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March 27, 2013 Ms. Sandra J. Paske Secretary to the Commission Public Service Commission of Wisconsin P. O. Box 7854 Madison, WI 53707-7854 Re: Application of Wisconsin Gas LLC, as a Gas Public Utility, for Authority to Construct a Lateral from the Viking Gas Transmission Company Interstate Pipeline to the City of Tomah, through Eau Claire, Jackson, Clark, and Monroe Counties, to Provide Natural Gas to Existing and New Service Areas in Municipalities in the Project Area Docket No. 6650-CG-233 Dear Ms. Paske: Pursuant to § 196.49, Wis. Stat., and Ch. PSC 133, Wis. Admin. Code, Wisconsin Gas LLC hereby requests a certificate of authority to install and place in service in western Wisconsin new natural gas distribution facilities. Those facilities, referred to as the "West Central Lateral," would start from a proposed interconnection with the Viking Gas Transmission Company pipeline in Eau Claire or Clark County and run south, including delivery points to Wisconsin Gas's existing distribution networks in Augusta, Hixton, Alma, Black River Falls and Tomah. As part of this application, Wisconsin Gas also requests authorization to provide new natural gas service to several communities that have expressed an interest in obtaining natural gas service located in the counties of Clark, Eau Claire, Jackson and Monroe, service which will be made possible by the West Central Lateral. Background Wisconsin Gas’s traditional firm system sales are comprised of residential and business customers who rely on Wisconsin Gas to provide reliable 24/7 gas service 365 days per year. Wisconsin Gas is obligated to serve the needs of these customers, especially on the coldest days of the year (usually the time when firm system sales demand is at its highest level, i.e., peak day). PSC REF#:182673 Public Service Commission of Wisconsin RECEIVED: 03/28/13, 7:32:43 AM

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Page 1: WCL Cover Letter

March 27, 2013

Ms. Sandra J. Paske

Secretary to the Commission

Public Service Commission of Wisconsin

P. O. Box 7854

Madison, WI 53707-7854

Re: Application of Wisconsin Gas LLC, as a Gas Public Utility, for

Authority to Construct a Lateral from the Viking Gas Transmission

Company Interstate Pipeline to the City of Tomah, through Eau

Claire, Jackson, Clark, and Monroe Counties, to Provide Natural Gas

to Existing and New Service Areas in Municipalities in the Project

Area

Docket No. 6650-CG-233

Dear Ms. Paske:

Pursuant to § 196.49, Wis. Stat., and Ch. PSC 133, Wis. Admin. Code, Wisconsin Gas

LLC hereby requests a certificate of authority to install and place in service in western

Wisconsin new natural gas distribution facilities. Those facilities, referred to as the "West

Central Lateral," would start from a proposed interconnection with the Viking Gas Transmission

Company pipeline in Eau Claire or Clark County and run south, including delivery points to

Wisconsin Gas's existing distribution networks in Augusta, Hixton, Alma, Black River Falls and

Tomah. As part of this application, Wisconsin Gas also requests authorization to provide new

natural gas service to several communities that have expressed an interest in obtaining natural

gas service located in the counties of Clark, Eau Claire, Jackson and Monroe, service which will

be made possible by the West Central Lateral.

Background

Wisconsin Gas’s traditional firm system sales are comprised of residential and business

customers who rely on Wisconsin Gas to provide reliable 24/7 gas service 365 days per year.

Wisconsin Gas is obligated to serve the needs of these customers, especially on the coldest days

of the year (usually the time when firm system sales demand is at its highest level, i.e., peak

day).

PSC REF#:182673Public Service Commission of Wisconsin

RECEIVED: 03/28/13, 7:32:43 AM

Page 2: WCL Cover Letter

Ms. Sandra J. Paske

Public Service Commission of Wisconsin

March 28, 2013

Page 2

Wisconsin Gas regularly purchases natural gas supply and contracts with pipeline service

providers to transport the gas to its distribution system network to serve its customers.

Wisconsin Gas currently purchases pipeline capacity from the Northern Natural Gas (NNG) with

firm delivery rights to its customers in western Wisconsin. Typically, on a system wide basis,

Wisconsin Gas maintains a reserve margin1 at or around 5% of peak day demand to cover

unanticipated growth, forecast error, unexpected conditions or system upsets.

When the reserve margin is negative, and a peak day occurs, gas service to residents and

businesses can be degraded to the point where firm gas transportation service is subject to

curtailment.2

The Challenge Facing Wisconsin Gas in western Wisconsin

Wisconsin Gas faces a growing reliability challenge in its service territories in west

central Wisconsin that currently receive natural gas supplies from the NNG Black River Falls

and Tomah delivery laterals. The challenge in providing service to customers in this part of

Wisconsin is that firm pipeline capacity on both NNG laterals is fully subscribed, creating a

situation in which available capacity is constrained. As a result, incremental firm transportation

service capacity to Wisconsin Gas’s service areas on these laterals is not available without

acquiring very expensive expansions of NNG lateral facilities. Unless capacity on the NNG

system is expanded; service reliability for Wisconsin Gas is potentially jeopardized.

The same capacity constraints on the NNG system also make it impossible to offer

natural gas service either to communities adjacent to Wisconsin Gas's service areas that currently

use more expensive propane or to support economic development. In west central Wisconsin,

economic development in particular the production of industrial (aka "frac") sand, would be

greatly advanced by increased availability of natural gas (which is used to dry the sand).

Wisconsin’s frac sand is used in the process of hydraulic fracturing across the country and

western Wisconsin has seen significant growth in sand frac mining and processing facilities in

the past few years. While these issues could potentially continue to be addressed by "stepped"

expansions of the NNG system and its associated delivery laterals, Wisconsin Gas has

experienced ever-increasing costs for that incremental approach.

Addressing the Challenge—the Wisconsin Gas Procurement Process

Wisconsin Gas initiated a competitive procurement process through the issuance of an

RFP (request for proposal) to address its need for additional pipeline capacity to serve the west

central Wisconsin region. Bidders were asked to submit proposals that covered a minimum of

four service quantity scenarios and that satisfied a number of other specified requirements. Four

bidders responded to the RFP: Northern Natural Gas Company, Viking Gas Transmission Co.,

ANR Pipeline Co., and Wisconsin Gas LLC - Customer Operations. Altogether twenty-one

alternatives were proposed by the bidders and evaluated against minimum bid criteria, economic

1 The term “Reserve Margin” is used to quantify the difference by which Contracted Capacity exceeds forecasted

Peak Day demand. 2 It is important to note that this is a physical limitation. Gas at any price (penalty gas or over-takes) is not available

from NNG. Therefore, curtailment would be the only option once the peaking unit is exhausted.

Page 3: WCL Cover Letter

Ms. Sandra J. Paske

Public Service Commission of Wisconsin

March 28, 2013

Page 3

criteria, and non-economic criteria. The economic evaluation employed both a base demand

growth rate scenario and a high demand growth rate scenario, and all of the alternatives were

compared against "stepped" expansions of the NNG system. The economic analysis compared

customers' gas cost savings under all of the various proposals against the cost to customers of

implementing each proposal, and calculated the customers' net present value of gas cost savings

as well as the return on their investment.

The conclusion reached was that the West Central Lateral, as proposed by Wisconsin Gas

LLC - Customer Operations, is the best choice, on both economic and non-economic grounds,

for increasing the availability of natural gas service in west central Wisconsin and solving the

problems described earlier.

The Benefits of the Wisconsin Central Lateral

The original analysis of alternatives was subsequently updated and its conclusion was

confirmed that on both economic and non-economic grounds the West Central Lateral is the best

choice to accomplish these objectives:

Deliver cost savings to customers. Compared to the alternative of

"stepped" expansions of the existing Northern Natural Gas (NNG) system,

the West Central Lateral is projected to deliver customers a net present

value of gas cost savings of between $100 million and $200 million,

depending on the precise route chosen and the discount rate used in the

NPV calculation.

