REX Zone 3 Capacity Enhancement Project

y rg Office of e n n ry io E o s l t s ra la i Energy Projects e u m d g e e m F o R C

August 2015

Rockies Express Pipeline LLC Docket No. CP15-137-000

Environmental Assessment

Washington, DC 20426

FEDERAL ENERGY REGULATORY COMMISSION WASHINGTON, D.C. 20426

OFFICE OF ENERGY PROJECTS In Reply Refer To: OEP/DG2E/Gas 1 Rockies Express Pipeline LLC Zone 3 Capacity Enhancement Project Docket No. CP15-137-000

TO THE PARTY ADDRESSED:

The staff of the Federal Energy Regulatory Commission (FERC or Commission) has prepared an environmental assessment (EA) for the Zone 3 Capacity Enhancement Project, proposed by Rockies Express Pipeline LLC (REX) in the above-referenced docket. REX requests authorization to construct and operate natural gas compression facilities in Fayette, Pickaway, Muskingum, and Warren Counties, Ohio and Decatur County, Indiana. The REX Zone 3 Capacity Enhancement Project would provide an additional 800 million cubic feet per day of east-to-west transportation service.

The EA assesses the potential environmental effects of the construction and operation of the REX Zone 3 Capacity Enhancement Project in accordance with the requirements of the National Environmental Policy Act. The FERC staff concludes that approval of the proposed project, with appropriate mitigating measures, would not constitute a major federal action significantly affecting the quality of the human environment.

The proposed REX Zone 3 Capacity Enhancement Project includes the following facilities:

 one new 49,428 horsepower (hp) compressor station in Pickaway County, Ohio (Columbus Compressor Station);  one new 31,791 hp compressor station in Fayette County, Ohio (Washington Court House Compressor Station);  one new 37,038 hp compressor station in Decatur County, Indiana (St. Paul Compressor Station);  an additional 38,400 hp of compression, gas cooling facilities, and a new power and control building at the existing Chandlersville Compressor Station in Muskingum County, Ohio; and  gas cooling facilities and a new power and control building at the existing Hamilton Compressor Station in Warren County, Ohio.

The FERC staff mailed copies of the EA to federal, state, and local government representatives and agencies; elected officials; environmental and public interest groups; Native American tribes; potentially affected landowners and other interested individuals and groups; newspapers and libraries in the project area; and parties to this proceeding. In addition, the EA is available for public viewing on the FERC’s website (www.ferc.gov) using the eLibrary link. A limited number of copies of the EA are available for distribution and public inspection at:

Federal Energy Regulatory Commission Public Reference Room 888 First Street NE, Room 2A Washington, DC 20426 (202) 502-8371

Any person wishing to comment on the EA may do so. Your comments should focus on the potential environmental effects, reasonable alternatives, and measures to avoid or lessen environmental impacts. The more specific your comments, the more useful they will be. To ensure that the Commission has the opportunity to consider your comments prior to making its decision on this project, it is important that we receive your comments in Washington, DC on or before September 30, 2015.

For your convenience, there are three methods you can use to file your comments with the Commission. In all instances please reference the project docket number (CP15- 137-000) with your submission. The Commission encourages electronic filing of comments and has expert staff available to assist you at 202-502-8258 or [email protected].

(1) You can file your comments electronically using the eComment feature located on the Commission’s website (www.ferc.gov) under the link to Documents and Filings. This is an easy method for submitting brief, text- only comments on a project;

(2) You can also file your comments electronically using the eFiling feature on the Commission’s website (www.ferc.gov) under the link to Documents and Filings. With eFiling, you can provide comments in a variety of formats by attaching them as a file with your submission. New eFiling users must first create an account by clicking on “eRegister.” You must select the type of filing you are making. If you are filing a comment on a particular project, please select “Comment on a Filing”; or

(3) You can file a paper copy of your comments by mailing them to the following address:

Kimberly D. Bose, Secretary Federal Energy Regulatory Commission 888 First Street NE, Room 1A Washington, DC 20426

Any person seeking to become a party to the proceeding must file a motion to intervene pursuant to Rule 214 of the Commission’s Rules of Practice and Procedures (18 CFR 385.214).1 Only intervenors have the right to seek rehearing of the Commission’s decision. The Commission grants affected landowners and others with environmental concerns intervenor status upon showing good cause by stating that they have a clear and direct interest in this proceeding which no other party can adequately represent. Simply filing environmental comments will not give you intervenor status, but you do not need intervenor status to have your comments considered.

Additional information about the project is available from the Commission’s Office of External Affairs, at (866) 208-FERC, or on the FERC website (www.ferc.gov) using the eLibrary link. Click on the eLibrary link, click on “General Search,” and enter the docket number excluding the last three digits in the Docket Number field (i.e., CP15- 137). Be sure you have selected an appropriate date range. For assistance, please contact FERC Online Support at [email protected] or toll free at (866) 208-3676, or for TTY, contact (202) 502-8659. The eLibrary link also provides access to the texts of formal documents issued by the Commission, such as orders, notices, and rulemakings.

In addition, the Commission offers a free service called eSubscription which allows you to keep track of all formal issuances and submittals in specific dockets. This can reduce the amount of time you spend researching proceedings by automatically providing you with notification of these filings, document summaries, and direct links to the documents. Go to www.ferc.gov/docs-filing/esubscription.asp.

1 See the previous discussion on the methods for filing comments.

REX Zone 3 Capacity Enhancement Project ENVIRONMENTAL ASSESSMENT

TABLE OF CONTENTS TECHNICAL ACRONYMS AND ABBREVIATIONS ...... iii A. PROPOSED ACTION ...... 1 A.1 Introduction ...... 1 A.2 Purpose and Need ...... 2 A.3 Public Review and Comment ...... 2 A.4 Proposed Facilities ...... 2 A.5 Non-jurisdictional Facilities ...... 3 A.6 Land Requirements ...... 3 A.7 Construction, Operation, and Maintenance Procedures ...... 4 A.8 Permits and Consultations ...... 7 B. ENVIRONMENTAL ANALYSIS ...... 8 B.1 Geology and Soils ...... 8 B.2 Groundwater ...... 11 B.3 Surface Water and Wetlands ...... 12 B.4 Vegetation and Wildlife ...... 12 B.5 Special Status Species ...... 14 B.6 Land Use, Recreation, and Visual Resources ...... 15 B.7 Cultural Resources ...... 18 B.8 Air Quality ...... 21 B.9 Noise ...... 28 B.10 Reliability and Safety ...... 31 B.11 Non-jurisdictional Facilities ...... 33 B.12 Cumulative Impacts ...... 34 C. ALTERNATIVES ...... 39 D. STAFF’S CONCLUSION AND RECOMMENDATIONS ...... 43 E. REFERENCES ...... 48 F. LIST OF PREPARERS ...... 49

LIST OF TABLES TABLE 1 PERMITS AND CONSULTATIONS ...... 7 TABLE 2 HYDROSTATIC TEST WATER VOLUMES ...... 12 TABLE 3 LAND USE REQUIREMENTS FOR CONSTRUCTION AND OPERATION ...... 15 TABLE 4 LAND USE AFFECTED BY CONSTRUCTION AND OPERATION ...... 17 TABLE 5 PROJECT CONSTRUCTION EMISSIONS ...... 23 TABLE 6 SUMMARY OF POTENTIAL-TO-EMIT OPERATIONAL EMISSIONS ...... 23 TABLE 7 OHIO MODELING SIGNIFICANT EMISSIONS RATES ...... 24 TABLE 8 ESTIMATED COMPRESSOR STATION NOISE LEVELS ...... 29 TABLE 9 NON-JURISDICTIONAL POWER LINE FACILITIES ...... 33 TABLE 10 PROJECTS CONSIDERED FOR CUMULATIVE IMPACTS ...... 35 TABLE 11 OPERATIONAL EMISSIONS FOR THE ZONE 3 EAST TO WEST PROJECT ...... 36 TABLE 12 SENECA COMPRESSOR STATION PTE EMISSIONS ...... 36 TABLE 13 PTE EMISSIONS FOR THE SENECA COMPRESSOR STATION EXPANSION ...... 36 TABLE 14 COLUMBUS COMPRESSOR STATION ALTERNATIVES ANALYSIS ...... 41

LIST OF FIGURES FIGURE 1 General Project Location Map ...... 6 FIGURE 2 Columbus Compressor Station Exceedance Locations ...... 25 FIGURE 3 Alternative Compressor Station Locations: Columbus ...... 40

LIST OF APPENDICES APPENDIX A: PROPOSED COMPRESSOR STATION AND STATION MODIFICATION LOCATIONS FIGURE A1 St. Paul Compressor Station FIGURE A2 Columbus Compressor Station FIGURE A3 Washington Court House Compressor Station FIGURE A4 Chandlersville Compressor Station FIGURE A5 Hamilton Compressor Station

APPENDIX B: Non-jurisdictional Water Line Routes FIGURE B-1 Columbus Compressor Station Potential Water Line Routes

TECHNICAL ACRONYMS AND ABBREVIATIONS

AII acceptable incremental impact AQCR air quality control region APE area of potential effect CAA Clean Air Act Certificate Certificate of Public Convenience and Necessity CFR Code of Federal Regulations CH4 methane CO carbon monoxide CO2 carbon dioxide CO2e carbon dioxide equivalents Commission Federal Energy Regulatory Commission dB decibel dBA decibels on the A-weighted scale Dth/d dekatherms per day DOT U.S. Department of Transportation EA Environmental Assessment EI Environmental Inspector EPA U.S. Environmental Protection Agency FERC Federal Energy Regulatory Commission FERC Plan FERC’s Upland Erosion Control, Revegetation, and Maintenance Plan FERC Procedures FERC’s Wetland and Waterbody Construction and Mitigation Procedures FWS U.S. Fish and Wildlife Service GHG greenhouse gas GWP global warming potential HAP hazardous air pollutants hp horsepower IDEM Indiana Department of Environmental Management IPCC Intergovernmental Panel on Climate Change Ldn day-night sound level Leq equivalent sound level MBTA Migratory Bird Treaty Act MMcf/d million standard cubic feet per day MOU Memorandum of Understanding N2O nitrous oxide NAAQS National Ambient Air Quality Standards NGA Natural Gas Act NEPA National Environmental Policy Act NESHAP National Emission Standards for Hazardous Air Pollutants NO2 nitrogen dioxide NOI Notice of Intent to Prepare an Environmental Assessment for the Proposed REX Zone 3 Capacity Enhancement Project and Request for Comments on Environmental Issues NOx nitrogen oxides NRCS Natural Resources Conservation Service NRHP National Register of Historic Places NSA noise sensitive area NSPS New Source Performance Standards Ohio EPA Ohio Environmental Protection Agency

iii

PHMSA Department of Transportation Pipeline and Hazardous Materials Safety Administration PM2.5 particulate matter less than 2.5 microns in diameter PM10 particulate matter less than 10 microns in diameter Project Zone 3 Capacity Enhancement Project PSD Prevention of Significant Deterioration PTE potential to emit REX Rockies Express Pipeline LLC RICE Reciprocating Internal Combustion Engines SHPO State Historic Preservation Officer SIP State Implementation Plan SO2 sulfur dioxide SPRP Spill Prevention and Response Plan tpy tons per year USGCRP U.S. Global Change Research Program USGS U.S. Geological Survey VOC volatile organic compounds

Rockies Express Pipeline LLC (Docket No. CP15-137-000)

ENVIRONMENTAL ASSESSMENT

A. PROPOSED ACTION

A.1 INTRODUCTION

On March 31, 2015, Rockies Express Pipeline LLC (REX) filed an application with the Federal Energy Regulatory Commission (FERC or Commission) in Docket No. CP15-137-000 under Section 7(c) of the Natural Gas Act (NGA), and Part 157 of the Commission’s regulations requesting a Certificate of Public Convenience and Necessity (Certificate) to construct, own, operate, and maintain natural gas compression and auxiliary facilities in Fayette, Pickaway, Muskingum, and Warren Counties, Ohio and Decatur County, Indiana. The REX Zone 3 Capacity Enhancement Project (Project), would provide an additional 800 million cubic feet per day (MMcf/d) of east-to-west transportation service within Zone 3 of REX’s mainline, from eastern Ohio to eastern Missouri. The Zone 3 Capacity Enhancement Project would consist of two new compressor stations and auxiliary facilities in Pickaway and Fayette Counties, Ohio for a total of 49,428 and 31,791 horsepower (hp), respectively; one new 37,038 hp compressor station in Decatur County, Indiana; installation of an additional 38,400 hp of compression and auxiliary facilities at its existing Chandlersville Compressor Station in Muskingum County, Ohio; and installation of auxiliary facilities at the existing Hamilton Compressor Station in Warren County, Ohio.

We1 prepared this Environmental Assessment (EA) in compliance with the requirements of the National Environmental Policy Act of 1969 (NEPA), (Title 40 of the Code of Federal Regulations [CFR], Parts 1500-1508 [40 CFR 1500-1508]), and with the Commission’s implementing regulations under 18 CFR 380. The EA is an important and integral part of the Commission’s decision on whether to issue REX a Certificate to construct and operate the proposed facilities. Our principal purposes in preparing this EA are to:

 identify and assess potential impacts on the natural and human environment that could result from implementation of the proposed action;  identify and recommend specific mitigation measures, as necessary, to minimize environmental impacts; and  assess reasonable alternatives to the proposed action that would avoid or minimize adverse effects to the environment.

