossing Standards: Technical Guidelines, August 6, 2004” (the Standards) including, a
minimum height of 6 feet, openness ratio of 0.5–0.75, natural bottom substrates through the
crossing structure, and spanning 1.2 times the bank-full width to the greatest extent practical. If
the project results in the placement of new culverts, the new crossing structure should, at
minimum, meet the general standards for new crossing and strive for the optimum standards
whenever possible including, a minimum height of 6 feet, openness ratio of 0.5–0.75, natural
bottom substrates through the crossing structure, and spanning 1.2 times the bank-full width to
the greatest extent practical. The Standards can be found at
http://www.umass.edu/nrec/pdf_files/guidelines_river_stream_crossings.pdf. Also, if the project
will alter the streambed, we request that the existing grade be maintained. Within the riverfront
areas, short and long-term stream bank stabilization should incorporate bioengineering with
natural materials such as vegetated geogrids, fiber rolls, live stakes and tree revetments in lieu of
the use of hard structures such as rip rap, gabion baskets or retaining walls. Geotextile fabric
should not be considered for moving water as experience has shown it becomes exposed and can
dislodge over time.
Per DEP’s stormwater management standards for critical areas such as coldwater fisheries
resources, BMPs are required that assure no untreated or warmwater runoff from impervious
surfaces directly enters these resources. Recent studies have shown that stormwater BMPs that
allow standing, surface water function as “heat sinks” in summer and lose heat in winter. As
such, retention and detention ponds, vegetated swales and hydrodynamic separators also have
little value as stormwater BMPs in the vicinity of coldwater resources. Stormwater systems that
have been found to be most protective of these resources are subsurface, infiltration, gravel
wetland and bioretention. Ideally, a chain of coldwater BMPs (e.g., bioretention to gravel
wetland to an infiltration system) with deep infiltration and filtration capabilities will cool the
stormwater to ground temperature in both summer and winter thereby providing the most
effective long-term protection of the coldwater resources.
o em er 21 201
n ironmental e iew
atural erita e and ndan ered pecies ro ram
assachusetts i ision o isheries and ildli e
1 a it ill oad
est orou h 015 1
ennessee as ipeline ompan . . .

ine 2 1 ipeline oopin ro ect
ear ir or adam
ennessee as ipeline ompan . . . ennessee a inder or an compan is plannin to

up rade its ine 2 1 natural as pipeline s stem. his would include a loopin up rade o 2.1 miles o
e istin pipeline s stem in awam assachusetts. he proposed pipeline loop up rade would e a 12
inch pipeline installed ad acent to ennessee s e istin inch 2 1 100 pipeline or a out 2 00 eet
and then ad acent to ennessee s e istin 10 inch 2 1 100 pipeline or the remainin proposed loopin
up rade len th. here the loop up rade is ad acent to the 2 1 100 pipeline ennessee proposes to
remo e an a andoned inch diameter pipeline where it e ists in this location and replace it with the 12
inch loop up rade.
he proposed pipeline up rade would cross atural erita e and ndan ered pecies ro ram
riorit a itat o are pecies 0 . ennessee is respect ull re uestin in ormation on the rare
species that ma occup the ha itat crossed the proposed pro ect. e uest or tate listed pecies
n ormation orm a topo raphic location map and a chec or 50.00 made pa a le to the
ommonwealth o are enclosed.
ou ha e an uestions re ardin this re uest please contact me at either 1 20 2 or ia e mail

at de i mccartne indermor an.com.
er trul ours
. . .
e orah . c artne
enior ermittin and ompliance pecialist
KINDER MORGAN
1001 ouisiana treet uite 1000
ouston e as 002
1 20 2 o ice
2 1 125 cell
c . eissman
. ohnson
Request for State-listed Species Information
Please complete this form to request state-listed species information from the Natural Heritage &
Endangered Species Program for a particular location (please submit only one project per form).
Fee: $50.00, Payable to Comm. of MA – NHESP (as required in 321 CMR 10.17(3))
No fee required if request is for conservation purposes or habitat management and you are a non-profit
conservation group, government agency or are working with a government agency.
Requestor Information
Name: Deborah McCartney Affiliation:
Address: 1001 Louisiana Street, Suite 100
City: Houston State: TX Zip Code: 77002
Daytime Phone: 713-420-6723 Ext. Email address: Debi_McCartney@kindermorgan.com
Project Information
Project or Site Name: Line 261B Pipeline Looping Project
Location: Town:
Parallel with Tennessee's existing pipelines Agawam, Massachusetts
Name of Landowner or Project Proponent (if different from Requestor):
Various (linear project)
Acreage of the Property:
N/A
Description of Proposed Project and Current Site Conditions: (If necessary attach additional sheet)
Tennessee Gas Pipeline Company, L.L.C. (Tennessee) is planning to upgrade its Line 261B natural gas pipeline system.
This would include a looping upgrade of 2.1 miles of existing pipeline system in Agawam, Massachusetts. The proposed
pipeline loop upgrade would be a 12-inch pipeline installed adjacent to Tennessee’s existing 8-inch, 261BP-100 pipeline
for about 2,300 feet and then adjacent to Tennessee’s existing 10-inch, 261B-100 pipeline for the remaining proposed
looping upgrade length. Where the loop upgrade is adjacent to the 261B-100 pipeline, Tennessee proposes to remove
an abandoned 6-inch-diameter pipeline where it exists in this location and replace it with the 12-inch loop upgrade.
Adjacent lands that may be required for construction include residential, agricultural, and forested uplands and wetlands.
Required: Enclose a map with the site location clearly marked and centered on the page.
Please mail this completed form, a topographic map, and fee (if applicable) to the above address, Attn:
Regulatory Review.
If no fee is required, you can email the information to natural.heritage@state.ma.us.
A written response will be returned within 30 days of receipt of all information required.
Proposed Pipeline
Existing TGP System
Figure 1. USGS Topographic Data Source: Office of Geographic WESTFIELD

WEST SPRINGFIELD
SPRINGFIELD
Map
AGAWAM
Tennesse Gas Pipeline

USGS West Springfield Quadrangle LONGMEADOW
Agawam, MA
09 Nov 2017
0 1,000 2,000
Feet
December 27, 2017
Deborah McCartney
Tennessee Gas Pipeline Company
1001 Louisiana Street
Houston TX 77002
RE: Project Location: TGP ROW 261B-100 Line (Pipeline Looping Project)
Town: AGAWAM
NHESP Tracking No.: 12-31546
To Whom It May Concern:
Thank you for contacting the Natural Heritage and Endangered Species Program of the MA Division of
Fisheries & Wildlife (the “Division”) for information regarding state-listed rare species in the vicinity of
the above referenced site. Based on the information provided, this project site, or a portion thereof, is
located within Priority Habitats 780 & 805 (PH 780, PH 805) and Estimated Habitats 643 & 658 (EH 643,
EH 658) as indicated in the Massachusetts Natural Heritage Atlas (14th Edition). Our database indicates
that the following state-listed rare species have been found in the vicinity of the site:
PH 780, EH 643
Scientific name Common Name Taxonomic Group State Status
Terrapene carolina Eastern Box Turtle Reptile Special Concern
Carphophis amoenus Eastern Worm Snake Reptile Threatened
PH 805, EH 658
Scientific name Common Name Taxonomic Group State Status
Terrapene carolina Eastern Box Turtle Reptile Special Concern
The species listed above are protected under the Massachusetts Endangered Species Act (MESA) (M.G.L.
c. 131A) and its implementing regulations (321 CMR 10.00). State-listed wildlife are also protected
under the state’s Wetlands Protection Act (WPA) (M.G.L. c. 131, s. 40) and its implementing regulations
(310 CMR 10.00). Fact sheets for most state-listed rare species can be found on our website
(www.mass.gov/nhesp).
Please note that projects and activities located within Priority and/or Estimated Habitat must be
reviewed by the Division for compliance with the state-listed rare species protection provisions of MESA
(321 CMR 10.00) and/or the WPA (310 CMR 10.00).
Wetlands Protection Act (WPA)