Ensure reliability. The construction of the Wisconsin Central Lateral will

enable Wisconsin Gas to meet peak day needs associated with firm system

sales requirements and ensure service reliability.

Address Demand Growth and Advance Economic Development. The West

Central Lateral will enable Wisconsin Gas to meet forecasted commercial and

industrial demand requirements for natural gas service (including rising demand

from "frac" sand operations in the region).

The construction of the West Central Lateral itself will lead to 375 to 400

construction jobs in the area for the duration of the construction process. In

addition, the addition of a single new sand frac facility alone generally delivers

the following economic benefits3:

--Construction spending of $20 - $40 million, with spending rising to as

much as $100 million if a resin coating facility is also included

--Construction jobs during plant development; and

3Wisconsin Department of Natural Resources, Silica Sand Mining in Wisconsin, January 2012.

Page 4: WCL Cover Letter
Page 5: WCL Cover Letter

Ms. Sandra J. Paske

Public Service Commission of Wisconsin

March 28, 2013

Page 5

Attachments

cc: Mr. Benjamin Callan - WDNR

Mr. Kyle Zibung - U.S. Army Corps of Engineers

Mr. Peter Nauth - Wisconsin Department of Agriculture, Trade and Consumer Protection

Page 6: WCL Cover Letter

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INFORMATION FOR NATURAL GAS PIPELINE APPLICATIONS

March, 2013

Page i of v

Table of Contents

3.1 ENGINEERING INFORMATION ........................................................................................ 1

3.1.1 Type of and Location of Construction ...................................................................... 1

3.1.2 General Description of Project.................................................................................. 1

3.1.3 Purpose and Necessity of Proposed Project ........................................................... 8

3.1.4 How the Project Relates to Future Projects in the Area ........................................ 23

3.1.5 Effect of Project on Cost of Operation and Reliability .......................................... 24

3.1.6 Cost and Method of Financing ................................................................................ 25

3.1.7 Description and Cost of Property Replaced or Retired ......................................... 26

3.1.8 Economic Evaluation ............................................................................................... 26

3.1.9 Construction Schedule ............................................................................................ 27

3.1.10 Description of Construction Procedures ............................................................... 28

3.1.11 Association with a Proposed Power Plant ............................................................. 29

3.2 PROJECT DEVELOPMENT AND ALTERNATIVES CONSIDERED ............................... 29

3.2.1 Describe System Alternatives and Why Not Selected ........................................... 29

3.2.2 Factors Considered in Evaluating Possible Routes .............................................. 30

3.2.3 Identify Alternative Routes that Were Not Chosen ................................................ 31

3.2.4 Description of Public Communications ................................................................. 43

3.2.5 Pre-Application Activities with PSC and DNR ....................................................... 43

3.2.6 Stakeholder and landowner Interactions ............................................................... 45

3.3 GENERAL PIPELINE SITING INFORMATION ................................................................ 50

3.3.1 Route Alternatives ................................................................................................... 50

3.3.2 Land Use Plans ........................................................................................................ 77

3.4 DETAILED ROUTE INFORMATION ................................................................................ 78

3.4.1 General Route Impacts ............................................................................................ 78

3.4.2 Impacts by Land Type ............................................................................................. 79

3.4.3 Route Summaries .................................................................................................... 81

3.4.4 Agricultural Land ..................................................................................................... 81

3.4.5 Forest Lands Segment and Route Summaries ...................................................... 85

3.4.6 Conservation Easements ........................................................................................ 89

3.4.7 Endangered, Threatened, Special Concern Species and Natural Communities . 94

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3.4.8 Archeological and Historic Resources ................................................................... 95

3.4.9 Access Issues .......................................................................................................... 98

3.4.10 Waterway Permitting Activities ............................................................................... 99

3.4.11 Wetlands ................................................................................................................. 102

3.5 Mapping Wetland and Waterway Crossings ............................................................... 106

3.6 CONSTRUCTION METHODS ........................................................................................ 106

3.6.1 General Construction Methods ............................................................................. 106

3.6.2 Roads and Driveway Crossings ............................................................................ 108

3.6.3 Waterway Crossings .............................................................................................. 109

3.6.4 Wetlands Crossings .............................................................................................. 112

3.6.5 Site Restoration ..................................................................................................... 117

3.6.6 Erosion Control Plan ............................................................................................. 119

3.7 MATERIAL MANAGEMENT PLAN ............................................................................... 120

3.7.1 Access Point Locations......................................................................................... 120

3.7.2 Haul Routes ............................................................................................................ 121

3.7.3 Stockpile Areas ...................................................................................................... 121

3.7.4 Equipment Staging Areas ..................................................................................... 122

3.7.5 Field Screening for Contaminants ........................................................................ 125

3.7.6 Contaminated Materials......................................................................................... 125

3.7.7 Excavation Methods .............................................................................................. 125

3.7.8 Dewatering of Excavated Materials ...................................................................... 125

3.7.9 Estimated Volumes of In-channel and Upland Excavated Materials .................. 125

3.7.10 Estimated Volumes and Location of Re-used Excavated Materials ................... 126

3.7.11 Off-site Disposal Plans .......................................................................................... 126

3.8 DEWATERING PLAN .................................................................................................... 126

3.8.1 Dewatering/Diversion of Flow ............................................................................... 126

3.8.2 Downstream Impact Minimization ........................................................................ 127

3.8.3 Possible System Overload Scenarios .................................................................. 127

3.8.4 Impacts of System Overload ................................................................................. 127

3.8.5 Discharge Locations .............................................................................................. 127

3.8.6 Back-up System ..................................................................................................... 127

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3.8.7 High Flow Plan ....................................................................................................... 127

3.8.8 Contaminated Water .............................................................................................. 128

3.9 ASSOCIATED FACILITIES INFORMATION .................................................................. 128

3.9.1 Location and Layout .............................................................................................. 128

3.9.2 Purchases Land Requirements ............................................................................. 129

3.9.3 Landscaping ........................................................................................................... 129

3.9.4 Plat and Topographic Maps .................................................................................. 129

3.9.5 Access Roads ........................................................................................................ 130

3.9.6 Construction Methods and Erosion Control ........................................................ 130

3.9.7 Environmental information ................................................................................... 131

3.10 DNR PERMITS AND APPROVALS ............................................................................... 133

3.10.1 Supplemental Documentation to Form 3500-053 ................................................. 134

3.10.2 Practicable alternatives analysis .......................................................................... 134

3.10.3 Storm Water Management ..................................................................................... 137

3.10.4 Endangered/Threatened Species Incidental Take ............................................... 137

3.11 OTHER AGENCY CORRESPONDENCE ...................................................................... 138

3.11.1 Company correspondence .................................................................................... 138

3.11.2 Agency responses ................................................................................................. 138

3.11.3 State Permits .......................................................................................................... 138

3.11.4 Local Permits ......................................................................................................... 139

3.11.5 Federal Permits ...................................................................................................... 140

3.11.6 Other Permits ......................................................................................................... 141

3.12 PROPERTY OWNER INFORMATION ........................................................................... 141

List of Figures

Figure 1 – West Central Wisconsin Pipeline Existing Infrastructure ........................................... 9

Figure 2 – Black River Falls Capacity vs. Peak Demand ............................................................ 12

Figure 3 – Tomah Capacity vs. Peak Demand ............................................................................. 13

Figure 4 – Mine/Processing Plants and West Central Lateral .................................................... 16

Figure 5 – Projected Commercial & Industrial Demand ............................................................. 17

