FERC National Fuel - Northern Access 2016 Project McKean, PA to Allegany, Cattaraugus, Erie & Niagara 14PR02428

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1 ANDREW M. CUOMO Governor ROSE HARVEY Commissioner June 29, 2015 Mr. Bruce Clark National Fuel 1100 State Street Erie, PA Re: FERC National Fuel - Northern Access 2016 Project McKean, PA to Allegany, Cattaraugus, Erie & Niagara 14PR02428 Dear Mr. Clark: Thank you for requesting the comments of the New York State Historic Preservation Office (SHPO). We have reviewed the Phase IA/IB Archaeology Investigation Report, prepared by Tetra Tech and dated March 2015, in accordance with Section 106 of the National Historic Preservation Act of These comments are those of the SHPO and relate only to Historic/Cultural resources. Based on this review, the SHPO understands that three previously unknown and two previously known Native American archaeological sites were encountered during the 2014 Phase IB archaeological testing and we concur with the below recommendations. Please continue to consult with the Seneca Nation of Indians, the Tonawanda Seneca Nation and the Tuscarora Nation. We do not recommend that Phase II archaeological fieldwork begin until Indian Nation consultation pertaining to this document has been concluded. If the Indian Nations have concerns regarding the Report, we would be pleased to reopen our review of this submission. Site Name Site Number Recommendations Simmons Site Avoidance via Re-Route Buffalo Terrace Site II Avoidance via Re-Route Brown Site Phase II or Re-Route Janiga South Avoidance via Re-Route Janiga North Phase II or Re-Route The SHPO appreciates the opportunity to comment on this document, and we look forward to reviewing the results of the additional Phase IB archaeological testing. Division for Historic Preservation P.O. Box 189, Waterford, New York (518)

2 Sincerely, Nancy Herter Archeology Unit Program Coordinator via only Division for Historic Preservation P.O. Box 189, Waterford, New York (518)

3 ANDREW M. CUOMO Governor ROSE HARVEY Commissioner July 07, 2015 Mr. Bruce Clark National Fuel 1100 State Street Erie, PA Re: FERC National Fuel - Northern Access 2016 Project McKean, PA to Allegany, Cattaraugus, Erie & Niagara 14PR02428 Dear Mr. Clark: Thank you for continuing to consult with the New York State Historic Preservation Office (SHPO). We have reviewed the Phase I Historic Architecture Survey Report, Northern Access 2016 Pipeline Project, prepared by Tetra Tech in February 2015 according to Section 106 of the National Historic Preservation Act of The following comments relate only to above-ground Historic/Cultural resources: - The report (page 8) notes that no historic properties were identified in the 800-foot wide project APE; however, it is unclear if this refers to buildings and structures 50 years and older, or only those determined to be not eligible for listing on the State or National Register of Historic Places (S/NRHP). Please provide a list of all buildings 50 years and older that lie in or adjacent to areas of the APE where above-ground work (e.g., tree clearing, the contractor yard in Hinsdale) is proposed, and provide photographs keyed to a map. - Please provide photographs from the APE to the S/NRHP listed Rider- Hopkins Farm and Olmsted Camp, keyed to a map. - Please continue to consult with our office for portions of the project where landowner restrictions or lack of finalized facility siting have resulted in no historic resources survey coverage to date. Please feel free to contact me if you have any questions. I can be reached at , or via (daria.merwin@parks.ny.gov). Sincerely, Daria Merwin, Survey and Evaluation Unit Division for Historic Preservation P.O. Box 189, Waterford, New York (518)

4 Lare, Sandy From: Sent: To: Cc: Subject: Locking, Bonnie Monday, February 08, :16 PM Lare, Sandy Peltier, Rob FW: SHPO Unrequested Submission Received for Project: 14PR02428 Hi Sandy, This is the Historic Architecture Report submittal on CRIS. Bonnie Locking, M.A., RPA Tetra Tech, Inc. Cultural Resource Services Group Main: Cell: From: New York State Parks CRIS Application Sent: Monday, February 08, :15 PM To: Locking, Bonnie Subject: SHPO Unrequested Submission Received for Project: 14PR02428 This message confirms that the New York State Historic Preservation Office (SHPO) has received submission BKLCT5O2YQMN for project 14PR02428: National Fuel - Northern Access 2016 Project. You will receive an notification when the submission is accepted to the project. You may view information about this project and New York State's historic resources by visiting the Cultural Resource Information System (CRIS) at If you have any questions about CRIS, please contact CRIS Help at CRISHelp@parks.ny.gov. For any other questions, please call SHPO at Sincerely, New York State Historic Preservation Office 1