We prepared this EA to assess the environmental impacts that would likely occur as a result of the construction and operation of the proposed facilities. We have developed and incorporated measures into this EA that we believe would appropriately and reasonably avoid,

1 “We,” “us,” and “our” refers to environmental staff of the Office of Energy Projects.

minimize, or mitigate environmental impacts associated with construction and operation of the Project.

A.2 PURPOSE AND NEED

Under Section 7 of the NGA, the Commission determines whether interstate natural gas transportation facilities are in the public convenience and necessity and, if so, grants a Certificate to construct and operate them. The Commission bases its decision on technical competence, financing, rates, market demand, gas supply, environmental impact, long-term feasibility, and other issues concerning a proposed project.

REX’s stated purpose of the Zone 3 Capacity Enhancement Project is to provide an additional 800 MMcf/d of east-to-west transportation service within Zone 3 of its mainline system.

A.3 PUBLIC REVIEW AND COMMENT

On April 29, 2015, the Commission issued a Notice of Intent to Prepare an Environmental Assessment for the Proposed REX Zone 3 Capacity Enhancement Project and Request for Comments on Environmental Issues (NOI). The NOI was mailed to interested parties including federal, state, and local officials; agency representatives; environmental and public interest groups; parties on the Commission’s official service list; Native American tribes; elected officials; local libraries and newspapers; and property owners potentially affected by the proposed facilities (i.e., landowners within one-half mile of the compressor stations).

We received comments from the U.S. Fish and Wildlife Service (FWS), the Allegheny Defense Project, Heartwood, the Ohio Valley Environmental Coalition, the Freshwater Accountability Project, and several landowners near the Columbus Compressor Station. The environmental concerns include impacts on the following resources: visual resources, water quality, wildlife, property values, air quality, noise, and public safety. We also received comments regarding alternative sites for the Columbus Compressor Station and cumulative impacts. All substantive comments are addressed in the appropriate sections of this EA.

A.4 PROPOSED FACILITIES

The Zone 3 Capacity Enhancement Project would consist of the following facilities:

 one new 49,428 hp compressor station in Pickaway County, Ohio (Columbus Compressor Station);  one new 31,791 hp compressor station in Fayette County, Ohio (Washington Court House Compressor Station);  one new 37,038 hp compressor station in Decatur County, Indiana (St. Paul Compressor Station);

 an additional 38,400 hp of compression, gas cooling facilities, and a new power and control building at the existing Chandlersville Compressor Station in Muskingum County, Ohio; and  gas cooling facilities and a new power and control building at the existing Hamilton Compressor Station in Warren County, Ohio.

The general facility locations for the Project are shown on figure 1. Additional U.S. Geological Survey (USGS) topographic maps for the individual proposed and modified compressor station sites are included in appendix A.

A.5 NON-JURISDICTIONAL FACILITIES

Under Section 7 of the NGA, the FERC is required to consider, as part of its decision to certificate jurisdictional facilities, all factors bearing on the public convenience and necessity. The jurisdictional facilities for the Project include the proposed compressor units, compressor and auxiliary buildings, inlet and outlet piping, and related supporting facilities necessary to operate the compressors. Occasionally, proposed projects have associated facilities that do not come under the Commission’s jurisdiction. These non-jurisdictional facilities may be integral to the need for the proposed facilities (i.e., a power plant at the end of a jurisdictional pipeline) or they may be minor, non-integral components of the jurisdictional facilities that would be constructed and operated as a result of the proposed facilities (i.e., electric power lines).

The power needed to operate the compressor stations would be delivered by means of a new overhead power line to be installed and operated by Duke Energy Corporation or Dayton Power & Light. These power lines would not fall under FERC’s jurisdiction; however, we believe they are an integral component of the proposed Project and have included these facilities in our environmental review. Section B.11 of this EA contains a discussion of the environmental impacts associated with the proposed power lines.

REX, at the request of landowners, may potentially install a water line as part of the station design for the Columbus Compressor Station. The water line, which would replace the original water well proposed by REX, would be used to provide potable water to the station. REX is considering three potential routes for the water line, in addition to the proposed water well. Section B.11 of this EA contains a discussion of the environmental impacts associated with the proposed water line.

A.6 LAND REQUIREMENTS

Construction of the REX Zone 3 Capacity Enhancement Project would impact about 80.6 acres of land during construction and 33.8 acres of land for facility operation. The new Columbus, Washington Court House, and St. Paul Compressor Station operational footprints would be 9.9, 9.5, and 9.1 acres, respectively. REX would generally use public roads to access the compressor station sites; no road improvements would be required. However, two new permanent access roads would be constructed to access the new Columbus and St. Paul Compressor Stations. Land use requirements for access roads are included in the compressor station land acreages. Storage of equipment and materials would be contained within the

temporary construction footprints of the compressor stations; no additional storage areas are proposed for the Project. Receipt and delivery taps into the existing REX pipeline would be completed within the new station footprints and therefore, no new pipeline facilities would be constructed outside of the proposed compressor station footprints. Upon completion of the Project, REX would own the new compressor station parcels.

Although REX has identified areas where extra workspace would be required, additional or alternative areas could be identified in the future due to changes in site-specific construction requirements. REX would be required to file information on each of those areas for our review and approval, prior to use.

A.7 CONSTRUCTION, OPERATION, AND MAINTENANCE PROCEDURES

REX would utilize conventional construction techniques for construction of aboveground facilities. Construction activities typically require the use of trucks, excavators, backhoes, cranes, and other equipment. Aboveground facility construction would involve vegetation clearing, grading, excavation for building foundations, laying of concrete foundations, installation of compressor units, piping, buildings, and ancillary facilities.

REX would design, construct, test, operate, and maintain the Project facilities in accordance with the requirements of 49 CFR 192, Transportation of Natural and Other Gas by Pipeline: Minimum Federal Safety Standards as further discussed below, and with all other appropriate local, state, and federal regulations and codes. To minimize potential impacts associated with construction and operation, REX has adopted the FERC Upland Erosion Control, Revegetation, and Maintenance Plan2 (FERC Plan) and FERC Wetland and Waterbody Construction and Mitigation Procedures3 (FERC Procedures) without deviation. Additionally, REX prepared a Spill Prevention and Response Plan (SPRP) that describes planning, prevention, and control measures to minimize impacts resulting from spills of fuels, petroleum products, or other regulated substances as a result of facility construction. We reviewed this plan and find it acceptable.

REX would restrict construction activities to the approved and clearly marked workspaces. Cleanup and stabilization of disturbed areas would be an ongoing process throughout construction, and would be performed in accordance with the FERC Plan and Procedures, which would minimize soil erosion impacts. Post construction, REX would restore temporary workspaces to pre-construction conditions to the extent possible and stabilize the ground surface at the compressor station sites.

REX anticipates construction would begin in January 2016 and conclude about 5 months later, with a projected in-service of June 2016.

2 The FERC Plan can be found on the Commission website at http://www.ferc.gov/industries/gas/enviro/plan.pdf 3 The FERC Procedures can be found on the Commission website at http://www.ferc.gov/industries/gas/enviro/procedures.pdf

Environmental Inspector

REX has committed to employing one environmental inspector (EI) for this project. However, given the distance between compressor stations, we believe that environmental monitoring would not be adequate and have recommended below, in section D of this EA, that REX employ at least two EIs to ensure that all environmental requirements are satisfied. Alternatively, REX could explain in its implementation plan how it would use fewer, or potentially not full-time, EIs to accomplish the EIs responsibilities for each facility. The EIs would have peer status with other inspectors and would have stop-work authority. Construction contractors employed by REX would observe and comply with federal, state, and local laws, ordinances, and regulations. In addition, we would conduct compliance inspections during construction and restoration to ensure compliance with the proposed action, the FERC Plan and Procedures, and environmental conditions in any FERC Certificate that may be issued for the Project.

A.8 PERMITS AND CONSULTATIONS

Federal, state, and local permits, authorizations, or clearances for construction of the Project, as well as filing status, are summarized in table 1. REX would be responsible for obtaining all necessary permits associated with the Project.

Table 1 Permits and Consultations Permit/Approval Permitting Agency Status FEDERAL Section 7(c) Application Federal Energy Regulatory Commission Under review Endangered Species Act - Section 7 Consultation Federal consultation in U.S. Fish and Wildlife Service, Region 3 and Migratory Bird Treaty Act progress

Ohio State Historic Preservation Office Completed May 8, 2015

National Historic Preservation Act – Section 106 Indiana Department of Natural Resources – Division of Historic Preservation and Received May 1, 2015 Archaeology STATE - OHIO Columbus: PTI Received Permit to Install (PTI) and Permit to Install and March 27, 2015 (PTIO Operate (PTIO)– Columbus and Chandlersville pending) Compressor Stations Ohio Environmental Protection Agency – Chandlersville: PTI pending Division of Air Pollution Control Permit to Install/Permit to Install and Operate (PTIO) – Washington Court House Compressor Received March 27, 2015 Station

Title V Operating Permit Received May 2, 2014

Ohio Department of Natural Resources – State Listed Endangered Species Consultation Completed May 8, 2015 Division of Wildlife

STATE - INDIANA

New Source Construction and Part 70 Operating Indiana Department of Environmental Received May 6, 2015 Permit – St. Paul Compressor Station Management – Office of Air Quality Indiana Department of Natural Resources – State Listed Endangered Species Consultation Completed April 7, 2015 Division of Fish and Wildlife Construction/Land Disturbance Storm Water Indiana Department of Natural Resources Pending (December 2015) Permit

B. ENVIRONMENTAL ANALYSIS

B.1 GEOLOGY AND SOILS

Geology

The Zone 3 Capacity Enhancement Project is within the Till Plains Section of the Central Lowland Physiographic Province and the Eastern edge of the Unglaciated Appalachian Plateau Physiographic Province. The geology of the Project area is characterized by glacial till over bedrock at four of the compressor station locations. The Chandlersville Compressor Station site, however, has not been glaciated and has been previously disturbed.

The St. Paul Compressor Station lies within the New Castle Till Plain subsection, in Indiana, and the Columbus, Washington Court House, and Hamilton Compressor Stations are located in the Southern Ohio Loamy Till Plain subsection in Ohio. The Chandlersville Compressor Station lies within the Muskingum-Pittsburgh Plateau subsection of the Unglaciated Appalachian Plateau.

The bedrock geology consists of sedimentary rock deposited during the Ordovician, Silurian, Devonian, Mississippian, and Pennsylvanian periods. These formations consist of sandstone, limestone, dolomite, clay, coal, and shale. In southern Indiana and western Ohio much of the bedrock is obscured by glacial till and moraines. Blasting is not expected for the Project due to the expected limited extent of disturbance and the extensive presence of glacial till at four of the compressor station locations, and the previously disturbed nature of the Chandlersville site.

Currently no active coal mines are located in the counties in which the new and existing compressor stations are located. Muskingum County currently has one clay and shale mining operation that is located 10 miles northwest of the Chandlersville Compressor Station, and there are no clay or shale mining operations near the other compressor stations. No limestone and dolomite mining operations are located in the counties where the Washington Court House, Hamilton, and St. Paul Compressor Stations are located. The closest limestone and dolomite mine is 13 miles northwest of the Chandlersville Compressor Station, and one limestone and dolomite mining operation is located 19 miles southwest of the Columbus Compressor Station. Warren County has five sand and gravel mines, with the closest sand and gravel mine located 6.25 miles north of the Hamilton Compressor Station. There are currently no sand and gravel mines within 6.25 miles of the Chandlersville, Columbus, Washington Court House, and the St Paul Compressor Stations. Based on the limited nature of Project construction disturbance and the distance to the identified mines, we conclude that construction and operation of the Project would have no adverse effects on mining operations, and would not be adversely affected by the mining operations.

The seismic risk in Ohio and Indiana is relatively low. Most earthquakes occur along the Fort Wayne Rift in Ohio which is not in proximity to the two existing and two proposed compressor stations in the state. Most of Indiana’s faults are in the southwest corner of the state

along the Wabash Valley Fault System which is not in proximity to the St. Paul Compressor Station. The USGS Seismicity Map for the period from 1973 to March 2012 shows relatively few earthquakes near the compressor stations. According to the USGS, the predicted Seismic Hazard with a two percent probability of exceedance in 50 years has a peak acceleration (expressed as a fraction of standard gravity) of 0.06 to 0.1. This means that a minor earthquake may occur but it is not likely.

The potential for subsidence in the Project area is low. Ohio has five significant karst regions, none of which are in proximity to the existing or proposed compressor stations.

The Project area in southwestern Ohio and southeastern Indiana is among the most fossiliferous rocks in the world, containing marine invertebrate fossils that are scientifically important. The glaciated portions of the state are areas where ice age fossils can be found including both plants and ancient mammals. The Project is not expected to impact paleontological resources due to the limited areas of disturbance and shallow excavations into glacial till which covers most of the bedrock. It is unlikely paleontological resources would be affected by this Project. If significant paleontological resources are encountered, REX would stop work and notify the Ohio Department of Natural Resources Division of Geological Survey.

Because of the lack of geologic resources and known significant fossils near the compressor station sites, Project impacts to geologic resources would be minimal. The potential for geologic hazards to impact the existing and proposed facilities at these sites would not be significant. As such, we conclude that construction and operation of the Project would not significantly impact geologic resources or be subject to significant geologic hazards.