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Figure 6 – Infrastructure with West Central Lateral .................................................................... 18

Figure 7 – Proposed Franchises .................................................................................................. 21

List of Tables

Table 1 – Segment Numbering Convention ....................................................................................... 2

Table 2 – Steel Pipe Design Information ........................................................................................... 3

Table 3 – Plastic Pipe Material Design Information ........................................................................... 4

Table 4 – Route A Lengths and ROW Requirements ........................................................................ 5

Table 5 – Route B Lengths and ROW Requirements ........................................................................ 6

Table 6 – Associated Facilities .......................................................................................................... 8

Table 7 – Proposed Franchises ...................................................................................................... 20

Table 8 – Potential Future Projects ................................................................................................. 24

Table 9 – West Central Lateral Cost ............................................................................................... 25

Table 10 – Distribution Facilities Cost ............................................................................................. 26

Table 11 –Property to be Retired .................................................................................................... 26

Table 12 – Rare Species Seasonal Constraints .............................................................................. 28

Table 13 – Routes Not Chosen ....................................................................................................... 32

Table 14 – Fairchild R.4 Route Comparison .................................................................................... 36

Table 15 –Route Segment Description ............................................................................................ 51

Table 16 – MFL Route A ................................................................................................................. 90

Table 17 – MFL Route B ................................................................................................................. 90

Table 18 – Historical Architectural Survey Summary ....................................................................... 97

Table 19 – Temporary Access Routes ............................................................................................ 99

Table 20 – List of waterways/waterbodies found to not be present along Route A ........................ 100

Table 21 – List of waterways/waterbodies found to not be present along Route B ........................ 101

Table 22 – Invasive Species Best Management Practices ............................................................ 114

Table 23 – Map Index: Staging Areas ........................................................................................... 122

Table 24 – Excavated Material ...................................................................................................... 126

Table 25 – Map Index: Project Location and Orthophotography .................................................... 129

Table 26 – Map Index: Topographic .............................................................................................. 130

Table 27 – Associated Facilities Impact ........................................................................................ 132

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Table 28 – State Permits ............................................................................................................... 138

Table 29 – Local Permits .............................................................................................................. 139

Table 30 – Federal Permits ........................................................................................................... 141

Appendices

Appendix A – Economics

Appendix B – Maps

Appendix C – Environmental Information

Appendix D – Agency Correspondence

Appendix E – Public Information

Appendix F – Lists

Appendix G – Gas Distribution System Resolutions

Appendix H – Construction Figures

Appendix I – Engineering Information

Appendix J – Letters of Support

Appendix K – Planning and Zoning

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3 INFORMATION REQUIREMENTS FOR NATURAL GAS PIPELINES

This document has been prepared in conformance with the format and content guidance provided in State of Wisconsin, Public Service Commission and Department of Natural Resources Application Filing Requirements for Natural Gas Pipeline Construction Projects, Version 11.

3.1 ENGINEERING INFORMATION

3.1.1 Type of and Location of Construction

Wisconsin Gas LLC (Wisconsin Gas or the Company) proposes to construct a new natural gas lateral in West Central Wisconsin (Eau Claire, Jackson, Clark and Monroe Counties). The West Central Lateral (the Project) would consist of new natural gas distribution facilities that would start from a proposed interconnect with the Viking Gas Transmission Company (Viking Gas or Viking Gas Transmission) pipeline (Viking pipeline) in Eau Claire or Clark County and run south, including delivery points to the Company’s existing distribution networks in the City of Augusta, Town of Hixton, Town of Alma, City of Black River Falls, and finally the City of Tomah. The West Central Lateral is proposed to be in service by November 1, 2015.

3.1.2 General Description of Project

The Project has been divided into 15 separate segments as shown on the West Central Lateral Segment Polygon Map and the West Central Lateral Segment Map in Appendix B – Maps to help simplify the route description and comparison/analysis process. The subsequent sections in this application will refer to these segment designations for route analysis/comparison. Table 1 below gives a brief summary of the 15 Project segments.

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Table 1 – Segment Numbering Convention

Project Segment Description

Route A Segment

Name

Route B Segment

Name

1 16"-475psig Lateral (Includes Augusta 6" Branch) - Viking TBS to Fairchild A.1 B.1

2 16"-475psig Lateral - Fairchild to Town House Rd, Alma A.2 B.2

3 16"-475psig Lateral - Town House Rd, Alma to Avon Rd, Alma A.3 B.3

4 16"-475psig Lateral - Avon Rd, Alma to Prindle Rd & Arnold Rd, Alma A.4 B.4

5 16"-475psig Lateral - Prindle Rd & Arnold Rd, Alma to Odeen Rd, Adams A.5 B.5

6 16"-475psig Lateral - Odeen Rd, Adams to Black River Falls DR A.6 B.6

7 12"-475psig Lateral - Black River Falls DR to Millston A.7 B.7

8 12"-475psig Lateral - Millston to Warrens Branch A.8 B.8

9 12"-475psig Lateral - Warrens Branch to Tomah DR A.9 B.9

10 Augusta 8"-60psig Distribution A.10 B.10

11 Hixton 4"-475psig Branch A.11 B.11

12 Alma 6"-275psig Distribution (Route A Only) A.12 -

13 Black River Falls 8"-60psig Distribution A.13 B.13

14 Tomah 12"-60psig Distribution A.14 B.14

15 Warrens 4"-475psig Branch A.15 B.15

3.1.2.1 Operating pressure, size and material

The new pipe to extend from the Viking Town Border Station (TBS) to the downstream district regulator stations (DR) is proposed to operate at a Maximum Allowable Operating Pressure (MAOP) of 475 psig with a design pressure of 720 psig. This lateral will be designed for Class 3 location. Approximately 39.9 miles of 16-inch steel (Route A) or approximately 45 miles of 16-inch steel (Route B) will extend from the proposed Viking TBS to the proposed Black River Falls DR. Approximately 33 miles of 12-inch steel (Route A) or approximately 29.3 miles of 12-inch steel (Route B) will extend from the proposed Black River Falls DR to the proposed Tomah DR. In addition to the 16-inch and 12-inch steel pipe, there will also be smaller diameter branches at the same pressure extending to the proposed Augusta DR, Hixton DR, and Warrens DR. The proposed Augusta Branch consists of approximately 7 miles of 6-inch steel for Route A and approximately 9.8 miles of 6-inch steel for Route B. The proposed Hixton Branch consists of approximately 3 miles of 4-inch steel for Route A and approximately 2.1 miles of 4-inch steel for Route B. The proposed Warrens Branch consists of approximately 0.9 miles of 4-inch steel for both Route A and Route B.

There are also several distribution main improvements required downstream of the proposed DRs to supply the existing distribution systems. The Hixton DR is located directly

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adjacent to the existing distribution main so there is no need for Hixton distribution main with this project. The required distribution main improvements are listed below:

Augusta Distribution - Extension of approximately 0.1 miles 8-inch plastic pipe with an MAOP and design pressure of 60 psig from the proposed Augusta DR to the existing Augusta 60 psig distribution system.

Alma Distribution – Extension of approximately 0.3 miles of 6-inch steel pipe with an MAOP and design pressure of 275 psig from the proposed Alma DR for Route A to the existing Alma 275 psig distribution system.

Black River Falls Distribution – Extension of approximately 1.9 miles of 8-inch plastic pipe with an MAOP and design pressure of 60 psig from the proposed Black River Falls DR to the existing Black River Falls 60 psig distribution system.

Tomah Distribution – Extension of approximately 0.2 miles of 12-inch steel with an MAOP and design pressure of 60 psig from the proposed Tomah DR to the existing Tomah 60 psig distribution system.