5 Historic Resources Survey Report Northern Access 2016 Project Erie, Cattaraugus, Allegany, and Niagara Counties, New York February 2016 FERC Docket No. CP (formerly PF ) OPRHP Project No. 14PR02428 Prepared for: National Fuel Gas Supply Corporation and Empire Pipeline, Inc. Prepared by: Robert J. Peltier, M.A., RPA, Principal Investigator and Suzanne Villacorta, Esq. Tetra Tech, Inc. 285 Ellicott Street Buffalo, NY 14203

6 CONTAINS PRIVILEGED INFORMATION DO NOT RELEASE MANAGEMENT SUMMARY Tetra Tech, Inc. s (Tetra Tech) Cultural Resources Group performed an historic resources survey for the proposed Northern Access 2016 Project (Project) from June 2014 through December 2014, on behalf of National Fuel Gas Supply Corporation and Empire Pipeline, Inc. (collectively referred to as National Fuel). Tetra Tech submitted the initial report (14PR02428) to the Office of Parks, Recreation, and Historic Preservation (OPRHP) in February In July 2015, the OPRHP requested additional information and a revised report once all proposed Projects facilities were finalized. Since then, the Project has been finalized and includes several reroutes and modifications. Additional historic resource investigations took place throughout November and December This report addresses the OPRHP s additional data request and includes the survey results for all new Project areas. National Fuel is seeking authorization from the Federal Energy Regulatory Commission (FERC) pursuant to Section 7(c) of the Natural Gas Act (NGA) to construct and operate the proposed Project, which is located in New York and Pennsylvania. The investigation was conducted in accordance with Section 106 of the National Historic Preservation Act (NHPA) and Section of the New York State Parks, Recreation, and Historic Preservation Law of 1980 and their implementing regulations requiring agencies to take into account the effects of their undertakings on historic properties listed in or eligible for listing in the National Register of Historic Places (NRHP). Through this proposed Project, Supply and Empire jointly propose to expand the Supply pipeline system to provide approximately 490,000 dekatherms per day (Dth/d) of new firm natural gas transportation capacity, and the Empire pipeline system to provide approximately 350,000 Dth/d of new firm natural gas transportation capacity. The proposed Project consists of the following Supply components: construction of approximately kilometers (km) (96.49 miles [mi]) of new 24-inchdiameter pipeline (Mainline Pipeline), from Sergeant Township, McKean County, Pennsylvania, to an interconnection with Supply s existing Line X-North, at Supply s existing Porterville Compressor Station in the Town of Elma, Erie County, New York; addition of approximately 5,350 horsepower to Porterville Compressor Station; construction of an interconnection with Tennessee Gas Pipeline s 200 Line in the Town of Wales, Erie County; addition of interconnect/tie-in facilities at the existing Hinsdale Compressor Station (Cattaraugus County), and X-North Pipeline (within the existing Porterville Compressor Station in Erie County); addition of a meter and regulator (M&R)/pressure reduction station at the existing Porterville Compressor Station; addition of 13 mainline valve (MLV) sites (10 of which are in New York); and, cathodic protection facilities (locations to be determined). National Fuel Gas i Historic Resources Survey Report Northern Access 2016 Project February 2016

