Sabal Trail has discovered the southeast has drought! That’s its excuse for not greening up its gouge across what it calls its “greenfield” route. Sabal Trail “will continue to be available” to address landowner concerns, as if they have addressed destroying Randy Dowdy’s world-record soybean fields. They claim they’ve resolved 271 of 279 landowner issues: as near as I can tell mostly by suing the landowners, like they did the Bell Brothers.

Pipeline company chutzpah! Solar power would do this faster, cheaper, and cleaner: “Granting Sabal Trail’s request by May 26 will allow Sabal Trail to commence service promptly to FPL and will significantly increase the available supply of natural gas to the Southeastern United States during the heart of the peak summer cooling season.” More likely Sabal Trail wants to be in-service by the end of May to avoid forfeiting that $200 million bond required by FPL’s RFP.

Sabal Trail’s list of karst features doesn’t match its own May 5th bi-weekly report (only one in Suwannee County, FL?), and the Flint River “depressions” still haven’t been “remediated”. But don’t worry about sinkholes: “Wetland monitoring will occur once per year”.

Do you think this will be sufficient?

Sabal Trail anticipates having one to two Environmental Inspectors per construction spread for spreads 1, 2, 3, and 6, and up to three Environmental Inspectors for spreads 4 and 5. The Environmental

Or “one to two Biological Monitors” per spread, or “up to three” for spreads 4 and 5? Maybe they can identify the exotic invasive grasses Sabal Trail planted on the right of way.

Clearly Sabal Trail expects FERC to rubberstamp this in-service request, given they’re putting up signs at rivers.

Sierra Club has already filed a request for FERC to deny all Sabal Trail in-service request until the pending court case is resolved.

The Sabal Trail authorization request is FERC Accession Number: 20170517-5098, “Request for Authorization to Place Project Facilities into Service of Sabal Trail Transmission, LLC under CP15-17.”

See also Jeremiah Shelor, Natural Gas Intelligence, 19 May 2017, Sabal Trail Seeks FERC OK to Begin Service in Late May,

…Florida, which relies heavily on natural gas-fired electric generation.

Now there’s the problem. The fix is obvious to anyone not associated with the fossil fuel industry: Get on with solar power for the Sunshine State!.

May 17, 2017

Ms. Kimberly D. Bose, Secretary
Federal Energy Regulatory Commission
888 First Street, NE
Washington, D.C. 20426

Re: Sabal Trail Transmission, LLC, Docket No. CP15-17-000
In-Service Request for Sabal Trail Project — Phase I

Dear Ms. Bose:

On February 2, 2016, the Federal Energy Regulatory Commission (“FERC” or “Commission”) issued an Order Issuing Certificates and Approving Abandonment in the abovereferenced docket granting Sabal Trail Transmission, LLC (“Sabal Trail”), among other authorizations, certificates of public convenience and necessity (i) to construct the greenfield portion of the Sabal Trail Project (“Project”) over three phases to create a total firm transportation design capacity of 1,075,000 dekatherms per day (“Dth/d”) and (ii) to lease the capacity created by the Hillabee Expansion Project.¹ Phase I of the Project is designed to provide an initial capacity of 830,000 Dth/d.

Pursuant to Environmental Condition No. 9 of the February 2 Order, Sabal Trail hereby requests written authorization on or before May 26, 2017 from the Director of the Office of Energy Projects (“OEP”) to place the Phase I Project facilities described below into service so that Sabal Trail can commence service as early as May 31, 2017. As Sabal Trail explained in its certificate application in this proceeding, the scheduled in-service date for the Project was May 1, 2017, the start of the peak summer cooling season in Florida and the Southeastern United States. Florida Power & Light Company (“FPL”), an anchor shipper for the Sabal Trail Project, has requested 400,000 Dth/d of service on the Project facilities at the earliest possible time. Granting Sabal Trail’s request by May 26 will allow Sabal Trail to commence service promptly to FPL and will significantly increase the available supply of natural gas to the Southeastern United States during the heart of the peak summer cooling season.

After placing these Phase I Project facilities into service and together with the lease of capacity created by the Hillabee Expansion Project, Sabal Trail will be able to provide approximately 400,000 Dth/d of service from the Transco Zone 4 pool to the interconnection between Transco’s system and the greenfield portion of the Sabal Trail Project in Tallapoosa County, Alabama, and Sabal Trail estimates that it will be able to provide up to approximately 470,000 Dth/d of transportation service on the greenfield portion of the Sabal Trail Project.

¹ Florida Southeast Connection, LLC, et al.,¹⁵⁴ FERC ¶ 61,080 (2016) (“February² Order”). The February² Order also granted authorizations to Transcontinental Gas Pipe Line Company, LLC (“Transco”) and Florida Southeast Connection, LLC related to the Hillabee Expansion Project and the Florida Southeast Connection Project, respectively.

