Millennium ESU TIMBER RATTLESNAKE SUPPLEMENTAL REPORT

20170126-5194 FERC PDF (Unofficial) 1/26/2017 4:48:52 PM
One Blue Hill Plaza, 7th Floor

Post Office Box 1565
Pearl River, NY 10965
845.620.1300 Voice | 845.620.1320 Fax
January 26, 2017
Ms. Kimberly D. Bose, Secretary

Federal Energy Regulatory Commission
888 First Street, N.E.
Washington, D.C. 20426
Re: Millennium Pipeline Company, L.L.C., Docket No. CP16-486-000

Eastern System Upgrade Project
Correspondence with New York State Department of Environmental Conservation
Dear Ms. Bose:
On July 29, 2016, Millennium Pipeline Company, L.L.C. (Millennium) filed with the
Federal Energy Regulatory Commission (Commission) in Docket No. CP16-486-000 an
Abbreviated Application for a Certificate of Public Convenience and Necessity (Application)
for its proposed Eastern System Upgrade Project (Project). 1 Millennium hereby submits
correspondence with the New York State Department of Environmental Conservations
(NYSDEC) in which it provided additional information requested by NYSDEC regarding the
state-listed threatened timber rattlesnake.
Description of Items Being Filed
Public
Cover letter to NYSDEC
Timber Rattlesnake Impact Assessment and Mitigation Plan prepared for the Project
Privileged and Confidential Non-Public:

Timber Rattlesnake (Crotalus horridus) Habitat Occurrence and Assessment for the
Eastern System Upgrade (January 2017).
1
Millennium Pipeline Company, L.L.C., Abbreviated Application for a Certificate of Public Convenience and
Necessity, Docket No. CP16-486-000 (July 29, 2016).
www.millenniumpipeline.com
Millennium is filing the additional information pursuant to the Commissions guidelines

for eFiling. If you have any questions regarding this filing, please contact me at 845-620-1300.
Respectfully submitted,
/s/ Georgia Carter
Georgia Carter
Vice President and General Counsel
Millennium Pipeline Company, L.L.C.
Attachment
cc: Eric Howard, FERC

Service List
www.millenniumpipeline.com
2
January 26, 2017
Mr. Stephen Tomasik, Project Manager

Major Projects Management Section
Division of Environmental Permits
625 Broadway, 4th Floor
Albany, NY 1233-1750
Re: Supplemental Information

New York State Department of Environmental Conservation
Millennium Pipeline Company, L.L.C. Eastern System Upgrade
Application ID: 0-9999-00055/00011 Water Quality Certificate
Application ID: 0-9999-00055/00012 Freshwater Wetlands
Application ID: 0-9999-00055/00013 Stream Disturbance
Dear Mr. Tomasik:
Millennium Pipeline Company, L.L.C. (Millennium) is providing this supplemental information to the New
York State Department of Environmental Conservations (NYSDEC) with respect to the proposed Eastern
System Upgrade (Project). The Project is currently under review by the Federal Energy Regulatory
Commission (FERC) under Docket No. CP16-486-000. On August 25, 2016, Millennium submitted a Joint
Permit Application (JPA) requesting a 401 Water Quality Certificate as well as NYSDEC review of the
Project under Articles 15 and 24 of the New York State Environmental Conservation Law (ECL).
Subsequent to the submittal of the JPA, NYSDEC and Millennium participated in a meeting on October
14, 2016 to discuss the Project and the application materials. At that meeting, NYSDEC requested
additional information on a number of topics including rare species, construction methodologies and
wetlands. These were summarized within a meeting summary provided by NYSDEC to Millennium on
October 24, 2016. With this correspondence Millennium is providing additional information requested by
NYSDEC at the October 2016 meeting regarding the state-listed threatened timber rattlesnake (crotalus
horridus). Millennium is currently preparing responses to the remaining topics covered in the October
meeting and anticipates submitting additional information and responses to those items in February 2017.
At the October 2016 meeting, NYSDEC requested the following information regarding the timber
rattlesnake: Additional details are needed in the review/assessment of all impacts to Timber rattlesnakes
for the three locations previously identified - Highland compressor station, West side of RT 209 on
Huguenot loop, and Ramapo metering station. These include impacts to foraging habitat and impacts to

0-9999-00055/00011, 00012, 00013
Eastern System Upgrade
January 26, 2017
Page 2 of 2
dens from construction/ rock removal, in addition to the discussed impacts to basking and denning areas.
The impact assessment should take the form of the outline for initial impact assessments in Article 11, Part
182 guidance (attached separately). In addition to looking at all the impacts, details on proposed take
avoidance measures and their implementation should also be provided. For example, no information on an
education and encounter plan, or the environmental monitors responsibilities, has been provided. Based
on the information and initial review, consideration should be given to enhancement of habitats or other
possible benefits to the species that could be accomplished (i.e. vegetation maintenance scheduling). BMPs
or take avoidance measures for ETS should be included in as a document that can be referenced by
contractors and construction personnel.
In response to this request, enclosed is a Timber Rattlesnake Impact Assessment and Mitigation Plan
prepared for the Project. The Plan includes an analysis of temporary and permanent impacts to timber
rattlesnake, take avoidance measures, and proposed habitat enhancement. As noted in the Plan, the
feasibility and exact locations for habitat enhancement at the Ramapo M&R is proposed to be developed in
coordination with NYSDEC, given the limited amount of temporary workspace available to create habitat
at the site and the proximity of several hiking trails.
Additionally, enclosed is an updated Timber Rattlesnake (Crotalus horridus) Habitat Occurrence and
Assessment for the Eastern System Upgrade (January 2017). The survey report has been updated to include
the Wagoner Interconnect and Pipe Yard 4, the maps of where photos were taken from, and clarifications
regarding the areas surveyed as requested by NYSDEC staff Lisa Masi during correspondence in December
2016.
On behalf of Millennium, TRC appreciates the opportunity to provide this additional information in support
of the Project. If you have any questions or need additional information to complete your review of the
Project pursuant to 6 NYCRR Part 182, please do not hesitate to contact me via phone at 978-697-0854 or
email at jzimmer@trcsolutions.com. Thank you for your continued consideration of this application.
Sincerely,
TRC Environmental Corporation
John Zimmer
Pipeline / LNG Market Director
Enclosures
cc: Ron Happach Millennium Pipeline Company, L.L.C.