Table 2 shows the proposed steel pipe to be installed with this project. The associated Percent Specified Minimum Yield Strengths (%SMYS) are also included in the table for both the MAOP and design pressure. Thicker wall pipe may be used for some bores. The actual wall thickness and yield strength of the pipe may vary and will depend on market pricing and availability. However, the pipe selected will maintain an MAOP %SMYS below 20% and a Design Pressure %SMYS below 30%.

Table 2 – Steel Pipe Design Information

Outside Diameter

(in)

Wall Thickness

(in)

Yield Strength

(psi)

Maximum Allowable Operating Pressure

(psig)

Maximum Allowable Operating Pressure %SMYS

Design Pressure

(psig)

Design Pressure %SMYS

Project Segments

16.000 0.312 65,000 475 18.7% 720 28.4% 1 - 6

12.750 0.250 65,000 475 18.6% 720 28.2% 7 - 9

6.625 0.219 52,000 475 17.1% 720 25.9% 1

4.500 0.188 52,000 475 10.9% 720 16.6% 11 & 15

6.625 0.219 52,000 275 8.0% 275 8.0% 12

12.750 0.219 52,000 60 3.4% 60 3.4% 14

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The %SMYS in the table above was calculated using the following formula:

%SMYS = [(p * D) /( 2 * t * S)] x 100

where:

p = Operating Pressure (psig)

D = Outside Diameter of Pipe (in)

t = Wall Thickness of Pipe (in)

S = Yield Strength of Pipe (psi)

Table 3 below shows the proposed plastic pipe to be installed with this Project.

Table 3 – Plastic Pipe Material Design Information

Outside Diameter

(in) Resin Type SDR/DR

Wall Thickness

(in)

Maximum Allowable Operating Pressure

(psig) Project

Segments

8.625 PE 100 13.5 0.6389 60 10 & 13

3.1.2.2 Pipeline length and ROW width requirements

Since the lengths vary between Route A and Route B, this information is best summarized in two separate tables shown below. In general, the 16-inch and 12-inch main is proposed to be within landowner easement. This will reduce the risk of conflict with other utilities or road improvement projects in the future. Typically, the Company will seek a 50’ wide permanent easement. In certain instances the permanent easement may be reduced to avoid existing above ground structures or other above ground appurtenances. There are short distances where the main is proposed to be within the road ROW to avoid above ground structures that are in close proximity to the road ROW. In these cases, no permanent easement is needed. In agricultural areas, a 50’ temporary easement for construction will generally be requested in addition to the permanent easement. In all other areas such as wetlands, forests, and populated/developed areas a 25’ temporary easement for construction will generally be requested in addition to the permanent easement to reduce the impact to the forests, wetlands, and landowners. Where the main is adjacent to a road and the landscape is wetland or forested, it is generally proposed that the road ROW be used as temporary workspace during construction.

A portion of the 6-inch main to Augusta is proposed to be within road ROW where the land is forested to avoid clearing a 50’ swath of trees. This is mainly along CTH M from CTH H to just east of Kempton Rd. The 6-inch main then transitions into a 50’ landowner easement as the land use becomes mostly agricultural. A temporary easement is not required for installation of the 6-inch main. The 4-inch branches to Hixton and Warrens are proposed to be within road ROW. The distribution main downstream of the DRs (ranging from an MAOP of 275 psig to 60 psig) is proposed to be installed within road ROW or on existing Company owned land (as is the case for the Tomah distribution).

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Widths and locations of actual easements obtained will vary according to conditions encountered along each route and based on negotiations with landowners. Section 3.6.1 describes the widths required for the various construction locations and segments in more detail.

Table 4 – Route A Lengths and ROW Requirements

Segment Segment Length

(ft)

Length in Public Road ROW

(ft)

Length in Landowner Easement

(ft)

1 115,284 17,896 97,388

2 48,805 871 47,934

3 21,143 167 20,976

4 21,506 515 20,991

5 30,422 261 30,161

6 10,866 1,384 9,482

7 81,020 3,414 77,606

8 41,118 7,882 33,236

9 52,052 3,207 48,845

10 537 468 69

11 15,991 14,665 1,326

12 1,761 1,729 32

13 10,120 10,120 0

14 959 33 926

15 4,743 4,743 0

Total 456,327 67,355 388,972

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Table 5 – Route B Lengths and ROW Requirements

Segment Segment Length

(ft)

Length in Public Road ROW

(ft)

Length in Landowner Easement

(ft)

1 138,286 17,483 120,803

2 52,380 1,228 51,152

3 24,627 1,219 23,408

4 21,549 475 21,074

5 34,286 855 33,431

6 17,957 4,993 12,964

7 64,719 2,552 62,167

8 37,586 1,027 36,559

9 52,441 3,306 49,135

10 537 468 69

11 10,937 10,829 108

12 0 0 0

13 10,120 10,120 0

14 959 33 926

15 4,743 4,743 0

Total 471,127 59,331 411,796

3.1.2.3 Other gas facilities needed

This Project requires the installation of one Town Border Station (TBS) that will connect the proposed Lateral to the Viking pipeline. For Route A, the TBS will be located at the intersection of the Viking pipeline and CTH H in the Town of Wilson approximately 4,200’ north of the intersection of CTH H and Forest #2 Rd on the west side of CTH H. For Route B, the TBS will be located at the intersection of the Viking pipeline and Dickerson Ave in the Town of Foster approximately 2,200’ north of the intersection of Dickerson Ave and Hinker Rd on the east side of Dickerson Ave. Viking Gas plans to purchase up to 20 acres of land for both Viking Gas’ facilities and the Company’s facilities. Of the 20 acre parcel, only 1 acre will be utilized for the Company’s facilities. Up to one acre may be utilized for Viking Gas’ tap and metering facilities. The Company’s site will include station pipe and valves including a remote shut-off valve (RSV), odorization equipment, regulation, heater, filter, and a 16-inch pig launcher.

A total of five DRs are proposed to regulate from 475 psig to either 275 psig or 60 psig to supply the existing downstream distribution systems. In addition, information for two future DRs that would serve the requested franchise areas of Fairchild and Warrens is included in this application. The locations for the Augusta DR, Fairchild DR, Hixton DR, Black River

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Falls DR, Warrens DR, and Tomah DR are the same for Route A & B. The location for the Alma DR varies depending on the route. Table 6 below describes the site locations for each route as well as the facilities to be installed at each site. All sites will have pressure regulation and associated pipe and valves. The Black River Falls DR will include a 16-inch pig receiver, and a 12-inch pig launcher. The Tomah DR will include a 12-inch pig receiver.

This 475 psig lateral will also include various mainline valve assemblies at locations other than the above-listed TBS and DR sites. The valve assemblies will be spaced no more than 8 miles apart to comply with the Class 3 location design requirement specified by the Company for this project. Each 16-inch and 12-inch valve assembly will typically include a below ground valve with an above ground operator and blow-downs on both sides of the valve for emergency and operational purposes. The 16-inch and 12-inch valve assemblies will be designed to accommodate RSVs. Once the actual route is chosen by the PSC, the locations for the valve assemblies will be identified by the Company following the above standards and the appropriate placement of RSVs will be discussed and agreed upon by the Company and the PSC.

For more information regarding the associated facilities, refer to Section 3.9.

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Table 6 – Associated Facilities

Facility Name Route A Location Route B Location Facility Description

Viking Town Border Station (TBS)

Southwest corner of Viking pipeline and CTH H in the Town of Wilson (approximately 4,200' north of Forest #2 Rd). The site will be approximately 200' to the west of the CTH H ROW.

Southeast corner of the Viking pipeline and Dickerson Ave in the Town of Foster (approximately 2,200' north of Hinker Rd). The site be directly adjacent to the Dickerson Ave ROW.