7 CONTAINS PRIVILEGED INFORMATION DO NOT RELEASE The proposed Project also consists of the following Empire components: construction of a new, approximately 22,214 horsepower compressor station at a new site location on Killian Road, in the Town of Pendleton, Niagara County; construction of a total of approximately 3.33 km (2.07 mi) of pipeline in the Town of Pendleton, Niagara County, comprised of 1) 1.45 km (0.90 mi) of 16-inch pipeline to connect the proposed Pendleton Compressor Station northward to the existing XM-10 pipeline (acquired from Supply) and on to Empire s Line EMP-03 (all to be called EMP-03) and 2) 1.88 km (1.17 mi) of 24-inch pipeline (EMP-12) to connect the Pendleton Compressor Station southward to Supply s existing X-North Pipeline. 1 construction of tie-in facilities at the south end of Line EMP-12, where it will connect to Supply s existing Line X-North; modification of tie-in facilities (including replacement of a 12-inch tap with a 16-inch tap at the north end of EMP-03 where it ties into the Empire (tie-in to Empire Pipeline) construction of a new natural gas dehydration facility on Liberty Drive in the Town of Wheatfield, Niagara County, New York; and, removal of an existing meter and odorizer station on Aiken Road in the Town of Pendleton, Niagara County, with relocation/reuse of certain metering and odorization equipment at the proposed Pendleton Compressor Station. In addition to the proposed aboveground facilities in New York, the proposed Project in New York includes the construction of a total of km (70.72 mi) of proposed pipeline, including approximately km (68.65 mi) of new 24-inch-diameter mainline pipeline, from the Porterville Compressor Station in the Town of Elma, Erie County to the Town of Genesee, Allegany County, where it then crosses into Pennsylvania. In addition, the proposed EMP-03 Pipeline is 3.33 km (2.07 mi), in Niagara County. The proposed construction right-of-way (ROW) corridor for these pipelines is 23 meters (m) wide (75 feet [ft]) wide. In addition, eight pipe and contractor yards will be used temporarily to support construction, including four contractor yards and four pipe yards. Also, a number of access roads will be used either temporarily to support construction, or established permanently to provide access to aboveground facilities (including the new compressor station, interconnects, and MLVs. In addition to the above Project permanent components, the following temporary components are proposed: Buffalo Crushed Stone Contractor Yard (City of Blasdell, Erie County) Hinsdale Contractor Yard (Town of Hinsdale, Cattaraugus County) Holland Contractor Yard (Town of Holland, Erie County) Jamison Fire Company Contractor Yard (Town of Elma, Erie County) Buffalo Crushed Stone Pipe Yard No. 1 (Town of Machias, Cattaraugus County) Buffalo Crushed Stone Pipe Yard No. 2 (Town of Machias, Cattaraugus County) Blasdell-Metalico Pipe Yard (City of Blasdell, Erie County) Inducon Pipe Yard (Town of Wheatfield, Niagara County) 1 Note: Replacing 3.05 miles of existing 16-inch Supply pipeline with 24-inch pipeline (formerly called Replacement Pipeline in previous filings) is no longer necessary or proposed, due to the new location selected for the proposed Pendleton Compressor Station. National Fuel Gas ii Historic Resources Survey Report Northern Access 2016 Project February 2016

8 CONTAINS PRIVILEGED INFORMATION DO NOT RELEASE Background research, online site files, and historic properties inventories searches were conducted for the Project Area. A review of site files available at the OPRHP, as well as the online database of the NRHP, determined that there were no historic properties listed in or eligible for listing in the NRHP within or immediately adjacent to the Project. The NRHP Rider-Hopkins Farm and Olmsted Camp is located approximately 61 m (200 ft) east of the Project. No other previously recorded historic structures, buildings, or districts are located within 122 m (400 ft) of the Project Area. The purpose of the study was to assess the potential impact of the proposed Project to historic resources within its Area of Potential Effect (APE). Typically, the APE for historic resources includes the geographic area or areas within which the undertaking may directly or indirectly cause changes in the character of, or use of, historic properties, if any such properties exist. The APE for the Project includes all areas from which there exists a view to or from the proposed Project ROW for the pipeline corridor, aboveground Project facilities, temporary workspace, additional temporary workspace (ATWS) areas access roads, staging areas, and contractor and pipe yards. The historic resources survey for the Project was conducted following the Secretary of the Interior's Standards and Guidelines for Archeology and Historic Preservation (48 Federal Register [FR] , September 29, 1983), the National Historic Preservation Act of 1966, as amended, Executive Order 11593, the regulations of the Advisory Council on Historic Preservation (36 Code of Federal Regulations [CFR] 800), Section of the New York State Parks, Recreation and Historic Preservation Law of 1980, the New York Archaeological Council s (NYAC) Standards for Cultural Resource Investigations and Curation of Collections (NYAC 1994), and Phase I Cultural Resource Investigation Guidance for Utility Corridors (OPRHP n/d). The survey included a visual assessment, site walkover, and photographic documentation of the entire Project APE. Investigations identified 31 previously undocumented properties 50 years or older within or immediately adjacent to the APE. Based on the results of this survey, no adverse effects on historic properties are anticipated for the Project as a result of construction and maintenance activities. A finding of no adverse indirect or direct effects on historic properties within the APE is recommended for the proposed Project. No additional historic resource investigations are recommended for the Northern Access 2016 Project. National Fuel Gas iii Historic Resources Survey Report Northern Access 2016 Project February 2016

