Letter requesting Columbia Gas Transmission, LLC to provide additional information w/in 5 days to assist in FERC's analysis of Columbia's proposed certificate application under CP13-478.

PACE ENVIRONMENTAL LITIGATION CLINIC, INC. PACE UNIVERSITY SCHOOL OF LAW 78 NORTH BROADWAY WHITE PLAINS, NEW YORK 10603 PHONE: 914.422.4343 FAX: 914.422.4437 SUPERVISING ATTORNEYS ADMINISTRATORS KARL S. COPLAN MARY BETH POSTMAN DANIEL E. ESTRIN JENNIFER RUHLE ROBERT F. KENNEDY, JR. October 9, 2012 VIA eFiling to FERC in Docket No. PF12-9 Kimberly D. Bose, Secretary Federal Energy Regulatory Commission 888 First Street, NE, Room 1A Washington, DC 20426 Re: Stop the Pipeline Comments on the Scope of Work for the Constitution Pipeline Draft Environmental Impact Statement. Dear Secretary Bose: On behalf of our client, Stop the Pipeline (STP), the Pace Environmental Litigation Clinic, Inc. respectfully submits the following comments on the scope of work for the Constitution Pipeline Draft Environmental Impact Statement. STP is a grass-roots coalition formed to stop the construction and operation of the proposed Constitution Pipeline. Its members live, work, and recreate in the six counties that would be affected by the construction and operation of this pipeline: Susquehanna County, PA, and Broome, Chenango, Delaware, Otsego, and Schoharie Counties in NY. We request that you also consider this letter a statement of status as an interested or affected person or party under the National Environmental Policy Act1 (NEPA) and, pursuant to the regulations promulgated by the Council on Environmental Quality, notify us of all NEPA related documents, as they become available, and NEPA related meetings, as they are scheduled.2 1 42 U.S.C. 4321, et seq. (2012). 2 40 CFR 1506.6(b) (2012). Kimberly D. Bose, Secretary, FERC October 9, 2012 Page 2 of 2 I. The three-week time period and the locations of the three scoping hearings are insufficient for soliciting meaningful and substantive comments. This inadequacy violates the publics right to meaningful participation, is contrary to the express purposes of NEPA, and violates the Due Process Clauses of the 5th and 14th Amendments. A. Background The Constitution Pipeline Company (Williams/Cabot) pre-filed an application for a 120-mile, interstate, 30-inch, high-pressure gas transmission line, and submitted Resource Reports 1 and 10 to the Federal Energy Regulatory Commission (FERC) on May 21, 2012. These reports described the general nature and purpose of the pipeline, and plotted the proposed and alternate routes on topographic maps. Shortly thereafter Williams/Cabot started contacting the affected landowners, and held Open Houses from 6:30 to 8:30 pm, on July 17, 18, 19, 24, and 25, in each of the counties targeted to host it (respectively in Susquehanna County, Pennsylvania, and Broome, Chenango, Delaware, and Schoharie Counties in New York). At these Open Houses landowners, and other interested people, were able to ...