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Algonquin NOV 3 2015 Access NE App.Pdf

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Algonquin NOV 3 2015 Access NE App.Pdf Mailing Address: 5400 Westheimer Court P.O. Box 1642 Houston, TX 77056-5310 Houston, TX 77251-1642 713.627.5400 main November 3, 2015 Ms. Kimberly D. Bose, Secretary Federal Energy Regulatory Commission 888 First Street, NE Washington, DC 20426 Re: Request for Approval of Pre-Filing Review Algonquin Gas Transmission, LLC Access Northeast Project - Docket No. PF16-___-000 Dear Ms. Bose: Pursuant to Section 157.21(b) of the regulations of the Federal Energy Regulatory Commission (“FERC” or “Commission”),1 Algonquin Gas Transmission, LLC (“Algonquin”) hereby requests approval from Commission Staff to initiate the Pre-Filing Review Process for the proposed Access Northeast Project (“Access Northeast Project” or “Project”).2 Upon completion of the Pre-Filing Review, Algonquin will file an application with the Commission for authorization to construct the Project under Section 7(c) of the Natural Gas Act (“NGA”) and abandon certain facilities under Section 7(b) of the NGA.3 Algonquin representatives met with Commission Staff on October 8, 2015, to discuss the Project and Algonquin’s use of the Pre- Filing Review Process. This Project is proposed to upgrade and expand the Algonquin pipeline system and construct a Liquefied Natural Gas (“LNG”) storage facility in New England to deliver, on peak days, up to 925,000 dekatherms per day (“Dth/d”) of natural gas. The Project is designed to meet the capacity needs of natural gas fired electric generation as coal and nuclear generation resources retire. As such, Access Northeast will be implemented in phases, with the initial phase currently projected to be November 1, 2018. Project Overview The Access Northeast Project is designed to advance a customized solution to New England’s electric challenges. With the ability to directly connect with 60 percent of ISO-New England’s power plants off the Algonquin and Maritimes & Northeast Pipeline, L.L.C. systems, Access Northeast will provide critically needed natural gas pipeline capacity and market area storage to ensure the reliability of New England’s power generation fleet. Further, over 95 percent of the pipeline route for this Project will utilize existing pipeline right of way (“ROW’), utility corridors, roads and other existing ROW, thus minimizing impacts on the environment and communities. 1 18 C.F.R. § 157.21(b) (2015). 2 The Access Northeast Project is being developed by Algonquin, whose members are Spectra Algonquin Holdings, LLC, Eversource Gas Transmission LLC and National Grid Algonquin LLC. 3 15 U.S.C. §§ 717f(b) and 717f(c) (2012). Ms. Kimberly D. Bose, Secretary November 3, 2015 Page 2 Demand for natural gas has continued to grow in the Northeast as the region seeks additional access to an economic source of fuel that is domestically produced, clean-burning and efficient. Due to pipeline constraints, however, the supply of natural gas in New England is not adequate to meet the demand, particularly on the coldest winter or peak days. The lack of adequate “last mile” supply deliverability continues to drive the cost of electricity higher and threaten reliability. The Access Northeast Project is designed to further the goals of reducing the cost of electricity and increasing the reliability of the New England electric system to benefit electric distribution customers. Since electric generation has not been directly served by recent Algonquin expansion projects, this Project is intended to satisfy demand for firm natural gas transportation capacity that has not been previously addressed and has utility independent of other expansion projects. Algonquin executed memoranda of understanding with seven electric distribution companies related to firm transportation service to deliver new natural gas supplies to the electric distribution companies’ service areas, with an initial project in-service date of November 1, 2018.4 These electric distribution companies are: Eversource Energy (“Eversource”): Connecticut Light & Power Company doing business as (“d/b/a”) Eversource, a Connecticut corporation; NSTAR Electric Company d/b/a Eversource, a Massachusetts corporation; Public Service Company of New Hampshire d/b/a Eversource, a New Hampshire corporation; and Western Massachusetts Electric Company d/b/a Eversource, a Massachusetts corporation. National Grid: Massachusetts Electric Company d/b/a National Grid, a Massachusetts corporation; The Narragansett Electric Company d/b/a National Grid, a Rhode Island corporation; and Nantucket Electric Company d/b/a National Grid, a Massachusetts corporation. Additionally, Central Maine Power Company submitted a bid in the open season for the Access Northeast Project to secure firm transportation service to deliver new natural gas supplies on the same projected in-service date.5 Algonquin is also in discussions with a local distribution company (“LDC”). Algonquin held an open season for the Access Northeast Project from February 18, 2015 through May 1, 2015 (“Open Season”). Additionally, Algonquin held a reverse open season for 4 These agreements were negotiated with affiliates of Eversource and National Grid who are not developers of the Access Northeast Project. 