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Supplemental to Statement made at FERC Scoping Meeting, Oct 24, 2012, in Oneonta, NY as presented to FERC 10/24/2012 by Kimberly Merenz

My name is Kimberly Merenz. I live in Richmondville, NY, and work for the US Department of Agriculture. My statements are not related to my official position as a Federal Officer, and are not the official position of the US Department of Agriculture.

I would ask that the Committee consider the soils and the water management for the planned Constitution Pipeline Project. The proposed route R will pass within 600 feet of my property and I have analyzed 1 mile of that nearby route.

Proposed route R would be buried in soils that are predominantly Volusia channery silt loam 8 to 15 percent slopes, Mardin channery silt loam 15 to 25 percent slopes, Lordstown and Oquaga very stony soils 0 to 35 percent slopes, Lordstown channery silt loam 15 to 25 percent slopes, and Chippewa and Norwich stony silt loams 3 to 15 percent slopes.

The suitability rating in these soils for shallow excavations, dug to a depth of 5 or 6 feet, is very limited, and unfavorable for the type of trenching that a 30 inch pipeline would require, and the limitations generally cannot be overcome without major soil reclamation, special design or expensive installation procedures, with poor performance and high maintenance expected.

Storm water management in these soils is rated as the most limited, indicating that the soil has one or more features that are unfavorable for design, construction and performance of storm water management wetlands, with poor performance and high maintenance expected.

Storm water infiltration in these soils is rated as the most limiting, indicating that the soils are not favorable for infiltration practices, and there will be poor performance, high maintenance, and a greater potential for ground water contamination.

The depth to the hard bedrock and cemented pan is less than 70 centimeters in about 40 percent of this area, and occurs mainly up slope of the residential area. Any trenching in this area would likely result in ground water contamination. The elevation in this area goes from 1200 to 1800 feet within 1 mile, with the depth to the soil restrictive layer the most shallow at the highest elevation.

The depth to the water table in this area is 0 to 46 centimeters, with numerous seeps exiting the ground where the lithic bedrock has penetrated the soil surface. The water table in this area is very susceptible to surface contamination. The residents in this area rely on this water table to recharge their well water and provide inputs to ponds and wetlands.

The frost action in this area is rated as moderate to high. The potential for upward and lateral expansion of the soil is likely, with frost heaving and low soil strength during thawing, which will cause damage to rigid structures. I have recorded temperatures of -­‐20 degrees Fahrenheit in the winter.

Many of the soil types in this area also present a moderate to high risk of corrosion. Special site examination is needed to determine if any combination of factors would result in a severe hazard of corrosion. The proposed route for this pipeline would cross many soil layers increasing the susceptibility to corrosion.

This soil information is based on publicly available data from the USDA Natural Resource Conservation Service Web Soil Survey.

I would also ask that the entire length of each proposed route be analyzed not only for soil and water management, but serious consideration be given to the numerous minor geological faults in which any proposed route would cross, and the likely damage to rigid pipelines from earthquakes. This area of New York has seen earthquakes up to 4.1 in magnitude and many are very shallow. The US Geological Survey has recorded 19 minor earthquakes over the past 5 years within an 18 kilometer radius* of the proposed Wright compressor station. (* Correction to public statement)

I would also ask that a complete survey be conducted for the Indiana Bat, which is a federally listed endangered species in Schoharie County, and for the following aquatic species of special concern in New York state: the Eastern Hellbender, Cryptobranchus alleganiensis (Daudin, 1803), which are experiencing decline in populations due to degradation of habitat; the Marbled Salamander, Ambystoma opacum (Gravenhorst, 1807), which is vulnerable to destruction and degradation through draining and filling, resulting in isolation by habitat fragmentation, and could eventually result in deleterious levels of inbreeding and reduced chances of re-establishment of locally extirpated populations; the Jefferson Salamander, Ambystoma jeffersonianum (Green, 1827), which is vulnerable to detrimental alteration of vernal pool breeding sites; the Blue-spotted Salamander, Ambystoma laterale (Hallowell, 1856); the Longtail Salamander, Eurycea longicauda (Green 1818); the Eastern Spadefoot Toad, Scaphiopus holbrookii (Harlan, 1835), which is negatively impacted by pesticide use in conjunction with forest pest management; and the Southern Leopard Frog Lithobates sphenocephalus (Cope , 1889); as well as any other endangered, threatened, or species of special concern to New York and Pennsylvania, as any occurrence of these species must be delimited and documented in order to determine the potential impacts to their limited populations. The biological surveys conducted by the Constitution Pipeline company in the summer of 2012 were not adequate, as many of the properties that the proposed routes might cross were not surveyed due to landowners not providing access. Also, it is not possible to conduct environmental inventories of species if they are not likely to be observed. I would ask that the surveys for any species of concern be conducted during the period of the life cycle and the circadian rhythm in which they are likely to be observed. Nocturnal amphibians are not likely to be observed during daylight business hours.

In addition, the Constitution Pipeline company has stated that, ‘Property owners directly affected by the Project will be compensated through the purchase of the land rights needed by Constitution.’ I would ask that consideration be given to all properties, those both directly and indirectly affected by placement of a 30 inch pipeline on or near their property.

Finally, I would ask that we remember that our ancestors came to this country for their freedom, and fought and died for our freedom to speak. When we deny even one of our neighbors their freedom to speak we dishonor all those who have died for that freedom. May you and all beings be happy and free from suffering.

Thank you.

Sources:
http://neic.usgs.gov
http://www.dec.ny.gov/animals/7494.html
http://websoilsurvey.nrcs.usda.gov/app/HomePage.htm
http://www.iucnredlist.org