Soils

Potential soil impacts related to clearing, grading, excavation, and equipment movement during construction could accelerate the erosion process and, without adequate protection, result in the discharge of sediment to waterbodies and wetlands. Soil loss due to erosion could also reduce soil quality and impair revegetation. Soil disturbances can increase the potential for erosion, which can cause topsoil to be lost, and can negatively affect soil stability and quality. Construction can also result in mixing of topsoil with subsoil, resulting in reduced soil structure and stability, soil fertility, and important soil biological function. In addition, operation of Project facilities may include impacts during temporary disturbance from site maintenance.

At the Chandlersville Compressor Station, soil data indicates 5.7 acres of the site is susceptible to water erosion, the entire disturbed area is susceptible to wind erosion, and 2.6 acres of prime farmland and 1.7 acres are farmland of local importance would be permanently taken out of agricultural production. None of the soils on the site are classified as poorly drained, and none of the soil types have a poor revegetation potential.

At the Columbus Compressor Station, soil data indicates that none are susceptible to water erosion, the entire site is susceptible to wind erosion, 2.6 acres of prime farmland and 5.9 acres of prime farmland if drained would be permanently taken out of agricultural production.

Also, most of the site is partially hydric, 16.8 acres are very poorly to somewhat poorly drained, and none of the soil types have a poor revegetation potential.

At the Washington Court House Compressor Station, none of the soils are susceptible to water erosion, and the entire disturbed area is susceptible to wind erosion, 4.1 acres are prime farmland and 5.3 acres are prime farmland if drained would be permanently taken out of agricultural production.

At the Hamilton Compressor Station, soil data indicates the one soil type present within the Project footprint is not susceptible to water erosion, but is susceptible to wind erosion. About 0.7 acre of the site is prime farmland if drained that would be taken out of production. This site is partially hydric, and is very poorly drained, but does not have a poor revegetation potential.

At the St. Paul Compressor Station, soil data indicates that 8.7 acres is susceptible to water erosion, the entire area of disturbance is susceptible to wind erosion, and 4.8 acres of prime farmland and 2.3 acres is prime farmland if drained would be permanently taken out of production. In addition, construction at this site impacts no hydric soils, 6.0 acres of somewhat poorly drained soils, and no soils having a poor revegetation potential.

To mitigate the impacts of construction on Project soils, REX would implement the FERC Plan, including post-restoration monitoring and repairs for at least 2 years or until the affected area is restored. Required mitigation measures include segregating topsoil and subsoil in agricultural areas stabilizing topsoil piles to minimize loss due to wind and water erosion, replacing soils in proper sequence, compacting to natural soil density, implementing erosion control measures, and reestablishing vegetation as soon as possible after construction. If soils on drained farmland are disturbed, care would be taken to minimize disruption of tile drains, and/or repairing tile drains according to the Plan if they are broken.

To the extent possible, REX would conduct site grading in such a way as to limit the areas of soil disturbance and conserve existing vegetation where applicable. Grading and clearing of vegetation would be conducted only to provide adequate construction and operational staging and access to the Project areas. To reduce the potential for rutting and compaction, REX would attempt to avoid construction activity during periods when the soils are wet. Additionally, mats or geo-textile fabric would be used, where appropriate, to reduce the potential for compaction or rutting.

During restoration, segregated topsoil in all temporary workspace areas would be replaced and graded level with the adjacent topography. If necessary to reduce any construction- related soil compaction, the affected area would then be chiseled and/or disked to break up the soil surface. Areas disturbed from construction activities that are outside the aboveground facilities and are not actively cultivated would be re-seeded. REX would re-seed these areas using a mix of annual and perennial species with vegetation adapted to the region. Reseeding would not be performed where surface facilities are located and where paved or graveled areas are located.

Soil contamination in the Project area may result from at least two sources: hazardous material (e.g. fuel spills during construction) and trench excavation through pre-existing contaminated areas. New soil contamination due to spills or leaks of fuels, lubricants, and coolants used during operation of construction equipment could occur and impact soils. REX would implement its SPRP to minimize and mitigate these impacts. We have reviewed this plan and find it acceptable. All construction personnel would observe disturbed soils for signs of possible contamination, and if existing contaminated soils are discovered, REX would follow the procedures outlined in the SPRP.

Because the use of our Plan would minimize erosion, stabilize disturbed areas, and restore temporary workspace, and because REX’s implementation of its SPRP would minimize spills, we conclude that impacts to soils would be minimal.

B.2 GROUNDWATER

The project is within the Central Lowland Physiographic Province in Ohio and Indiana. The four compressor stations in Ohio are in the Southern Ohio Loamy Till Plain Physiographic Province and the compressor station in Indiana is in the Quaternary New Castle Till Aquifer System. The Miami Valley Buried Aquifer, in the vicinity of the existing Hamilton Compressor Station, is a U.S. Environmental Protection Agency (EPA)-designated sole-source aquifer. Sole- source aquifers supply at least 50 percent of the drinking water consumed in the area where no alternative drinking water source is available that could physically, legally, or economically supply the area. No other project facilities were within a designated sole-source aquifer. REX reviewed available water well databases for Ohio and Indiana to identify public and private wells in the vicinity of the project facilities. No community groundwater wells were identified within one mile of the project areas. Additionally, no domestic wells were identified within 150 feet of the project areas. The nearest groundwater wells to the proposed facilities are as follows: 1,200 feet to the existing Chandlersville Compressor Station; 2,200 feet to the proposed Columbus Compressor Station; 2,800 feet to the proposed Washington Court House Compressor Station; 2,600 feet to the existing Hamilton Compressor Station; and 1,900 feet to the proposed St. Paul Compressor Station. REX conducted an environmental data search to identify any potential sources of groundwater contamination within one mile of the project areas. No such sites were identified within one mile of the compressor stations. Clearing and grading of the construction workspace could result in changes to overland water flow and subsequent recharge of shallow aquifers. In addition, inadvertent spills of hazardous materials used during construction could contaminate shallow groundwater. REX proposes to implement the FERC Plan which ensures that revegetation is completed as soon as possible following construction. REX would also implement its SPRP for any activities involving the storage of fuels and other materials. With the use of these plans, we conclude that any potential impacts on groundwater would be minimized.

B.3 SURFACE WATER AND WETLANDS

Based on National Wetlands Inventory maps and REX’s field surveys, there are no waterbodies or wetlands present on any of the existing and proposed compressor station sites. Therefore, no direct impacts would occur on these resources. Although no wetlands or waterbodies are on the sites, these resources exist in the vicinity of the Project. Potential project-related impacts on nearby wetlands and waterbodies include stormwater runoff, erosion of sediments, and spills of hazardous materials. Any indirect impacts would be avoided by REX’s implementation of its SPRP and the FERC Plan and Procedures.

Hydrostatic testing

REX would conduct hydrostatic testing of the new piping and equipment prior to placing them into service. REX estimates that a total of 774,900 gallons of water would be required for the Project. Table 2 shows the volumes of water REX expects would be required for each station. The required water would be obtained from municipal or other sources and trucked into the sites. REX does not propose to use surface water for hydrostatic testing. After the testing is complete, the water would be hauled offsite to a state approved disposal facility. Therefore, we conclude there would be no adverse environmental impacts on water resources from hydrostatic testing.

Table 2 Hydrostatic Test Water Volumes Facility Name Volume (gallons) Chandlersville Compressor Station 176,400 Columbus Compressor Station 159,600 Washington Court House Compressor Station 199,500 St. Paul Compressor Station 176,400 Hamilton Compressor Station 63,000 TOTAL 774,900

B.4 VEGETATION AND WILDLIFE

Vegetation

Construction of the three new compressor stations (Columbus, Washington Court House, and St. Paul) would primarily impact active agricultural land and the Columbus Compressor Station would also impact a small amount of deciduous forest. Construction activities at the two existing compressor stations (Chandlersville and Hamilton) would impact herbaceous land and developed land. Currently, the affected agricultural land is used to grow corn, soybeans, and wheat. In total, 68.3 acres of active agricultural land, 6.4 acres of herbaceous vegetation, and 2.0 acres of deciduous forest would be affected by the Project during construction.

After construction is complete, 28 acres of active agricultural land, 2.5 acres of herbaceous vegetation, and 0.4 acre of deciduous forest would be permanently converted to

natural gas facility use. The remainder of the areas disturbed by construction would be revegetated in accordance with the FERC Plan. In addition, implementation of the measures included in the FERC Plan would minimize any potential off-site impacts from erosion during construction.

REX proposes several measures to prevent the spread of noxious weeds during construction, including cleaning all construction equipment prior to mobilization to the sites. During restoration and post-construction monitoring, the area would be monitored for noxious weeds which would be controlled with spraying or hand removal.

The FWS recommended that revegetation of the disturbed areas include plant species of nectar producing plants and milkweed to promote monarch butterfly and other pollinator species. REX contacted the Ohio and Indiana Natural Resources Conservation Service (NRCS) Offices to obtain the recommended seed mixes for pollinating plants and has committed to implementing the NRCS seed mix recommendations during its revegetation efforts.

The agricultural and herbaceous vegetation impacts in the temporary workspaces would be short-term (typically one to three growing seasons). Impacts on forest vegetation in the temporary workspaces would be long-term (up to 30 years). While the Project would permanently remove about 31 acres of vegetation, these vegetation types are plentiful in the Project area. Therefore, we conclude that vegetation impacts would not be significant.

Wildlife

The most common wildlife habitats that would be affected by the Project are cultivated cropland and herbaceous land, followed by deciduous forest. Vegetation removal for construction of the compressor stations would decrease the amount of habitat available in the Project area. However, agricultural land, which comprises the majority of the land affected, provides minimal habitat for wildlife. The habitat areas that would be crossed that provide the most value to wildlife are the forested areas at the Columbus Compressor Station site, which are relatively small, consisting of hedgerows between cultivated fields. The deciduous forest habitat type may provide foraging and cover habitat for many species of birds, raptors, bats, deer, coyote, and small mammals. Mobile species, such as most birds and larger mammals, would be expected to move out of the Project area once construction activities commence. Smaller species and less mobile individuals could be unintentionally killed by construction equipment.

Given the limited nature of Project impact on wildlife habitat and the availability of similar habitat in the general area, we conclude that the Project would not have a significant impact on the region’s wildlife.

Migratory Birds

Migratory birds are species that nest in the United States and Canada during the summer, and make short or long-distance migrations for the non-breeding season. Neotropical migrants migrate to and from the tropical regions of Mexico, Central and South America, and the Caribbean.

Migratory birds are protected under the Migratory Bird Treaty Act ([MBTA]-16 U.S. Code 703-711), and Bald and Golden Eagles are additionally protected under the Bald and Golden Eagle Act (16 U.S. Code 668-668d). The MBTA, as amended, prohibits the taking, killing, possession, transportation, and importation of migratory birds, their eggs, parts, or nests unless authorized by the FWS. Executive Order 13186 directs federal agencies to identify where unintentional take is likely to have a measurable negative effect on migratory bird populations and avoid or minimize adverse impacts on migratory birds through enhanced collaboration with the FWS, and emphasizes species of concern, priority habitats, and key risk factors, and that particular focus should be given to population-level impacts.

The nesting season for migratory birds in the Project area is April 1st- August 31st. The majority of the areas that would be disturbed by construction are active agricultural land which do not provide suitable nesting habitat. The only quality nesting bird habitat is a small forested area (about 2 acres) at the Columbus Compressor Station site. Based on FWS recommendations, REX proposes to conduct tree clearing between October 1st and Match 31st to avoid impacts on nesting birds. However, if construction is delayed until spring of 2016, REX would conduct preconstruction surveys in accordance with FWS protocols prior to any clearing. Due to the highly disturbed nature of the Project areas and REX’s time of year and survey commitment, we conclude that the Project would not have a significant impact on migratory birds.

B.5 SPECIAL STATUS SPECIES

Special status species are those species for which state or federal agencies provide an additional level of protection by law, regulation, or policy. Included in this category are federally listed and federally proposed species that are protected under the Endangered Species Act, or are considered as candidates for such listing by the FWS, and those species that are state- listed as threatened or endangered.

Federally Listed Species

REX reviewed the FWS’ Information Planning and Conformation System website to obtain information on federally listed species with the potential to occur in the Project area. Potential suitable habitat for federally endangered Indiana bat and the federally threatened northern long-eared bat exists at the Columbus Compressor Station site. No suitable habitat is present for any other federally listed species. No suitable habitat for federally listed species was identified at the other compressor station sites.

Indiana bats roost during the summer months in trees in riparian, bottomland, and upland forests from approximately April 1st to September 15th. Indiana bats may summer in a wide range of habitats, from highly altered landscapes to intact forests. Roost trees are generally large, dead, or dying. Roost trees can also be live trees with peeling or exfoliating bark favoring exposure to the sun. In the winter, Indiana bats hibernate in large caves or mines with stable, cool temperatures around 40 oF. Similar to the Indiana bat, the northern long-eared bat roosts in cavities, crevices, and underneath bark of live and dead trees during the summer months, but is considered more of a habitat generalist. In the winter, this species hibernates in large caves or mines.

In letters dated May 1, 2015 and May 28, 2015, the FWS recommended tree clearing occur between October 1st and March 31st to avoid impacts on Indiana bats and northern long- eared bats. REX has committed to this tree clearing restriction for the Project which would avoid impacts on these two bat species. Therefore, we conclude that the Project may affect, but is not likely to adversely affect the Indiana bat and northern long-eared bat.