5 To the extent that minor modifications to the Maritimes facilities may be necessary for the Access Northeast Project, the resource reports and other pre-filing submissions will be revised as appropriate. Ms. Kimberly D. Bose, Secretary November 3, 2015 Page 3 the Access Northeast Project from October 2, 2015 through October 30, 2015, to ascertain whether current firm shippers were interested in releasing transportation entitlements that would reduce the scope of Algonquin’s facility requirements for the Project. Algonquin did not receive any offers to turnback capacity. Algonquin respectfully requests that the Commission approve this request by November 13, 2015 to initiate the Pre-Filing Review Process. As demonstrated herein, Algonquin has engaged in extensive efforts in anticipation of filing its certificate application to ensure that the Project adheres to the timeline discussed below and meets the November 2018 target initial project in-service date. To further support its request, Algonquin submits the following in compliance with the Commission’s regulations in Section 157.21(d) and Commission Staff’s guidance for initiating the Pre-Filing Review Process. 1. A description of the schedule desired for the project including the expected application filing date and the desired date for Commission approval. To meet the target date for initial project in-service, Algonquin requests that the Director of the Office of Energy Projects issue a notice approving use of the Pre-Filing Review Process by November 13, 2015. Algonquin intends to submit an initial draft of Environmental Resource Report No. 1 and a draft alternatives analysis within 30 days of the date that the notice authorizing use of the Pre-Filing Review Process is issued, and a draft of all Environmental Resource Reports no later than June 2016. Algonquin anticipates submitting the certificate application for the Project in November 2016. Algonquin is committed to addressing environmental and landowner concerns as part of the Pre-Filing Review Process and requests issuance of a final environmental document no later than October 2017 and a certificate order no later than January 2018. Adhering to this timeline will allow for receipt of any remaining applicable permits and authorizations necessary for Algonquin to begin pre-construction activities, including the orderly mobilization of contractors and materials and the resolution of any outstanding landowner issues, and allow for construction to commence as soon as feasible in 2018. Timely commencement of these activities in early 2018 is critical to ensure an initial project in-service date of November 1, 2018. 2. Explain why the project sponsor needs/wants to participate in the pre-filing process. Algonquin is seeking authorization to use the Pre-Filing Review Process to provide the necessary environmental information to Commission Staff for review at the earliest practicable time in order to expedite the processing of Algonquin’s certificate application. Use of the Pre-Filing Review Process will benefit Algonquin, interested federal, state, and local agencies, and other stakeholders by: Assisting in the development of initial information about the Project and identifying affected parties; Ms. Kimberly D. Bose, Secretary November 3, 2015 Page 4 Facilitating issue identification and resolution; Providing a process that accommodates site visits, meetings with federal, state, and local agencies and stakeholders, participation in public information meetings (e.g., open houses), and the examination of alternatives; Providing interested federal, state, and local agencies and stakeholders with access to draft Environmental Resource Reports and other Project-related information; Minimizing the number of Commission Staff environmental data requests and subsequent filings; Maintaining a coordinated schedule for a thorough environmental impact review; and Facilitating preparation of Environmental Resource Reports and other related documents. 3. Provide a detailed description of the project, including location maps and plot plans to scale showing all major plant components. The Project includes the construction of approximately 123 miles of various pipeline facilities, modifications at seven existing compressor stations,6 the construction of one new compressor station, associated pipeline facilities including metering and
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