Comment of New England Power Company and Boston Gas Company, each d/b/a National Grid, under PF14-5.

Christopher J. Novak Counsel nationaigrid VIA E-FILING Kimberly D. Bose, Secretary Federal Energy Regulatory Commission 888 First Street NE, Room 1A Washington, DC 20426 March 10, 2014 Re: Algonquin Gas Transmission, LEC, Docket No. PF14-5-000 Dear Secretary Bose, Pursuant to the public notice issued February 7, 2014, in the above-captioned docket, the Boston Gas Company and New England Power Company, each d/b/a National Grid, (National Grid) are taking this opportunity to offer to the Federal Energy Regulatory Commission (the FERC) its comments regarding the Salem Lateral Project (the Project) involving construction and operation of facilities by Algonquin Gas Transmission, LLC (Algonquin) in Salem, Massachusetts. National Grid supports Algonquin s Project which will deliver natural gas to the proposed Footprint Power Generating Station and has been working with Algonquin to coordinate the siting of a portion of the proposed Project over a portion of National Grids property and right-of-way. National Grid offers the comments set forth below to aid the FERC in its evaluation ofthe Projects potential environmental, safety and reliability impacts. I. Background. National Grid owns property which is situated along the proposed Project route that currently has active liquefied natural gas (LNG) storage and electric transmission facilities that are critical to providing dependable and reliable gas and electric service to surrounding communities. Algonquin has been granted permission by National Grid to perform due diligence activities such as survey, wetland delineation, archeological exploration and soil sampling as part ofits Project preliminary design process. II. Comments. National Grids preliminary discussions with Algonquin regarding the Project have revealed two areas that require further review and consideration: environmental impact and electric transmission line safety. A. Environmental Impact. Protecting the environment is a paramount concern for National Grid, and to this end, the Projects location adjacent to National Grids Salem LNG facility poses unique challenges. The 1 Salem LNG facility was formerly the site of a manufactured gas plant (MGP) which operated from the 1 890s to the 1 960s. Operation of the former MGP resulted in contamination of the site, for which National Grid undertook costly and extensive remediation efforts to address upland and near shore impacts in accordance with the Massachusetts Contingency Plan (MCP 3 10 CMR4O.0000 et seq.). The remedy for this site entailed the installation of a four layer protective cap that serves as a barrier over contaminants that, in light of the cap, are allowed to remain in place under the MCP. It is essential ...