The Phase I facilities and related appurtenances to be placed into service are as follows:

• Mainline Pipeline — approximately 482.4 miles of 36-inch diameter mainline pipeline that originates at the interconnection with Transco in Tallapoosa County, Alabama and terminates at the interconnection with Florida Southeast Connection’s project in Osceola County, Florida;
• Alexander City Compressor Station in Tallapoosa County, Alabama o Titan 250 (1) — 30,000 horsepower (“hp”);
• Reunion Compressor Station in Osceola County, Florida o Titan 130 (1) — 20,500 hp; and
• Transco Hillabee M&R in Tallapoosa County, Alabama; Gulfstream M&R in Osceola County, Florida; FSC M&R in Osceola County, Florida.

Sabal Trail confirms that it has met all of the other conditions in the February 2 Order to place the Phase I facilities into service and, as reflected in the biweekly status reports, submits that restoration of the right-of-way and other areas affected by the Project is proceeding satisfactorily.

Sabal Trail provides the following in support of this in-service request:

Karst Geology

Each of the potential karst features encountered during construction of the Project and identified in the biweekly status reports submitted to Commission Staff was addressed in accordance with Sabal Trail’s Karst Mitigation Plan. Specifically, Sabal Trail identified a total of eight potential karst features along the mainline pipeline route, one in each of the following counties: Russell, AL; Dougherty, GA; Mitchell, GA; Lowndes, GA; Hamilton, FL; Suwannee, FL; Sumter, FL; and Lake, FL. In addition, a total of 9 potential karst features were identified along the horizontal directional drilling routes, one in each of the following counties: Russell, AL; Brooks, GA; Hamilton, FL; and Sumter, FL; two in Osceola, FL; and three in Dougherty, GA. All potential karst features, with the exception of the potential karst feature in Dougherty, GA, have been addressed and mitigated. For this remaining feature, Sabal Trail has recently contacted the landowner to begin mitigation activities now that the water level has receded.

As described in Sabal Trail’s Karst Mitigation Plan, when a potential karst feature is identified during construction, the area is isolated from construction activities and geotechnical engineers evaluate the potential karst feature and determine the mitigation method applicable to that feature. The mitigation measure employed for a number of the potential karst features was placement of successive lifts of sand until the elevation was within one foot of the original elevation; topsoil was then applied to bring the elevation back to the original level. At some locations, the feature was graded and topsoil added, and at other locations, no mitigation was necessary as the pre-existing feature was avoided. Each of the identified potential karst features will continue to be monitored and any potential issues addressed, as appropriate, with a brief description included in the periodic reports to be filed with the Commission.

Revegetation Status

The area of the southeastern United States through which the Sabal Trail Project traverses is currently experiencing abnormally dry conditions, varying from abnormally dry to severe drought in the areas of southwest Georgia and Florida (see Southeast U.S. Drought Monitor map below from the National Drought Mitigation Center). These conditions have affected the establishment of the perennial vegetative cover on the construction right-of-way.

Restoration of the mainline pipeline route is approximately 88 percent complete. Approximately 19 percent of the mainline pipeline route has been successfully vegetated, either by return to cultivated agricultural practices, no impact areas (crossed by horizontal directional drill), or re-seeding efforts. Approximately 21 percent of the mainline pipeline route has some visible form of permanent vegetative growth (20-50 percent growth). The remaining 60 percent of the mainline pipeline route has minimal vegetative cover.

Sabal Trail Environmental Inspectors will continue to monitor via pedestrian surveys the rainfall conditions and vegetative growth along the pipeline route, and Sabal Trail anticipates that the vegetative coverage will increase during the typically wet summer months ahead. Sabal Trail will re-evaluate the growth status throughout the summer growing season and will determine based on rainfall amounts and the growing season if additional re-seeding of specific areas is needed. Sabal Trail will provide updates on the status of restoration in the quarterly and annual reports to be filed with the Commission.

Sabal Trail’s remaining activities with respect to restoration include the following:

Staffing for Post In-service Activities

Sabal Trail will retain inspection staff at each construction spread with responsibility to oversee completion of right-of-way restoration and activities at the compressor station sites. The inspection staff will also coordinate with Sabal Trail construction staff to remedy any event that may occur on the right-of-way or compressor station sites.

Following completion of cleanup activities, Sabal Trail will continue working on the restoration punch lists that were compiled by Sabal Trail’s construction staff, right-of-way land agents, Environmental Inspectors and the FERC Monitors. Following completion of the restoration punch list items, anticipated in mid-summer to late fall 2017, Sabal Trail will have construction staff on call and all necessary equipment readily available to complete any rehabilitation requirements, as-needed.