If the project site is within Estimated Habitat and a Notice of Intent (NOI) is required, then a copy of the
NOI must be submitted to the Division so that it is received at the same time as the local conservation
commission. If the Division determines that the proposed project will adversely affect the actual
NHESP File No. 12-31546, Page 2 of 2
Resource Area habitat of state-protected wildlife, then the proposed project may not be permitted (310
CMR 10.37, 10.58(4)(b) & 10.59). In such a case, the project proponent may request a consultation with
the Division to discuss potential project design modifications that would avoid adverse effects to rare
wildlife habitat.
A streamlined joint MESA/WPA review process is available. When filing a Notice of Intent (NOI), the
applicant may file concurrently under the MESA on the same NOI form and qualify for a 30-day
streamlined joint review. For a copy of the NOI form, please visit the MA Department of Environmental
Protection’s website: http://www.mass.gov/eea/agencies/massdep/service/approvals/wpa-form-
3.html.
MA Endangered Species Act (MESA)

If the proposed project is located within Priority Habitat and is not exempt from review (see 321 CMR
10.14), then project plans, a fee, and other required materials must be sent to Natural Heritage
Regulatory Review to determine whether a probable Take under the MA Endangered Species Act would
occur (321 CMR 10.18). Please note that all proposed and anticipated development must be disclosed,
as MESA does not allow project segmentation (321 CMR 10.16). For a MESA filing checklist and
additional information please see our website: www.mass.gov/dfw/nhesp/regulatory-review.
We recommend that rare species habitat concerns be addressed during the project design phase prior
to submission of a formal MESA filing, as avoidance and minimization of impacts to rare species and
their habitats is likely to expedite endangered species regulatory review.
This evaluation is based on the most recent information available in the Natural Heritage database,
which is constantly being expanded and updated through ongoing research and inventory. If the
purpose of your inquiry is to generate a species list to fulfill the federal Endangered Species Act (16
U.S.C. 1531 et seq.) information requirements for a permit, proposal, or authorization of any kind from a
federal agency, we recommend that you contact the National Marine Fisheries Service at (978)281-9328
and use the U.S. Fish and Wildlife Service's Information for Planning and Conservation website
(https://ecos.fws.gov/ipac). If you have any questions regarding this letter please contact Lauren
Glorioso, Endangered Species Review Assistant, at (508) 389-6361.
Sincerely,
Thomas W. French, Ph.D.

Assistant Director
February 28, 2018
Ms. Kathleen Auer, Health Agent

Agawam Health Department
36 Main Street
Agawam, MA 01001

Dear Ms. Auer:
Tennessee Gas Pipeline Company, L.L.C. (Tennessee), a Kinder Morgan company, is planning to upgrade
its Line 261B natural gas pipeline system. This would include a looping upgrade of 2.1 miles of existing
pipeline system in Agawam, Massachusetts (Project). The proposed pipeline loop upgrade would be a 12-
inch pipeline installed adjacent to Tennessee’s existing 8-inch, 261BP-100 and 10-inch, 261B-100 pipelines
to the greatest extent possible. Where the loop upgrade is adjacent to the 10-inch 261B-100 pipeline,
Tennessee proposes to remove an abandoned 6-inch-diameter pipeline where it exists in this location and
replace it with the 12-inch loop upgrade.
An Environmental Report, required as part of the Federal Energy Regulatory Commission (FERC) Blanket
Certificate Prior Notice process, is currently being prepared for the Project. As part of the FERC National
Environmental Policy Act review, it is necessary to identify whether the proposed Project will cross or be
within 0.25-mile of the following sensitive environmental areas:
• Designated aquifers or aquifer protection areas

• Surface drinking water supplies or surface water protection areas
• Any known existing or proposed public or private drinking water wells, reservoirs, or springs
within 300 feet of the proposed alignment
Tennessee respectfully requests that the Agawam Health Department review its records relative to any of
the above-referenced areas and provide written comments pertaining to the identified resources. We have
enclosed for your review a USGS location map depicting the proposed Project location.
Page 2
If you have any questions regarding this request, please contact me at either (713) 420-6723 or via e-mail
at debi_mccartney@kindermorgan.com.
Very truly yours,
______________________________
KINDER MORGAN
713-420-6723 (office)
832-691-6125 (cell)
c: R. Weissman, SWCA
Proposed Pipeline
Existing TGP System

WEST SPRINGFIELD
SPRINGFIELD
AGAWAM

Agawam, MA

0 1,000 2,000
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APPENDIX D
Summary of EDR Report
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EDR DataMap - Area Study
.
SUMMARY OF POTENTIAL DATABASE LISTINGS WITHIN 0.25‐MILE OF
261 UPGRADE PROJECTS
AGAWAM, MA
Distance Spill / Contaminant/

Site /Facilty Name County Milepost Address Direction Relevant Database Status Notification Date Source Quantity RTN/ ID Number Gradient Comments Contamination Map ID

low potential for soil and groundwater
impacts

SUMMARY OF POTENTIAL DATABASE LISTINGS WITHIN 0.25‐MILE OF
261 UPGRADE PROJECTS
AGAWAM, MA
Distance Spill / Contaminant/

Site /Facilty Name County Milepost Address Direction Relevant Database Status Notification Date Source Quantity RTN/ ID Number Gradient Comments Contamination Map ID

low potential for soil and groundwater
impacts

APPENDIX E
GHG Analysis
Greenhouse Gas Analysis
BACKGROUND INFORMATION
1.1 MEPA Greenhouse Gas Policy and Protocol
The Executive Office of Energy and Environmental Affairs (“EOEEA”) has established a Greenhouse
Gas (“GHG”) Emissions Policy and Protocol (“Policy,” last revised May 5, 2010) in accordance with the
Massachusetts Environment Policy Act (“MEPA”). The purpose of the Policy is to inform the MEPA
office of the quantity of GHG associated with proposed projects, by assessing the project baseline,
considering available alternatives, and evaluating the feasibility and impact of performing the alternatives.
The Policy applies to new projects which file an Environmental Notification Form (“ENF”) which
initiates MEPA review after the May 5, 2010 effective date of the revised Policy. Tennessee Gas Pipeline
Company, L.L.C. (“Tennessee”) is requesting a Single Environmental Impact Report (“EIR”) and
preparing an Expanded ENF (“EENF”) for the project.
Calculated emissions are presented in terms of carbon dioxide (“CO2”) equivalents (“CO2e”) which is an
accounting measure of GHGs which takes into account different species and places them on a single basis
using Global Warming Potentials (“GWP”) 1. For example, one ton of CO2 is equivalent to one ton of
CO2e, one ton of methane (“CH4”) is equivalent to 34 tons of CO2e, and one ton of nitrous oxide (“N2O”)
is equivalent to 298 tons of CO2e. The combined GHG total, represented as CO2e, is the amount of CO2
that has the equivalent global warming impact as the combination of different GHG species.
1.2 Description of Projects

upgrades at Tennessee Gas Pipeline Company, L.L.C.’s (“Tennessee”) existing Compressor Station 261
(“CS 261”). Both projects are located in Agawam, Massachusetts. Figure 2-1 in Appendix A of the
EENF depicts the general location of the Projects’ components.
pipeline, Tennessee proposes to remove an inactive 6-inch-diameter pipeline from this location and
1.3 Scope of Projects

The scope of the Projects within Massachusetts is limited to the construction and operation of the
proposed 2.1 miles of natural gas looping pipeline, new combustion turbine and gas compressor, and
appurtenant facilities. The proposed pipeline will only transport natural gas for shippers pursuant to
transportation service agreements from the upstream transmission network to the downstream
1
Global Warming Potentials (including carbon-climate feedback) are taken from Chapter 8, Table 8.7 of the IPCC Fifth
Assessment Report, Climate Change 2013 The Physical Science Basis
E-1
transmission network. Therefore, for the purpose of this GHG analysis, Tennessee is not evaluating the
life cycle of the natural gas before or after it enters and leaves the physical pipeline proposed within the
Massachusetts sections of the Projects since it is outside the scope.
1.4 Sources of Greenhouse Gas Emissions