Brian Orzel USACE
Sita Crounse NYSDEC
Heather Gierloff NYSDEC
Lisa Masi NYSDEC
Timber Rattlesnake Impact Assessment and Mitigation Plan

Millennium Eastern System Upgrade
Orange, Sullivan, Delaware and Rockland Counties, New York
Prepared for
One Blue Hill Plaza
P.O. Box 1565
Pearl River, NY 10965
By
Kathy Michell
KT Wildlife, LLC
42 School Street
Narrowsburg, NY 12764
January 2017
TABLE OF CONTENTS
Section Page
Project Description: Eastern System Upgrade ........................................ 1

Timber Rattlesnake Impact Assessment .................................................. 3
Highland Compressor Station ............................................................................................ 3
West side of Route 209 on the Huguenot Loop .............................................................. 10
Ramapo Metering & Regulating Station .......................................................................... 13
Timber Rattlesnake Impact Assessment i Eastern System Upgrade

and Mitigation Plan
Timber Rattlesnake Impact Assessment and Mitigation Plan

Millennium Eastern System Upgrade
Orange, Sullivan, Delaware and Rockland Counties, New York
Project Description: Eastern System Upgrade

Millennium Pipeline Company, L.L.C. (Millennium) is seeking authorization from the Federal
Energy Regulatory Commission (FERC or Commission) pursuant to Section 7(c) of the Natural Gas
Act to construct, install, operate, and maintain the Eastern System Upgrade (Project). The Project
includes construction of approximately 7.8 miles of 30- and 36-inch pipeline loop in Orange
County, New York (Huguenot Loop). Millennium proposes to locate a majority of the pipeline
loop overlapping with and adjacent to the permanent easement associated with its existing
mainline (Millennium Pipeline). Additionally, as part of the Project, Millennium proposes to
construct and operate (1) a new compressor station (Highland CS) in Sullivan County, New York,
(2) additional horsepower (hp) at the existing Hancock Compressor Station (Hancock CS) in
Delaware County, New York, (3) modifications to the existing Ramapo Meter and Regulator
Station (Ramapo M&R) in Rockland County, New York, (4) modifications to the existing Wagoner
Interconnect in Orange County, New York and (5) additional pipeline appurtenant facilities at the
existing Huguenot Meter Station (Huguenot M&R) and Westtown Meter Station (Westtown
M&R) in Orange County, New York. Dependent upon receipt of necessary approvals,
construction of the Project is anticipated to commence in the fall of 2017 to meet a target in-
service date in September 2018.
The Commission, as the lead agency in the review of the Project, is required to consult with the
United States Fish and Wildlife Service (USFWS) to determine whether federally listed species,
species proposed for listing, or their designated critical habitat may occur in the Project areas
and to determine the Projects potential effects on these species and critical habitats. However,
in accordance with Section 380.13(b) of FERCs regulations, the Project sponsor is designated as
FERCs non-federal representative for purposes of informal consultation with the USFWS.
The purpose of the Project is to permit Millennium to transport an incremental volume of

223,000 dekatherms per day of natural gas from Millenniums Corning Compressor Station to an
existing interconnect with Algonquin Gas Transmission, L.L.C. (Algonquin) located in Ramapo,
New York. The Project is supported by long-term, firm transportation contracts with local
distribution companies and a municipality. Therefore, the Project is needed to meet this express
market demand for new natural gas transportation capacity.
The Project facilities have been specifically designed to provide for an additional 223,000
dekatherms per day of firm transportation, as well as to maintain adequate operating pressures
at intermediate delivery points following the construction of the Project, to continue to meet
customer demand on Millenniums system during the summer months, and to ensure continued
deliveries to interconnecting pipelines.
Timber Rattlesnake Impact Assessment 1 Eastern System Upgrade

and Mitigation Plan
The Project consists of the following components and facilities:
approximately 7.8 miles of new 30- and 36-inch diameter pipeline looping generally
overlapping with and adjacent to Millenniums existing pipeline right-of-way in Orange
County, New York;
construction and operation of a new 22,400 hp compressor station, Highland CS in
Sullivan County, New York;
construction and operation of an additional 22,400 hp at the existing Hancock CS in
Delaware County, New York;
modifications to the Ramapo M&R in Rockland County, New York;
modifications to the Wagoner Interconnect in Orange County, New York;
addition of pipeline appurtenant facilities, which includes pigging facilities, at the
Huguenot M&R and the Westtown M&R in Orange County, New York; and
addition of an alternate interconnect to the 16-inch Valley Lateral at milepost (MP) 7.6.

and Mitigation Plan
Timber Rattlesnake Impact Assessment

The impact of the proposed Project on timber rattlesnakes and their various habitats will be
discussed separately for each of the following three facilities previously identified by the New
York State Department of Environmental Conservation (NYSDEC) as being within the range of
rattlesnake activities:
Highland Compressor Station

West side of Route 209 on the Huguenot Loop
Ramapo Metering & Regulating Station
Highland Compressor Station