With the publication of this EA, we are requesting that the FWS provide concurrence with our determinations of effect for the Project. To ensure the required consultations under the Endangered Species Act are complete prior to construction, we recommend that REX should not begin construction activities until:

a. the FERC staff receives comments from the FWS regarding the proposed action; b. the FERC staff completes formal consultation with the FWS, if required; and c. REX has received written notification from the Director of the Office of Energy Projects (OEP) that construction or use of mitigation may begin.

State listed species

Potential suitable habitat for one state-listed species, the upland sandpiper, exists at the existing Hamilton Compressor Station. The upland sandpiper nests in native grasslands, with a mixture of tall grasses and broad-leafed weeds. The grassy areas that would be affected by the Project are routinely disturbed by mowing; therefore, we conclude that it is unlikely to be utilized by this species for nesting. Therefore, significant impacts on upland sandpipers would not occur.

B.6 LAND USE, RECREATION, AND VISUAL RESOURCES

The proposed Project would be constructed within each compressor station site’s permanent boundary. About 80.6 acres of temporary disturbance would be required during construction, 33.8 acres of which would be permanently converted for operation of the aboveground facilities. All temporary workspace would be restored and allowed to revert back to preconstruction conditions.

Table 3 Land Use Requirements for Construction and Operation

Compressor Station Construction Land Requirements Operational Land Requirements Facility (acres) (acres)

Chandlersville 9.0 4.6 Columbus 23.4 9.9

Washington Court House 25.9 9.5 Hamilton 1.2 0.7 St. Paul 21.1 9.1 TOTAL 80.6 33.8

Existing public roads would be used during Project construction to move equipment and materials to and from the compressor station and ancillary activity locations. These roads would be used without modification or improvement, although some maintenance to public roads may be required. REX would construct two new permanent access roads to access the new Columbus and St. Paul Compressor Stations. Land use requirements for access roads are included in the compressor station land acreages shown in table 3. The land use types affected by construction and operation of the Project are shown in table 4 below.

Property Values

Several commentors expressed concern over the impact of the Columbus Compressor Station on their property values. It is possible that certain prospective home-buyers may find the compressor station to be a detractor and it could influence a potential buyer to not purchase a nearby property. However, each potential purchaser has different criteria and differing values or considerations for purchasing land. The compressor station would be on land owned by REX and would not preclude any existing or future use of nearby properties.

Due to the lack of studies evaluating property values and aboveground natural gas facilities, the effects on property values are difficult to quantify. Because the proposed site for this facility would be on land owned by REX, any potential impacts on property values would be on adjacent or nearby properties and likely be attributable to noise, appearance, and/or negative public perception. REX’s visual screening analysis4 shows that views of the compressor station are obstructed by natural vegetative screening in most instances, with the exception of hilltop locations. As discussed in section B.9, the noise attributable to the Columbus Compressor Station would meet FERC requirements and would not be significant. Further, section B.8 demonstrates that the air emissions from the station would be below major source thresholds and would not violate the National Ambient Air Quality Standards (NAAQS), which protect human health and the environment. The perception of residents and potential buyers are varied. Based on our analysis, we conclude that there is no conclusive evidence indicating that the compressor station would have a significant impact on adjacent property values.

Recreation and Special Land Uses

The Project area is not within 0.25 mile of any federal land, state land, or land administered by local agencies or private conservation organizations. No National Parks, National Landmarks, or National Scenic Rivers would be affected by the Project. As such, we conclude that the Project would not result in a significant impact on any special land types or uses.

4 REX filed a visual screening analysis for the Columbus Compressor Station (in the form of a presentation) on July 10, 2015, under Docket No. CP15-137-000.

Table 4 Land Use Affected by Construction and Operation

Visual Resources

The Project would not cross or be within any federal, state, or locally designated visual resources of significance (e.g., scenic roads/highways or National Wild and Scenic Rivers).

The existing visual impacts associated with the Chandlersville and Hamilton Compressor Stations would change incrementally, but would be consistent with the existing land use. Construction and operational visual impacts would be limited to the existing station boundaries. Therefore, we conclude that these stations would have no significant impact on visual resources.

The construction and operation of the proposed Columbus, Washington Court House, and St. Paul Compressor Stations would be in rural areas with low density residential and agricultural use. Permanent land impacts associated with the construction of the compressor stations would be limited to the station fencelines, while the property boundaries would extend beyond those areas. We received comments regarding visibility of the Columbus Compressor Station and whether REX would incorporate trees in its design to provide visual mitigation. While the area of disturbance is agricultural, the Columbus Compressor Station site (within the property boundary) has trees on the north and east sides that provide a visual buffer. REX would retain the existing trees and vegetation surrounding the site, as practicable. REX conducted a visual screening analysis, presented during a June 23, 2015 meeting with landowners, which showed that the compressor station would not be visible or would barely be visible to nearby landowners. However, it is possible that landowners at higher elevations would have a more clear view of the facility. In addition, during winter months the station would be more visible. As a result of the meeting, REX stated that it would consider additional measures such as additional tree plantings and underground power lines. We encourage REX to continue working with landowners near the site to mitigate visual impacts; however, we find the proposed site design provides adequate visual mitigation and conclude that impacts on visual resources from these facilities would be minimal.

We received comments from landowners regarding lighting at the Columbus Compressor Station. REX has committed to the following lighting mitigation measures and specifications: no more than 10 lights per compressor station site; lights would not exceed 30 feet in height; installation of downcast lighting; minimizing lighting to process and/or work areas only; focused light technology (no scatter); use of foot-candles at lowest acceptable levels; and limiting lighting to times where personnel are onsite. We conclude that these measures would adequately minimize nighttime lighting impacts on surrounding residences.

B.7 CULTURAL RESOURCES

Section 106 of the National Historic Preservation Act, as amended, requires the FERC to take into account the effects of its undertakings on properties on or eligible for listing on the National Register of Historic Places and to afford the Advisory Council on Historic Preservation an opportunity to comment. REX, as a non-federal party, is assisting us in meeting our obligations under Section 106 and the implementing regulations at 36 CFR 800.

REX conducted cultural resource surveys for the three new compressor stations; the Columbus Compressor Station in Pickaway County, Ohio; the Washington Court House Compressor Station in Fayette County, Ohio; and the St. Paul Compressor Station in Decatur County, Indiana. The proposed work at existing facilities is within areas that were previously surveyed and received State Historic Preservation Offices (SHPO) clearance under Docket No. CP07-208-000. Additionally, REX has a memorandum of understanding (MOU) with the Ohio SHPO that exempts certain types of projects from cultural resources review. REX’s Project activities at existing facilities meet the criteria of the MOU, so no additional consultation with the Ohio SHPO and no cultural resources surveys are required for those facilities.

Cultural resource surveys of the new compressor station sites included archeological and architectural surveys. The archeological survey included pedestrian survey and shovel testing. In total, 103 acres received archeological survey. Surveys for aboveground resources were conducted to assess the indirect effects of the Project on any historic properties that would have a viewshed of the Project. That survey was conducted in a 0.5-mile radius around the three new compressor stations.

Ohio Survey Results

Archeological survey identified five sites in Ohio (33PI908, 33PI1003, 33PI1332, 33PI1335, 33FE364). Four are prehistoric, and one is a multi-component prehistoric and historic site. All of the sites in Ohio were recommended as not eligible for listing on the National Register of Historic Places (NRHP).

In Ohio, survey for aboveground resources identified two historic-age resources (50 years old or greater) within the 0.5-mile area of potential effects (APE) for the Columbus Compressor Station (the Hagers-Peters House and the Burlington Church Cemetery). Records indicate that the burials from the cemetery were moved by 2003. Therefore, the Burlington Church Cemetery is recommended as not eligible for listing on the NRHP. Recorded local lore indicates that the Hagers-Peters House was associated with the Underground Railroad. The current survey was not able to substantiate those claims, and recommended that the house was not eligible for listing on the NRHP. However, the report indicated that the NRHP-eligibility could change if additional research found a connection to significant events in the history of the country. Therefore, REX assessed the potential visual impacts on the Hagers-Peters House. The viewshed survey found that mature trees along Little Walnut Creek block the view of the compressor station, and the proposed compressor station would have no effect on the resource. No historic properties were identified within the 0.5-mile APE for the Washington Court House Compressor Station.

REX provided Phase I survey reports and supplemental survey reports for Ohio to the FERC and the Ohio SHPO. In two letters dated August 3, 2015, the Ohio SHPO concurred that the project would not affect historic properties. We concur as well.

Indiana Survey Results

Cultural resource survey identified four sites in Indiana (12DE993, 12DE994, 12DE995, 12DE996). Three are prehistoric, and one is a multi-component prehistoric and historic site.

Three of the sites in Indiana were recommended as not eligible for listing on the NRHP. The multi-component site was recommended for avoidance or for additional testing to determine eligibility. REX redesigned the Project area in order to avoid this site.

In Indiana, survey for aboveground resources identified one historic-age resource (50 years old or greater) within the 0.5-mile APE for the St. Paul Compressor Station (the Arnold Cemetery). The Arnold Cemetery was originally recorded in 1999 and has been recommended as a “contributing property,” implying that it is eligible for the National or State Register of Historic Places. Although the historic district to which it “contributes” is not specified, its contributing status likely relates to its state listing as an Indiana Heritage Cemetery.

The cemetery is fully surrounded by deciduous trees that obscure most views of the open farmland in the direction of the proposed compressor station. Additionally, Interstate 74 is situated between the cemetery and the proposed compressor station location, with traffic along that roadway representing an existing substantial modern intrusion into the setting of the cemetery. REX recommended that the St. Paul Compressor Station would have no effect on the historic cemetery.

REX provided a Phase I survey report and supplemental survey report to the FERC and the Indiana SHPO. In a letter dated May 1, 2015, the Indiana SHPO provided comments on the survey report. The SHPO indicated that there were additional archeology sites in the vicinity of the Project, but they had been determined not eligible for listing on the NRHP. Therefore, they concurred that no historic properties would be affected. We also concur.

Native American Consultation

REX contacted the following Native American tribes in or with ties to the Project area: Absentee Shawnee Tribe of Oklahoma, Delaware Nation, Eastern Shawnee Tribe of Oklahoma, Miami Tribe of Oklahoma, Peoria Tribe of Oklahoma, and Shawnee Tribe of Oklahoma. The Peoria Tribe of Indians of Oklahoma indicated that they have no known cultural resources in the vicinity and no objection to the Project, but indicated that they want to be notified if any human remains, funerary items, or important cultural objects are identified during construction.

We sent the same tribes our NOI and in separate letters dated June 6, 2015, we also invited each of those tribes to consult regarding the Project. On July 28, 2015, REX filed on the docket email correspondence from the Delaware Nation regarding their official response of no concern. To date, we have received no other responses.

REX provided an Unanticipated Discovery Plan to deal with the unexpected discovery of historic properties and human remains during construction. We find this plan acceptable.

Conclusion

Based on the results of the cultural resources survey, and through consultation with the Indiana and Ohio SHPOs and Native American tribes, we believe that the project would have no effect on historic properties.

B.8 AIR QUALITY

Air quality can be affected by both construction and operation of the proposed facilities. The EPA has established NAAQS for criteria pollutants for the purpose of protecting human health (primary standards) and public welfare (secondary standards). The EPA set NAAQS for the following air contaminants designated as “criteria pollutants”: nitrogen dioxide (NO2), carbon monoxide (CO), sulfur dioxide (SO2), lead, particulate matter with an aerodynamic diameter less than or equal to 10 microns (PM10), particulate matter with an aerodynamic diameter less than or equal to 2.5 microns (PM2.5), and ozone. Ozone is the result of a reaction between nitrogen oxides (NOx) and volatile organic compounds (VOC); as a result, ozone formation cannot be directly controlled. Limiting NOx and VOC emissions would result in a lower potential for ozone formation.

These NAAQS reflect the relationship between pollutant concentrations and health and welfare effects, and are supported by sound scientific evidence. The states implement and enforce the NAAQS through State Implementation Plans (SIPs), which must be approved by the EPA. The state of Ohio implements its SIP through the Ohio Environmental Protection Agency (Ohio EPA) and the State of Indiana implements its SIP through the Indiana Department of Environmental Management (IDEM).

Air quality control regions (AQCRs) are areas established for air quality planning purposes in which SIPs describe how ambient air quality standards would be achieved and maintained. AQCRs were established by the EPA and local agencies, in accordance with Section 107 of the Clean Air Act of 1970 and its amendments (CAA), as a means to implement the CAA and comply with the NAAQS through SIPs. The CAA is the basic federal statute governing air pollution. AQCRs are intra- and interstate regions such as large metropolitan areas where improvement of the air quality in one portion of the AQCR requires emission reductions throughout the AQCR. Each AQCR, or portion thereof, is designated based on compliance with the NAAQS. AQCR designations fall under three categories as follows: “attainment” (areas in compliance with the NAAQS), “nonattainment” (areas not in compliance with the NAAQS), or “unclassifiable/attainment” (areas that cannot be classified on the basis of available information as meeting or not meeting the NAAQS). Areas in nonattainment with the NAAQS for any criteria pollutant are held to more restrictive air emissions limits when determining whether the facility is a major source under federal programs.