Sources of GHG emissions from the Projects are divided into four categories, three of which are
temporary in duration once operation has started. The four categories are:
• Construction (temporary);
• Commissioning (temporary);
• Normal Operation; and
• Non-routine Operations (temporary).
During the construction period, GHG emissions will be emitted from diesel and gasoline fired non-road
construction equipment, and diesel and gasoline fired on-road construction vehicles. Emissions can also
occur when gas is vented as the new pipeline loop is tied into the existing pipeline lateral (“tie-in”). GHG
emissions associated with construction activities are CO2, CH4, and N2O from internal combustion
engines. CH4 and CO2 may be released from pipeline operations involved with the tie-in. This is a one-
time event where emissions associated with construction will not continue beyond the construction
period.
During the commissioning process of the Projects, CH4 and CO2 may be released from pipeline
operations and the proposed new compressor. These GHG emissions will result from purging the air out
of the new pipeline or compressor casing and filling it with natural gas. This is a necessary and important
step to make sure that the oxygen level inside of the pipeline meets safety thresholds. A safety valve will
be opened to allow the air to vent from the pipeline and small amounts of natural gas will vent to ensure
that all the air is removed prior to placing the pipeline into service. In addition, shortly after placing the
pipeline segments into service, Tennessee will run a pipeline inspection gauge through the pipeline to
clean impurities and check pipe wall integrity. These in-line inspection gauges are round cylindrical
objects which are used to clean and inspect the inside of the pipeline without having to remove individual
sections of pipe. Emissions from in-line inspections are a result of venting the launcher and receiver
tubes (“barrels”) prior to opening hatches. Launcher and receiver barrels are short sections of pipe which
protrude out of the ground to allow loading and unloading of the in-line inspection gauges. The loading or
removal of the inspection/maintenance will cause a small amount of natural gas to escape when the
launcher or receiver barrel is vented prior to opening. These purging and inspection operations during
commissioning are one-time events where emissions will not continue beyond the construction period.
During normal operation, the combustion of natural gas in the compressor turbine is expected to be the
single largest source of GHG emissions (CO2, CH4, and N2O). Potential emissions from the turbine are
estimated using maximum potential annual fuel use values and emission factors from the United States
Environmental Protection Agency (“USEPA”) GHG reporting program. Very small amounts of CH4 and
CO2 emissions may occur from fugitive leaks in the pipeline during normal operation. The location of
fugitive leaks is primarily limited to valves at either end of the new pipeline. The underground pipeline
itself is not expected to be a source of fugitive leaks. Even though the underground pipeline is not
expected to be a source of fugitive leaks during normal operation, fugitive emissions were still estimated
using standard emission factors from the Interstate Natural Gas Association of America2 (INGAA) and
the length of pipeline to conservatively account for some level of fugitive leaks. The emissions quantified
in Section 2.3 are the estimated emissions that would be emitted each year.
2INGAA GHG Emission Estimates – Table 4-4 http://www.ingaa.org/Topics/ClimateChange/6490.aspx
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Other non-routine operations may occur for long-term maintenance procedures or unplanned blowdowns
of pipeline sections. Long-term maintenance consists of pipeline inspections and small releases of gas
when venting the pig launcher or receiver prior to opening the hatches. As noted above, a one-time in-
line inspection event will also occur during commissioning. Blowdowns occur when a section of pipe
that is in service must be vented for safety purposes. Blowdowns may be required if there is a need to
perform unplanned maintenance repair on a section of pipeline. Blowdowns are performed to reduce the
pressure within the pipeline and release gas to safely perform any required repairs. There are no planned
blowdowns expected to occur along the pipeline loop. CH4 and CO2 emissions from in-line inspections
and blowdowns are sporadic in nature and are expected to occur infrequently. Ongoing in-line
inspection/maintenance of the new pipeline sections may occur once every 5-7 years or more and
blowdowns are expected to be an even rarer event as they only occur as a result of an unplanned response
to a discrete incident.
BASELINE AND ALTERNATIVE ANALYSIS

Pursuant to the MEPA GHG Policy and Protocol, this section presents a quantification and evaluation of
the Projects’ baseline, and alternatives to the baseline which may represent GHG mitigation or reduction
opportunities.
The baseline and alternative analysis is conducted separately for each of the four emission categories
identified in Section 1.4. The analysis is conducted in this manner since the alternative/mitigation
approaches evaluated are very specific to the phases of the Projects.
2.1 Construction
2.1.1 Baseline
The Baseline is based on construction equipment’s engine emissions. These emissions are calculated
using standard emission factors and assumptions and venting 4 miles of the 10-inch lateral pipeline at a
pressure of 700 psig during the pipeline tie-in process. The 2.1-mile, 12-inch pipeline loop will be
connected to the 10-inch lateral. For safety purposes in the baseline case, the entire existing lateral would
have to be depressurized and evacuated in order to perform the connection.
GHG emissions from construction equipment engines (non-road and on-road) which are used during the
Project construction have been estimated based on the anticipated types of non-road and on-road
equipment and their levels of use. The estimates of equipment and usage levels are based on other similar
pipeline construction projects conducted by Tennessee. Emission factors for diesel on-road vehicles were
developed from EPA’s MOVES2014a model 3. Emissions for diesel and gasoline non-road equipment
engines are derived from EPA’s NONROAD model calculation procedures and documentation 4. For
conservatism, emission factors using EPA Tier 2 diesel engine standards have been assumed to apply to
construction equipment engines during 2020 and do not reflect the anticipated phasing-in of more
stringent EPA Tier 3 and 4 emissions standard compliant engines. Also, most emissions reductions from
the use of higher EPA tier engines are seen in non-GHG pollutants (nitrogen oxides [“NOx”], carbon
monoxide [“CO”], volatile organic compounds [“VOC”], and particulate matter [“PM”]). Ultra-low
sulfur diesel fuel use was assumed for the non-road diesel vehicles, which complies with the
Massachusetts Department of Environmental Protection (MassDEP) Diesel Retrofit Program. The
3 http://www.epa.gov/moves
4 http://www.epa.gov/otaq/nonrdmdl.htm#techrept
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detailed construction emission estimates including assumptions, data, and emission factors used are
provided in Appendix F of the EENF.
While the amount of GHG emission reductions are not quantified, exhaust emissions from diesel-fueled
construction equipment and vehicle engines will be minimized by federal design standards imposed at the
time of manufacture of the vehicles and will comply with USEPA mobile and non-road emission
regulations (40 Code of Federal Regulations “CFR” Parts 85, 86, and 89). Construction of the Projects is
scheduled to occur in 2020 so the available mix of equipment with USEPA engine tiers will be
determined at the time of construction upon consultation with contractors in the area. Emissions also will
be controlled by purchasing commercial diesel fuel products whose specifications are controlled by
federal and state air pollution control regulations applicable to fuel suppliers and distributors. Contractors
and employees will be encouraged to minimize vehicle and equipment idling time to the extent practical
during construction activities, pursuant to Massachusetts regulations (310 Code of Massachusetts
Regulations “CMR” 7.11).
GHG emissions from the venting release during the construction tie-in process have been estimated
assuming the need of 4 miles of pipeline to be vented at an initial pressure of 700 pounds per square inch
gauge (“psig”). The configuration of the existing lateral and seasonal timing of when construction is
expected to occur makes it uncertain whether the line can be drawn down to a lower pressure prior to
venting. The venting release is associated with removing existing natural gas in a portion of the existing
pipeline segment prior to connecting the new pipeline. Similar venting is also required at the compressor
station when performing the work of disconnecting the existing compressors and turbines to safely
perform the disconnection and removal of the equipment. The detailed emission estimates including
assumptions, data, and emission factors used are provided in Appendix F of the EENF. The calculated
GHG emissions for the Baseline are shown in Table 2-1.
Table 2-1. Construction Emissions - Baseline