9 CONTAINS PRIVILEGED INFORMATION DO NOT RELEASE TABLE OF CONTENTS SECTION PAGE MANAGEMENT SUMMARY... i 1.0 INTRODUCTION PROJECT DESCRIPTION DEFINITION OF THE AREA OF POTENTIAL EFFECT INVESTIGATION METHODOLOGY RECORDS SEARCH AND PREVIOUSLY IDENTIFIED HISTORIC RESOURCES RESULTS AND RECOMMENDATIONS REFERENCES LIST OF TABLES SECTION PAGE Table 1. Northern Access 2016 Aboveground Facilities... 3 Table 2. Properties Over 50 Years of Age Identified Within or Adjacent to the APE ATTACHMENT Attachment A (Sheets 1-24) Attachment B (Sheets 1-110) Attachment C Attachment D LIST OF ATTACHMENTS SITE LOCATION MAP USGS TOPOGRAPHIC QUADRANGLES PROJECT LOCATION SHOWN ON CURRENT AERIALS PHOTOGRAPHIC RECORD CONCEPTUAL DRAWINGS FOR THE PENDLETON STATION National Fuel Gas iv Historic Resources Survey Report Northern Access 2016 Project February 2016

10 Lare, Sandy From: Sent: To: Subject: Locking, Bonnie Monday, February 08, :08 PM Lare, Sandy FW: SHPO Unrequested Submission Received for Project: 14PR02428 Hi Sandy, Below is the receipt of the addendum NY archaeology report. As you can see in the addresses, Bruce was also notified of its upload. Bonnie Locking, M.A., RPA Tetra Tech, Inc. Cultural Resource Services Group Main: Cell: From: New York State Parks CRIS Application Sent: Monday, February 08, :35 PM To: Locking, Bonnie Subject: SHPO Unrequested Submission Received for Project: 14PR02428 This message confirms that the New York State Historic Preservation Office (SHPO) has received submission 2HTKLHULBIBR for project 14PR02428: National Fuel - Northern Access 2016 Project. You will receive an notification when the submission is accepted to the project. You may view information about this project and New York State's historic resources by visiting the Cultural Resource Information System (CRIS) at If you have any questions about CRIS, please contact CRIS Help at CRISHelp@parks.ny.gov. For any other questions, please call SHPO at Sincerely, New York State Historic Preservation Office 1