Measurement, odorization, regulation (pipeline pressure to 475psig), heater, filter, and 16" pig launcher.

Augusta District Regulator Station (DR)

On the south side of USH12 and approximately 500' east of CTH M in the Town of Bridge Creek.

Same as Route A. Regulation (475psig to 60psig), heater, and filter.

Future Fairchild District Regulator Station (DR)

On the south side of E Main St and approximately 2,400' east of N Camp Rd in the Town of Fairchild.

Same as Route A. Regulation (475psig to 60psig), heater, and filter.

Hixton District Regulator Station (DR)

Northwest corner of CTH FF & S Alma Rd in the Town of Hixton.

Same as Route A. Regulation (475psig to 60psig), heater, and filter.

Alma District Regulator Station (DR)

Southeast corner of Prindle Rd and Arnold Rd in the Town of Alma.

Northeast corner of USH12 and Garage Rd in the Town of Alma.

Regulation (475psig to 275psig), heater, and filter.

Black River Falls District Regulator Station (DR)

Northwest corner of the Union Pacific railroad and STH 54 in the Town of Brockway (approximately 500' northeast of Vaudreuil Rd (1) & STH 54).

Same as Route A. Regulation (475psig to 60psig), heater, filter, 16" pig receiver and 12" pig launcher.

Future Warrens District Regulator Station (DR)

On the north side of CTH EW and approximately 1,400' east of Arctic Rd in the Town of Lincoln.

Same as Route A. Regulation (475psig to 60psig), heater, and filter.

Tomah District Regulator Station (DR)

The Company's existing Tomah Propane Air property at 1200 W Veterans St in the City of Tomah.

Same as Route A. Regulation (475psig to 60psig), heater, filter, and 12" pig receiver.

16" Valve Assembly

Various locations along Segments 1-6 with a maximum spacing of 8 miles. Exact locations to be identified once a final route is chosen by the PSC.

16" valve isolation and blow-down facilities.

12" Valve Assembly

Various locations along Segments 7-9 with a maximum spacing of 8 miles. Exact locations to be identified once a final route is chosen by the PSC.

12" valve isolation and blow-down facilities.

3.1.2.4 Map of the proposed pipeline, including alternates

The West Central Lateral Overview Map (Route A & B) in Appendix B – Maps provides an overview of the project. This map shows both routes with proposed stations.

3.1.3 Purpose and Necessity of Proposed Project

Purpose

Within the next few years, Wisconsin Gas will face a shortage of firm natural gas

transportation capacity to fulfill the firm sales demand requirements of its service areas in

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West Central Wisconsin1. After investigating alternatives to meet this projected capacity

shortfall, Wisconsin Gas has determined that the proposed West Central Lateral is the best

solution to enable the Company to maintain the capacity required to meet firm sales

requirements in this area.

Currently, natural gas is delivered to Wisconsin Gas’ West Central Wisconsin service areas via the Northern Natural Gas Company (NNG) interstate pipeline system. These West Central Wisconsin service areas are located on a portion of NNG’s system that is fully subscribed at locations far removed from NNG’s mainline transportation system. As illustrated in Figure 1 below, Wisconsin Gas’ Black River Falls distribution system is located at the end of an approximate 120 mile NNG delivery lateral (the Black River Falls Lateral) and the Tomah distribution system is located at the tail end of an approximate 155 mile NNG delivery lateral (the Tomah Lateral).

Figure 1 – West Central Wisconsin Pipeline Existing Infrastructure

The near term challenge for Wisconsin Gas in providing service to its current customers in this part of Wisconsin is that Firm Transportation Capacity on both NNG laterals is fully subscribed, creating a situation in which available capacity is constrained. As a result,

1 For this application, the term “West Central Wisconsin” refers to the geographic area south of the

Viking interstate pipeline in portions of Eau Claire, Jackson, Clark and Monroe counties where current and proposed Company franchises are located.

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incremental firm transportation service capacity to Wisconsin Gas’ service areas on these laterals is not available without acquiring very expensive expansions of NNG lateral facilities.

Recognizing the transportation capacity constraint on the NNG system to West Central Wisconsin and the undesirable situation of paying ever increasing costs for incremental NNG expansions, several years ago, Wisconsin Gas began exploring ways to more cost effectively meet the needs of its customers.

As discussed herein, Wisconsin Gas determined that the Project is the best cost effective solution to meet the near and long-term reliability needs of its customers in the area; and advance economic growth in the region.

The West Central Lateral will;

meet growing peak day needs associated with traditional Firm System Sales

requirements;

meet forecasted commercial and industrial demand requirements, including rising

demand from industrial (a.k.a. “frac”) sand operations;

eliminate the Company’s current reliance on a single service provider to deliver

interstate pipeline service to the region by providing a competitive alternative that will

deliver reliable, lower cost gas service;

introduce natural gas service to municipalities that currently have no natural gas

service;

allow Wisconsin Gas to retire its Tomah Liquid Propane Gas (LPG) peaking facility;

and

advance economic development in West Central Wisconsin.

Need

Traditional Firm System Sales Requirements and Supply Challenges

Traditional Firm System Sales are comprised of residential and business customers who rely on Wisconsin Gas to provide reliable 24/7 gas service 365 days per year. Wisconsin Gas is obligated to serve the needs of these customers, especially on the coldest days of the year (usually the time when Firm System Sales demand is at its highest level, i.e., Peak Day).

Wisconsin Gas purchases natural gas supply and contracts with pipeline service providers to transport the gas to its distribution system network. Wisconsin Gas currently purchases Firm Transportation Capacity from NNG (Contracted Capacity) with firm delivery rights to its markets in West Central Wisconsin. The term “Reserve Margin” is used to quantify the difference by which Contracted Capacity exceeds forecasted Peak Day demand. Typically, on a system wide basis, Wisconsin Gas maintains a Reserve Margin at or around 5% of

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Peak Day demand to cover unanticipated growth, forecast error, unexpected conditions or system upsets.

When the Reserve Margin is negative, and a Peak Day occurs, gas service to residents and businesses can be degraded to the point where firm gas transportation service is subject to curtailment.2

In light of the limited gas supply challenges it faces in West Central Wisconsin, Wisconsin Gas has traditionally held slightly higher capacity Reserve Margins to this area than in the other areas its serves. In fact, over the past five years, because of the limited availability of capacity on the NNG system, the high costs associated with expansion of NNG’s system and long lead times required to initiate expansion facility projects, Wisconsin Gas has maintained average capacity reserves of approximately 8% into markets in this area. The addition of new pipeline capacity provided by the West Central Lateral will enable the Company to reduce its capacity reserve to these markets to the target system level of 5% on an ongoing basis. This reduction in Reserve Margin from 8% to 5% will deliver cost savings for Wisconsin Gas and its customers moving forward.

The charts below provide a comparison of Wisconsin Gas’ current Contracted Capacity versus forecasted Firm System Sales Peak Day requirements3 for its Black River Falls and Tomah service areas. These charts clearly indicate a projected shortfall in Contracted Capacity at Black River Falls in the year 2015 and at Tomah in the year 2017. Additionally, Wisconsin Gas’ target Reserve Margin of 5% of Peak Day demand is breached in the winter of 2012-13 at Black River Falls and 2014-15 at Tomah. As a result, Wisconsin Gas has determined that additional pipeline transportation capacity is needed to continue to meet Firm System Sales requirements in these areas in future years. Since existing NNG facilities serving these areas are fully subscribed and constrained, new facilities will have to be built in order to meet these growing Firm System Sales requirements.

2 It is important to note that this is a physical limitation. Gas at any price (penalty gas or over-takes)

is not available from NNG. Therefore, curtailment would be the only option once the peaking unit is exhausted.

3 2013 Consensus forecast.