Construction Phase – Tons
CO2 CH4 N2O CO2e

Pipeline Non-Road and On-Road Construction Equipment and
2,227.66 0.07 0.10 2,261
Vehicles
Pipeline Tie-In Venting Release 0.01 11.64 -- 396
Compressor Non-Road and On-Road Construction Equipment
914.90 0.02 0.06 932
and Vehicles
Compressor Venting 0.02 20.21 -- 687
Total 3,142.59 31.95 0.16 4,276
2.1.2 Alternative 1
Alternative 1 involves conducting the pipeline loop tie-in to the existing lateral using a process called
“hot-tapping.” Hot tapping is the technique of attaching a mechanical or welded branch fitting to piping in
service and creating an opening in the piping without taking the existing piping out of service. It allows
the new pipe to be safely connected to the existing pipe without the need to perform a safety related
venting release. Therefore, the existing pipe will not need to be vented, and thus no emissions will result
during construction from the tie-in phase. Table 2-2 shows what emissions would be if this alternative is
chosen.
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As previously explained in Section 2.1.1, the engine emissions from construction are the same as in the
baseline case because of the uncertainty of equipment availability and procurement. Therefore,
Tennessee is not proposing an alternative for the construction equipment at this time.
Table 2-2. Construction Emissions - Alternative 1

Construction Phase – Tons
CO2 CH4 N2O CO2e

Pipeline Non-Road and On-Road Construction Equipment and
2,227.66 0.07 0.10 2,261
Vehicles
Pipeline Tie-In Venting Release -- -- -- --
Compressor Non-Road and On-Road Construction Equipment
914.90 0.02 0.06 932
and Vehicles
Compressor Venting 0.02 20.21 -- 687
Total 3,142.58 20.31 0.16 3,880
2.1.3 Preferred Alternative

Tennessee is planning on using the hot-tap methodology for connecting the pipelines. Therefore, there
would be no venting associated with the tie-in and this will result in a decrease of approximately 396 tons
of CO2e compared to the Baseline. Total construction-related GHG emissions and compressor venting
will be those of Alternative 1.
2.2 Commissioning
Commissioning the pipeline is a two-stage process which involves (1) pressure testing the pipes to ensure
that they can handle a maximum pressure beyond what they will function during normal operations when
transporting natural gas and (2) safety-related purging of the pipes of any air before final placement into
service. Purging is also a necessary safety process for installation and placing into service of the new
compressor header/casing.
2.2.1 Baseline
Tennessee is committed to pressure testing all segments of the pipeline using hydrostatic testing prior to
placement in service. Hydrostatic testing involves using water to pressurize the pipeline to a level that
exceeds any pressure that the pipe will function with when transporting natural gas. Because water is
used in this process, there is no venting of natural gas and thus no GHG emissions.
Before the pipeline can be placed into service, all air from the pipes must be removed and replaced with
natural gas. Purging is intended to remove air or impurities from the pipeline after construction and to
prepare the pipeline prior to filling it with natural gas. Purging is completed via Tennessee’s Operating
and Maintenance Procedure. The natural gas is not introduced to the new pipe section until a monitoring
gauge measures 100% natural gas. An additional two minutes of gas venting is allowed after it appears
that all the air has been purged to ensure that there is absolutely no oxygen left within the new pipe
section before shutting the blow-off valve. During the purging process natural gas is released to the
atmosphere from a blow-off valve as the pipe is being filled. This is a one-time only event during
commissioning and the emissions are minimal as shown in Table 2-3. This is a very important process
for pipeline safety which is required by, and regulated under, 40 CFR 169 to minimize the oxygen content
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in the pipeline, and therefore prevent a hazardous mixture of gas and oxygen in the line. As mentioned,
purging will also be performed on the new compressor header/casing to minimize oxygen content.
An in-line inspection gauge is run through the new section of pipeline to further clean any impurities from
the construction operations and inspect pipe wall welding integrity. Small amounts of emissions result
from opening the launcher and receiver hatches as shown in Table 2-3.
Emissions from the commissioning phase are detailed in Table 2-3. Emissions are based on the amount of
gas expected to be released during in-line inspections and purging operations. Detailed calculations are in
Appendix F of the EENF.
Table 2-3. Commissioning Emissions – Baseline
Commissioning – Tons
CO2 CH4 CO2e

Pipeline Pressure Testing -- -- --
Pipeline Purging 0.0005 0.59 20
Pipeline In-Line Inspection 0.00006 0.07 2
Compressor Purging 0.0005 0.59 20
Total 0.001 1.24 42
2.2.2 Alternative 1
Since there are no GHG emissions from hydrostatic testing, there are no alternatives to the Baseline
pressure testing methodology. The other processes related to commissioning of the pipeline and
compressor are necessary for the safety of the construction workers and the public and therefore, no
alternatives are proposed for these processes.
As can be seen in Table 2-3, GHG emissions from the purging and inspection operation are insignificant.
As a result, it would not be practical or cost effective to apply an emissions control. It would not be
economically feasible to recompress or flare the small amount of natural gas that would be released
during purging since the venting would just occur for a few minutes. The in-line inspection process would
only release approximately 20 cubic feet of natural gas, not enough to make flaring or recompressing a
feasible option.

The Preferred Alternative is the Baseline. Tennessee is already committed to pressure testing the pipeline
using non-GHG hydrostatic testing. Emissions resulting from purging and the initial inspection of the
pipeline, and compressor purging are minimal enough to make any control attempt impractical as seen in
Table 2-3.
2.3 Normal Pipeline Operation
2.3.1 Baseline
Normal operation of the pipeline involves routine and non-routine inspections and maintenance. During
normal operation, emissions may occur from fugitive leaks in the pipeline. The location of fugitive leaks
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is primarily limited to valves at either end of the new pipeline. The pipeline itself, which is underground,
is not expected to be a source of fugitive leaks.
To minimize pipeline emissions during operation, Tennessee implements the following measures:
Cathodic protection to minimize and control corrosion of the steel pipeline. This is known as protected
steel. According to the INGAA, by using protected steel, CO2 emission factors are reduced from 30.5 lbs
CO2 per pipeline mile to 2.2 lbs CO2 per mile, assuming a 2 percent volume CO2 in natural gas. The
amount of CH4 reduces to 15.1 lbs CH4 per pipeline mile from 276 lb CH4 per mile, assuming 93.4
percent volume CH4 in natural gas. This is a significant reduction resulting from the use of cathodically
protected steel pipe.
Transportation of odorized natural gas. This allows for quicker recognition of a leak and allows for
repairs earlier than may occur if detection was reliant of periodic inspections. The natural gas is odorized
upstream of New England by Tennessee.
Periodic flyovers of the pipeline right-of-way. This allows for potentially quicker recognition of leaks and
allow for expedited repair. Flyovers may occur once a month during the winter and twice a month during
the balance of the year. The flyovers will be conducted in compliance with 49 CFR 192.705 and 49 CFR
192.706. The frequency of the flyovers may be more than the required frequency of once per year.
Readily available supply of emergency pipe, leak repair clamps, sleeves, and other equipment needed for
repair activities. By keeping such supplies readily available, repairs are expedited and the amount of
leakage with associated emissions is limited.
Table 2-4 illustrates the estimated annual emissions for normal operations. Fugitive emissions from the
valves and pipeline are estimated using emission factors from INGAA and are based on the length of
pipeline. The INGAA emission factors used are the factors for protected steel transmission pipe and are
adjusted to account for the anticipated actual natural gas composition of 96.8 volume percent CH4 and
0.03 volume percent CO2, versus the INGAA defaults of 93.4 volume percent CH4 and 2 volume percent
CO2. These compositions are based on historical data for natural gas through this section of pipeline.
Table 2-4. Normal Operation Emissions - Baseline

Normal Pipeline Operating – Tons (per Year)
CO2 CH4 CO2e

Pipeline Fugitives 0.001 0.02 0.6
2.3.2 Alternative 1
To evaluate potential emissions minimization options, the USEPA Natural Gas STAR 5 program was
reviewed. The Natural Gas STAR program was developed by USEPA in 1993 to work in conjunction
with the oil and natural gas industries to provide a framework to encourage partner companies to
document and implement methane reduction strategies and practices. The Natural Gas STAR program
hosts a list of technologies and methods that partner companies have utilized to reduce methane
emissions. Tennessee continues to be a registered partner since the inception of the program in 1993.
The following are options which the Natural Gas STAR program lists as potentially applicable to normal
operations of transmission pipelines. Because of the limited individual components of transmission
5 http://www.epa.gov/gasstar/
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pipelines, there are only a few options. A description of the applicability to the Project is included. Note
that due to the very insignificant nature of emissions outlined in the Baseline, and the nature of the
minimization options, it is not practical to quantify any potential emission reductions.
Options which are applicable to the proposed Projects:
• Test and Repair Pressure Safety Valves – Tennessee will test annually and repair if necessary.
• Composite Wrap for Non-Leaking Pipeline Defects – Tennessee repairs non-leaking pipeline
defects per its Operating & Maintenance Procedure 213. If the defect cannot be removed by
mechanical means such as sanding/buffing out, filling with a hardener, etc., coating will be
reapplied or a composite wrap will be installed as appropriate. Repair sleeves fabricated out of
pipe of similar design may also be used in lieu of composite wraps, if needed.
Options not applicable to the proposed Projects:
• Convert Natural Gas-Driven Chemical Pumps – There are no natural gas-driven chemical pumps
on the pipelines.
• Inject Blowdown Gas into Low Pressure Mains of Fuel Gas System – There are no low-pressure
mains or fuel gas systems on the pipeline.

