Comment of Allegheny Defense Project and Pennsylvania Alliance for Clean Water and Air under CP15-115.

UNITED STATES OF AMERICA BEFORE THE FEDERAL ENERGY REGULATORY COMMISSION National Fuel Gas Supply Corporation ) Docket No. CP15-115-000 Empire Pipeline, Inc. ) COMMENTS OF ALLEGHENY DEFENSE PROJECT AND PENNSYLVANIA ALLIANCE FOR CLEAN WATER AND AIR The following comments are provided on behalf of the Allegheny Defense Project (Allegheny) and Pennsylvania Alliance for Clean Water and Air (PACWA) regarding National Fuel Gas Supply Corporations (Supply) and Empire Pipeline Companys (Empire) (collectively, National Fuel)1 proposed Northern Access 2016 Project (2016 Project or Project). Supply proposes to: (i) construct 96.65 miles of 24-inch diameter pipeline; (ii) add 5,350 horsepower of compression at the Porterville, NY compressor station; (iii) construct an interconnect meter and regulation (M&R) station with Tennessee Gas Pipeline Companys (Tennessee) 200 Line; (iv) construct an M&R station and tie-in in Hinsdale, NY; (v) construct an interconnection with NFG Midstream Clermont; (vi) modify an existing tie-in; (vii) construct a pressure reduction station; (viii) abandon, via sale to Empire, all 3.09 miles of Supplys existing Line XM-10 pipeline; and (ix) charge an initial incremental firm recourse rate for the Project. Supply also seeks a waiver of General Terms and Conditions Section 31.1 of its tariff to permit Seneca Resources, National Fuel Gas Companys exploration and production subsidiary and the Foundation Shipper for the Project, to shift its primary delivery point for a portion of the Projects incremental capacity more than 90 days after its initial request. The Project would result in approximately 497,000 dekatherms per day of new firm capacity. 1 National Fuel Gas Supply Corporation and Empire Pipeline, Inc. are both subsidiaries of National Fuel Gas Company. 1 Empire proposes to: (i) construct a new 22,214 horsepower compressor station in Pendleton, NY; (ii) construct 3.05 miles of 24-inch pipeline, replacing 3.05 miles of existing Supply 16-inch XM-10 pipeline; (iii) construct a new dehydration facility; (iv) modify two existing tie-ins; and (v) acquire from Supply the aforementioned 3.09 miles of Line XM-10. The Project would result in approximately 350,000 dekatherms per day of new firm capacity. In total, the Project would result in approximately 847,000 dekatherms per day of new firm capacity. On July 10, 2014, National Fuel filed a request to initiate the pre-filing process for the Project, which FERC granted on July 24, 2014. On October 22, 2014, FERC published a Notice of Intent to Prepare an Environmental Assessment (EA) for the Project. See 79 Fed. Reg. 64,379 (Oct. 29, 2014). On November 21, 2014, Allegheny submitted comments in response to FERCs Notice of Intent to Prepare an EA. On March 17, 2015, FERC published the Notice of Application ...