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Figure 2 – Black River Falls Capacity vs. Peak Demand

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Figure 3 – Tomah Capacity vs. Peak Demand

The values in the charts above and conclusions which can be drawn are highly sensitive to industrial and commercial customers’ gas supply decisions. For example, if one industrial customer elects to become a Firm System Sales customer, Firm Peak Day sales could jump up 1000 Dth/day. Recently a customer made such a decision, adding 200 Dth/day to Firm Peak Day demand.

Since NNG’s service laterals are fully subscribed, in order to meet Wisconsin Gas future demand requirements utilizing NNG’s existing infrastructure, Wisconsin Gas requested costs estimates from NNG to implement expansion projects in recent years. Recent quotes from NNG for such incremental expansions demonstrate just how costly those expansion costs to meet incremental demand have become. For example, Wisconsin Gas submitted a service realignment request to NNG to realign 2,550 Dth/day of existing Firm Transportation Capacity rights to these areas in 2011. NNG provided a quote of

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approximately $[ Redacted ] to install facilities required to realign this capacity (see Figure 1). By way of contrast, if this capacity were needed in a non-constrained area (i.e. capacity on NNG was available), Wisconsin Gas would expect to incur far less expensive realignment costs on the order of $[ Redacted ] depending upon the need to upgrade measurement and/or regulation facilities at the delivery gate station.

Faced with the ongoing need to incur significant expansion costs to support each increment of future demand growth on the NNG system to its customers in western Wisconsin, Wisconsin Gas chose to study other alternatives to meet this demand growth in the most cost effective manner, including alternative providers. This analysis resulted in Company’s decision to pursue construction of the West Central Lateral and is more fully described in Section 3.2.

The West Central Lateral will enable Wisconsin Gas to secure a new source of supply that will deliver the needed Firm Transportation Capacity to keep pace with demand; and ensure system reliability in this area of western Wisconsin.

As part of its needs analysis, Wisconsin Gas considered whether or not to expand its existing LPG plant in Tomah, Wisconsin to meet incremental demand requirements. This alternative, however, is not a viable long term option to meet the growing demand of this market due to mixing requirements of natural gas and LPG supplies. In order to maintain an acceptable delivered gas composition, the LPG quantity cannot exceed 50% of the delivered gas quantity to consumers. The Tomah LPG plant currently provides the capability to deliver up to 2,960 Dth per day of LPG to Wisconsin Gas’ Tomah gas distribution system. Today, the LPG plant’s deliverability represents more than 40% of the 7,000 Dth/day of the forecasted Peak Day demand of the Tomah gas distribution system and is further limited by inventory to two days of backup service. Because an expanded LPG facility could not provide more than 50% of the delivered gas quantity to this location, expansions of this facility beyond 50% of Peak Day demand would also require equivalent distribution system expansions (new construction) to maintain the appropriate gas composition. Further, the Tomah LPG plant is located behind the Tomah TBS and can only deliver LPG to the distribution system behind this TBS. Therefore, expansion of this plant is not a long term solution absent pipeline capacity expansions.

Commercial and Industrial Demand Requirements

In addition to Firm System Sales Peak Demand growth, western Wisconsin is also experiencing steady growth in natural gas demand to support growing commercial and industrial requirements, including the growth associated with industrial [frac] sand development projects. The challenge facing Wisconsin Gas in meeting this growing demand remains the same--large portions of West Central Wisconsin are served by a single service provider, NNG--and are utilizing delivery laterals that are fully subscribed. The cost to develop new facilities required to meet incremental industrial/commercial demand via the existing NNG system is substantial and some cases is deterring economic growth in the area.

For example, during the fourth quarter of 2011, an industrial sand plant developer sought to become a Wisconsin Gas transportation service customer and submitted a service request for 2,000 Dth/day of new Firm Transportation Capacity to a delivery point located behind

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NNG’s Hixton TBS on NNG’s Black River Falls Lateral. In response, NNG provided a quote of approximately $[ Redacted ] to install the expansion facilities required to serve this customer (see Figure 1). To place this cost into perspective, the NNG expansion costs of $[ Redacted ] represented more than a 40% cost premium to build the plant in the absence of such an expensive natural gas facility expansion requirement. The potential customer later advised Wisconsin Gas that the additional cost to secure natural gas service was prohibitive and as a result, this customer has since cancelled this project.

This recent experience with the frac sand developer illustrates the challenge Wisconsin Gas faces in addressing the continuing growth in commercial and industrial natural gas demand in the absence of additional incremental pipeline capacity.

The largest contributor to commercial and industrial demand in the area is projected to come from industrial sand processing facilities. As shown in Figure 4 below, the West Central Lateral would traverse an area of potential growth in industrial sand mining and processing. Wisconsin Gas has already received letters of support from existing and potential commercial and industrial companies in the area as discussed in Section 3.2.6, Stakeholder and landowner Interactions.

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Figure 4 – Mine/Processing Plants and West Central Lateral

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Figure 5, below is Wisconsin Gas’ projection of industrial/commercial demand growth that could be facilitated by the West Central Lateral. Typical industrial [frac] sand processing facilities use from 850 to 2,000 Dth/day of natural gas, depending upon the size of the facility.

Figure 5 – Projected Commercial & Industrial Demand

Wisconsin Gas also sees additional demand in this area rising in other key sectors of the economy:

Agriculture: A number of farming operations have expressed interest in natural gas to fuel existing or planned grain dryers;

Recreation/ Hospitality: The Three Bears Lodge located close to the planned route of the West Central Lateral in Warrens, Wisconsin would realize significant energy cost savings by shifting to natural gas fuel;

Transportation: With the growing affordability of natural gas, natural gas could be used as fuel for commercial truck fleets and individual vehicles as the natural gas vehicle (NGV) market grows in the coming years. Most NGV professionals point to the price spread between diesel and compressed natural gas (CNG) and liquefied natural gas (LNG) as the most important factor in fleet adoption of NGVs. Wisconsin Gas has seen increased demand for CNG fueling stations and provided service for 2 new public refueling stations in 2012 which are on track to require about 500,000 therms of natural gas per station annually. A Wisconsin convenience store operator which has plans to add 2 additional CNG refueling stations in 2013 and is also targeting 2 additional sites within the vicinity of the West Central Lateral.

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Introduce a Second Service Provider to West Central Wisconsin

As illustrated in Figure 6 below, construction of the West Central Lateral will introduce a second natural gas transportation service provider to West Central Wisconsin which will serve to eliminate the current reliance on a single, constrained service provider. In addition to meeting the future natural gas demand requirements to the region, introduction of a second service provider will also (i) introduce competitive access to pipeline services, (ii) enhance service reliability and (iii) provide Wisconsin Gas with the opportunity to replace upstream NNG Transportation capacity with less expensive transportation capacity on the Viking Gas Transmission pipeline system. The existence of this competition will provide opportunities for competitive alternatives for supplies and services for many years into the future.

Figure 6 – Infrastructure with West Central Lateral

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Enhance Service Reliability

As is the case with any pipeline system designed to operate at or near capacity in meeting contractual delivery obligations, the interruption or loss of deliveries from upstream pipeline systems or the interruption or loss of localized compression or transmission facilities will, to varying degrees, affect the ability of that interstate system to meet the service requirements of its customers (e.g. 2003 NNG Chatfield Compressor incident; 2009 Black River Falls third-party, lateral hit).4

For example, the loss of an un-looped section of a delivery lateral, such as NNG’s Black River Falls or Tomah laterals could result in the loss of 100% of delivery capacity to points downstream of the affected segment of the lateral. Additionally, the loss of a compressor or a single loop of a multi-loop portion of NNG’s mainline could result in the loss of a portion of capacity to downstream markets.

