Scoping Comment of Delaware Riverkeeper Network under PF13-7.

June 26, 2013 Kimberly D. Bose, Secretary Federal Energy Regulatory Commission 888 First Street, N.E. Washington D.C. 20426 RE: Response to Notice of Intent to Prepare an Environmental Assessment and Request for Comments on Environmental Issues Columbia East Side Expansion Project (Docket No. PF13-7). Dear Secretary Bose: The Delaware Riverkeeper Network (DRN) submits the following comments on the scope of the Environmental Assessment (EA) to be prepared by the Federal Energy Regulatory Commission (FERC or Commission) with respect to the East Side Expansion Project (the "Project" or ESE) proposed by Columbia Gas Transmission (Columbia). The proposed Project will include construction of two natural gas looping pipelines and related facilities. The Line 1278 Loop is proposed to consist of approximately 8.9 miles of 26-inch-diameter pipeline in Chester County, Pennsylvania, and the Line 10345 Loop will consist of approximately 7.4 miles of 20-inch-diameter pipeline in Gloucester County, New Jersey. Columbia is seeking authorization to expand its pipeline system by 310,000 dekatherms per day (Dth/d). I. Environmental Impacts from Pipeline Construction Activity A brief survey of published environmental studies suggests that pipeline construction activities result in four primary impacts to groundcover affecting water resources, including: erosion and sedimentation, loss of riparian vegetation, forest and habitat loss and fragmentation, sedimentation plumes in nearby water resources.6 Columbia should be required to provide design parameters and typicals for erosion control measures that can withstand significant rain events in vulnerable portions of the project area (for example, on steep slopes), or be required to submit detailed plans specifying how Columbia plans to address situations where erosion controls are overwhelmed, such plans should include response time requirements. Pipeline construction also results in the loss of riparian vegetation.7 For each pipeline construction technique, there is a resulting loss of foliage associated with clearing the stream banks. This reduction in foliage increases stream temperature and reduces its suitability for fish incubation, rearing, foraging and escape habitat.8 Columbia should be required to perform baseline testing on water temperature of all water resources to be crossed or impacted by construction activity to ensure that the temperatures substantially the same post-construction temperatures as they were present pre-construction. The loss of vegetation also makes streams more susceptible to erosion events, as the natural barrier along the stream bank has been removed. Deposited sediment from construction activities can also fill in the interstitial spaces of the streambed, changing its porosity and composition, and thereby increasing embeddedness and reducing riffle area ...