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12 CONTAINS PRIVILEDGED INFORMATION DO NOT RELEASE MANAGEMENT SUMMARY SHPO Project Review Number (if available): 14PR02428 Involved State and Federal Agencies (DEC, CORPS, FHWA, etc.): FERC, USACE, DEC Phase of Survey: I Location Information Minor Civil Division: County: Genesee, Clarksville, Portville, Hindsdale, Ischua, Humphrey, Franklinville, Machais, Yorkshire, Sardina, Colden, Aurora, Wales, Marilla, Elma, Wheatfield, Pendleton Allegany, Cattaraugus, Erie, and Niagara Survey Area (Metric and English) Length: 45.7 km (28.4 mi) Depth (when appropriate): Not applicable Number of Acres Surveyed: Number of Square Meters and Feet Excavated (Phase II, Phase III only): Not applicable Percentage of the Site Excavated (Phase II, Phase III only): Not applicable USGS 7.5-Minute Quadrangle Map: Tonawanda East, Tonawanda West, East Aurora, Holland, Sardinia, Arcade, Delevan, West Valley, Franklinville, Hinsdale, Cuba, Portville Archaeological Survey Overview Number and Interval of Shovel Tests: 6,795 ST; 50 feet (15 m) interval Number and Size of Units: Not applicable Width of Plowed Strips: Not applicable Surface Survey Transect Interval: feet (3 to 5 meter) Results of Archaeological Survey Number and name of prehistoric sites identified: Porterville Site Number and name of historic sites identified: 0 Number and name of sites recommended for Phase II/Avoidance: Porterville Site Report Author(s): Bonnie L. Locking, M.A., Scott Padamonsky, Mark Karpinsky Date of Report: February 2016

13 CONTAINS PRIVILEDGED INFORMATION DO NOT RELEASE TABLE OF CONTENTS SECTION PAGE 1.0 INTRODUCTION ORGANIZATION OF REPORT PROJECT DESCRIPTION DEFINITION OF THE AREA OF POTENTIAL EFFECT ACKNOWLEDGEMENTS ARCHAEOLOGICAL FIELD INVESTIGATIONS METHODOLOGY RESULTS Porterville 1 Site NFG-NA-ER-915 Isolate 1 - Prehistoric Prehistoric Isolate NFG-NA-AL-260 Isolate 1 Prehistoric Hinsdale Yard Prehistoric Isolates Hinsdale Yard Prehistoric Site Brown Site ( ) REFERENCES CITED LIST OF TABLES TABLE PAGE Table Northern Access Phase I Archaeological Investigation Summary... 7 Table Artifact Inventory for the Porterville Site Table Artifact Inventory for the Hinsdale Yard Site Loci Table Archaeological Investigations Summary LIST OF FIGURES FIGURE PAGE Figure 1. Phase 1 Archaeological Investigation at the Porterville Site, Erie County, New York Figure 2. Phase 1 Archaeological Investigation at the Hinsdale Site, Cattaraugus County, New York Figure 3. Phase 1 and 2 Archaeological Investigation at the Brown Site ( ), Cattaraugus County, New York Tetra Tech, Inc. v Addendum Phase I Archaeological Investigations Report Cultural Resources Services Group Northern Access 2016 Project

14 CONTAINS PRIVILEDGED INFORMATION DO NOT RELEASE LIST OF ATTACHMENTS ATTACHMENT Appendix A Appendix B Appendix C Appendix D DESCRIPTION Project Maps Photographic Record Shovel Test Record Artifact Catalogue Tetra Tech, Inc. vi Addendum Phase I Archaeological Investigations Report Cultural Resources Services Group Northern Access 2016 Project

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16 ANDREW M. CUOMO Governor ROSE HARVEY Commissioner February 24, 2016 Mr. Bruce Clark National Fuel 1100 State Street Erie, PA Re: FERC National Fuel - Northern Access 2016 Project Brown Site Revised Alignment 14PR02428 Dear Mr. Clark: Thank you for requesting the comments of the New York State Historic Preservation Office (SHPO). We have reviewed the Brown Precontact Site ( ) Alignment Change in accordance with Section 106 of the National Historic Preservation Act of These comments are those of the SHPO and relate only to Historic/Cultural resources. Given the minor nature of the alignment change and the use of matting to reduce ground disturbance, the SHPO has no cultural resource concerns and does not recommend any additional archaeological survey work. If you have any questions, I can be reached at (518) Sincerely, Nancy Herter Archeology Unit Program Coordinator nancy.herter@parks.ny.gov via only Division for Historic Preservation P.O. Box 189, Waterford, New York (518)