The Preferred Alternative is the Baseline with odorizing gas, flyovers, repair of valves, and reduction of
pipeline pressure (when possible) prior to performing maintenance activities. INGAA emission factors for
transmission pipes do not account for leak reductions due to leak repairs and coated/composite-wrapped
pipes. Even without taking these practices into account, the emissions from pipeline normal operations
are shown to be minimal as seen in Table 2-4.
2.4 Normal Compressor Engine Operation

As described in the EENF, the Horsepower Replacement portion of the 261 Upgrade Projects involves the
replacement of two older model Solar combustion turbines and associated natural gas compressors with a
single new Solar Taurus 70 combustion turbine and compressor.
2.4.1 Baseline
Baseline emissions for the Projects are taken from the Non-Major Comprehensive Plan Approval
(“NMCPA”) air permit application. Note that the NMCPA application is in the process of being revised
and will be resubmitted to MassDEP via their on-line filing system (“ePlace”). The revised NMCPA will
reflect changes to the project as well as to respond to an information request received on the original
application (MassDEP May 15, 2018 letter to Tennessee). The annual potential fuel use of the
combustion turbine was used along with EPA emission factors to estimate GHG emissions for the
proposed new combustion turbine summarized in Table 2-5.
Table 2-5. Combustion Turbine Emissions – Baseline

Normal Compressor Operation – Tons (per Year)
CO2 CH4 N2O CO2e

Combustion Turbine 46,635 0.88 0.09 46,691
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2.4.2 Alternative 1
As an alternative to operating the combustion turbine (fueled with natural gas) to drive the gas
compressor is the use of an electric motor. The compressor setup would be similar to that of the
combustion turbine but would be driven by an electric motor. This alternative has the advantage of not
directly burning fuel and creating direct GHG emissions. However, indirect GHG emissions are created
in the production of the electricity to drive the motor, as summarized in Table 2-6. To estimate the
indirect emissions, the mechanical horsepower of the combustion turbine was converted to mechanical
kilowatts and a nominal generator efficiency was used to convert the motor output to an electrical
kilowatt input. Emission factors for electricity use were based on ISO New England data 6 for CO2 and
USEPA’s 2016 eGRID data 7 from the New England electrical subregion for CH4 and N2O. These data
are the most recent available which provide an estimation of GHG from indirect electricity use. The data
was calculated on a year-round basis to be consistent with the calculation used for the baseline case.
Table 2-6. Electric Motor Indirect Emissions – Alternative 1

Normal Compressor Operation – Tons (per Year)
CO2 CH4 N2O CO2e

Electric Motor 32,730 4.15 0.55 33,036

The Preferred Alternative is the Baseline with using the Solar Taurus 70 combustion turbine and
compressor. The combustion turbine would only be utilized to match customer needs, for maintenance
operations, and safety-related purposes. The use of an electric compressor has the advantage of not
directly burning fuel, but also produces indirect emissions from electricity use. While there are GHG
advantages of the alternative option, Tennessee evaluated the use of electric motor-driven compression
and determined that it was not feasible for these Projects. Tennessee chose to replace the existing natural
gas turbine driven compressor units with modern natural gas turbine compressor units for the reasons
provided below.
• Although electric driven compression would eliminate certain stationary source emissions at CS
261, these emissions would simply be transferred to electric generation facilities in the area, the
majority of which utilize natural gas. An even worse emissions scenario occurs if an electric
motor driven compressor consumed electricity from the marginal electric supplier using coal, oil,
refuse, or wood fired generation. In New England, these sources accounted for 8.4 percent of the
generation fuel in 2017 and 11.3 percent through the first four months of 2018 (ISO-NE 2017).
• While reliability of the local electric transmission lines is good, electric supply is still vulnerable
and not as reliable as using natural gas for fuel. The supply of electricity for electric motor driven
compression is subject to power line outages (such as during storm events including ice) or black
or brown-outs due to power plant outages or general lack of generating capacity. Continued
retirement of nuclear, coal, and oil-fired capacity in New England is expected to further constrain
electricity supply (i.e., closure of Vermont Yankee, Brayton Point, and Pilgrim) (U.S. NRC 2017;
Finucane 2017; Abel and Ellement 2016). Peak natural gas usage (and thereby also compression
use) and peak electricity usage occur simultaneously for this region during cold winter weather,
further increasing the chances of loss of electric power exactly when the compression is most
needed.
6 https://www.iso-ne.com/static-assets/documents/2018/01/2016_emissions_report.pdf
7 https://www.epa.gov/energy/emissions-generation-resource-integrated-database-egrid
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• Mechanical problems with an electric motor drive can be much more complex and result in
extended downtime while the motor is repaired or replaced. Purchasing a spare standby motor is
not practical.
• Additional ancillary equipment (transformers, switchgear, breakers, etc.) would be required to

deliver power to an electric motor, which would result in additional environmental impacts.
• Electric driven compression would necessitate the construction of a new building and electric
substation within Tennessee’s existing CS 261 site. Given the existing facilities on the site, the
only location where these facilities could be located would be in the southwest portion of the site,
which has a large wetland system associated with Worthington Brook. This work would require a
substantial amount of wetland fill, likely requiring substantial approvals pursuant to the Wetlands
Protection Act. In contrast, Tennessee’s proposed HP Replacement Project will not require
construction beyond the existing developed portion of the site, and only minimal (0.03 acres),
temporary wetland disturbance during construction. Siting electric driven compression facilities
on an adjacent site (e.g., the Hickory Street Yard property) would require extensive tree clearing
within forested wetlands to route the necessary power lines to the site.
• Significantly higher capital cost to customers would be incurred from installing an electric drive
compressor unit ($43.6MM) as compared to the proposed natural gas driven Taurus turbine
($22.9MM).
• Fuel costs for electric driven compression is significantly higher compared to natural gas. Over
20 years, Tennessee estimates the additional fuel cost would amount to approximately $84MM.
2.5 Non-Routine Operations

As previously described, non-routine operations include periodic in-line inspection/maintenance and
unplanned blowdowns. These operations are considered non-routine because it is anticipated that these
will occur only sporadically rather than annually.
2.5.1 Baseline
In-line inspections will occur approximately once every 5-7 years after commissioning the pipeline. It
should be noted that the amounts of launchers/receivers are the same as before the new pipeline is
installed, and there will be no increase in amount of in-line inspections. Thus, there is no change in
emissions from existing conditions. To illustrate, however, that emissions are minimal for in-line
inspections, Table 2-7 depicts the total amount of GHG emissions resulting from launching and receiving
the inspection gauges/tools along the 2.1-mile pipeline loop. These are the same emissions as the
commissioning in-line inspections.
Table 2-7. In-Line Inspection Emissions – Baseline