1. Project Description
The Highland CS is a proposed, new compressor station located in Sullivan County, approximately
25 miles east of the existing Hancock CS in Delaware County. Millennium proposes to install one
22,400 hp Solar Titan 130E compressor at the new station.
The auxiliary facilities will include the compressor building, and will be constructed of a rigid steel
frame with sheet metal roofs and walls. An auxiliary building will house station controls and
communications equipment as well as an emergency electrical power generator and compressed
air system. The proposed facilities will also include valves, filter-separators, an emergency
generator, a fuel gas heater, parking and access areas, and a fence enclosure. Utilities that will
be supplied from local utility companies are electric power and communications circuits. These
utilities will require minor construction to bring the services into the station property. No new
utility right-of-way is anticipated. The station site work will include a self-contained on-site water
well and sanitary sewer system.
2. Impact Analysis
The Millennium owned property at the Highland CS site consists of 80 acres of predominantly
upland forest, none of which is previously developed. Millennium has a 50-foot permanently
cleared easement that extends along the western border of the parcel. The proposed Project
will affect 27.88 acres of this land during the construction of the facilities. Following construction
and restoration of temporary workspaces, 15.73 acres will remain affected by the operation of
the facility. This 15.73 acres will be permanently lost as timber rattlesnake foraging habitat for
the rattlesnake population from the closest known den approximately one mile from the site.
The property boundary and Project footprint, including the temporary workspace, permanent
easement, and permanent access road are shown in Figure 1.
Timber rattlesnake habitat and presence/absence surveys were conducted by KT Wildlife in the
spring of 2016 on the entire 80-acre parcel. No critical timber rattlesnake habitats (i.e., den and

and Mitigation Plan
gestating areas) were found on the property. The impact associated with the Project will be
limited to the loss of upland habitat potentially used by timber rattlesnakes for seasonal foraging.
a. Temporary Impacts to Habitat and Individuals

The temporary impacts to the habitat include the clearing of 27.88 acres for workspaces
and access roads during construction of the facility, of which 12.15 acres will be temporarily
impacted and restored. Temporary impacts to individual snakes may include: the risk of
injury or death from construction vehicle traffic and heavy equipment; disruption in their
seasonal movements if they encounter barrier fences such as silt fence; and an increased
probability of human/snake interactions. Impact avoidance and Minimization Measures
which will be implemented are discussed in Section 4.
i. Limits of Grading
The temporary limits of grading are shown in Figure 1 as the workspaces, overlaid on the
forested habitat.
ii. Limits of Vegetation Clearance

These temporary limits of vegetation clearance are essentially the same as the grading
limits shown in figure 1.
iii. Work Space During Construction

The Project requires additional temporary work space outside of the construction area
for storage of heavy equipment, materials, and for rock and soil spoils areas. During
clearing and grading, several large machines such as bulldozers, excavators and dump
trucks will be present along with operator vehicles. Clearing during the active season
poses a risk to individual animals which may not be visible, i.e., hiding in leaves, brush
piles, under a rock, etc. These temporary potential impacts will be mitigated with timing
restrictions for clearing and/or construction monitoring by a qualified snake biologist.
iv. Timing of Work

Construction of the Project is anticipated to commence in the fall of 2017 with an in-
service completion date of September 2018, dependent upon receipt of necessary
approvals.
v. Quality of Surrounding Habitat

The forest on the Project property is composed of a rocky substrate with a mix of
deciduous trees including, white oak (Quercus alba), chestnut oak (Quercus prinus), red
oak (Quercus rubra), sugar maple (Acer saccharum), and black cherry (Prunus serotina).
The understory is predominantly mountain laurel (Kalmia latifolia) and huckleberry
(Gaylussacia baccata). There are scattered white pines (Pinus strobus) and some pitch
pine (Pinus rigida) present. This type of mixed deciduous forest is excellent foraging

and Mitigation Plan
habitat for timber rattlesnakes since it supports a healthy rodent population. There will
be a temporary loss of 12.15 acres of foraging habitat.
During clearing and grading activities there will be noise and dust generated. The noise
levels are anticipated to be similar to noise at typical construction or road work sites. The
extent of rock that will require blasting is unknown until construction begins. Any blasting
will adhere to the New York State standards. Specifically, vibrations at the nearest
property line shall be a maximum of 2 inches per second which would not harm a timber
rattlesnake. Since the closest rattlesnake den to the Project workspace is approximately
one mile, hammering and/or blasting should have no adverse impact on the snakes or
their critical habitats.
Vegetation which is not being cleared for the Project will not be subject to any temporary
impacts during the construction of the Project.
b. Permanent Impacts to Habitat and Individuals

The permanent impact to individual snakes following the completion of the Project will
primarily be the increased human activity in the area, vehicular traffic, and the possible
attraction of the snakes to the open area. The permanent impact to the local rattlesnake
populations and individuals is the removal of potential foraging habitat from 15.73 acres
of upland wooded habitat.
i. Permanent Limits of Project

The permanent limits of disturbance for the Project are shown as the permanent access
road and the permanent easement on Figure 1. As seen in the aerial view, the current
status of the property, as previously described, is a mixed deciduous upland forest. The
Project will remove 15.73 acres of the wooded habitat.
ii. Maintenance of Surrounding Areas

Routine operation and maintenance of the facility will require service vehicles to access
the site on a regular basis utilizing the permanent access road. Snow plowing and other
road maintenance will also be conducted as needed at the site. The habitat of the
surrounding area should not be affected by these activities.
iii. New Roads and/or Human Encounter

The potential impact to timber rattlesnakes from the operation of the facility includes the
risk of accidental injury or death, particularly on the access road. Since the facility is
located within the range of timber rattlesnakes from at least one den, there is also a risk
of human/rattlesnake encounters. Both risks can be minimized through the Project-
specific Encounter Plan (see Section 4. a. iv, below).