Warren County, Ohio is designated as marginal nonattainment with the NAAQS for ozone. All other counties associated with the Project are in attainment with the NAAQS for all criteria pollutants.

On December 7, 2009, the EPA defined air pollution to include six of the greenhouse gases (GHGs): carbon dioxide (CO2), methane (CH4), nitrous oxide (N2O), hydrofluorocarbons, perfluorocarbons, and sulfur hexafluoride.5 GHGs occur in the atmosphere both naturally and as

5 See volume 74 of the Federal Register, page 66,496 (74 FR 66,496).

a result of human activities, such as the burning of fossil fuels. These gases are the integral components of the atmosphere’s greenhouse effect that warms the earth. The most abundant GHGs are water vapor, CO2, CH4, and N2O. No fluorinated gases would be emitted during construction or operation of the Project. GHG emissions are typically estimated as carbon dioxide equivalents (CO2e). GHGs are ranked by their global warming potential (GWP), which is the potential of each gas to increase heating in the atmosphere. The GWP is a ratio relative to CO2 that is based on the GHG’s ability to absorb solar radiation as well as the residence time within the atmosphere and is expressed as a multiple of the GWP of CO2. Based on EPA guidelines, CO2 has a GWP of 1, CH4 has a GWP of 25, and N2O has a GWP of 298.

State Air Quality Regulations

REX must comply with applicable regulatory standards in Chapter 3745 of the Ohio Administrative Code and Chapter 326 of the Indiana Administrative Code, which outline air quality standards that could potentially apply to construction and operation of REX’s Project.

Air Quality Construction Impacts and Mitigation

Emissions of regulated air pollutants would occur as a result of construction and operation of the Project. Emissions associated with construction activities generally include exhaust from construction equipment, fugitive dust associated with vehicle movement at the Project sites, and fugitive dust associated with trenching, backfilling, and other earth-moving activities. Exhaust emissions would depend on the equipment used and the hp-hours of operation. The quantity of fugitive dust emissions would depend on the moisture content and texture of the soils that would be disturbed. Table 4 displays the estimated construction emissions in tons per year (tpy).

Emissions from construction equipment exhaust would be temporary in nature. Once construction in the Project area are completed, fugitive dust and construction vehicle/equipment emissions associated with the compressor station construction would subside. Therefore, we conclude that emissions associated with construction of the Project would not result in a significant impact on local air quality.

General Conformity

The General Conformity Rule is codified in 40 CFR 93, Subpart B, Determining Conformity of General Federal Actions of State and Federal Implementation Plans. A General Conformity applicability analysis is required for parts of the Project occurring in nonattainment or maintenance areas for criteria pollutants. The Hamilton Compressor Station is in Warren County, Ohio, which is in marginal nonattainment for ozone. We reviewed REX’s estimated construction emissions in Warren County for comparison to the General Conformity thresholds in 40 CFR 93.153(b)(1). As shown in table 5, the estimated applicable Project emissions in Warren County would be well below the applicable General Conformity threshold of 50 tpy for VOC and 100 tpy of NOx; therefore, a General Conformity Determination is not required.

Table 5 Project Construction Emissions

Source 2016 Construction Emissions (tpy) NOX CO SO2 VOC PM10 PM2.5 CO2e Columbus Compressor Station 39.03 59.76 2.40 15.17 5.45 4.94 9,119 Washington Court House Compressor 39.03 59.76 2.40 15.17 5.46 4.94 9,119 Chandlersville Compressor Station 39.03 59.76 2.40 15.17 5.38 4.93 9,119 St. Paul Compressor Station 39.04 59.82 2.40 15.17 5.44 4.94 9,119 Hamilton Compressor Station 17.34 29.92 1.09 7.14 2.33 2.14 4,043

Air Quality Operation Impacts and Mitigation

Emissions of regulated air pollutants would occur as a result of operation of the Project. REX filed its air quality permit applications for the Columbus, Washington Court House, Chandlersville, and St. Paul Compressor Stations with the Ohio EPA and IDEM. Table 6 displays the potential to emit (PTE) emissions of criteria pollutants and hazardous air pollutants (HAPs) for each station. The PTE emissions represent the maximum capacity of a stationary source to emit an air pollutant, although actual operational emissions may be less. There would be no change in emissions sources at the Hamilton Compressor Station as a result of the Project. Therefore, the Hamilton Compressor Station is not discussed further.

Table 6 Summary of Potential-to-Emit Operational Emissions Emissions (tpy) Source

NOx VOC CO SO2 PM10 PM2.5 Total HAP CO2e Columbus CS 133.8 20.78 137.7 8.0 29 28.4 2.7 262,751 Washington Court House CS 91.8 15.26 95 5.5 20 19.4 1.9 180,101 Chandlersville CS1 240.7 83.61 128.5 6.3 26.6 26.5 15.8 259,462 St. Paul CS 91.8 16.48 95 5.5 20.0 19.4 6.4 180,101 1 The PTE for the Chandlersville Compressor Station includes existing and modified emissions of criteria pollutants.

REX conducted air quality modeling for the St. Paul Compressor Station. Based on modeling results, the St. Paul Compressor Station would be in compliance with the NAAQS for all criteria pollutants.

In compliance with the Ohio EPA and as part of its air quality permit applications, REX performed air quality modeling using EPA-approved AERMOD air dispersion model for the Columbus, Washington Court House, and Chandlersville Compressor Stations.6 These results were then compared to the Ohio Acceptable Incremental Impact (AII). Table 7 provides Ohio AII levels.

6 Detailed air modeling analyses and results can be found in appendices 9A, 9B, and 9C of resource report 9 in REX’s application under Docket No. CP15-137-000.

Table 7 Ohio Modeling Significant Emissions Rates (SER) Ohio Modeling SER Ohio Acceptable Incremental Impact Pollutant (tpy) (micrograms/cubic meter)

8.5 – Annual PM 15 10 15 – 24‐hr 2 – Annual PM 10 2.5 4.5 – 24‐hr 12.5 – Annual NO 40 2 188 – 1‐hr 10 – Annual 45.5 – 24‐hr SO2 40 256 – 3‐hr 196 – 1‐hr 2,500 – 8‐hr CO 100 10,000 – 1‐hr

The Chandlersville Compressor Station would not cause or contribute to exceedances of any of the Ohio AII levels for CO, SO2, NO2 or PM10. However, the modeling analysis indicated an exceedance of the 24‐hr PM2.5 Ohio AII level; the station measured 5.4 3 3 micrograms/cubic meter (g/m ), which exceeds the 4.5g/m level. REX performed further analysis of the PM2.5 modeling results and found that the exceedance was limited two receptors located on the property boundary. There would be no offsite exceedances.

Based on the modeling results, the Washington Court House Compressor Station would not cause or contribute to exceedances of any of the Ohio AII levels for CO, NO2, SO2, or PM10. However, the modeling analysis indicated an exceedance of the 24‐hr PM2.5 Ohio AII level; the 3 3 station measured 6.1 g/m , which exceeds the 4.5g/m level. REX performed further analysis of the PM2.5 modeling results and found that the exceedance was limited to a single receptor located on the property boundary. There would be no offsite exceedances.

REX’s modeling results for the Columbus Compressor Station demonstrated that operation of the station would not result in exceedances of any of the Ohio AII levels for NO2, CO, SO2, or PM10. However, the results did indicate a possible exceedance of the 24‐hr PM2.5 Ohio AII level. REX performed further analysis of the PM2.5 modeling results and found that the exceedances of the Ohio AII level for 24‐hr PM2.5 were limited to 11 receptors located on or directly adjacent to the station property boundary. While offsite impacts would be experienced, the locations of the exceedances are situated such that it is not likely to impact the general public. Figure 2 shows the locations where the Ohio AII was exceeded for the Columbus Compressor Station.

Figure 2 – Columbus Compressor Station Exceedance Locations

Federal Air Quality Regulations

During operation, the proposed and modified compressor stations would emit quantities of regulated air pollutants and would be subject to federal and state air quality regulations that are driven by the CAA. The provisions of the CAA that are potentially relevant to this Project are discussed below.

New Source Review – Prevention of Significant Deterioration

Prevention of Significant Deterioration (PSD) federal review regulations are part of the New Source Review program. PSD regulations are intended to protect the national public health and welfare as well as preserve the existing air quality in areas of special national or regional scenic, natural, recreational, or historic value where regulated pollutant levels are in compliance with the NAAQS. PSD regulations impose specific limits on the amount of pollutants that new major sources or major modifications at existing stationary sources may contribute to existing air quality levels. In addition, for existing PSD sources, modifications that exceed the PSD significant-emissions-increase rates are subject to PSD regulations. For natural gas compressor stations, the PSD regulations define a major source as any source that emits or has the PTE any

regulated pollutant equal to or greater than 250 tpy. As shown in table 6, the Chandlersville, Columbus, Washington Court House, and St. Paul Compressor Stations would not emit 250 tpy of any criteria pollutant. Therefore, these stations would not be subject to PSD regulations.

Greenhouse Gases

On September 22, 2009, the EPA issued the final Mandatory Reporting of Greenhouse Gases Rule. It requires reporting of GHG emissions from suppliers of fossil fuels and facilities that emit greater than or equal to 25,000 metric tons7 of GHG per year. The combustion-related GHG emissions from operation of the Project facilities are projected to exceed 25,000 metric tons per year; therefore, REX would be required to report GHG emissions under the Mandatory Greenhouse Gas Reporting Rule.

On May 13, 2010, the EPA tailored the applicability criteria for stationary sources and modification projects, resulting in the PSD GHG Tailoring Rule.8 The Tailoring Rule applied to new sources exceeding 100,000 tpy of CO2e or modified sources resulting in a GHG increase exceeding 75,000 tpy CO2e, whether or not they were major for a criteria pollutant. However, on June 23, 2014, the Supreme Court ruled that the EPA cannot require PSD permitting based solely on GHG emissions, striking down a portion of the rule.9 The proposed and modified compressor stations associated with the REX Zone 3 Capacity Enhancement Project would each emit criteria pollutants at levels less than 250 tpy, making them minor sources under PSD regulations. Therefore, the GHG Tailoring Rule would not apply.

New Source Performance Standards

New Source Performance Standards (NSPS), codified at 40 CFR 60, establish emission limits and requirements for monitoring, reporting, and recordkeeping for specific emission source categories. NSPS apply to new, modified, or reconstructed sources. The general provisions of NSPS (subpart A) would apply to Chandlersville, Columbus, Washington Court House, and St. Paul Compressor Stations.

Subpart JJJJ would apply to the new emergency generators at the Chandlersville, Columbus, Washington Court House, and St. Paul Compressor Stations as each would be greater than 130 hp. REX would comply with the emissions limits and requirements under subpart JJJJ by installing a non‐resettable hour meter. REX would also ensure that each emergency generator satisfies the compliance requirements for periodic testing and maintenance specified in 40 CFR 60.4243(b)(2), the operational restrictions for emergency engines in 40 CFR 60.4243(d), and the notification, reporting and recordkeeping requirements specified in 40 CFR 60.4245.

Subpart KKKK, Standards of Performance for Stationary Combustion Turbines, would apply to the modified or new turbines at each of the compressor stations because the heat input at

7 A metric ton is 2,205 pounds, or approximately 1.1 tons. 8 75 FR 31,514. 9 http://www.supremecourt.gov/opinions/13pdf/12-1146_4g18.pdf.

peak load would be greater than 10 million British thermal units per hour. Emissions limitations for the modified/reconstructed units are 150 parts per million NOx at 15 percent O2 and a fuel sulfur standard equivalent to 0.060 pounds SO2 per million British thermal units. The turbines would be required to meet specific emission limits, and performance testing, monitoring, recordkeeping, and reporting requirements.

Subpart ZZZZ – National Emission Standards for Hazardous Air Pollutants for Reciprocating Internal Combustion Engines would apply to the emergency generators at the Chandlersville, Columbus, Washington Court House, and St. Paul Compressor Stations. Each generator would comply with the subpart ZZZZ by complying with NSPS subpart JJJJ. The Emergency Generator (P004) would meet the requirements under Reciprocating Internal Combustion Engine (RICE) National Emission Standards for Hazardous Air Pollutants (NESHAP) by complying with NSPS Subpart JJJJ for spark ignition RICE.

Title V Operating Permit

The Title V Operating Permit Program, as described in 40 CFR 70, requires major sources of air emissions to obtain a federal operating permit. The major source emissions thresholds for determining the need for a Title V Operating Permit are 100 tpy for all criteria pollutants, 10 tpy for a single HAP, and 25 tpy for all HAPs combined. Air emissions from the Columbus and Chandlersville Compressor Stations would exceed the Title V major source threshold for NOx and CO; therefore, REX would be required to obtain a Title V operating permit for each station. In compliance with Ohio state air quality regulations, REX would apply for a Title V permit within 12 months of placing the stations in service.

National Emissions Standards for Hazardous Air Pollutants

The NESHAPs, codified in 40 CFR 61 and 63, regulate the emissions of HAPs from existing and new sources and apply to major sources of HAPs. A major source under NESHAP is defined as a source with PTE emissions exceeding 25 tpy for all HAPs or 10 tpy for individual HAPs. As shown in table 6, the compressor facilities associated with the Project would be below the NESHAP major source thresholds. Therefore, these stations would not be subject to NESHAP regulations.