Sabal Trail anticipates having one to two Environmental Inspectors per construction spread for spreads 1, 2, 3, and 6, and up to three Environmental Inspectors for spreads 4 and 5. The Environmental Inspectors will conduct the necessary inspections in accordance with the stormwater permits, until the Notices of Termination for the permits are accepted by the Alabama, Georgia, and Florida regulatory agencies. The Environmental Inspectors will also inspect erosion control devices and other work performed. The Environmental Inspectors will be responsible for ensuring that post-construction issues are resolved in accordance with the requirements and conditions of the applicable permits.

Plan for Addressing Landowner Complaints

As reported to the Commission in Sabal Trail’s biweekly status reports, a total of 279 landowner issues, including such issues as dust, noise, vibration, construction schedule and road conditions, have been raised. Of the issues raised, 271 have been resolved. Sabal Trail is committed to working with landowners to address concerns that are currently outstanding or that may arise following in-service. Sabal Trail representatives and the toll free hotline will continue to be available to address any landowner questions or concerns regarding restoration and rehabilitation, and any other project related items. Following in-service, landowners will also be provided via letter with contact information for Sabal Trail operations staff, who will be available to address any future questions or concerns about the pipeline facilities. Further, Sabal Trail’s webpage will continue to be available to all stakeholders to access Sabal Trail representatives.

Biological/Wetland Monitoring Plan

Biological monitoring of wetlands and revegetation along the right-of-way and facility sites will continue in accordance with Section VII of the FERC’s Upland Erosion Control, Revegetation, and Maintenance Plan, Section VI.D.6 of the FERC’s Wetland and Waterbody Construction and Mitigation Procedures (“FERC Procedures”), and the U.S. Army Corps of Engineers permit requirements. Sabal Trail anticipates having one to two Biological Monitors per construction spread for spreads 1, 2, 3, and 6 and up to three Biological Monitors for spreads 4 and 5. Starting in June/July 2017, the monitors will assess vegetative cover and identify the presence of any nuisance and exotic species. When areas of nuisance and/or exotics are noted, the monitors will notify the appropriate staff to address any potential issues and treatments. The monitors will continue assessing each spread until the required vegetative coverage is achieved. It is anticipated that this approach will be reviewed for effectiveness in June 2018 and revised as necessary.

Wetland monitoring will occur once per year in the June/July time frame for a period up to five years. Pre-construction monitoring and pre-construction conditions have already been established and the monitoring will continue until satisfactory restoration is achieved in accordance with the FERC Procedures and the U.S. Army Corps of Engineers permit requirements. The first monitoring period is scheduled for July 2017.

In addition to revegetation and wetlands monitoring, Biological Monitors will also conduct sweeps prior to ongoing or future restoration/reseeding activities in accordance with mitigation measures for the protection of threatened and endangered species.

Right-of-Way Monitoring

In addition to the monitoring specified above, Sabal Trail operations personnel will monitor the right-of-way via aerial patrol on a weekly basis and on the ground along the pipeline route on an ongoing basis to identify and address potential problem areas.

Summary of Request

The facilities that are included in this request will be ready to be placed into service by the dates contemplated herein and restoration is proceeding satisfactorily. Based on the projections for mechanical completion, current status, ongoing commitments to monitor and address right-of-way restoration and rehabilitation progress, and Sabal Trail’s confirmation that it has met all of the other conditions in the February 2 Order to place the Phase I facilities into service, Sabal Trail respectfully requests that the Director of OEP grant authorization by May 26, 2017 to place the Phase I Project facilities listed herein into service so that Sabal Trail can be in a position to place such facilities into service on the later of May 31, 2017 or the date such facilities are available for service. Issuance of an order by May 26, 2017 is necessary to allow Sabal Trail to meet the needs of its customer, FPL, and to complete the necessary business activities required to initiate firm transportation service as early as May 31, 2017.

Sabal Trail will submit separate requests to the Director of OEP to place the remaining Phase I Project facilities into service.

If you have any questions regarding this filing, please contact me at (713) 627-4102 or David A. Alonzo, Specialist I, Rates and Certificates at (713) 627-4957.

Sincerely,
Sabal Trail Transmission, LLC
By: Sabal Trail Management, LLC,
Its Operator
/s/ Lisa A. Connolly
Lisa A. Connolly
Director, Rates and Certificates

cc: John Peconom (FERC)
Pamela Boudreau (FERC)
Monique Watson (FERC)

 -jsq, John S. Quarterman, Suwannee RIVERKEEPER®

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