and Mitigation Plan
3. Analysis of Alternatives
The Highland CS is an integral part of the Millennium Eastern System Upgrade and is necessary
to maintain adequate operating pressures at the intermediate delivery points in the
interconnecting pipelines. Hydraulic modeling results for optimum efficiency dictate that the
compressor station be located within approximately 0.25 mile of Millenniums existing mainline
and between approximate milepost 134 to 136, which led to the identification of two (2)
potential sites for the new station. Other considerations given to the siting of the station were
the remoteness from residences and avoidance of environmentally sensitive areas. Millennium
identified one alternative site (Alternate Site A) for the proposed new compressor station in its
Environmental Report filed with FERC for the Project. Alternate Site A is not being proposed due
to 1) impacts to the 100-foot adjacent area of a NYSDEC-regulated wetland system associated
with Halfway Brook, and 2) the presence of significantly more residential properties / noise
sensitive areas within 0.5 mile (i.e., affected landowners). The Environmental Report for the
Project is currently being reviewed by FERC.
4. Take Avoidance Measures (Mitigation Plan)

a. Measures to Avoid, Minimize and Mitigate for Temporary Impacts
Avoidance measures to be taken to reduce the risks of harm to individuals during the
construction of the Project include: construction monitoring by a licensed, qualified
timber rattlesnake monitor; construction timing for certain activities such as clearing,
education of workers; and an Encounter Plan. Mitigation for the temporary impacts to
foraging habitat are addressed in the restoration and re-vegetation plans for the site.
The following measures are being taken to minimize and/or eliminate the risks to timber
rattlesnakes during the construction phase of the Project.
i. Construction Monitoring
Construction monitoring will be provided by a qualified rattlesnake biologist with the
necessary license to handle rattlesnakes as necessary based on the seasonal activities of
the rattlesnakes and the phase of the construction (i.e., move them outside the
workspace or to a nearby basking area). The responsibilities of the monitor shall include
the following:
Contractor education on timber rattlesnake awareness and construction

Encounter Plan
Surveying workspace for timber rattlesnakes
Safely capturing and moving snakes a safe distance from workspace
Documenting and reporting all timber rattlesnake activity on-site
Following all NYSDEC Bio Safety Protocols
Implementation of Encounter Plan

and Mitigation Plan
ii. Construction Timing

Unless a qualified timber rattlesnake monitor is present, land clearing and rough grading
will be limited to the time frame of November 1st through March 31st. This will eliminate
(or greatly reduce) the risk of injury to any rattlesnakes during these operations since they
will be unlikely to have traveled from their dens to the site before March 31st and most
will have returned to their dens by November 1st or be in close proximity. Clearing during
the active season can pose a significant risk to individual animals which may not be visible
due to thick vegetation and/or rock cover. This timing restriction and/or monitoring will
prevent harm or mortality to rattlesnakes.
iii. Education
Timber rattlesnake awareness training will be presented to all personnel working at the
Project site. This will be in the form of an initial PowerPoint presentation to supervisory
personnel, inspectors, and workers if possible (depending on the size of the training
facilities on site). All workers will receive a flyer with pictures of timber rattlesnakes taken
at actual construction sites to help them be aware of what they are looking for as they
operate machinery and vehicles during construction. All workers will also be given a card
with the phone number of the on-site monitor in the event they encounter a snake.
iv. Encounter Plan

The following Encounter Plan will be distributed to all personnel in the form of a flyer.
Timber Rattlesnake Encounter Plan

Personnel on site play an active role in protecting the timber rattlesnake during the construction
of this Project. Distribution of this plan, in additional to the presence of the on-site timber
rattlesnake monitor will enable the employees to deal with any timber rattlesnake encounters.
Management and Employee Responsibilities to Protect Timber Rattlesnakes During

Construction and Operation of the Project Facility
1. Provide all staff with a copy of this Encounter Plan and information regarding any other
NYSDEC required mitigation procedures, including reporting requirements.
2. All personnel will be required to attend a short PowerPoint presentation on the

responsibilities of contractors for the protection of timber rattlesnakes. The initial
training will be conducted by a New York Qualified Timber Rattlesnake Biologist. A copy
of the presentation will be kept on-site and will be shown to new personnel as necessary.
3. Be alert and use caution when driving on the access roads and right-of-ways on the
property. This awareness should extend to public roadways in the area where
rattlesnakes have been observed crossing.

and Mitigation Plan
4. Provide staff with contact information for the monitor present on-site. Contact
information for a New York licensed rattlesnake rehabilitator should be provided in the
event of an injured rattlesnake or any other unusual circumstances.
5. If a rattlesnake is encountered in the work area:
a. If the snake is actively moving away from the work area and out of harms way,
allow it to continue, watching until it is a safe distance from the work area.
Alert the on-site monitor that a snake was encountered and provide location
and direction that it was moving.
b. If the snake is in the work area, contact the on-site monitor who will safely
capture the snake, placing it in a covered bucket and immediately releasing it
no more than a few hundred yards from the workspace. Watch the snake from
a distance of approximately 10 feet until the monitor arrives since they can
easily blend back into the vegetation. The monitor is knowledgeable in safe
capture techniques.
c. Any rattlesnakes which require relocation should be kept in a cool place, not
in the sun, until released which should be done as soon as possible.
d. The monitor will keep a log of the date, the location and approximate size and
color of any rattlesnakes which are encountered.
Capturing a rattlesnake Releasing snake from a bucket

and Mitigation Plan
b. Measures to Avoid, Minimize and Mitigate for Permanent Impacts