The construction of the West Central Lateral will provide an improvement in reliability should these types of events occur.

The West Central Project will provide a second source of natural gas deliveries to West Central Wisconsin which today relies on natural gas deliveries from a single service provider, NNG. As such, the addition of the West Central Lateral infrastructure will unquestionably improve the reliability and security of natural gas deliveries to these market areas. From a regional standpoint, as the West Central Lateral represents new pipeline capacity to the area, by definition it increases natural gas transmission capacity and therefore reliability of natural gas service throughout West Central Wisconsin. From a more specific and local viewpoint, the construction of the West Central Lateral provides an additional source of natural gas supply in the event of an outage on either of NNG’s approximately 120 mile long Black River Falls lateral or NNG’s approximately 155 mile long Tomah lateral. Further, as it will provide an additional source of supply not reliant upon NNG’s mainline, the West Central Lateral will also provide protection against the loss of capacity due to a pipe outage or compressor station outage on NNG’s mainline resulting in a restriction in capacity available on NNG’s system. Finally, it will make available additional storage capacity from the Viking Gas and ANR systems.5

Displace More Costly Upstream Capacity

While the primary driver leading to the proposed construction of the West Central Lateral is the need for incremental capacity to the region, the installation of this second service provider to the region will also provide an opportunity for Wisconsin Gas to displace a portion of its contracted NNG pipeline capacity with less expensive Viking Gas capacity.

Provide natural gas service to municipalities that currently have none

The route of the proposed West Central Lateral runs through various municipalities where there is currently no existing natural gas delivery infrastructure. In comparison to alternate

4 In 2003, 2008, 2009 flows on single-feed laterals in Western WI were materially impacted by

upstream incidents.

5 Storage capacity is important as it provides operational flexibility to meet peak winter demands.

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fuel supply options such as propane, delivered natural gas service would result in a significant cost savings to consumers in these municipalities. In fact, Wisconsin Gas’ average delivered price of natural gas to residential consumers during the 2011-2012 winter season was approximately $8.05 per Dekatherm. In comparison, the average delivered Propane Price to Wisconsin residential consumers during this same winter was approximately $21.96 per Dekatherm equivalent.6 Thus, if natural gas service had been available to consumers in these municipalities in the 2011-12 winter, these customers would have had the potential to reduce energy costs by more than 50%.

As part of this application, Wisconsin Gas LLC requests authority to provide natural gas service in the towns and villages listed below in the counties of Clark, Eau Claire, Jackson and Monroe pursuant to § 196.49, Wis. Stats., and § PSC 133.03 (1) (a), Wis. Adm. Code.

Table 7 – Proposed Franchises

Towns Villages

Fairchild Fairchild

Foster Warrens

Cleveland

Garden Valley

Manchester

Millston

Grant

Lincoln

Mentor

The proposed West Central Lateral routes will traverse these municipalities as well as others that are already served by Wisconsin Gas (See Figure 7 below). The Company will provide service upon request in these municipalities in accordance with extension rules or will request Certificates of Authority from the Commission where required. Due to the location of the proposed Lateral, the only natural gas utility reasonably capable of providing cost effective service is Wisconsin Gas. Any other natural gas utility would have to take extraordinary measures to extend service to these areas. The Company has requested Resolutions from the Towns and Villages along the proposed routes. Those we have received as of the time of filing are provided in Appendix G – Gas Distribution System Resolutions. Additional Resolutions will be filed as a supplement to that Appendix when received.

6 Propane price reflects average price of the “Weekly Wisconsin Propane Residential Prices” as

published by the Energy Information Administration (“EIA”) of the US Department of Energy. Propane prices are reported by the EIA in prices of $ per gallon and have been converted to $ per Dekatherm equivalent based upon conversion factors of 91,500 Btu/gallon of propane and 1 Dekatherm per MMBtu heat value equivalent.

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Figure 7 – Proposed Franchises

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Advance Economic Development in western Wisconsin

Our nation is experiencing substantial growth in the use of natural gas, due primarily to the increased affordability and availability of this resource. One immediate benefit of the West Central Lateral is that it will offer the capability of delivering natural gas today to portions of the state that either have no natural gas service at all or receive service via NNG laterals that are fully subscribed. The introduction of affordable natural gas will help advance economic development in western Wisconsin.

For municipalities that currently have no access to natural gas service the introduction of affordable natural gas via the West Central Lateral will likely displace more expensive propane providing a significant energy cost savings to consumers in the area. These cost savings could serve to promote economic development as the savings have the potential to increase disposable household income in the area as well as increase economic efficiency of local businesses. Further, competition from natural gas could also serve to exert competitive downward pressure on delivered propane prices in the area resulting in further cost savings for local consumers.

For the areas currently receiving natural gas service via the fully subscribed NNG laterals, the West Central Lateral will provide access to available pipeline capacity and natural gas supplies. This one time construction of the West Central Lateral will provide access to available natural gas supplies for many years to come and will represent a significant upgrade to the current environment in which additional natural gas demand can only be served via planned incremental expansions of the NNG system. This availability of natural gas supply could well lead to economic development growth in the region as available energy sources are a key driver in economic development decisions.

As discussed above, the West Central Lateral supports the future development of industrial [frac] sand processing facilities in the region. Development of a typical facility results delivers the following benefits to the economy7:

Construction Spending of $20 - $40 million, with spending rising to as much as $100

million if a resin coating facility is also included;

Construction jobs during plant development; and

Permanent jobs for the area with each plant adding 50 – 80 jobs for a processing

plant as well as around 10 or more jobs for mining and transportation activities.

Wisconsin Gas anticipates continued growth in demand for industrial sand to support gas and oil well development with a corresponding growth in mining and processing in Wisconsin. If the Project is built, the development of industrial [frac] sand processing operations in the West Central area would be facilitated. While it is difficult to predict the quantity and timing of these new operations, the Company believes the equivalent of five (5) large (2,000 Dth/day) sand processing operations are likely to develop over the first 6 years of operation; potentially creating about 300 to 450 permanent jobs.

7Wisconsin Department of Natural Resources, Silica Sand Mining in Wisconsin, January 2012.

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In addition to the direct spending, economic development on this level is likely to have secondary impacts on the local economy both through the initial investments and through spending of disposable income by those hired into the jobs created at the facilities.

Finally, the construction of the West Central Lateral itself will lead to 375 to 400 construction jobs in the area for the duration of the construction process.

Benefits to West Central Wisconsin

When completed, the West Central Lateral will provide a new supply of natural gas to meet anticipated load growth in West Central Wisconsin. Further, the introduction of a new independently routed pipeline will serve to enhance service reliability to these areas. Finally, the Project will introduce pipeline competition to areas in West Central Wisconsin currently served by a single pipeline, providing a competitive, lower cost choice between two pipeline service providers to Wisconsin Gas and its customers.

3.1.4 How the Project Relates to Future Projects in the Area

The West Central Lateral is planned to be in service in 2015. This application is limited to requesting approval for the West Central Lateral Project. Five (5) additional extensions staged-in over the subsequent seventeen (17) year period are anticipated; these extensions will be the subject of future applications to PSC for approval as appropriate.

The initial construction of the West Central Lateral and associated distribution facilities proposed in this filing will provide an additional source of natural gas to Augusta, Hixton, Black River Falls and Tomah (referred to as Connected Markets); addressing Wisconsin Gas’ most near-term needs and setting the foundation for longer-term extensions as currently foreseen. Initial construction of the West Central Lateral also introduces the availability of natural gas service to the Villages of Warrens and Fairchild that have no existing natural gas service.

Similar to the Connected Markets, Wisconsin Gas serves a number of other Firm System Sales markets upstream of these markets along NNG’s constrained Tomah and Black River Falls Laterals (referred to as Future-Connected Markets). These markets include Sparta, McCoy, Taylor, Blair, Osseo, Bangor, West Salem and Pigeon Falls.