Conclusion

We received numerous comments regarding impacts of the Columbus Compressor Station on air quality and public health. While the Columbus Compressor Station would be a major source of air emissions under Title V and would be required to comply with certain reporting requirements, the station would be a minor source under PSD and would not be subject to emissions restrictions. In addition, the total potential emissions from the proposed station would comply with the EPA’s NAAQS, in accordance with the CAA. These standards were established to protect human health and public welfare and take into account “sensitive”

populations such as asthmatics, children, and the elderly. 10 As such, we conclude that no significant impact to air quality would occur as a result of operation of the Columbus Compressor Station.

B.9 NOISE

Construction and operation of the Project would affect the local noise environment. Two measurements used by federal agencies to relate the time-varying quality of environmental noise to its known effects on people are the equivalent sound level (Leq) and the day-night sound level (Ldn). The Leq is an A-weighted sound level containing the same sound energy as instantaneous sound levels measured over a specific time period. Noise levels are perceived differently, depending on length of exposure and time of day. The Ldn takes into account the duration and time the noise is encountered. Late night through early morning (10:00 p.m. to 7:00 a.m.) noise exposures are penalized +10 decibels (db) to account for people’s greater sensitivity to sound during nighttime hours. An Ldn of 55 decibels on the A-weighted scale (dBA) is equivalent to a continuous Leq noise level of 48.6 dBA.

The EPA has indicated that an Ldn of 55 dBA protects the public from indoor and outdoor activity interference. We have adopted this criterion and use it to evaluate the potential noise impact from operation of compressor facilities. There are no state noise regulations applicable to the Project.

Construction Activities

Construction activities associated with the Project would be performed with standard heavy equipment such as track-excavators, backhoes, bulldozers, dump trucks, and cement trucks. The most prevalent sound source during construction would be the internal combustion engines used to power the construction equipment. Construction activities would temporarily increase ambient sound levels in the immediate vicinity of the compressor station construction site. Construction of the Project would be limited to daytime hours, short-term, and transitory, and would subside once construction is complete; therefore, we conclude that no significant increase of local noise levels would result from construction of the Project.

Compressor Station Operation

REX’s noise consultants, Noise Solutions USA Inc., conducted an acoustical analysis for the proposed and modified compressor stations in January 2015. The estimated noise attributable to operation of the Columbus, Washington Court House, Ct. Paul, and Chandlersville Compressor Stations is shown in table 8.

10 http://www.epa.gov/air/criteria.html

Table 8 Estimated Compressor Station Noise Levels Predicted Noise Level Ambient + Compressor Noise Increase NSA (Ldn dBA) Station (Ldn dBA) (dBA) Columbus Compressor Station NSA 1 46.8 48.4 6.2 4,030 feet northeast NSA 2 51.8 52.2 10.4 2,500 feet east NSA 3 49.4 50.1 8.3 2,600 feet southeast NSA 4 55.0 55.2 13.4 1,570 feet south NSA 5 50.6 51.1 9.3 2,630 feet west NSA 6 46.3 47.6 5.8 3,700 feet northwest Washington Court House Compressor Station NSA 1 52.6 54.9 4 2,800 feet north NSA 2 43.1 51.6 0.7 6,450 feet east-southeast NSA 3 42.2 51.5 0.6 5,800 feet southwest NSA 4 42.9 51.6 0.7 4,600 feet northwest NSA 5 49.3 53.2 2.3 2,630 feet north -northwest St. Paul Compressor Station NSA 1 54.8 63.9 0.5 2,300 feet northeast NSA 2 45.3 63.4 0 4,800 feet north- northwest NSA 3 44.2 63.4 0 4,800 feet north- northeast NSA 4 41.3 63.4 0 5,800 feet east-northeast NSA 5 50.9 63.6 0.2 2,000 feet south Existing Facility Predicted Noise Noise Increase NSA (Ldn dBA) (Ldn dBA) (dBA) Chandlersville Compressor Station (existing) NSA 1 55.0 55.0 0 1,398 feet north-northwest NSA 3 49.8 51.0 1.2 1,381 feet southeast NSA 4 53.8 54.9 1.1 1,411feet southwest NSA 5 50.0 53.9 3.9 1,489 feet northwest

Noise attributable to the modified Hamilton Compressor Station would decrease at all noise sensitive areas (NSA) as a result of the Project. Therefore, we conclude that the Hamilton Compressor Station would not result in significant noise impacts in the Project area.

The noticeable noise increase threshold for humans is about 3 dBA; 5 dBA is a clearly noticeable increase in noise, while an increase of 10 dBA is perceived as a doubling of noise. As shown in table 7, the estimated noise attributable solely to each of the compressor stations would be at or below our criterion of a day-night noise level of 55 dBA. The noise increase from ambient conditions resulting from the Washington Court House, St. Paul, and Chandlersville Compressor Stations would be relatively minor (below 5 dBA). However, to ensure that noise levels from these stations comply with our noise requirement, we recommend that:

REX should file a noise survey(s) with the Secretary of the Commission (Secretary) no later than 60 days after placing Washington Court House, St. Paul, and Chandlersville Compressor Stations in service. If a full load condition noise survey is not possible, REX should provide an interim survey at the maximum possible horsepower load and provide the full load survey within 6 months. If the noise attributable to the operation of all of the equipment at the Washington Court House, St. Paul, and Chandlersville Compressor Stations under interim or full horsepower load conditions exceeds an Ldn of 55 dBA at any nearby NSAs, REX should file a report on what changes are needed and should install the additional noise controls to meet the level within 1 year of the in-service date. REX should confirm compliance with the above requirement by filing a second noise survey with the Secretary no later than 60 days after it installs the additional noise controls.

We received numerous comments from landowners expressing concern over noise levels from the Columbus Compressor Station and requesting that REX undertake noise mitigation measures to ensure noise is not a nuisance. REX has committed to implementing noise- abatement measures, as recommended by Noise Solutions USA Inc., including, but not limited to: acoustically treating buildings; installing engine air intake silencers; and installing turbine exhaust silencers. REX would also implement its landowner complaint process and follow up with landowners within 48 hours. The Columbus Compressor Station would comply with our noise requirement; however, the noise levels at multiple NSAs would experience a doubling (or nearly a doubling) of noise. We conclude that REX’s proposed compressor station design would adequately mitigate noise impacts to acceptable levels. However, to ensure that the noise from the Columbus Compressor Station does not become a nuisance, we recommend that:

REX should make all reasonable efforts to ensure its predicted noise levels from the Columbus Compressor Station are not exceeded at nearby NSAs and file noise surveys showing this with the Secretary no later than 60 days after placing the Columbus Compressor Station into service. If a full load condition noise survey is not possible, REX should provide an interim survey at the maximum possible horsepower load and provide the full load survey within 6 months. However, if the noise attributable to the operation of the

Columbus Compressor Station at full load exceeds an Ldn of 55 dBA at any nearby NSA, REX should file a report on what changes are needed and should install additional noise controls to meet the level within 1 year of the in-service date. REX should confirm compliance with this requirement by filing a second noise survey with the Secretary no later than 60 days after it installs the additional noise controls.

In addition to normal operation, the proposed compressor stations would experience infrequent blowdown events. During a blowdown, natural gas would be vented to the atmosphere. These events occur prior to maintenance activities, during start-up and shutdown operations, and during emergencies. Blowdown noise from the Columbus Compressor Station would be silenced to 52 dBA at 500 feet; the nearest NSA to the Columbus Compressor Station is about 1,570 feet. This would be less than our 55 dBA requirement. In addition, REX would provide advanced notice to nearby NSAs prior to commencing scheduled blowdown activities.

Based on the estimated sound levels, REX’s mitigation measures, and our recommendations, we conclude that the noise attributable to operation of the Columbus, Washington Court House, Chandlersville, St. Paul, and Hamilton Compressor Stations would not cause a significant impact on the surrounding environment.

B.10 RELIABILITY AND SAFETY

The transportation of natural gas by pipeline involves some incremental risk to the public due to the potential for accidental release of natural gas. The pressurization of natural gas at a compressor station involves some risk to the public in the event of an accident and subsequent release of gas. The greatest hazard is a fire or explosion following a leak, or rupture at the facility.

Methane, the primary component of natural gas, is colorless, odorless, and tasteless. It is not toxic, but is classified as a simple asphyxiate, possessing a slight inhalation hazard. If breathed in high concentration, oxygen deficiency can result in serious injury or death. Methane has an auto-ignition temperature of 1,000 °F and is flammable at concentrations between 5 percent and 15 percent in air. An unconfined mixture of methane and air is not explosive; however, it may ignite and burn if there is an ignition source. A flammable concentration within an enclosed space in the presence of an ignition source can explode. It is buoyant at atmospheric temperatures and disperses rapidly in air.

The compressor stations must be designed, constructed, operated, and maintained in accordance with the U.S. Department of Transportation (DOT) Minimum Federal Safety Standards in 49 CFR 192. The regulations are intended to ensure adequate protection for the public and to prevent facility accidents and failures. Part 192.163 – 192.173 of 49 CFR specifically addresses design criteria for compressor stations, including emergency shutdowns and safety equipment. Part 192 also requires a pipeline operator to establish a written emergency plan that includes procedures to minimize the hazards in an emergency.

Safety Standards

The DOT is mandated to provide pipeline safety under Title 49, U.S.C. Chapter 601. The DOT’s Pipeline and Hazardous Materials Safety Administration (PHMSA) administers the national regulatory program to ensure the safe transportation of natural gas and other hazardous materials by pipeline. It develops safety regulations and other approaches to risk management that ensure safety in the design, construction, testing, operation, maintenance, and emergency response of pipeline facilities. Many of the regulations are written as performance standards which set the level of safety to be attained and allow the pipeline operator to use various technologies to achieve safety. PHMSA ensures that people and the environment are protected from the risk of pipeline incidents. This work is shared with state agency partners and others at the federal, state, and local level.

The DOT provides for a state agency to assume all aspects of the safety program for intrastate facilities by adopting and enforcing the federal standards. A state may also act as DOT's agent to inspect interstate facilities within its boundaries; however, the DOT is responsible for enforcement actions. The DOT pipeline standards are published in 49 CFR 190- 199. Part 192 specifically addresses natural gas pipeline safety issues.

Under an MOU on Natural Gas Transportation Facilities dated January 15, 1993, between the DOT and the FERC, the DOT has the exclusive authority to promulgate federal safety standards used in the transportation of natural gas. Section 157.14(a)(9)(vi) of the FERC's regulations require that an applicant certify that it will design, install, inspect, test, construct, operate, replace, and maintain the facility for which a Certificate is requested in accordance with federal safety standards and plans for maintenance and inspection. Alternatively, an applicant must certify that it has been granted a waiver of the requirements of the safety standards by the DOT in accordance with Section 3(e) of the Natural Gas Pipeline Safety Act. The FERC accepts this certification and does not impose additional safety standards. If the Commission becomes aware of an existing or potential safety problem, there is a provision in the Memorandum to promptly alert DOT. The MOU also provides for referring complaints and inquiries made by state and local governments and the general public involving safety matters related to pipelines under the Commission's jurisdiction.

The FERC also participates as a member of the DOT's Technical Pipeline Safety Standards Committee which determines if proposed safety regulations are reasonable, feasible, and practicable.

REX must establish a continuing education program to enable the public, government officials, and others to recognize an emergency at the facility and report it to appropriate public officials. In addition, each pipeline operator is required to establish an emergency plan that includes procedures to minimize the hazards of a natural gas pipeline emergency. Key elements of the plan include procedures for:

 receiving, identifying, and classifying emergency events, gas leakage, fires, explosions, and natural disasters;  establishing and maintaining communications with local fire, police, and public

officials, and coordinating emergency response;  emergency system shutdown and safe restoration of service;  making personnel, equipment, tools, and materials available at the scene of an emergency; and  protecting people first and then property, and making them safe from actual or potential hazards.

REX’s construction and operation of the proposed and modified compressor stations would represent a minimum increase in risk to the nearby public. We conclude that the Project would not result in significant impacts on public safety.

B.11 NON-JURISDICTIONAL FACILITIES

The power needed to operate the new Columbus, Washington Court House, and St. Paul Compressor Stations would be delivered by new overhead power lines to be installed and operated by Duke Energy Corporation and Dayton Power & Light. The Public Utilities Commission of Ohio has permitting authority for the power lines associated with the Columbus and Washington Court House Compressor Station while the Indiana Utility Regulatory Commission has permitting authority over the power lines associated with the St. Paul Compressor Station. Table 9 shows the land required for the planned power line facilities. Table 9 Non-Jurisdictional Power Line Facilities

Columbus Compressor Washington Court House St. Paul Station Compressor Station Compressor Station

Owner Duke Energy Corporation Dayton Power & Light Duke Energy Corporation

2,200 foot long Power line 8,712 feet long power line 1,400 feet long power line

Facilities 480 volt transformer 480 volt transformer 480 volt transformer Required associated breakers associated breakers associated breakers

Land Required 0.06 acre 0.95 acre 0.68 acre

0.78 acre – cultivated 0.05 acre – cultivated crops crops 0.68 acre – cultivated Land Use 0.14 acre – residential crops 0.07 acre - road 0.03 acre – road

The pole structures would likely be visible to nearby residents, but would be similar in nature to existing power lines in the area and would not span large distances. Based on the limited scope and land requirements for the planned power lines facilities and the oversight from permitting authorities, we do not believe the non-jurisdictional power lines would result in a significant impact on the Project areas.