17 See Inset 1 k Cr Inset 2 e ek a ovi n ze Blasdell-Metalico Pipe Yard (Temporary Use) Cr Buffalo Creek E Branch Ca ff a lo Riv er Lake Erie Bu _Buffalo ^ Proposed Wheatfield Dehydration Facility Genesee CANADA Bu ll ee Inducon Pipe Yard Orleans (Temporary Use) Inset 1 Niagara See Inset 2 Wyoming Erie reek sc raugu Catta Isc Cattaraugus hu a Cr _Bradford ^ R iv er k ny Be l ls NEW YORK PENNSYLVANIA Canada Lake Ontario LEGEND NA 2016 Project Facilities Lake Erie Coastal Zone PA Source: ESRI Street Map. NYS Department of State Coastal Boundary, wa yo C re e k Coastal Zones Near Northern Access 2016 Project Legend NY Os Miles 10 E Prepared For: Prepared By: Date: Date: 12/22/2015 G:\GIS_files\NorthernFuel\mxd\permitting\CoastalZones.mxd Br oo k Ol ea Do dg n e Cr «ghe k ee 17 l Oi ee Cr «Cr A ll e k ee k uqua ee Alleg

18 CONTACT REPORT TO: Sandy Lare FROM: Rachel Silva DATE: 12/23/2015 TT FILE/ PROJECT: 112C06774 Northern Access 2016 CONTACT: Kaitlyn Smith TITLE: Coastal Resources Specialist AFFILIATION: ADDRESS: CC: SUMMARY: NYS Department of State Coastal Management Program Consistency Review Unit, Office of Planning & Development 99 Washington Avenue One Commerce Plaza Suite 1010 Albany, NY PHONE: (518) SUBJECT: Coastal Zone Consistency for Blasdell Pipeyard Ms. Silva spoke with Ms. Smith to inquire about the required formal process for Coastal Consistency Review of the Blasdell Pipeyard. Ms. Silva shared that the pipe yard is part of a larger pipeline project, of which no permanent facilities are located within the coastal zone. Furthermore, the Blasdell Pipeyard is currently industrial and will have no new permanent structures. No structures of any kind will be built on the site; only construction trailers will be there during the temporary duration of construction. Ms. Smith confirmed that because the project requires a federal permit, and since a portion (even temporary) is located within the coastal zone, the applicant will need to fill out a Federal Consistency Assessment Form (FCAF), in addition to submitting the Joint Permit Application in its entirety (with maps and basic project analysis) to the NYSDOS Coastal Management Program. Within the FCAF is a coastal policy analysis that certifies that the project is consistent with the Coastal Policies. Ms. Smith followed up with an providing a copy of both the FCAS and the Coastal Policies. 12/29/15 UPDATE: Ms. Silva spoke with Ms. Smith on Tuesday, December 29, 2015 with additional questions about requirements for the Coastal Consistency Review. Ms. Smith confirmed that even if the project activity that is within the coastal zone is outside of the Local Waterfront Revitalization Plan (LWRP) boundary, the Coastal Consistency Review request still needs to be submitted to the NYSDOS Coastal Management Program. The only difference is that if the project activity

19 were located within the LWRP, the project would need to be in concurrence with that specific LWRP policies, instead of the state-wide policies. Furthermore, the Consistency determination of NYSDOS is not contingent upon receipt of permits from other agencies such as NYSDEC or USACE permits for streams and wetlands. NYSDOS will issue the Consistency Assessment determination independently of all other permits. Ms. Smith said that the NYSDOS Coastal Management Program office can take up to 6 months to review the request, but typical duration is between days. ACTION ITEMS: At National Fuel s direction, Tetra Tech will complete FCAF and submit to NYS Coastal Management Program along with a complete copy of the Joint Permit Application to the address Ms. Smith provided via Denise Caldwell One Commerce Plaza 99 Washington Ave, Suite 1010 Albany, NY 12210

