Wildlife and Aquatic Resources - Bullet Points

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4.6 Wildlife and Aquatic Resources

            • Route would traverse major cover types- agricultural land, upland forest, open land, developed land, and wetlands. Wildlife diversity and density in natural habitats such as extensive contiguous forest tracts, successional habitats and grasslands. (4-86)

            • Some habitats crossed support populations of big game and/or small game (black bear, white-tailed deer, wild turkey, gray squirrel, cottontail rabbit, waterfowl, mallard, wood duck, American coot, grouse). (4-86)

            • Sensitive wildlife habitat includes state or fed lands managed to support populations of wildlife- this project would not cross any PA state forests designated "wild areas" to protect special animal communities. It would not cross any Special Regulation Areas. (4-87)

            • Important Mammal Areas- does not proved legal protection, but is to promote the conservation of mammals by identifying sites or regions that include habitats critical to their survival- CPLS has one IMA in it- Stony Mt. Woodrat Complex (IMA no 26)- 84,800 acres (4-89-90)

            • Construction of CPLS would affect 219.1 acres of IMA no. 26- party in the St. Anthony's Wilderness. (4-90)

            • Important Bird Areas (IBA)- designated and recognized as most critical regions in state for conserving bird diversity and abundance- portions of 4 IBAs would be crossed by pipelines in PA- Ricketts Glen, Lower Susquehanna River Gorge, Conowingo/Muddy Run, St. Anthony's Wilderness, Kittatinny Ridge. (4-90)

            • CPLN and S woudl affect about 133.4 acres within the iba's during construction- 50.1 acres on Transco's proposed permanent ROW. Effects on these lands could potentially have an effect on migratory bird species. (4-91).

            • Executive Order 13186 requires that all fed agencies undertaking activities that may negatively affect migratory birds take a prescribed set of actions. FERC entered into an MOU with the FWS in March 2011. (4-91).  (Why the federal agency is required to take a set of actions here, when it is the pipeline installer who is doing the damage to the IBA- and I want to know what actions FERC is taking- what this agreement (MOU?) was and how it will be implemented by Transco, and who will hold Transco accountable?  Was this MOU an exemption?  or what?)

            • Of Transco's proposed facilities, the pipelines in PA have the greatest potential to affect migratory birds. (4-92)

            • 157 migratory bird species are regular breeders in project counties. (4-92)

            • Transco developed a Draft Migratory Bird Plan for the project- and initial comments from the FWS have been incorporated into the plan- describes avoidance and minimization measures that Transco has implemented during the planning phase or would implement during the construction phase of the project to reduce direct and indirect effects on migratory birds and their habitats. (4-92). (So, that's it?  Transco says they will minimize damage, and they get the green light to go forward? How is the decision made that their attempts to minimize damage is enough?)

            • Construction and maintenance activities that would take place during the migratory bird breeding seasons may have direct effects on migratory birds including mortality/injury, sensory disturbance, or increased predation. Adult migratory birds are generally highly mobile and would be able to avoid project vehicles and equipment during, clearing, grading, excavation, and maintenance activities.  Eggs and young birds would be more susceptible to crushing, mortality, or injury, and adult birds may potentially suffer mortality or injury of breeding birds and their eggs or young by clearing vegetation outside of the breeding season to the extent practicable, particularly in key habitat areas.  Transco would conduct vegetation maintenance activities during the operations phase outside of the breeding season. (4-92)  (Where to begin?  We know it will do damage- to a lot of animals and their habitats- the noise, the disturbance of the land, the heavy equipment- when does any of this matter?  Could I go to the home of a FERC commissioner and bulldoze their home? knowing the noise is a disturbance, and if they are home, indeed, their lives may be endangered, esp. their children,  but there are plenty of other human beings in the world- so it is merely collateral damage.  Besides, there are plenty of other homes in the world for to seek shelter in.. Does naming the damage mean Transco is exempt from proving it's necessity for their private gain? )

            • Habitat in project area for- Bald eagle, Upland Sandpiper, Short-eared owl, Eastern Whippoorwill, Red-headed Woodpecker, Peregrine falcon, Olive-sided flycatcher, Wood thrush, worm-eating warbler, Louisiana waterthrush, Blue-winged warbler, Golden-winged warbler, Kentucky warbler, Cerulean warbler, Prairie warbler, Canada warbler, Henslow's sparrow, Rusty blackbird. (4-93)

            • Artificial lights associated with the night-lighting of project activities occurring between sunset and sunrise may disorient migratory birds- (4.94)  (Wait a minute- do they intend to work night and day for the installation? How will landowners deal with this disturbance?)

            • Trash from project personnel has the potential to attract predators like gulls, crows, and raccoons, sometimes in large numbers. However Transco would dispose of construction debris according to fed, state, and local regulations, and construction crews would practice good housekeeping to prevent garbage from attracting predators.  Transco would train personnel accordingly to completely avoid and minimize the potential for these effects. (4-94)  (Now which way is it? Either Transco workers allow trash to attract predators "sometimes in large numbers" or they will "train their personnel" to throw their trash in trash cans and take with them. It can't be both ways. To state that "large numbers " of predators may be attracted suggests it has been done before. What kind of training is going to take place? And who is going to keep them accountable?)