In response to landowner requests, REX is reviewing options to install a potable water line to replace the proposed water well at the Columbus Compressor Station site. The water line

would be used to provide potable water to the office building at the site and would potentially provide tie-ins for nearby landowners. The water well currently proposed would be a private well constructed within the footprint of the compressor station. If possible, REX would select one of the three water line options. In the event that the line cannot be constructed, REX would move forward with the proposed water well.

Each of the three routes for the water line would be partially collocated with the new access road for the Columbus Compressor Station. Appendix B, figure B-1 contains a depiction of each water line route. Earnhart Hill Regional Water and Sewer District would construct the water lines and would be responsible for obtaining all necessary permits. REX would construct the onsite well and would obtain any required permits. The land use types affected during construction and operation (including, but not limited to, cultivated crops, grassland, deciduous forest, and residential land) would be similar and relatively minor for each route; typically impacting less than 1 acre per land use type per route. The water lines and private well would each require installation of 6-inch high-density polyethylene or polyvinyl chloride pipe, however, the pipe associated with the well would be installed completely within the station property boundaries. A 15-foot-wide right-of-way would be required for each of the water line routes; however, the land would typically be returned to previous uses once construction is complete. The water well would result in less environmental impacts as the disturbance would be completely within the Columbus Compressor Station property boundary; however, because each of the three water line routes would result in minor disturbance, is requested by nearby landowners, and would result in landowner access to public water supplies, we conclude that each option (the water lines and private well) would not result in significant impacts on environmental resources.

B.12 CUMULATIVE IMPACTS

In accordance with NEPA, we considered the cumulative impacts of the proposed Project and other projects or actions in the area. Cumulative impacts represent the incremental effects of a proposed action when added to other past, present, or reasonably foreseeable future actions. Cumulative impacts can result from individually minor, but collectively significant, actions taking place in the same general area over a given period of time. The direct and indirect impacts of the Project are discussed in other sections of this EA.

An action must meet the following criteria to be included in the cumulative impacts analysis:  impact a resource area potentially affected by the Project;  cause this impact within all, or part, of the Project area; and  cause this impact within all, or part, of the time span for the potential impact of the Project.

As described throughout this EA, the impacts associated with the proposed Project would primarily be limited to the compressor station sites. The potential for cumulative impacts would be localized, with the exception of air quality. There are no impacts on wetland or waterbodies. Impacts on soil, land use, and other resources would be limited to the permanent impacts within

each compressor station’s boundaries. Therefore, only air quality impacts will be discussed further.

We received several comments regarding other REX projects (see table 10) that could potentially have cumulative impacts with the Zone 3 Capacity Enhancement Project. We analyzed these projects, in addition to the proposed Rover Pipeline Project, below.

Table 10 Projects Considered for Cumulative Impacts Proposed Project Name Description Location Construction Status REX Zone 3 East to West Modification of various aboveground Docket No. CP14-498-000 facilities, including Chandlersville and Hamilton CS, to provide bidirectional Various counties in Under natural gas flow along REX’s Zone 3 OH and IL Construction mainline pipeline. REX Seneca Lateral Project 14.3 miles of 24-inch-diameter lateral Noble and Monroe Docket No. CP13-539 pipeline; a booster compressor Complete station; and measurement facilities. Counties, Ohio REX Seneca Compressor Three compressors (12,250 hp) at the Expansion Project existing Seneca Compressor Station; CP14-194-000 installation of upgraded metering Noble County, Ohio Complete (Section 311) equipment at the existing MarkWest Seneca Processing Plant. ET Rover Pipeline Company Construction of approximately 380 LLC Rover Pipeline Project miles of 36-inch/42-inch diameter Various counties in mainline pipeline, additional Pennsylvania, West January 2016 to horsepower at five new mainline Virginia, Ohio, June 2017 compressor stations, and construction Michigan, Canada of six new delivery meter stations along the mainline pipeline.

The Rover Pipeline Project, if approved, would result in construction of pipeline facilities in various locations in Ohio. However, these facilities are at least 30 miles from the proposed and modified compressor stations associated with the REX Zone 3 Capacity Enhancement Project. Construction emissions from the compressor stations would be localized and would subside once construction is complete. Operational air quality associated with Rover Pipeline Project and the Zone 3 Capacity Enhancement Project could potentially result in cumulative environmental impacts. However, there are no aboveground facilities within 50 miles of the proposed compressor stations associated with the Zone 3 Capacity Enhancement Project. The Rover Pipeline Project would not result in operational emissions and, as such, would not result in a cumulative impact on air quality during operation.

We received several comments regarding REX projects recently before the Commission and their cumulative impacts with the proposed Project. Tables 11, 12, and 13 display the operational emissions associated with the Zone 3 East to West Project, the Seneca Lateral Project, and the Seneca Compressor Expansion Project, respectively.

Table 11 Operational Emissions for the Zone 3 East to West Project Midwestern Edgar NGPL Moultrie Trunkline Douglas Putnam Pollutant Meter Station Meter Station Meter Station Meter Station (tpy) (tpy) (tpy) (tpy)

NOx 16.4 53.3 13.64 9.40 CO 13.7 44.8 11.46 7.90 VOC 0.9 2.9 0.75 0.52 SO2 0.1 0.3 0.08 0.06 PM10 1.2 4.1 1.04 0.72 Total HAPs 0.3 1.3 0.26 0.18 Total CO2e 19,572 63,635 16,293 11,220

Table 12 Seneca Compressor Station PTE Emissions PTE Pollutant (tpy) PM 1.26

SO2 0

NOx 36.02 CO 71.73 VOC 3.95 HAP 2.17

CO2e 14,715

Table 13 PTE Emissions for the Seneca Compressor Station Expansion PTE Pollutant (tpy) PM 2.94

SO2 0

NOx 48.28 CO 14.88 VOC 7.0 HAP 5.12

CO2e 34,674

The REX Zone 3 East to West Project includes modifications to the Chandlersville and Hamilton Compressor Stations to allow for bidirectional natural gas flow. These modifications would result in construction air emissions, but there would be no additional stationary air emissions sources. The Seneca Lateral Project consists of pipeline and a booster compressor station (Seneca Compressor Station). Impacts on air quality would be limited to the construction phase for the pipeline portion of the project. However, the Seneca Compressor Station would result in emissions of criteria pollutants and GHGs during operation. In addition, the compression added to the Seneca Compressor Station under the Seneca Compressor Station Expansion Project would also contribute to any regional cumulative impact on air quality. However, based on the distance between the proposed Project facilities and the Seneca Compressor Station, we do not believe the impact would be significant. Further, the proposed compressor stations, as well as the Seneca Compressor Station, are minor sources of air emissions and would be required to comply with the State of Ohio’s SIP.

We received comments regarding the impacts of induced drilling in the Marcellus shale play as a result of the proposed Project. Commentors assert that the impacts associated with drilling must be fully analyzed because there is a direct (or indirect) correlation with the Project. The development of the Marcellus shale, which is regulated by the states, continues to drive the need for takeaway pipeline capacity to allow the gas to reach markets. Therefore, FERC jurisdictional interstate transmission facilities are being built in response to this new source of gas supply; however, Marcellus shale upstream facilities are outside the scope of this cumulative analysis because the exact location, scale, and timing of future facilities, as they pertain specifically to the proposed action, is unknown.

Climate Change

Climate change is the change in climate over time, whether due to natural variability or as a result of human activity, and cannot be represented by single annual events or individual anomalies. For example, a single large flood event or particularly hot summer are not indications of climate change, while a series of floods or warm years that statistically change the average precipitation or temperature over years or decades may indicate climate change. The Intergovernmental Panel on Climate Change (IPCC) is the leading international, multi-governmental scientific body for the assessment of climate change. The U.S. is a member of the IPCC and participates in the IPCC working groups studying various aspects of climate change. The leading U.S. scientific body on climate change is the U.S. Global Change Research Program (USGCRP). Thirteen federal departments and agencies participate in the USGCRP, mandated by Congress in the Global Change Research Act of 1990. The IPCC and USGCRP have recognized that:

 globally, GHGs have been accumulating in the atmosphere since the beginning of the industrial era (circa 1750);

 combustion of fossil fuels (coal, petroleum, and natural gas), combined with agriculture and clearing of forests, is primarily responsible for the accumulation of GHG;

 anthropogenic GHG emissions are the primary contributing factor to climate change; and

 impacts extend beyond atmospheric climate change alone, and include changes to water resources, transportation, agriculture, ecosystems, and human health. In May 2014, USGCRP released the Third National Climate Assessment, a comprehensive report on climate change and its impacts in the United States. The report describes the effects of global change on different regions of the U.S. and on various societal and environmental sectors, such as water resources, agriculture, energy use, and human health. Although climate change is a global concern, for this analysis, the focus is on the cumulative impacts of climate change in the Project area. The USGCRP’s report notes the following observations and projections of environmental impacts that may be attributed to climate change in the Midwest region:

 between the 2046 to 2065, if GHG emissions continue to increase, a warming of 4.9 °F is projected while warming ranges from about 3.8 °F is projected if global emissions were reduced substantially;

 winter and spring precipitation in the Midwest is projected to increase by 10 to 20 percent by late-century (2071 to 2099) while summer and fall precipitation levels are not expected to see increases outside natural variations;

 the frequency, intensity, and duration of heat waves is expected to increase;

 under the scenario of continued increases in emissions, much of the eastern portion of the region, including Ohio and Indiana, is projected by mid-century to experience up to 20 additional days per year above 95 °F compared to the end of last century. This will affect the region’s vulnerable populations, infrastructure, agriculture, and ecosystems; and

 seasonal drought risk is also projected to increase in summer and fall as higher temperatures lead to greater evaporation and earlier winter and spring snowmelt. GHG emissions associated with operation of the proposed and modified compressor stations are estimated at 882,415 tpy of CO2e, in aggregate. Emission of GHGs from the Project would not have any direct impacts on the environment in the Project area. Currently, there is no standard methodology to determine how the Project’s relatively small incremental contribution to GHGs would translate into physical effects on the global environment. The GHG emissions from the construction and operation of REX’s Project would contribute less than 0.001 percent of the Ohio and Indiana GHG emission inventories. The Project would comply with all EPA GHG regulations, including the Reporting Rule for GHG emissions over 25,000 tpy CO2e. While the Project would represent an incremental increase in GHG emissions, we do not believe it would contribute significantly to climate change. Based on the scope and timing of the proposed Project, the minor air emissions associated with the projects listed in table 10, and each individual project’s compliance with federal air permit requirements, we conclude that the Zone 3 Capacity Enhancement Project would not contribute to a significant cumulative impact on air quality.

C. ALTERNATIVES

In accordance with NEPA and Commission policy, we evaluated alternatives to the Project to determine whether they would be reasonable and environmentally preferable to the proposed action. These alternatives included the no-action alternative and aboveground facility siting alternatives.

The evaluation criteria used for developing and reviewing alternatives were:

 technical and economic feasibility and practicality;  significant environmental advantage over the proposed action; and  ability to meet the Project’s stated objectives (i.e., provide an additional 800 MMcf/d of east-to-west transportation service within Zone 3 of its mainline system).

Information used to evaluate alternatives to the proposed Project included comments and suggestions from regulatory agencies and the public; and data and analyzes provided by REX in its application and supplemental filings.

No-Action Alternative

Under the No-Action Alternative, the Project would not be constructed and the impacts associated with construction and operation would not occur. REX would be unable to provide 800 MMcf/d of natural gas capacity to customers. REX states that the Project would provide the ability to meet contract pressure and capacity obligations and would provide needed system flexibility by allowing east-to-west natural gas transportation. Although it is speculative and beyond the scope of this analysis to predict what action might be taken by end users in response to the No-Action Alternative, it is possible that other natural gas companies could construct projects in substitute for the natural gas supplies offered by REX. Such alternative projects could require the construction of additional and/or new pipeline and compression facilities in the same or other locations to transport the gas volumes proposed by the Project. These projects would result in their own set of specific environmental impacts that could be equal to or greater than those described for the current proposal.

Although pursuing the No-Action Alternative would avoid the environmental impacts associated with the Project’s construction and operation, we have demonstrated in our analysis that these impacts would not be significant and that the Project would be an environmentally acceptable action. We conclude that the No-Action Alternative would not meet the objectives of the proposed action; thus, we are not recommending it.

Aboveground Facility Alternatives

We received numerous comments from landowners regarding alternative sites for the proposed Columbus Compressor Station. We analyzed three additional sites provided by REX. Figure 3 shows the location of the alternative sites.

Figure 3 Alternative Compressor Station Locations: Columbus

Table 14 provides a summary of each alternative’s potential impacts on environmental resources as compared to the proposed site.

