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Constitution Pipeline, LLC, subsidiary of Williams Companies
Filed with FERC for reissuance of Certificate and waiver for 401 Water Quality Certificate from NY. Memo also filed notifying FERC of intent of Iroquios pipeline to file for reissuance of Certificate for Wright Interconnect Project

FERC Dockets:
CP13-499-006 – Petition for reissuance of Constitution Pipeline Certificate for Public Convenience and Necessity. The certificate includes Constitution Pipeline, Wright Interconnect Project (WIP), and two blanket authorization certificates.
Memo about Iroquois Wright Interconnect Project‘s plan to file for the joint WIP project.
CP18-5-004 – Petition for Declaratory Order that NYSDEC waived 401WQC for Constitution.

Williams Co.’s subsidiary, Constitution Pipeline, LLC filed its application in sub-dockets under the original 2013 and 2018 docket numbers, asking FERC for a reissuance of the previously granted Certificate, and a waiver of the NY Dept. of Environmental Conservation (NYDEC) 401 Water Quality Certificate. Unlike the also revived Williams’ Northeast Supply Enhancement (NESE) project, the FERC Certificate for Constitution was vacated.

Constitution has also filed a memo notifying FERC of Iroquois Pipeline’s intention to re-file an application for the reissuance of the Certificate for the Wright Interconnect Project, a joint project connected to the end of the Constitution Pipeline.

Petitioning for a reissuance of a previously granted and Court of Appeals vacated Certificate, if granted by FERC, could drastically cut the opportunities for public input over a new application. It’s likely there would only be a swift comment period and no public hearings, once the petition is Noticed by FERC.


DESCRIPTION:
Pipeline
– 124.77 miles of 30” diameter pipeline
– Maximum allowable operating pressure (MAOP) 1,480 pounds per square inch gauge (psig)
(Potential Impact Radius approx. 796 ft.)
– 650,000 dekatherms a day (Dth/d) capacity

Meter & Regulation Stations (M&R) and Main Line Valves (MLV)
2 Meter & Regulation Stations (M&R)
– Turnpike Road M&R Receipt Station, including Pig Launcher, Kickoff MLV; Brooklyn, PA
– Westfall Road M&R Delivery Station, including Pig Receiver, MLV terminus; Wright, NY

9 additional MLVs between M&R Stations
Locations:
Jackson PA, Sanford (2), Masonville, Franklin, Davenport, Summit, Richmondville & Schoharie, NY
*Table 1.2-1, Att. I, p. 10-11

Interconnections:
– Tennessee Gas Pipeline (TGP) 200 line in PA, at start of the Constitution pipeline
– Tennessee Gas Pipeline (TGP) 300 line in NY, at end of the Constitution pipeline
– Iroquois Gas Transmission System (IGTS) in NY, at the end of the Constitution pipeline, at the proposed Wright Interconnect Project


» You can view the filed application documents online here or download them from the FERC eLibrary (Search Dockets CP13-499, CP18-5).

Any questions concerning this application may be directed to:
Constitution Pipeline Company, LLC
PO Box 1396, Houston, Texas 77251
(888) 275-9084
email
outreach@williams.com.

The exact legal name of Constitution’s owners is:
Constitution Pipeline Company, LLC,
2800 Post Oak Boulevard, Houston, Texas 77056-6106.
wholly owned, indirect subsidiary of The Williams Companies, Inc (“Williams”)


LANDOWNER NOTIFICATION AND STAKEHOLDER OUTREACH (Att. I, Pg. 24)
Materials to be provided to landowners:

  • Project location map
  • Copy of the Notice of Petition to be issued by FERC
  • List of libraries where public may review a full copy of the Petition materials
  • FERC pamphlet “An Interstate Natural Gas Facility on My Land? What Do I Need to Know?”

Notifications will be mailed to landowners in the following categories:

  • Property directly affected
  • Property abuts either side of an existing right of way (ROW) or facility site, or contains a residence within 50 feet of the proposed construction work area
  • Property is within one-half mile of proposed compressors of their enclosures

Landowners have the right to participate in comment periods to be specified in the Notice of Petition to be filed by FERC.
“The comment should be mailed to: Debbie-Anne A. Reese, Secretary, Federal Energy Regulatory Commission, 888 First Street N.E., Washington, DC 20426 or by hand or by other delivery method to the attention of Ms. Reese at 12225 Wilkins Avenue, Rockville, Maryland 20852. Landowners may also comment on the record at the e-filing link at www.ferc.gov. Also, copies of comments can be mailed to Constitution Pipeline Company, LLC, PO Box 448, Kinderhook, New York 12106.”*


ASSERTIONS MADE IN THE APPLICATION: (Petition, starting p. 15)
• “The Project Will Deliver up to $8.5 Billion in Savings to Consumers During Its First 15 Years in Service
• “The Project Is Needed to Improve Reliability and Resilience of the Natural Gas and Electric Systems in the Northeast”
• “The Project Would Supply Natural Gas to Electric Generators That Are Unable to Enter into Long-Term Agreements for Firm Capacity on Natural Gas Pipelines”
• “The Project Would Facilitate Conversion from Heating Oil to Natural Gas for Heating, Thereby Reducing Emissions Intensity”
• “Customers, Existing Pipelines, Landowners, and Other Stakeholders”
• “The Public Benefits of the Project Outweigh Any Potential Adverse Effects”

In the VII. Environmental Impacts section of the Petition (p. 40), Williams cites use of NextGen Gas systems to track “wellhead-to-delivery point” emissions intensity.

COUNTER-ARGUMENTS
• It’s worth noting that this anticipated surge in gas use runs counter to climate policies throughout the Northeast. The shifting political dynamics of funds for large offshore wind projects being withdrawn has put pressure on the region’s governors to accept additional gas expansion. » More info under “Shifting Landscape” subheader

• It’s also worth noting that though expansions to existing pipeline systems, gas capacity to the region has expanded by over 50% since 2014 (Source: Acadia Center via WBUR), yet prices have continued to spike. More gas is not the answer to price hikes.

• There’s also the fact that Williams is trying to revive two FERC orders that were vacated by the US Court of Appeals for the Second Circuit. FERC *should* address this fact before just blindly reissuing the Certificate and Declaratory Order against NY DEC’s denial of the 401 Water Quality Certificate. Will FERC step up to the plate? We’ll see.


The application documents filed consist of:
The Petition which is a 108 page application containing their description of need for the project and summary overviews of environmental and procedural issues described in more depth in Attachment I.


Attachment F (9 documents) which has construction plans on aerial imagery showing the pipeline route, temporary work zones, wetlands delineations, etc.


Attachment which G (15 documents) has aerial imagery comparisons between 2014 and 2025

Attachment I, the Environmental Consistency Summary, which has detailed project descriptions (table of contents starting on p. 2)

Memo filed to alert FERC to the intent of Iroquois pipeline to file an application for the Wright Interconnection for certificate reissuance. FERC Docket CP13-502