UNITED STATES ENVIRON MENTAL PROTECTION AGENCY
REGION Ill
1650 Arch Street
Phi ladelphia, Pennsylvania 19103-2029

Nathaniel J. Davis, Sr., Deputy Secretary
Federal Energy Regu latory Commission
888 First Street NE, Room 1A
Wash ington, DC 20426

JUN 1 1 20\G

Re:
Atlantic Sunrise Project Draft Environmental Impact Statement; Pennsylvania, Maryland,
Virginia, North Carolina and South Carolina; May 2016 (FERC Docket No. CP15- 138;
CEQ# 20 16-11223)
Dear Deputy Secretary Davis:
In accordance with the National Environmental Policy Act (NEPA) of 1969, Section 309
of the Clean Air Act and the Council on Environmental Quality (CEQ) regulations implementing
NEPA (40 CFR 1500-1 508), the U.S. Environmental Protection Agency (EPA) has reviewed the
Draft Environmental Impact Statement (DEIS) for Transcontinental Gas Pipe Line Company,
LLC's (Transco or the applicant) Atlantic Sunrise Project. The DEIS has been prepared by the
Federal Energy Regu latory Commission (FERC) tasked with approving certificates for interstate
natural gas pipeline facilities. Additionally, EPA is concurrently reviewing the Clean Water Act
Section 404 Public Notice (PN) issued by the U.S. Army Corps of Engineers (Corps or USACE)
Baltimore District, a cooperating agency on the DEIS, and will also be provid ing comments on
the proposed project in response to the PN.
Transco proposes to construct and operate an expansion of its existing natural gas
transmission system in Pennsylvania, Virginia, Maryland, North Carolina, and South Carolina.
Transco's project purpose is to provide an incremental 1.7 million dekatherms per day
(MMDth/d) of year-round firm transportation capacity from the Marcellus Shale production area
in northern PA to Transco's existing market areas, extending to the Station 85 Pooli ng Point in
Choctaw County, Alabama. The EIS will not determine whether the need for the Project exists,
as th is will be determined by the Commission later; however the purpose ofNEPA is informed
decision making, using relevant information and public engagement in the process, which could
be compromised by deferring this analysis.
The Atlantic Sunrise project, in the alignment ofTransco's preferred alternative, includes
the construction and operation of 197.7 miles of pipeli ne to provide ability to transport 1.7
MMDth/d natural gas. Atlantic Sunrise is proposed to be collocated for 54.6 miles (28 percent)
with or adjacent to existi ng pipelines and/or electric transmission utility rights-of-way. The

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 majority of the line is new 30 inch and 42 inch natural gas pipeline. Atlantic Sunrise also
proposes the construction and operation of two new compressor stations in Wyoming and
Columbia Counties, PA, and modification to three existing compressor stations in Columbia and
Lycoming Counties, PA and Howard County, MD. Minor modifications at existing
aboveground facilities at various locations in Pennsylvania, North Carolina, South Carolina, and
Virginia to allow for bi-directional flow and the installation of supplemental odorization, odor
detection , and/or odor masking/deodorization equipment are also proposed.
The DEIS presented alternatives beyond the applicant's preferred alternative, including
the no-action alternative, two system alternatives, three major route a lternatives, other minor
route modifications and variations, and aboveground facil ity site alternatives. FERC has
recommended that several minor modifications be incorporated beyond those that were
incorporated by T ransco. Beyond these minor modifications, all other system and major route
alternatives were dismissed. Only the applicant's preferred alternative was carried forward for
detailed analysis in the DEIS. It is not clear if there are additional route modifications that could
be made to the appli cant's alternative which may reduce adverse environmental impacts.
The alternatives analysis presented in the DEIS seems to include reasonable alternatives
which were not carried forward fo r detailed consideration. Based on the information provided in
the study, EPA recommends two system alternatives be retained for further detailed study,
including the Transco system alternative, which is collocated for 91% of its route, and the
expanded PennEast alternative, wh ich would expand the Ill mile PennEast pipeline by 80 miles
and eliminate the need for the Atlantic Sunrise pipeline. EPA recommends FERC fully consider
these two alternatives and include the analysis in the EIS. These two alternatives appear to have
the potential to meet the project purpose and need while minimizing adverse environmental
impacts. Without additional analysis of alternatives, it is not clear that the preferred alternative
is the only one to meet the stated purpose and need.
EPA is concerned by the statement in the EIS that project need will not be vetted in the
EIS, but outside ofthe NEPA process by FERC. The purpose and need is the basis for the
alternatives analysis and is the foundation for the analysis under NEPA. Assessing the need and
a full suite of alternatives is a critical component of the NEPA process, and a component in
which the public has shown great interest as well as concern. We recommend FERC provide
transparency in the decision-making process and include as much of this information within the
NEPA document for full disclosure to the public and afford the public the opportunity to provide
comment.
EPA is concerned about the amount of detailed information that has yet to be filed and is
not evaluated in the DEIS. This includes surveys for land, rare species, historic resources, water
supplies, air modeling, mitigation measures to manage and dispose of contaminated
groundwater, proposed mitigation measures for source water protection areas, geotechnical
feasibility studies for HOD crossing locations and mitigation measures to minimize drilling risks,
and a detailed aquatic resource compensatory mitigation plan. This information is relevant and
critical to evaluation of potential impacts. EPA is concerned that a fully informed decision may
not be made without this information. EPA is interested in discussing with FERC when and how
this information will be assessed and disclosed to the public.