            • The Impact of grading, clearing, and excavation of open lands, non-forested wetlands, open water, ag lands, and developed lands would be short in duration- 1-5 years.  The effect of clearing, grading, and ROW maintenance in upland and wetland forested lands would be more prominent and long term, these areas may not be restored to their preconstruction condition potentially for decades, if at all. (4-94).  (At what point is this amount of land that will never be returned to its preconstruction condition not worth it?  Just a question.... )

            • Transco has attempted to avoid and minimize effects on sensitive wildlife habitat by collocating the workspace with other existing ROWs. (4-95 (The Central Penn Line is a greenline, and there is no existing ROW- we highly suggest that the Central Penn Line S NOT be permitted by FERC- it is an unnecessary exploitation for land and environment and people's rights, with little benefit - and only benefits for the gas industry. Deny Central Penn Line South)

            • Construction would affect 2,775.5 acres of land-88.9 is developed land- Transco would reseed the disturbed workspaces to stabilize the soils and speed revegetation- there would be the permanent conversion of about 409.1 acres of upland forest and 6.4 acres of forested wetlands. (4-95)

            • Removal of vegetation within forested land could cause long-term displacement of some local wildlife populations- forested habitat would be converted to successional stages of open herbaceous and scrub-scrub habitat either permanently or for several years to decades until a mature forest community redevelops on the temporary workspaces. (4-95)

            • Conclusion- overall, wildlife resources are not expected to be significantly affected due to construction and operation of the Project based on the presence of suitable adjacent habitat available for use, the proposed clearing window for avoidance of the migratory bird nesting season, and our recommendations, which would further minimize effects on wildlife due to forest clearing.  (4-96)  (This is not true for the Greenfield line- the Central Penn Line S would see significant impacts and we recommend it NOT be PERMITTED- just stating that there is no significant impact does not make it true).

            • 171 waterbody crossings that contain sensitive fisheries-Transco would implement and minimize impacts- proposing to use a wet open-cut crossing method at 8 crossings. A wet open-cut crossing involves crossing waterbodies without any attempt to control or divert the flow of water over the trench. The remaining crossings would be completed using a dry crossing method0 that maintains the flow of the waterbody during the crossing- dam and pump, flume, Hdd and conventional bore.  The last two of these trenchless methods does not impact the stream be or bank. (4-99)

            • Impacts would include temporary stream bank disturbance, short term increase in sedimentation and water turbidity, a temp reduction in shading and over, and temp modification of flow. (4-99)  (and these impacts are stated to be NOT SIGNIFICANT- which begs the question... what would be considered significant?)

            • Measures include: completing waterbody crossings during appropriate in-stream construction windows and completing open cut crossings within 24 hours and 48 hours for minor and intermediate crossings, installing temp erosion controls and maintaining flow rates, dispersing any downstream discharges to minimize scour and downstream siltation, crossing waterbodies perpendicular to the channel or as close as practicable, promptly restoring stream channels to their original contours and flow rates and stabilizing banks. (4-99)  (Again- who is going to keep transco accountable to maintain these measures?)

            • Transco would allow a 25 foot wide riparian strip along each waterbody bank to revegetate with native flora in order to stabilize banks, reduce erosion impacts, and provide shading and cover for fisheries resources- (4-99)  (Does this mean that Transco is going to replant native flora?  Please require them to, FERC, because if they do not replant, then invasive and potentially non-native plants will take over, and destroy the native.)

            • Dry crossing Method-would have some of the same effects as open cut wet trench crossings. Transco would screen the intakes of its pumps to minimize the potential for impact. (4-11).

            • Trenchless crossings- Transco is evaluating two methods of trenchless construction- conventional horizontal bore and HDD. Conventional crossings include:  Huntington Creek, Pikes Creek, Chiques Creek, Qureg Run, unnamed slough at MP 95.8.  HDD crossings include Susquehanna River, Conestoga River, Susquehanna River. (4-100)

            • The greatest potential for effects on aquatic resources associated with an HDD crossing would be if there was an inadvertent release of drilling fluid into the waterbody either as a result of a direct discharge, or an indirect discharge resulting from the runoff of drilling fluid from an onshore inadvertent release. (4-100)

            • Blasting-55 waterbodies may require blasting- If blasting is required, Transco would develop a detailed, site-specific blasting plan for that location. (4-101).  (Just want to clarify- isn't this the Environmental Impact Study?  How are we supposed to comment on the actions of the industry in installing this pipeline (and how can FERC approve it) if the details of the installation are not complete?  This is not complete at all, and does not take into consideration all impacts.)

            • Hydrostatic Test Water- Transco would conduct hydrostatic testing oft he pipeline prior to placing it in service. Transco proposed to sue 14 waterbodies in PA, 2 in VA. - Transco would mitigate impacts of hydrostatic water withdrawals and discharges on aquatic resources. No chemicals or additives would be added to the water except where necessary to eradicate non-native aquatic species and the rate of discharges of used water would be regulated to minimize erosion. (4.101).  (What does it mean to mitigate impacts?  and how is that mitigation determined to have no significant impact?  What determines that chemical additives are necessary? and who regulates what chemicals are used and how much?  Who holds Transco accountable to regulate the discharge of used hydrostatic water? and the damage that discharge does?)

            • Conclusion- we conclude that the project would result in some temporary effects on aquatic resources as described above, but that these effects would be adequately mitigated through adherence to the measures described. (4-101) (Again- I ask- what would the impacts have to be for FERC to think that the proposed mitigations were not adequate? Are there any standards measurable to which they hold the industry? This all sounds like rubber stamps.)