In-Line Inspection – Tons
(Launcher/Receiver)
CO2 CH4 CO2e
In-Line Inspection 0.00006 0.07 2.2
As described in Section 1.4, blowdowns may occur if there is a need to perform maintenance repair on a
section of pipeline. These are not typical or planned occurrences, but for purposes of GHG estimation are
included in this document. Blowdowns are expected to be a rare event, if they occur at all, as they only
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occur as an unplanned response to a discrete incident. Because of the nature of why a blowdown may be
needed, there is no reasonable way to definitively determine the amount of natural gas and resulting GHG
emissions that will be released. However, a conservative estimate is depicted in Table 2-8. The
emissions shown in Table 2-8 are considered conservative because they assume entire length of new pipe
loop (2.1 miles) needs to be vented at the maximum 700 psig pressure.
Table 2-8. Blowdown Emissions – Baseline

Blowdown – Tons Per Event
CO2 CH4 CO2e

Blowdown 0.01 8.8 299
2.5.2 Alternative 1
One potential minimization option for the sporadic in-line inspections that will occur is to recover the
natural gas lost during this process. A recovery process would require that once the natural gas is
captured, it would have to be compressed to be reintroduced into the pipeline. However, since just a very
small amount of natural gas is lost during in-line inspections from the launcher and receiver barrels, it is
not economically feasible to recover it. By recompressing the natural gas to try to recover it, potential
new combustion emissions (NOx, CO, and additional GHG) would be introduced to the environment. The
addition of these emissions would diminish the theoretical savings of approximately 17 tons of CO2e.
For unplanned blowdowns, a minimization option would be to draw down the natural gas (reduce the
pressure and amount of natural gas) prior to the required maintenance. This is also included in the Natural
Gas STAR program as “Using Pipeline Pump-Down Techniques to Lower Gas Line Pressure Before
Maintenance.” Tennessee will draw down the natural gas before any maintenance is conducted, if this
becomes necessary so long as it does not cause a reduction or loss of supply to customers. Tennessee is
not in the business to lose gas un-necessarily since it is a loss of product. As a result, Tennessee will do
what is practical and feasible to minimize any natural gas losses that could be released during
maintenance and repair procedures. However, if a blowdown is needed for safety or other practical
reasons, there is typically no time to plan out and implement such controls due to the urgency to fix the
issue that created the need for a blowdown and resupply gas to the pipeline that it needed by the public for
their homes/businesses and by electrical generating plants to generate electricity needed for
homes/businesses. Controlling a blowdown would require similar compression to put the natural gas
back into the pipeline, as described in the above paragraph describing the alternative for controlling in-
line inspection emissions. This process may emit more GHG in the form of combustion than it will save.
Another option to minimize blowdown emissions would be to capture the natural gas as explained above
or use a flare to burn the gas. Flaring would have the benefit of converting CH4 emissions into CO2. This
would be beneficial since the global warming potential of CO2 is 34 times less than CH4. However, this
would result in the formation of additional pollutants such as NOx, CO, and VOC, including various
hazardous air pollutants, resulting from combustion of the gas in the flare. Additionally, it would be
difficult to transport a flare/compressor to the new pipe section due to the short notice, the forested
remoteness, and variable topography of the pipeline location. As with the drawdown option, there is
typically no time to plan out and implement such controls due to the urgency to fix the issue that created
the need for a blowdown.
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Due to the evaluation of options provided in Alternative 1 as technically infeasible, the Preferred
Alternative is the Baseline. It is understood that the emissions calculated for the blowdown operation are
considered “worst case” since it assumes the full length of the pipeline is vented and no controls were
implemented due to timing constraints.
CONCLUSIONS
The Projects’ scope is limited to the construction and operation of the proposed 2.1 miles of natural gas
pipeline loop, the new combustion turbine and compressor, and appurtenant facilities. The proposed
pipeline only transports natural gas for shippers pursuant to transportation service agreements from the
upstream transmission network to the downstream transmission network. Thus, annual emissions of
GHGs are primarily limited to operation of the compressor turbine. As described in the sections above,
annual emissions due to normal operating fugitive leaks are minimal, below 1 ton of CO2e. There are
some one-time emission releases due to necessary operations for construction and commissioning of the
pipeline, but those emissions will be limited to a three- to four-month timeframe and will not be
reoccurring.
The Preferred Alternative emissions for all phases of the Projects are summarized in Table 3-1.
For the construction phase, Tennessee is planning on using the hot-tap methodology for connecting the
pipelines which eliminates natural gas venting from this process. On- and-off road vehicles and engines
used during the construction phase will minimize emissions by utilizing vehicles adhering to the more
stringent Tier 3 and 4 emissions standards when available and practical. All construction vehicles will
operate with ultra-low sulfur diesel fuel and limit the amount of engine idling time.
For the commissioning phase, Tennessee is planning on pressure testing the pipeline using hydrostatic
testing which eliminates the need to use, and then vent, natural gas to pressure test the pipes. Emissions
from purging and in-line inspections of the pipeline are minimal enough to make any control attempt
impractical.
For the normal operation of the pipeline, protected steel pipes will be installed, regular inspections will
check for potential leaks, and all practical efforts will be made to fix leaks expeditiously to limit the
amount of natural gas vented into the atmosphere. Locations of potential leaks are expected to be
primarily limited to valves at either end of the new pipeline segments.
For non-routine operations, in-line inspection emissions will only occur approximately once every 5 to 7
years. Since just a very small amount of natural gas is lost during the in-line inspections from the launcher
and receiver barrels, it is not economically feasible to recover. Blowdown emissions will only occur due
to unplanned discrete incidents and thus may never need to occur. If blowdowns are needed, it is likely
that no controls can be implemented due to timing constraints. Emissions calculated assume the worst
case scenario where the entire length of the Project pipeline will be required to be vented.
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Table 3-1. GHG Emissions - Summary
Emissions – Tons
Duration CO2 CH4 N2O CO2e

Construction Once 3,143 20.31 0.16 3,880
Commissioning Once 0.001 1.24 - 42
Normal Operation Annual 46,635 0.90 0.09 46,692

Once per 5 to 7 years/
0.00006 0.07 - 2
Sporadic
Non-Routine Operation
Infrequent/
0.01 8.80 - 299
Only if Needed
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APPENDIX F
Air Emissions Calculations
Tennessee Gas Pipeline - 261 Upgrade Project (Looping Project and HP Replacement Project)
Construction Emissions - Summary
Pipeline Loop Construction

CO NOx VOC SO2 PM 10 PM 2.5 CO2 CH4 N2O CO2e HAPs
Total 33.57 14.48 1.57 0.03 19.00 3.63 2,227.66 0.07 0.10 2,261.01 0.10
Station 261 HP Replacement

Total 7.47 6.25 0.69 0.01 2.75 0.79 914.92 20.23 0.06 1,619.30 0.04
Tons per Construction Period - Hampden County, MA

Total 41.05 20.73 2.26 0.04 21.75 4.42 3,142.58 20.31 0.16 3,880.31 0.15
Construction Emissions - Off-Road Engines - 12" Pipeline Loop
Engine
2
Equipment category based on 1 Fuel Technology Equipment Number of Total BSFC
2
EFss (g/hp-hr) Load
Description SCC
NONROAD classification Type Type HP Equipment Total Total Total Hours Working 2
lb/hp-hr HC CO PM NOx Factor
Days Weeks Months per Day hrs
NOTES:
Tennessee Gas Pipeline - 261 UpTennessee Gas Pipeline - 261 Upgrade Project (Looping Project and HP Replacement Project)
Construction Emissions - Off-Ro Construction Emissions - Off-Road Engines - 12" Pipeline Loop
3
Deterioration factor 4 Adjusted EF (g/hp-hr) 8
Description Age "A" 3 SPM adj N2O EF
3 g/hp-hr 5,9 5,9 4,9 6,9 7 g/MMBtu
Factor HC CO PM NOx HC CO PM NOx HC CO PM SO2 NOx 5,9 CO2
Construction Total (Tons)
NOTES:
(table 13.7) (table 13.1)