The permanent impacts to the site include the loss of 15.73 acres of seasonal timber
rattlesnake foraging habitat and the increased risk of encounters on the permanent
access road and at the facility. The following measures are proposed to minimize and
mitigate for these permanent impacts.
i. Habitat Enhancement
The Project site is surrounded by land that is predominantly forested. Although timber
rattlesnake denning and foraging activities are located in forested lands, it is essential for
the survival of the populations to have an open basking area in the vicinity of the den
which provide a gestation area for the gravid (pregnant) females and basking
opportunities for pre-shed snakes and those emerging from their dens in the spring. The
timber rattlesnake habitat impacted by the proposed Project has a limited number of
these basking areas. Most snakes from the closest den use the habitat which was created
by Millennium following the 2008 construction of the Millennium Pipeline.
As part of the restoration of the temporary workspaces, particularly in the southeastern

portion of the Project property, rock basking habitat could be added similar to that of
2008 to enhance basking/gestating opportunities for timber rattlesnakes. The exact
number and locations of these habitats would need to be determined following the
completion of the Project by surveying the temporary workspaces for the appropriate
conditions, such as slope, substrate, aspect and accessibility for equipment to build the
rock habitats. During the grading and excavations, large rocks, a minimum of 3 X 3,
particularly slab type rock approximately 8 to 12 thick, could be salvaged from the site
and stockpiled. The type of rock habitat would consist of multiple slab rocks placed in
close proximity so that snakes can shift from one to another and avoid human predation
as well as animal predators. Each habitat should be approximately 10 X 20.
ii. Education and Signage at the Facility

To help minimize the possibility of accidental injury or death to rattlesnakes traveling
through the station area or crossing the access road, signage alerting drivers of the
possibility of a rattlesnake encounter will be placed on the access road and fence around
the buildings.
iii. Removal of Potential Habitat within the Compressor Station Facility.

Timber rattlesnakes are known to use open spaces under buildings at older natural gas
aboveground facilities and radio tower buildings. To deter rattlesnakes and other snake
species from entering the station area and using these buildings for basking sites, any
buildings and structures with small spaces (2-4) between them and the ground should
have crushed stone pushed under and around the building to prevent the entry of
rattlesnakes. Another deterrent is a border of crushed stone around the perimeter of the
facility, which snakes are less likely to cross.

and Mitigation Plan
c. Net Conservation Benefit to the Species

The enhanced rock basking habitat would provide a significant benefit to the local
population since basking habitat in this area is somewhat limited. Multiple basking sites
provide choices for the snakes to find the most favorable conditions for basking and
gestating. In addition, with multiple sites, the snakes are not concentrated in one area
where they are more vulnerable to predation and human persecution.
d. Methods to Ensure the Avoidance and Mitigation Measures are Implemented

i. Monitoring Activity
Monitoring activities and all timber rattlesnake encounters during construction and
restoration activities will be reported annually by the monitor per the conditions of their
NYSDEC Scientific Collecting permit.
ii. Enhanced Habitat

A spring survey of any enhanced rock basking habitats will be conducted for five years to
determine the effectiveness by the presence or absence of rattlesnakes and/or shed skins.
iii. Reporting
An on-site log will be kept of all employee rattlesnake awareness training.
West side of Route 209 on the Huguenot Loop

Huguenot M&R (Modified)
Work at the existing Huguenot M&R will include the removal of the existing Millennium 30-inch
pipeline receiver stub-up piping assembly and the extension of the 30-inch Millennium pipeline
across the meter yard and ultimately to the new 30-inch receiver facility located at MP 0.1. Work
will also include the installation of new regulator facilities to reduce the maximum allowable
operating pressure from the existing Millennium 30-inch pipeline (1,200 psig) to the existing
Millennium 24-inch pipeline (920 psig), the installation of a new permanent 24-inch pig launcher
barrel to the existing Millennium 24-inch launcher piping assembly, and installation of the
indirect heater relocated from the Wagoner Interconnect. All new facilities will be located within
the existing Huguenot M&R site except for the extension of the 30-inch pipeline to the new Pig
Launcher / Receiver at MP 0.1, and the new indirect heater.
Included in the impact assessment for this portion of the Project is Pipe/Contractor Yard 4 located
a short distance northwest of the Huguenot M&R. This pipe/contractor yard is currently cleared
of all woody vegetation with only grasses and herbaceous plants remaining (see description and
photos in Timber Rattlesnake Habitat and Occurrence Assessment, Eastern System Upgrade

and Mitigation Plan
report, rev. January 2017). Figure 2 shows the temporary and permanent workspaces in both
the Huguenot M&R and Pipe/Contractor Yard 4.
2. Impact Analysis
This Huguenot M&R facility is located on the western side of Route 209 in Huguenot and is
situated on 0.40 acres. The proposed Project will be located inside the existing Huguenot M&R
site except for the extension of the 30-inch pipeline to the new Pig Launcher/Receiver which will
involve an additional 0.26 acres. This additional area will be a permanent easement. A
temporary workspace area extends from the back of the existing facility along the pipeline right-
of-way approximately 300 feet.
Timber rattlesnake habitat and presence/absence surveys were conducted by KT Wildlife in the
spring of 2016 on the entire 0.49 acre parcel of the Huguenot M&R Station. No critical timber
rattlesnake habitats (i.e., den and gestating areas) were found on the property. No suitable
timber rattlesnake foraging habitat was present, since this is a residential area. There were some
trees along the property line between the facility and several houses. There should be no impacts
to timber rattlesnakes from the construction and permanent changes to this facility.
Pipe/Contracor Yard 4 consists of 9.57 acres located northwest of the Huguenot Station on quarry
property. As described in the Assessment report, the property is open land which is subject to
vegetation maintenance, making it less suitable as foraging habitat than a wooded area. There
are residential streets on all sides of the proposed pipe/contractor yard which is approximately
0.8 miles from the closest known timber rattlesnake den. The only timber rattlesnake activity
that may occur here would be an occasional rattlesnake traveling through the area.
Pipe/Contractor Yard 4 will have no permanent impacts to timber rattlesnakes.
b. Temporary Impacts to Habitat and Individuals