 EPA is concerned about direct, secondary and cumulative impacts to aquatic resources,
groundwater, and water quality. Aquatic resources have the potential to be impacted by many
activities, including waterbody crossings, clearing, blasting, and water withdraws for hydrostatic
testing. Some of the resources within the proj ect are high quality and sensitive resources,
including Exceptional Value (EV) and trout streams. The full assessment of these
simultaneously occurring impacts to resources needs to be conducted. With the potential for
complex impacts to occur, such as changes in recharge patterns and flow status, additional
avoidance and minimization measures may be necessary to protect the aquatic ecosystem.
Additional comments on aquatic resources can be found within the enclosures to this document.
The EIS reports that a total of 50.4 acres of wetlands would be either crossed by the
Project, affected by temporary extra workspaccs, or located within the construction right-of-way.
The Project would involve 33 1 waterbody crossings. EPA believes additional information on
aquatic resources should be included in the EIS, including impact breakdowns and compensatory
mitigation concepts, which are provided in the Corps' PN, detailed stream and wetland
assessment data on the quality or functions of the systems, and detailed, or at a minimum
conceptual, compensatory mitigation plans. Additionally, as part of the Section 404, CWA
permit process, a detailed compensatory mitigation needs to be prepared and submitted. Without
more detailed infonnation it is uncertain if the proposed mi tigation wi ll compensate for the
functions lost.
Large impacts to terrestrial resources, including forest and forest interior dwe lling species
(FIDS) habitat, are also of concern to EPA. Construction of the Proj ect would disturb about
3,905.8 acres of land, inc luding pipeline facilities, aboveground facilities, pipe yards, contractor
yards, and staging areas, temporary and permanent construction access roads, and right of way.
Permanent operations would require about 1,208.3 acres of the 3,905.8 acres of construction
lands. The Project would cross 45 interior forests along CPL North and South and would affect
270.4 acres of interior forest habitat during construction. About I 18.9 acres of the affected
interio r forest wou ld be permanently eliminated due to Transco's maintenance of the right-ofway during operation of the pipeline facilities. Using the distance of 30 fee t from the edges of
newly created edge habitat into interior forest, the DEIS estimates that I ,993.8 acres of interior
fores t would be indirectly impacted. This may be an underestimation of indirect interior forest
impacts, as the use of only a 30 foot buffer is not supported or documented in the EIS.
Mitigation should address the loss of mature forest and FIDS, which may take decades to
replace.
EPA acknowledges that the DEIS cumulative impact analysis included natural gas
infrastructure, including gathering lines, FERC-jurisdictional natural gas transmission projects,
and natural gas wells. Consideration of natural gas production, transm ission and use could be
expanded in the anal ysis to provide a more comprehensive understanding of impacts. It is
recommended that FERC active ly seek to unravel and describe the highly complicated, interrelated network of pipeli nes. This is important fo r public understanding and also a step toward
identifying cumulative impacts from combinations of past, present and reasonably foreseeable
infrastructure and non-infrastructure activities. Please consider our detailed comments regarding
cumulative impacts presented in enclosure to this document.

 EPA is concerned that the selection of the current preferred alternative may result in
significant adverse environmental impacts. EPA recommends that available systems alternatives
be retained for detailed study. EPA also recommends that the information not currently included
in the DEIS be disseminated and appropriately evaluated with the resource agencies and public
stakeholder participation prior to the issuance of any certificates by FERC. EPA is interested in
di scussing with FERC the most appropriate way for system alternatives and other information to
be considered and included for public information and agency consideration, which may possibly
be accomplished through the use of a revised DEIS.
Based on our review of the DEIS and the amount of detailed information which has not
been included or completed, EPA has rated the environmental impacts associated with all of the
action alternative corridors as Environmental Concerns ("EC") and the adequacy of the impact
statement as "2" (Insuffi cient Information). This rating is due to the direct, indirect and
cumulative impacts of the proposed corridors on terrestrial resources, including interior forests,
aquatic resources, rare, threatened and endangered species. EPA recommends additional
alternatives be explored to help further reduce impacts to resources resulting from the proposed
action. Details on the basis for this rating are contained in the remainder of this letter. A
description of our rating system can be found at:
www .epa.gov/compliance/ nepa/comments/ratings. htm I.
Please consider the issues, questions and comments included in this letter and enclosure.
We recognize the complexity of the analysis needed and difficulty in balancing impacts to
natural resources, farmland and communities for any build alternative. We would appreciate the
opportunity to discuss the comments provided here, at your convenience. Thank you for
allowing EPA with the opportunity to review and comment on the Atlantic Sunrise DEIS. If you
have questions regarding these comments, the contact for this project is Ms. Alaina McCurdy;
she can be reached at (2 15) 814-2741 or mccurdy.alaina@epa.gov.
Sincerely,

Enclosure ( 1) Narrati ve Technical Comments
(2) Detailed Technical Comments