Tennessee Gas Pipeline - 261 UpTennessee Gas Pipeline - 261 Upgrade Project (Looping Project and HP Replacement Project)
Construction Emissions - Off-Ro Construction Emissions - Off-Road Engines - 12" Pipeline Loop
10 PM 11/ 12 11 11 11 13 14 GHG 15
VOC 11 12 PM2.5 SO2 NOx CO2 CH4 N2O
Description CO tons PM10 tons of
tons tons tons tons tons tons tons
tons CO2e
1.28 31.85 0.79 0.77 0.02 11.75 1,574 0.05 0.10 1,607
NOTES:
Construction Emissions - Off-Road Engines - Station 261 HP Replacement
Engine
2
Equipment category based on 1 Fuel Technology Equipment Number of Total BSFC
2
EFss (g/hp-hr) Load
Description SCC
NONROAD classification Type Type HP Equipment Total Total Total Hours Working 2
lb/hp-hr HC CO PM NOx Factor
Days Weeks Months per Day hrs
NOTES:
Tennessee Gas Pipeline - 261 UpgraTennessee Gas Pipeline - 261 Upgrade Project (Looping Project and HP Replacement Project)
Construction Emissions - Off-Road Construction Emissions - Off-Road Engines - Station 261 HP Replacement
3
Deterioration factor 4 Adjusted EF (g/hp-hr) 8
Description Age "A" 3 SPM adj N2O EF
3 g/hp-hr 5,9 5,9 4,9 6,9 7 g/MMBtu
Factor HC CO PM NOx HC CO PM NOx HC CO PM SO2 NOx 5,9 CO2
Construction Total (Tons)
NOTES:

Tennessee Gas Pipeline - 261 UpgraTennessee Gas Pipeline - 261 Upgrade Project (Looping Project and HP Replacement Project)
Construction Emissions - Off-Road Construction Emissions - Off-Road Engines - Station 261 HP Replacement
10 PM 11/ 12 11 11 11 13 14 GHG 15
VOC 11 12 PM2.5 SO2 NOx CO2 CH4 N2O
Description CO tons PM10 tons of
tons tons tons tons tons tons tons
tons CO2e
0.50 6.93 0.42 0.41 0.01 5.54 726 0.01 0.06 743
NOTES:
Construction Emissions - Off-Road Engines - 12" Pipeline Loop
Engine 4
HAP Emissions (Tons)
Equipment category based on Fuel Technology Equipment Number of Total BSFC
2
Load
Description SCC 1
NONROAD classification Type Type HP Equipment Total Hours Working 2
lb/hp-hr Factor
Days per Day hrs Benzene Toluene Xylenes Propylene Acrolein PAHs 1,3-Butadiene Formaldehyde Acetaldehyde
Construction Total (Tons) 8.99E-03 3.94E-03 2.74E-03 2.48E-02 8.91E-04 1.62E-03 3.77E-04 1.14E-02 7.39E-03
Large
Small Diesel Diesel
Units Units
3
Emission Factor lb/MMBtu lb/MMBtu
NOTES:
Construction Emissions - Off-Road Engines - Station 261 HP Replacement
Engine 4
HAP Emissions (Tons)
Equipment category based on Fuel Technology Equipment Number of Total BSFC
2
Load
Description SCC 1
NONROAD classification Type Type HP Equipment Total Hours Working
lb/hp-hr Factor 2
Days per Day hrs Benzene Toluene Xylenes Propylene Acrolein PAHs 1,3-Butadiene Formaldehyde Acetaldehyde
Construction Total (Tons) 4.14E-03 1.81E-03 1.26E-03 1.14E-02 4.10E-04 7.45E-04 1.73E-04 5.24E-03 3.40E-03
Large
Small Diesel Diesel
Units Units
3
Emission Factor lb/MMBtu lb/MMBtu
NOTES:
Construction Emissions - On-Road Vehicles - 12" Pipeline Loop - Hampden County, MA
Category Based on MOVES2014a Number of Total Total Working Hours

Description Total Days Mi/hr 2
Classification 1 Equipment Weeks Months Days per Day
Category Based on MOVES2014a NOx3 VOC3 SO23 PM103 PM2.53 CO23 CH43 CO2e3 HAPs3,4
Description Calc. VMT 2 CO3 g/VMT
Classification g/VMT g/VMT g/VMT g/VMT g/VMT g/VMT g/VMT g/VMT g/VMT
Category Based on MOVES2014a CO VOC

SO2 ton/yr
PM10 PM2.5 CO2 CH4 CO2e HAPs4
Description NOx ton/yr
Classification ton/yr ton/yr ton/yr ton/yr ton/yr ton/yr ton/yr ton/yr
Total 1.725 2.730 0.283 0.00560 0.2949 0.1700 653.8361 0.0246 654.45 0.0411
NOTES:
Construction Emissions - On-Road Vehicles - Station 261 HP Replacement - Hampden County, MA
Category Based on MOVES2014a Number of Total Total Working Hours 2

Description 1 Total Days Mi/hr
Classification Equipment Weeks Months Days per Day
3 3 3 3 3 3
Category Based on MOVES2014a NOx3 VOC3 SO2 PM 10 PM 2.5 CO2 CH4 CO2e HAPs3,4
Description Calc. VMT 2 CO3 g/VMT
Classification g/VMT g/VMT g/VMT g/VMT g/VMT g/VMT g/VMT g/VMT g/VMT
4
Category Based on MOVES2014a CO VOC PM 10 PM 2.5 CO2 CH4 CO2e HAPs
Description NOx ton/yr SO2 ton/yr
Classification ton/yr ton/yr ton/yr ton/yr ton/yr ton/yr ton/yr ton/yr
Total 0.541 0.712 0.082 0.00162 0.0773 0.0439 189.0523 0.0075 189.24 0.0120
NOTES:
Construction Emissions - Fugitive Dust from Construction Activities
12" Pipeline Loop Station 261 HP Replacement
PM2.5
PM10
PM30
Heavy Construction Operations

Emission Factor PM2.5 PM10 PM30
E = 1.2 tons/acre/month of activity
NOTES:
Construction Emissions - Baseline Venting
Density of CO2 Density of CH4

Released Volume CO2 CH4 CO2 CH4 at Standard at Standard CO2 CH4
(mcf) (mol fraction) (mol fraction) (scf) (scf) Conditions Conditions CO2e
Emissions Emissions
(kg/scf) (kg/scf)
(tons) (tons) (tons)
395.82
VOC HAPs
Released Volume Gas Density Released Gas VOCs HAPs
Emissions Emissions
(mcf) (lbs/scf) Volume (lbs) (wt%) (wt%)
(tons) (tons)
Input Data for Line Blowdown

556 = IPCC AR5 GWPs
=
=
=
2
Q = (D/2) x 3.1416 x L x (P/14.5) / 1000
Construction Emissions - Station Venting
Density of CO2 Density of CH4

Released Volume CO2 CH4 CO2 CH4 at Standard at Standard CO2 CH4
(mcf) (mol fraction) (mol fraction) (scf) (scf) Conditions Conditions CO2e
Emissions Emissions
(kg/scf) (kg/scf)
(tons) (tons) (tons)
687.24
VOC HAPs
Released Volume Gas Density Released Gas VOCs HAPs
Emissions Emissions
(mcf) (lbs/scf) Volume (lbs) (wt%) (wt%)
(tons) (tons)
966 = IPCC AR5 GWPs

=
=
Q = V x (P/14.5) / 1000
Non-Construction Emissions - Summary
Portion Source CO2 CH4 N2O CO2e VOCs HAPs
Total 46635.00 11.00 0.09 47035.39 0.05 0.00
Source CO2 CH4 N2O CO2e VOCs HAPs

Commissioning Emissions - Pipeline Purging
Density of CO2 at Density of CH4 at

Released Volume CO2 CH4 CO2 CH4 Standard Standard
(mcf) (mol fraction) (mol fraction) (scf) (scf) Conditions Conditions CO2 Emissions CH4 Emissions
(kg/scf) (kg/scf) (tons) (tons) CO2e (tons)
20.01
Released Volume Gas Density Released Gas HAPs VOC Emissions HAPs Emissions
VOCs (wt%)
(mcf) (lbs/scf) Volume (lbs) (wt%) (tons) (tons)
Input Data (constant release) for Gas Purging During Commissioning