There are no temporary impacts to the habitat since the property is already cleared and
will be left in the same condition following completion of the Project. Temporary impacts
to individual snakes may include: the risk of injury or death from construction vehicle traffic
and heavy equipment; disruption in their seasonal movements if they encounter barrier
fences such as silt fence; and an increased probability of human/snake interactions.
Avoidance and Minimization Measures which will be implemented are discussed in Section
4.
existing Huguenot M&R facility.

limits shown in figure 2.

and Mitigation Plan

This Project requires additional temporary work spaces such as Pipe/Contractor Yard 4,
outside of the construction area for storage of heavy equipment, materials, and for rock
and soil spoils areas. These temporary potential impacts will be mitigated with
construction monitoring by a qualified snake biologist.
iv. Timing of Work

approvals.

The Project property and Pipe/Contractor Yard 4 are currently disturbed cleared
properties. They will essentially be in the same condition following the completion of the
Project.

There should be no permanent impacts to timber rattlesnakes or habitat at the Huguenot
M&R site or Pipe/Contractor Yard 4.
The Huguenot M&R Station is an existing facility with infrastructure. No alternatives were
considered. There is no impact to timber rattlesnakes at this site from the Project.

timber rattlesnake monitor; education of workers; and an Encounter Plan. The following
measures are being taken to minimize and/or eliminate the risks to timber rattlesnakes
during the construction phase of the Project.
the following:

and Mitigation Plan

Encounter Plan
ii. Education
iii. Encounter Plan

An Encounter Plan will be distributed to all personnel in the form of a flyer. See Section
4.a.iv under Highland Compressor Station for Encounter Plan.
a. Measures to Avoid, Minimize and Mitigate for Permanent Impacts

No permanent impacts to rattlesnakes or their habitat are anticipated at this site.
Ramapo Metering & Regulating Station

Ramapo M&R (Modified)
The existing Ramapo M&R is located at Millenniums interconnect with the Algonquin pipeline
system approximately one half-mile southwest of the Algonquin right-of-way crossing of Sky
Meadow Road in Ramapo, New York. The proposed modifications would be generally located
within the limits of the meter station facility and includes a new filter/separator, over pressure
protection/back feed to existing facility, in-line heater, and ultrasonic meters and flow/pressure
control valves to control the required capacity of natural gas through the station.
Millennium intends to use the permanent access road to the station for the period of
construction and for operation. Use of the existing 20-foot wide permanent access road for the
Project will require some tree clearing for maintenance of the existing road. Additionally,
Millennium proposes to widen the entrance of the access road from Sky Meadow Road. Tree

and Mitigation Plan
clearing and entrance improvements will be conducted as part of the Project and will not
commence until approvals are received. Millennium is also currently in the process of obtaining
a permanent easement from Orange County for placement of the new filter/separators and/or
other new equipment, including but not limited to new meters, heater, flow and pressure control
regulation.
2. Impact Analysis
The current Ramapo M&R Station occupies 1.93 acres. The existing permanent access road
occupies 1.09 acres. No additional workspace will be used for the access road during the Project.
The proposed Station workspace including both temporary and permanent spaces located
outside the boundaries of the Station totals 4.41 acres. Of this property 1.77 will be a permanent
easement on the southern and western sides of the Station. The temporary workspace, totaling
2.64 acres includes a narrow border on the northern boundary of the Station, approximately 400
feet of the existing pipeline right-of-way east of the Station, and an additional temporary
workspace located along the north side of Sky Meadow Road. This additional workspace area is
an open field on the pipeline right-of-way and has been used for vehicle parking during past
upgrades at the Station. Figure 3 is a map of the existing facility and the workspaces.
a. Temporary Impacts to Habitat and Individuals

The temporary impacts to the habitat include the clearing of the wooded portions of the
4.41 acres outside the existing facility. Over half of this area is currently open field or right-
of-way. Of this 4.41 acres, 2.64 will be temporarily impacted and restored. Temporary
impacts to individual snakes may include: the risk of injury or death from construction
vehicle traffic and heavy equipment; disruption in their seasonal movements if they
encounter barrier fences such as silt fence; and an increased probability of human/snake
interactions. Avoidance and Minimization Measures which will be implemented are
discussed in Section 4.
habitat, some of which is forested.

limits shown in Figure 3.

This Project requires additional temporary work spaces outside of the construction area
for storage of heavy equipment, materials, and for rock and soil spoils areas. During
clearing and grading several large machines such as bulldozers, excavators and dump
trucks will be present along with operator vehicles. Clearing during the active season
poses a significant risk to individual animals which may not be visible (i.e., hiding in leaves,

and Mitigation Plan
brush piles, under a rock, etc.). These temporary potential impacts will be mitigated with
timing restrictions for clearing and/or construction monitoring by a qualified snake
biologist.
iv. Timing of Work

approvals.

The forest on the Project property is composed of a rocky substrate with a mix of
deciduous trees including, white oak (Quercus alba), chestnut oak (Quercus prinus), red
oak (Quercus rubra), sugar maple (Acer saccharum), and black cherry (Prunus serotina).
This type of mixed deciduous forest is excellent foraging habitat for timber rattlesnakes
since it supports a healthy rodent population. There will be a temporary loss of 2.64 acres
of foraging habitat, portions of which are forested.
During clearing and grading activities there will be noise and dust generated. The noise
levels are anticipated to be similar to noise at typical construction or road work sites, and
similar to other upgrades which have been made to the Station in recent years.
Vegetation which is not being cleared for the Project will not be subject to any temporary
impacts during the construction of the Project.