Table 14 Columbus Compressor Station Alternatives Analysis

Proposed Site Plazier Road Sitterley Road Pickerington Alternative Alternative Road Alternative 6 NSAs 24 NSAs 8 NSAs 38 NSAs

NSAs within 0.5-mile Closest NSA – Closest NSA – Closest NSA – 1,270 Closest NSA – 1,030 1,570 feet 1,150 feet feet feet

Pipeline Construction No – REX No – REX No – REX No – REX intersects Required intersects site intersects site intersects site site Agricultural Agricultural Land Use Agricultural Agricultural Forest Forest Requirements Water Water 23.4 acres 23.4 acres 23.4 acres 23.4 acres (construction) (construction) (construction) (construction) Land Requirements 9.9 acres 9.9 acres 9.9 acres 9.9 acres (operation) (operation) (operation) (operation) Horsepower Required 49,428 hp 49,428 hp 49,428 hp 49,428 hp N/A – no No wetlands N/A – no wetlands No wetlands Wetland/Waterbody wetlands or 574 feet – Hockling or waterbodies 27 feet – Little Walnut Impacts waterbodies River and present Creek present unnamed tributary

The proposed Columbus Compressor Station site (Ett Noecher Road) and the Plazier, Sitterley Road, and Pickerington Road Alternatives are generally comparable. Construction at the alternative sites, with the exception of Plazier, could result in waterbody impacts that would not be present at the proposed site. The equipment and emissions would be similar at each location. While land use acreages would be equal across the proposed and alternative sites, forested areas would be impacted at the Sitterley and Pickerington Road alternative locations. The presence of forested land use would provide noise benefits if used as a buffer; however, clearing the site of mature trees to install aboveground facilities would negate the noise benefit. Tree removal at the proposed Columbus Compressor Station site would be minimal. Because the equipment would be similar at each location, the noise is anticipated to be similar at nearby NSAs, although variations would be experienced based on topography. The Plazier Road Alternative is the most comparable site to the proposed Ett Noecher Road site; however, the alternative site has 24 NSAs within 0.5 mile, while the proposed site has 6. In all cases, no pipeline installation would be required outside of the site boundaries.

While there are potential benefits (and impacts) to constructing the Columbus Compressor Station at the alternative compressor station sites, none offer a clear environmental benefit over the proposed site. For this reason, and based on our analysis above, these sites are not considered further. With REX’s proposed mitigation measures and our recommendations, we conclude that the proposed site would not result in significant adverse environmental impacts.

To limit environmental impacts, REX has sited facilities within its existing compressor stations to the extent practicable and added additional compression facilities to areas that would minimize overall impacts. We have not identified any issues that would drive the need to identify and evaluate alternative facility locations for the remainder of the facilities, nor were any alternatives suggested during the public scoping period.

In conclusion, we have determined that REX’s proposed Project is the preferred alternative that can meet the Project objectives.

D. STAFF’S CONCLUSION AND RECOMMENDATIONS

Based on the above environmental analysis, the staff has determined that approval of the Project would not constitute a major federal action significantly affecting the quality of the human environment. FERC staff recommends that the Commission Order contain a finding of no significant impact and include the mitigation measures listed below as conditions to any Certificate the Commission may issue to REX.

1. REX shall follow the construction procedures and mitigation measures described in its application and supplements (including responses to staff data requests) and as identified in the EA, unless modified by the Order. REX must:

a. request any modification to these procedures, measures, or conditions in a filing with the Secretary of the Commission (Secretary); b. justify each modification relative to site-specific conditions; c. explain how that modification provides an equal or greater level of environmental protection than the original measure; and d. receive approval in writing from the Director of the Office of Energy Projects (OEP) before using that modification.

2. The Director of OEP has delegated authority to take whatever steps are necessary to ensure the protection of all environmental resources during construction and operation of the project. This authority shall allow:

a. the modification of conditions of the Order; and b. the design and implementation of any additional measures deemed necessary (including stop-work authority) to assure continued compliance with the intent of the environmental conditions as well as the avoidance or mitigation of adverse environmental impact resulting from project construction and operation.

3. Prior to any construction, REX shall file an affirmative statement with the Secretary, certified by a senior company official, that all company personnel, EIs, and contractor personnel will be informed of the EI’s authority and have been or will be trained on the implementation of the environmental mitigation measures appropriate to their jobs before becoming involved with construction and restoration activities.

4. The authorized facility locations shall be as shown in the EA. As soon as they are available, and before the start of construction, REX shall file with the Secretary any revised detailed survey maps/sheets at a scale not smaller than 1:6,000 with station positions for all facilities approved by the Order. All requests for modifications of environmental conditions of the Order or site- specific clearances must be written and must reference locations designated on these maps/sheets.

5. REX shall file with the Secretary detailed maps/sheets and aerial photographs at a scale not smaller than 1:6,000 identifying all facility relocations, and staging areas, pipe storage yards, new access roads, and other areas that would be used or disturbed and have not been previously identified in filings with the Secretary. Approval for each of these areas must be explicitly requested in writing. For each area, the request must include a description of the existing land use/cover type, documentation of landowner approval, whether any cultural resources or federally listed threatened or endangered species would be affected, and whether any other environmentally sensitive areas are within or abutting the area. All areas shall be clearly identified on the maps/sheets/aerial photographs. Each area must be approved in writing by the Director of OEP before construction in or near that area.

This requirement does not apply to extra workspace allowed by the FERC Plan and/or minor field realignments per landowner needs and requirements which do not affect other landowners or sensitive environmental areas such as wetlands.

Examples of alterations requiring approval include all route realignments and facility location changes resulting from:

a. implementation of cultural resources mitigation measures; b. implementation of endangered, threatened, or special concern species mitigation measures; c. recommendations by state regulatory authorities; and d. agreements with individual landowners that affect other landowners or could affect sensitive environmental areas.

6. Within 60 days of the acceptance of the Certificate and before construction begins, REX shall file an Implementation Plan with the Secretary for review and written approval by the Director of OEP. REX must file revisions to the plan as schedules change. The plan shall identify:

a. how REX will implement the construction procedures and mitigation measures described in its application and supplements (including responses to staff data requests), identified in the EA, and required by the Order; b. how REX will incorporate these requirements into the contract bid documents, construction contracts (especially penalty clauses and specifications), and construction drawings so that the mitigation required at the project site is clear to onsite construction and inspection personnel; c. the number of EIs assigned, and how the company will ensure that sufficient personnel are available to implement the environmental mitigation; d. company personnel, including EIs and contractors, who will receive copies of the appropriate material;

e. the location and dates of the environmental compliance training and instructions REX will give to all personnel involved with construction and restoration (initial and refresher training as the project progresses and personnel change); f. the company personnel (if known) and specific portion of REX’s organization having responsibility for compliance; g. the procedures (including use of contract penalties) REX will follow if noncompliance occurs; and h. for each discrete facility, a Gantt or PERT chart (or similar project scheduling diagram), and dates for:

(1) the completion of all required surveys and reports; (2) the environmental compliance training of onsite personnel; (3) the start of construction; and (4) the start and completion of restoration.

7. REX shall employ at least two EIs for the project. The EIs shall be:

a. responsible for monitoring and ensuring compliance with all mitigation measures required by the Order and other grants, permits, certificates, or other authorizing documents; b. responsible for evaluating the construction contractor's implementation of the environmental mitigation measures required in the contract (see condition 6 above) and any other authorizing document; c. empowered to order correction of acts that violate the environmental conditions of the Order, and any other authorizing document; d. responsible for documenting compliance with the environmental conditions of the Order, as well as any environmental conditions/permit requirements imposed by other federal, state, or local agencies; and e. responsible for maintaining status reports.

8. Beginning with the filing of its Implementation Plan, REX shall file updated status reports with the Secretary on a monthly basis until all construction and restoration activities are complete. On request, these status reports will also be provided to other federal and state agencies with permitting responsibilities. Status reports shall include:

a. an update on REX’s efforts to obtain the necessary federal authorizations; b. the construction status of the project, work planned for the following reporting period, and any schedule changes for stream crossings or work in other environmentally sensitive areas; c. a listing of all problems encountered and each instance of noncompliance observed by the EIs during the reporting period (both for the conditions imposed by the Commission and any environmental conditions/permit requirements imposed by other federal, state, or local agencies);

d. a description of the corrective actions implemented in response to all instances of noncompliance, and their cost; e. the effectiveness of all corrective actions implemented; f. a description of any landowner/resident complaints which may relate to compliance with the requirements of the Order, and the measures taken to satisfy their concerns; and g. copies of any correspondence received by REX from other federal, state, or local permitting agencies concerning instances of noncompliance, and REX’s response.

9. Prior to receiving written authorization from the Director of OEP to commence construction of any project facilities, REX shall file with the Secretary documentation that it has received all applicable authorizations required under federal law (or evidence of waiver thereof).

10. REX must receive written authorization from the Director of OEP before placing the project facilities into service. Such authorization will only be granted following a determination that rehabilitation and restoration of the project sites and other areas affected by the project are proceeding satisfactorily.

11. Within 30 days of placing the authorized facilities in service, REX shall file an affirmative statement with the Secretary, certified by a senior company official:

a. that the facilities have been constructed in compliance with all applicable conditions, and that continuing activities will be consistent with all applicable conditions; or b. identifying which of the conditions in the Order REX has complied with or will comply with. This statement shall also identify any areas affected by the project where compliance measures were not properly implemented, if not previously identified in filed status reports, and the reason for noncompliance.

12. REX shall not begin construction activities until:

a. the FERC staff receives comments from the FWS regarding the proposed action; b. the FERC staff completes formal consultation with the FWS, if required; and c. REX has received written notification from the Director of OEP that construction or use of mitigation may begin.

13. REX shall file a noise survey(s) with the Secretary no later than 60 days after placing Washington Court House, Hamilton, St. Paul, and Chandlersville Compressor Stations in service. If a full load condition noise survey is not possible, REX shall provide an interim survey at the maximum possible horsepower load and provide the full load survey within 6 months. If the noise

attributable to the operation of all of the equipment at the Washington Court House, St. Paul, and Chandlersville Compressor Stations under interim or full horsepower load conditions exceeds an Ldn of 55 dBA at any nearby NSAs, REX shall file a report on what changes are needed and shall install the additional noise controls to meet the level within 1 year of the in-service date. REX shall confirm compliance with the above requirement by filing a second noise survey with the Secretary no later than 60 days after it installs the additional noise controls.

14. REX shall make all reasonable efforts to ensure its predicted noise levels from the Columbus Compressor Station are not exceeded at nearby NSAs and file full load noise surveys showing this with the Secretary no later than 60 days after placing the Columbus Compressor Station in service. If a full load condition noise survey is not possible, REX shall provide an interim survey at the maximum possible horsepower load and provide the full load survey within 6 months. If the noise attributable to the operation of the Columbus Compressor Station at full load exceeds an Ldn of 55 dBA at any nearby NSA, REX shall file a report on what changes are needed and shall install additional noise controls to meet the level within 1 year of the in-service date. REX shall confirm compliance with this requirement by filing a second noise survey with the Secretary no later than 60 days after it installs the additional noise controls.

E. REFERENCES

Council on Environmental Quality. 1997. Considering Cumulative Effects Under the National Environmental Policy Act. Available online at http://ceq.hss.doe.gov/nepa/ccenepa/ccenepa.htm

International Right of Way Online. 2011. “The Effects of Natural Gas Pipelines on Residential Value.” Available at: http://www.irwaonline.org/eweb/upload/web_jan_NaturalGas.pdf Accessed July 2015.

Interstate Natural Gas Association of America Foundation. 2001. “Natural Gas Pipeline Impact Study.” Available at: http://www.ingaa.org/Foundation/ Studies/FoundationReports/207.aspx. Accessed July 2105.

Ohio Environmental Protection Agency. Division of Air Pollution Control Rules and Laws. http://www.epa.ohio.gov/dapc/permits/permitdes.aspx#164664910-regulatory-programs. Accessed July 2015.

Ohio Environmental Protection Agency. Division of Air Pollution Control Rules and Laws. http://www.epa.ohio.gov/dapc/DAPCrules.aspx. Accessed July 2015.

U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration. 2014. Distribution, Transmission, and Liquid Accident and Incident Data. Accessed online at: http://www.phmsa.dot.gov/pipeline/library/datastatistics/pipelineincidenttrends.

U.S. Environmental Protection Agency. National Ambient Air Quality Standards. Available online at http://www.epa.gov/air/criteria.html.

U.S. Environmental Protection Agency. Greenbook: Access to Non-attainment Data. Available online at http://www.epa.gov/oar/oaqps/greenbk/.

U.S. Geological Survey. “Ohio Earthquake History” USGS Earthquake Hazard Program. Accessed Online: http://earthquake.usgs.gov/earthquakes/states/ohio/history.php. Accessed July 2015.

U.S. Geological Survey. “Ohio Earthquake History” USGS Earthquake Hazard Program. Accessed Online: http://earthquake.usgs.gov/earthquakes/states/indiana/history.php. Accessed July 2015.

U.S. Global Change Research Program. 2014. U.S. Global Change Research Program, Third National Climate Assessment, http://nca2014.globalchange.gov/downloads. Accessed June 2015.

F. LIST OF PREPARERS

Harris, Jessica – Project Manager – Land Use, Air Quality and Noise, Reliability and Safety, Cumulative Impacts, Alternatives M.S., Energy Policy and Climate, 2015, Johns Hopkins University B.S., Mechanical Engineering, 2006, Clark Atlanta University

Allen, Christine – Surface Waters, Vegetation, Wildlife, Threatened and Endangered Species B.S., Marine Biology, 2005, University of North Carolina at Wilmington

Kopka, Robert – Geology, Soils M.S., Soil Science, 1990, Cornell University B.S., Agronomy, 1987, Delaware Valley College of Science and Agriculture

St. Onge, Ellen – Cultural Resources M.A., Anthropology, 1994, University of Maryland, College Park B.A., Anthropology, 1987, University of Maryland, College Park

Appendix A

Compressor Station and Station Modification Locations

Appendix B

Potential Non-jurisdictional Water Line Routes