20 FERC PDF (Unofficial) 1/8/2016 5:18:59 PM Northern Access 2016 Project Docket No. CP , 001 National Fuel Response to National Park Service Letter to FERC Dated November 24, 2015 On November 24, 2015, the National Park Service (NPS) submitted a letter to the Federal Energy Regulatory Commission (FERC) referencing the Northern Access 2016 Project (Project) crossing of the North Country National Scenic Trail (NST) in Cattaraugus County, New York. In the letter, the NPS expresses concern regarding mitigation and restoration measures for the trail. Since receipt of that letter, National Fuel s consultant, Tetra Tech, has been in contact via telephone and communications with Mark Weaver, Manager, and Chris Loudenslager, Trail Planner, both of the North Country National Scenic Trail office in Lowell, Michigan. On December 10, 2015, Mr. Loudenslager provided Tetra Tech with a map via that identifies the proposed Project Mainline Pipeline route in relation to the North Country NST and indicates portions where the trail is certified. From this map and communication with Mr. Loudenslager, it appears as though the section of North Country NST where the Project crosses is certified (see attached maps). Mr. Loudenslager indicated that certified trail is trail that is considered done, permanent, and protected, and therefore, afforded the greatest level of protection. As such, their priorities are to protect the trail from any disturbance that modifies its current character or user experience to the greatest extent possible. Part of their response will require coordination with Bear Creek State Forest, as this entity (New York State Department of Environmental Conservation, Division of Lands and Forests) is the managing authority and owner of the parcel. Mr. Loudenslager will consult with Bear Creek State Forest to identify the types of restorative vegetation most appropriate for this site and will provide that information to Tetra Tech. He also indicated that the trail head parking area on the western portion of the Project should be restored to its original condition or improved upon. Mr. Loudenslager also requested coordination with his office on woody revegetation following construction as well as long-term maintenance and inspection needs for the ROW. Mr. Loudenslager indicated that, in addition to coordinating with Bear Creek State Forest, he will also be coordinating with their partnering organizations, the Finger Lakes Trail Association and the North Country Trail Association, but that these offices will be unavailable to collaborate on the issue of the Project crossing of the North Country NST until after the New Year holiday. As such, coordination with the North Country NST and NPS is ongoing and Tetra Tech will provide further more substantive information in January Maps showing the proposed pipeline in relation to the North Country NCT, and photos showing where the Project crosses the North Country NST from various vantage points on either side of the existing utility ROW are provided on the following sheets. Response Prepared By: Sandy Lare Tetra Tech, Inc.

21 Northern Access 2016 Project Docket No. CP , 001 National Fuel Response to National Park Service Letter to FERC Dated November 24, 2015

22 Northern Access 2016 Project Docket No. CP , 001 National Fuel Response to National Park Service Letter to FERC Dated November 24, 2015

23 FERC PDF (Unofficial) 1/8/2016 5:18:59 PM PHOTOGRAPHIC LOG Company: National Fuel Gas Supply Corporation and Empire Pipeline, Inc. Project: Northern Access 2016 Project Photographer: Photos 1 5: Hatch Mott MacDonald; Photos 6 7: Tetra Tech Date: December 4, 2015 Photo No: Direction: 1 East Comments: East side of existing utility ROW on North Country National Scenic Trail Photo No.: Direction: 2 West Comments: East side of North Country National Scenic Trail Photo 3 Comments: East side of Photo No: 4 Comments: West side No.: existing utility ROW on of existing utility ROW Direction: East North Country National Scenic Trail Direction: West on North Country National Scenic Trail 4 P a g e

24 FERC PDF (Unofficial) 1/8/2016 5:18:59 PM PHOTOGRAPHIC LOG Company: National Fuel Gas Supply Corporation and Empire Pipeline, Inc. Project: Northern Access 2016 Project Photographer: Photos 1 5: Hatch Mott MacDonald; Photos 6 7: Tetra Tech Date: December 4, 2015 Photo No: Direction: 5 West Comments: West side of existing utility ROW on North Country National Scenic Trail Photo No.: Direction: 6 North Comments: Powerline corridor on Bear Creek State Park property, about 0.47 mile north of NCT trail crossing (Wetland 289a). Photo No.: 7 Direction: North Comments: Powerline corridor on Bear Creek State Park property, about 0.09 mile south of NCT trail crossing (Wetland 291a). 5 P a g e