The permanent impact to individual snakes following the completion of the Project will
be minimal since the facility will be operating in a similar capacity to its existing use.
Human activity and vehicular traffic will remain the same. This area has a history of
timber rattlesnake usage at the site on an annual basis and staff are very aware of their
presence and have current impact avoidance measures in place. The permanent impact
to the local rattlesnake populations and individuals is the removal of potential foraging
habitat from the portions of the 2.64 acres of the temporary workspace which are
wooded habitat. As shown in Figure 3, these wooded areas are immediately adjacent to
the existing facility.
i. Permanent Limits of Project

The permanent limits of disturbance for the Project are shown as the permanent access
road and the permanent easement on Figure 3. This includes the existing 1.93 acre facility
and the proposed 1.77 acre permanent addition for a total of 3.7 acres. The 1.09 acre
permanent access road remains the same.

and Mitigation Plan
ii. Maintenance of Surrounding Areas

Routine operation and maintenance of the facility require service vehicles to access the
site on a regular basis utilizing the permanent access road. Personnel using this access
road are aware of the presence of timber rattlesnakes and use the necessary precautions
when traveling the road and working at the site. Snow plowing and other road
maintenance are also conducted as needed at the site. The habitat of the surrounding
area should not be affected by these activities.
iii. New Roads and/or Human Encounter

The potential impact to timber rattlesnakes from the operation of the facility includes the
risk of accidental injury or death, particularly on the access road. Since the facility is
located within the range of timber rattlesnakes from multiple dens, there is also a risk of
human/rattlesnake encounters. Both risks can be minimized through an Encounter Plan,
which has been in place for many years at this site. There have been no reports of
rattlesnake mortality at the current facility.
The Ramapo M&R Station is an existing facility servicing several pipelines. No alternative sites
for the station are being considered.

timber rattlesnake monitor; construction timing for certain activities such as clearing,
education of workers; and an encounter plan. Mitigation for the temporary impacts to
foraging habitat are addressed in the restoration and re-vegetation plans for the site.
The following measures are being taken to minimize and/or eliminate the risks to timber
rattlesnakes during the construction phase of the Project.
the following:

Encounter Plan

and Mitigation Plan

ii. Construction Timing

Unless a qualified timber rattlesnake monitor is present, land clearing and rough grading
will be limited to the time frame of November 1st through March 31st. This will eliminate
(or greatly reduce) the risk of injury to any rattlesnakes during these operations since they
will be unlikely to have traveled from their dens to the site before March 31st and most
will have returned to their dens by November 1st or be in close proximity. Clearing during
the active season can pose a significant risk to individual animals which may not be visible
due to thick vegetation and/or rock cover. This timing restriction and/or monitoring will
prevent harm or mortality to rattlesnakes.
iii. Education
iv. Encounter Plan

An Encounter Plan will be distributed to all personnel in the form of a flyer. See Section
4.a.iv under Highland CS for the Encounter Plan.
b. Measures to Avoid, Minimize and Mitigate for Permanent Impacts

The permanent impact to the site involves the loss of 1.77 acres of seasonal timber
rattlesnake foraging habitat and some potential basking rock, left from former
construction at the site, immediately adjacent to the station. The following are proposed
to minimize and mitigate for these permanent impacts.
i. Habitat Enhancement
The Project site is surrounded by land that is predominantly forested. Although timber
rattlesnake denning and foraging activities are located in forested lands, it is essential for
the survival of the populations to have an open basking area in the vicinity of the den
which provide a gestation area for the gravid (pregnant) females and basking
opportunities for pre-shed snakes and those emerging from their dens in the spring.

and Mitigation Plan
As part of the restoration of the temporary workspaces, rock basking habitat could be
added to enhance basking/gestating opportunities for timber rattlesnakes, particularly on
the north side of the Station. The feasibility and exact locations of these habitats would
need to be determined following the completion of the Project by surveying the
temporary workspaces for the appropriate conditions, such as slope, substrate, aspect
and accessibility for equipment to build the rock habitats. During the grading and
excavations, large rocks, a minimum of 3 X 3, particularly slab type rock approximately
8 to 12 thick, could be salvaged from the site and stockpiled. The number and type of
rock habitat would consist of multiple slab rocks placed in close proximity so that snakes
can shift from one to another and avoid human predation as well as animal predators.
Each habitat should be approximately 10 X 20.
There are several hiking trails in the area and the proximity to the trails as well as the
station facility will need to be considered when determining whether rock habitats should
be constructed and where they should be located. A site visit with NYSDEC would be
advisable to discuss this possibility.
ii. Education and Signage at the Facility

To help minimize the possibility of accidental injury or death to rattlesnakes traveling
through the station area or crossing the access road, signage alerting drivers of the
possibility of a rattlesnake encounter will be placed on the access road and fence around
the buildings.
iii. Removal of Potential Habitat within the Station Facility.