28.1 = IPCC AR5 GWPs
=
=
*Q = 1.342 x A x P x min/60
Commissioning Emissions - In-Line Inspections

Pigging CO2 CH4 CO2 CH4 Standard Standard
Operation CO2 Emissions CH4 Emissions
Volume (mcf) (mol fraction) (mol fraction) (scf) (scf) Conditions Conditions
1.11
1.11
Total for Event (Launching and Receiving) 2.21
Released Gas Density Released Gas VOCs HAPs

Operation VOC Emissions HAPs Emissions
Volume (mcf) (lbs/scf) Volume (lbs) (wt%) (wt%)
(tons) (tons)
Input Data for Line Inspection

IPCC AR5 GWPs
0.6 1.0 =
=
=
=
Q = (D/2)2 x 3.1416 x L x (P/14.5) / 1000

Commissioning Emissions - Compressor Purging

Released Volume CO2 CH4 CO2 CH4 Standard Standard
(mcf) (mol fraction) (mol fraction) (scf) (scf) Conditions Conditions CO2 Emissions CH4 Emissions
20.01
Released Volume Gas Density Released Gas HAPs VOC Emissions HAPs Emissions
VOCs (wt%)
(mcf) (lbs/scf) Volume (lbs) (wt%) (tons) (tons)
Input Data (constant release) for Gas Purging During Commissioning

28.1 = IPCC AR5 GWPs
=
=
*Q = 1.342 x A x P x min/60
Normal Operating Emissions
CO2e (tons) Pipeline gas composition

0.56
Pipeline fugitive emissions will be calculated using Tier 3 emission factors referenced in INGAA GHG Guidelines 1 .
Emission Emissions CO2 Emissions CH4 Emissions CO2e Emissions VOC Emissions
Sector Pipeline Type GHG Factor Basis (tons) (tons) (tons) (tons) HAPs (tons)
Total 0.001 0.02 0.560 0.00009 0.000001
Volume 1 - GHG Emission Estimation Methodologies and Procedures
Actual CH mol
CH emissions tons Emi ssion Factor lb mile Pi peline Length mile
Default CH mol
1 ton
2 000 lb
Actual CO2 mol

CO2 emissions tons Emission Factor lb mile Pipeline Length mile IPCC AR5 GWPs
Default CO2 mol
1 ton
2 000 lb
Normal Operating Emissions - Electric Compression Option
Indirect Emissions from Electricity Baseline Difference

lb/MW-h lb/hr ton/yr ton/yr ton/yr Comparison
Non-Routine Emissions - Pipeline In-Line Inspections

Pigging CO2 CH4 CO2 CH4 Standard Standard
Operation CO2 Emissions CH4 Emissions
Volume (mcf) (mol fraction) (mol fraction) (scf) (scf) Conditions Conditions
1.11
1.11
Released Gas Density Released Gas VOCs HAPs

Operation VOC Emissions HAPs Emissions
Volume (mcf) (lbs/scf) Volume (lbs) (wt%) (wt%)
(tons) (tons)
Input Data for Line Inspection

IPCC AR5 GWPs
0.6 1.0 =
=
=
=
Q = (D/2)2 x 3.1416 x L x (P/14.5) / 1000

Non-Routine Emissions - Pipeline Blowdowns

Blowdown CO2 CH4 CO2 CH4 Standard Standard CO2 CH4
Volume (mcf) (mol fraction) (mol fraction) (scf) (scf) Conditions Conditions Emissions Emissions CO2e
(kg/scf) (kg/scf) (tons) (tons) (tons)
299.24
Released Volume Gas Density Released Gas VOCs HAPs VOC Emissions HAPs Emissions
(mcf) (lbs/scf) Volume (lbs) (wt%) (wt%) (tons) (tons)
Input Data for Line Blowdown IPCC AR5 GWPs

420 =
=
=
=
Q = (D/2)2 x 3.1416 x L x (P/14.5) / 1000

Representative Gas Analysis
100.000 16.502 100.000

F-24
Existing Station 261 Turbines Potential Annual Emissions
Heat Input Heat Input

(average)
Project Potential Annual Emissions (ton/ yr) (< 0ºF)
Centaur H (EU #1) 54.8 60.28
Saturn T1001 (EU #2) 16.46 16.46
Hours at each heat input 8460 300
Saturn
Centaur
T1001
H (EU #1)
(EU #2)
Pollutant kg/ MMBtu ton/ yr ton/ yr
CO2 53.06 28,173 8,433
CH4 0.001 0.53 0.16
N2O 0.0001 0.05 0.02
CO2e 53.1238 28,207 8,444
Annual emissions calculations for GHGs are based on the same methodology used for criteria pollutant estimates
provided with 2013 Operating Permit renewal application package.
GHGs = kg/ MMBtu * (avg. MMBtu/ hr * 8,460 hr/ yr) + < 0ºF MMBtu/ hr * 300 hr/ yr) * 2.20462 lb/ kg / 2,000 lb/ ton
CO2, CH4, N2O based on 40 CFR Part 98 Tables C-1 and C-2.
CO2e based on GWP from IPCC AR5, Climate Change 2013 The Physical Science Basis, Table 8.7 (CO2 = 1, CH4 = 34,
N2O = 298).
Air Emissions - Appendix F to the EENF - Taurus 70.xlsm

Appendix F - Air Emission Calculations Existing Turbines

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EXPANDED ENVIRONMENTAL NOTIFICATION

FORM – 261 UPGRADE PROJECTS,

Secretary Matthew Beaton

RE: Expanded Environmental Notification Form

Dear Secretary Beaton:

Environmental Notification Form

Attachment 1 – USGS Topographic Maps

Attachment 2 – Map Books

Attachment 3 – Environmental Constraints Maps

Attachment 4 – ENF Distribution List

Attachment 5 – Permit and Consultation List

Attachment 6 – Expanded Environmental Notification Form Narrative

Environmental Notification Form

Project Name: 261 Upgrade Projects

Effective January 2011

New acres of land altered 18.40 acres (temp)

Square feet of new bordering 289,000 sf (temporary)

Number of housing units N/A N/A N/A

Maximum height (feet) N/A 25.5 feet N/A

Parking spaces N/A N/A N/A

Water withdrawal (GPD) N/A N/A N/A

Wastewater generation/treatment N/A N/A N/A

Length of sewer mains (miles) N/A N/A N/A

Has this project been filed with MEPA before?

AREAS OF CRITICAL ENVIRONMENTAL CONCERN:

HISTORICAL /ARCHAEOLOGICAL RESOURCES:

SOLID AND HAZARDOUS WASTE:

DESIGNATED WILD AND SCENIC RIVER:

II. Impacts and Permits

II. Impacts and Permits

II. Wetlands Impacts and Permits

Coastal Wetlands Area (square feet) or Temporary or

Land Under the Ocean _______0_________ ___N/A_____________

E. Will the project:

III. Waterways and Tidelands Impacts and Permits

C. For non-water-dependent use projects, indicate the following:

F. Is the project non-water-dependent and located on landlocked tidelands or waterways or

Beach Nourishment ___

II. Impacts and Permits

Permitted Existing Avg Project Flow Total

G. Does the project involve:

II. Impacts and Permits

Existing Change Total

Discharge of sanitary wastewater ________ ________ ________

Existing Change Total

Permitted Existing Avg Project Flow Total

Existing Change Total

II. Traffic Impacts and Permits

C. If applicable, describe proposed mitigation measures on state-controlled roadways that the

C. Is there a Transportation Management Association (TMA) that provides transportation demand

II. Transportation Facility Impacts

B. Will the project involve any

II. Impacts and Permits

D. Describe the project's other impacts on energy facilities and services:

II. Impacts and Permits

The turbine air emissions will exhaust through a 67.5-foot stack.

II. Impacts and Permits

Existing Change Total

D. If the project involves demolition, do any buildings to be demolished contain asbestos?

Springfie ld South Quadrangle

Topographic Quadrangle SUFFIELD

LL# 6.01 LL# 9

Cable Trays New Exhaust

Land Under the Ocean _0_ _N/A_____________

Discharge of sanitary wastewater