READ. ANDLANIADO, LLP ATTORNEYSATLAW, 25 EAGLE: STREET ALBANY, NEW YORK 12207-1901 (518) 465-93131 MAIN (518)4 465-93151 FAX www.readlaniado.com KEVINI R.I BROCKS DAVIDI B.J JOHNSON SAMM.LANIADO KONSTANTIN PODOLNY HOWARDJ. READ PATRICK: A. SILER Of Counsel Via Electronic Delivery or Overnight Mail September 14, 2015 Hon. Kathleen H. Burgess Secretary Empire State Plaza Agency Building 3 Albany, New York 12223-1350 New York State Public Service Commission Re: CASE 13-T-0538 - Application of Williams Field Services Company, LLC and DMP New York, Inc. For a Certificate of Environmental Compatibility and Public Need to Construct an Approximately 9.5-Mile Natural Gas Gathering Pipeline in the Town of CASE 10-T-0350 - Joint Petition ofDMP New York, Inc. and Laser Northeast Gathering Company, LLC to Amend the Certificate in 10-T-0350 (July 25, 2012) to add two Windsor, Broome County, State ofl New York. compressor units. Dear Secretary Burgess: Williams Field Services Company, LLC and DMP New York, Inc. (collectively, "Williams"), has received the New York State Department of Environmental Conservation ("NYSDEC") comments on the proposed New York ("NY") Mainline Loop Pipeline Project ("Project") and certificate conditions, dated September 4, 2015, regarding Case 13-T-0538. The NYSDEC letter also requested the certificate to clarify the relationship between Case 13-T-0538 and Case 10-1-0350. For ease of review, we have provided the NYSDEC's comments in italicized font followed by Williams' response. Hon. Kathleen H. Burgess September 14, 2015 Page 2of3 Comment 1: With regard to temporary culverts, flows should be calculated based onj flows Response 1: Williams will ensure that temporary culverts are sized appropriately based on site associated with recent flooding events. conditions, expected flows and recent flooding events. Comment 2: A condition should be added that the Trowbridge Creek shall be crossed using HDD. Comment 2: Williams accepts this certificate condition addition. Comment 3: A condition should be added regarding use of herbicides along the ROW indicating that they are subject to 6 NYCRR Part 325, including all New York pesticide label restrictions. Comment 3: Williams does not use herbicides as part of its standard operating procedures for ROW maintenance and, therefore, does not plan on using herbicides along the ROW at this time. As such, Williams accepts this certificate condition addition and will adhere to 6 NYCRR Part 325, including all NY pesticide label restrictions should herbicides be used. Comment 4: Proposed Condition 11: Include DEC staff. from Region 7 in the consultation Comment 4: Although blasting is not anticipated, Williams accepts this certificate condition meeting on blasting activity proposed. language modification. Comment. 5: Proposed conditions 13 and 30: The crossing methods for streams and wetland Comment 5: Tables 1 and 2 of the Application identifies the proposed crossing method for should be specified in the Plan and Profile drawings. streams and wetlands, respectively. Williams will append these tables to the Erosion and Sediment Control Drawings. Comment 6: Proposed Condition 19: The Natural Heritage Database is constantly updated. Accordingly, a new search of the Natural Heritage Database should be performed ifthe results from the proceeding search are over one year old. Comment 6: Williams will update its search oft the Natural Heritage Database. Comment 7: Proposed Condition 36: For clarification, DEC proposes the following: "Applicant shall maintain a minimum burial depth of not less than 10 feet 2 Hon. Kathleen H. Burgess September 14, 2015 Page 30 of3 between the natural stream bed bottom and the top of the bore hole when crossing under Trowbridge Creek. " Comment 7: Williams accepts this certificate condition language: modification. Comment 8: Proposed Condition 39: Delete and replace with "Erosion control measures shall be inj place and maintained in accordance with the SWPPP and the SPDES GP. " Comment 8: Williams accepts this certificate condition language change. Comment 9: In the certificate, the Commission should clarify whether the certification of the gas transmission line is being segmented, from its review oft the amendment to the certificate for the Dunbar compressor facility to add two turbine compressor units, or whether the gas transmission line has independent utility and can be operated independent of the Dunbar additional turbines. Comment 9: Although this comment is directed to the Staff and/or the Commission, it is Williams understanding that the two applications are being reviewed together. All correspondence or questions concerning the Application (Case 13-T-0538) and Case 10-T-0350 should be addressed to the undersigned. Thank you. Respectfully submitted, READ. AND LANIADO, LLP and DMP New York, Inc. Attorneys for Williams Field Services Company, LLC By: Sam M. Laniado /s/ CC: Attached Service Lists Mr. John Strub, New York State Department of Public Service Mr. Corey Strub, New York State Department of] Public Service Mr. Steven Blow, Esq., Office of General Counsel Mr. Scott Cook, New York State Department of] Environmental Conservation Mr. Lawrence Weintraub, Esq., New York State Department of Environmental Conservation 3