Timber rattlesnakes are known to use open spaces under buildings at some natural gas
aboveground facilities and radio tower buildings, including the Ramapo M&R Station. To
deter rattlesnakes and other snake species from entering the station area and using these
buildings for basking sites, any buildings and structures with small spaces (2-4) between
them and the ground should have crushed stone pushed under and around the building
to prevent the entry of rattlesnakes. Another deterrent is a border of crushed stone
around the perimeter of the facility, which snakes are less likely to cross. Construction of
a rock slab basking habitat described above in 4.b.i on the north side of the station could
also provide an alternative for the snakes to bask and deter them from entering the
facility. Attachment 6 in the Timber Rattlesnake Habitat and Occurrence Assessment,
Eastern System Upgrade report, rev. January 2017 shows the location of the closest dens
to the Station.
c. Net Conservation Benefit to the Species

If on-site enhanced rock habitat is feasible, this could provide a significant benefit since
multiple basking sites provide choices for the snakes to find the most favorable conditions
for basking and gestating. In addition, with multiple sites, the snakes are not concentrated
in one area where they are more vulnerable to predation and human persecution.

and Mitigation Plan
In areas where on-site habitat enhancement is not feasible, conservation benefit to the
species could involve discussions with NYSDEC to provide habitat enhancement off-site at
a location where it is needed and feasible. Other options to benefit the species include
critical habitat land acquisition and funding for rattlesnake research, particularly on
methods for making linear utility construction safer for rattlesnakes and other
herpetofauna.
In addition, the education and awareness programs for operations staff will minimize and
offset the Projects potential impacts on timber rattlesnakes.
d. Methods to Ensure the Avoidance and Mitigation Measures are Implemented

i. Monitoring Activity
Monitoring activities and all timber rattlesnake encounter information will be reported
annually by the monitor per the condition of their permit.
ii. Enhanced Habitat

A spring survey of any enhanced rock basking habitats will be conducted for five years to
determine the effectiveness by the presence or absence of rattlesnakes and/or shed skins.
iii. Reporting
An on-site log will be kept of all employee rattlesnake awareness training.

and Mitigation Plan
Figure 1

and Mitigation Plan
Figure 2

and Mitigation Plan
Figure 3

and Mitigation Plan
CERTIFICATE OF SERVICE
Pursuant to Rule 2010 of the Commissions Rules of Practice and Procedure, 18
C.F.R. 385.2010 (2016), I hereby certify that I have this day served the foregoing
document upon each person designated on the official service list compiled by the
Secretary in this proceeding.
Dated at Washington, D.C., this 26th day of January, 2016.
/s/ Marco Bracamonte

Marco A. Bracamonte
Van Ness Feldman LLP
1050 Thomas Jefferson St., N.W.
Seventh Floor
Washington, D.C. 20007-3877
(202) 298-1800
Document Content(s)
Cover Letter 012617.PDF...............................................1-29

Millennium ESU TIMBER RATTLESNAKE SUPPLEMENTAL REPORT

Uploaded by

Copyright:

Available Formats

You might also like

Millennium ESU TIMBER RATTLESNAKE SUPPLEMENTAL REPORT

Uploaded by

Document Information

Copyright

Available Formats

Share this document

Share or Embed Document

Sharing Options

Did you find this document useful?

Is this content inappropriate?

Copyright:

Available Formats

Millennium ESU TIMBER RATTLESNAKE SUPPLEMENTAL REPORT

Uploaded by

Copyright:

Available Formats

20170126-5194 FERC PDF (Unofficial) 1/26/2017 4:48:52 PM

One Blue Hill Plaza, 7th Floor

January 26, 2017

Ms. Kimberly D. Bose, Secretary

Re: Millennium Pipeline Company, L.L.C., Docket No. CP16-486-000

Dear Ms. Bose:

Description of Items Being Filed

Privileged and Confidential Non-Public:

Millennium is filing the additional information pursuant to the Commissions guidelines

/s/ Georgia Carter

cc: Eric Howard, FERC

January 26, 2017

Mr. Stephen Tomasik, Project Manager

Re: Supplemental Information

Dear Mr. Tomasik:

Millennium Pipeline Company, L.L.C.

cc: Ron Happach Millennium Pipeline Company, L.L.C.

Timber Rattlesnake Impact Assessment and Mitigation Plan

Project Description: Eastern System Upgrade ........................................ 1

Timber Rattlesnake Impact Assessment i Eastern System Upgrade

Timber Rattlesnake Impact Assessment and Mitigation Plan

Project Description: Eastern System Upgrade

The purpose of the Project is to permit Millennium to transport an incremental volume of

Timber Rattlesnake Impact Assessment 1 Eastern System Upgrade

The Project consists of the following components and facilities:

Timber Rattlesnake Impact Assessment 2 Eastern System Upgrade

Timber Rattlesnake Impact Assessment

Highland Compressor Station

Highland Compressor Station

Timber Rattlesnake Impact Assessment 3 Eastern System Upgrade

a. Temporary Impacts to Habitat and Individuals

ii. Limits of Vegetation Clearance

iii. Work Space During Construction

iv. Timing of Work

v. Quality of Surrounding Habitat

Timber Rattlesnake Impact Assessment 4 Eastern System Upgrade

b. Permanent Impacts to Habitat and Individuals

i. Permanent Limits of Project

ii. Maintenance of Surrounding Areas

iii. New Roads and/or Human Encounter

Timber Rattlesnake Impact Assessment 5 Eastern System Upgrade

4. Take Avoidance Measures (Mitigation Plan)

Contractor education on timber rattlesnake awareness and construction

Timber Rattlesnake Impact Assessment 6 Eastern System Upgrade

ii. Construction Timing

iv. Encounter Plan

Timber Rattlesnake Encounter Plan

Management and Employee Responsibilities to Protect Timber Rattlesnakes During

2. All personnel will be required to attend a short PowerPoint presentation on the

Timber Rattlesnake Impact Assessment 7 Eastern System Upgrade

5. If a rattlesnake is encountered in the work area:

Capturing a rattlesnake Releasing snake from a bucket

Timber Rattlesnake Impact Assessment 8 Eastern System Upgrade

b. Measures to Avoid, Minimize and Mitigate for Permanent Impacts

As part of the restoration of the temporary workspaces, particularly in the southeastern

ii. Education and Signage at the Facility

iii. Removal of Potential Habitat within the Compressor Station Facility.

Timber Rattlesnake Impact Assessment 9 Eastern System Upgrade

c. Net Conservation Benefit to the Species