Upon completion of the West Central Lateral, Wisconsin Gas will initially support growth at the Future-Connected Markets via the use of displaced Firm Transportation Capacity previously dedicated to the Connected Markets. Over time, as capacity requirements at the Future-Connected markets continues to grow, Wisconsin Gas plans to optimize the economic benefits for its customers via the extension and expansion of the West Central Lateral as required to connect the Future-Connected Markets to the project to meet ongoing demand growth requirements at these markets.

Based upon current forecasted demand growth requirements in the West Central Wisconsin area, the table below illustrates Wisconsin Gas’ projection of the timing associated with the installation of each of these anticipated future extension facilities.

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Table 8 – Potential Future Projects

Facility Installation Estimated

Length

Projected Installation

Year Future-Connected Markets

Tomah to Sparta 16.0 Miles 2019 Sparta and Fort McCoy

Hixton to Taylor and Blair 18.4 Miles 2023 Taylor, Blair

Augusta to Osseo 11.6 Miles 2024 Osseo

Sparta to Bangor & West Salem 14.4 Miles 2030 Bangor, West Salem

Taylor to Pigeon Falls 10.1 Miles 2032 Pigeon Falls

Receipt Point Compression N/A 2032 N/A

Wisconsin Gas has based the forecasted installation dates associated with these future facilities upon current demand growth forecasts. As such, the actual in service dates for facilities projected to be installed in 2019 and beyond may vary based upon the variance between current forecasts and actual future market conditions.

The installation dates of the facilities identified in the table above have been developed based upon Wisconsin Gas’ current forecasted demand growth and are representative of projected investments included within the life cycle economic models of the Project. However, as noted above, Wisconsin Gas is not requesting approval of these extension facilities at this time.

Facilities to be constructed in later years (after 2015) will be subject to distinct investment decisions that will have to stand on their own merit at the time of investment. Thus, each subsequent extension illustrated in the table will be subject to Wisconsin Gas’ internal evaluation process to insure that it is the most cost effective strategy for Wisconsin Gas’ customers at the time of investment. Further, as these projects each represent distinct project investments, Wisconsin Gas recognizes that each will be subject to its own future regulatory process and PSC approval process where applicable.

Measured expansion will moderate Wisconsin Gas’ and its customers’ exposure to future investment costs and will enable Wisconsin Gas to tailor its approach to meet future demand growth as it occurs. If actual demand growth varies versus current forecasts, the lateral lines in the table could potentially (i) be installed earlier than projected; (ii) be installed later than projected; or (iii) not be installed at all. Further, if demand growth occurs in areas not currently included in the forecast, Wisconsin Gas would be prepared to install alternate laterals not currently included in the life cycle projections.

3.1.5 Effect of Project on Cost of Operation and Reliability

The construction of the West Central Lateral brings an additional independent source of gas supply to an area of West Central Wisconsin currently served by a single pipeline service provider. This introduction of an additional service provider will foster competition, resulting in improved choices and opportunities for Wisconsin Gas and its customers.

Wisconsin Gas’ service areas in West Central Wisconsin currently receive natural gas service via lengthy (120 mile +) small diameter delivery laterals operated by NNG. With no other current alternate source of supply, any interruptions along these service laterals can result in a loss of service to these West Central markets. The introduction of a second source of natural gas supply via the West Central Lateral will provide a reliability improvement to these markets.

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Construction and operation of the West Central Lateral will increase the cost of operation due to the need to operate and maintain the new facilities. However, as indicated in Section 3.1.8 Economic Evaluation, these incremental costs of operation will be more than offset by the gas cost and transportation cost savings provided by the West Central Lateral.

Wisconsin Gas has determined that the proposed Project is the most appropriate means to meet its obligations as a public utility. The proposed facilities are necessary to meet growing demands of the Company’s natural gas customers. The proposed facilities meet this need and do not provide facilities in excess of probable future requirements. As such, when placed in operation, the proposed facilities will not result in annual costs disproportionate to the service value of the work performed or the quantity of service available.

3.1.6 Cost and Method of Financing

The estimated capital cost is presented in the two tables below. Table 9 provides the cost estimate for the lateral alone to facilitate a direct comparison between the West Central Lateral and the other system level alternatives (i.e., competing proposals). The distribution costs which would be incurred regardless of the proposal selected are presented in Table 10.

The estimated capital cost of the West Central Lateral by facility type is as follows:

Table 9 – West Central Lateral Cost

Route A Route B

Gate Station $ 4,022,000 $ 4,022,000

Land 3,731,000 3,731,000

Main 162,776,000 173,035,000

Structures 500,000 500,000

Subtotal 171,029,000 181,288,000

AFUDC 6,973,000 7,430,000

Total $178,002,000 $188,718,000

The cost of distribution facilities including five (5) regulator stations and distribution pipe line required to connect to Wisconsin Gas’ existing distribution networks are as follows:

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Table 10 – Distribution Facilities Cost

Route A Route B

Regulator Station $3,048,000 $3,048,000

Land (Regulator Station) 81,000 81,000

Main 1,171,000 961,000

Structures 86,000 86,000

Subtotal 4,386,000 4,176,000

AFUDC 157,000 148,000

Total $4,543,000 $4,324,000

The cost of this Project will be met from internal sources and/or the issuance and sale of securities.

3.1.7 Description and Cost of Property Replaced or Retired

Installation of the proposed 8-inch 60 psig distribution main along STH 54 in the City of Black River Falls, Segment 13, will result in approximately 1,317 feet of existing 60 psig distribution main being retired as shown in the Table 11, below. The existing main shown below is located within the existing STH 54 road ROW. The estimated cost of the property to be retired is $4,639.40.

Table 11 –Property to be Retired

Main Size

Main Material Type

Installation Year Length (ft) Net Book Value

2" Plastic 1997 873 $22.30

4" Steel 1972 444 $4,617.10

$4,639.40

3.1.8 Economic Evaluation

As discussed in Section 3.2.1, economic evaluations of system alternatives were performed to determine the best approach to meeting the Company’s projected demand growth. To test whether the gas cost savings projections associated with the West Central Lateral project remain intact, an updated gas cost savings analysis of the West Central Lateral was performed using conditions and assumptions prevailing in March 2013. The details of that analysis are provided in the Updated Gas Cost Savings Analyses report contained in Appendix A – Economics.

The updated analysis confirmed that the West Central Lateral provides significant gas cost savings to the Wisconsin Gas and its customers when compared with the alternative of ongoing stepped expansions of the existing NNG system.

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For Route A, the West Central Lateral is projected to provide a net present value of gas cost savings of approximately $121.61 million when calculated using a 6.10% discount rate8,9 and $188.12 million when calculated using a 5.00% discount rate under the Base Case demand growth forecast.

For Route B, the West Central Lateral is projected to provide a net present value of gas cost savings of approximately $108.62 million when calculated using a 6.10% discount rate and $173.48 million when calculated using a 5.00% discount rate under the Base Case demand growth forecast.

3.1.9 Construction Schedule

Following PSC approval and the receipt of necessary permits and easements, construction of the Project is planned from the beginning of 2015 through October of 2015 in order to be in service for the winter of 2015/16. This schedule may be modified as necessary to address any constraints that are identified as the environmental screening proceeds. The Company will continue to work with the appropriate agencies in regards to any restriction windows for construction. Seasonal constraints to the construction schedule at this time are as follows:

Trout streams including the Mill Creek Fishery & Halls Creek Fishery Areas – construct during May 15th to September 15th to avoid disturbing any trout spawning activity in this area

To avoid or spread oak wilt, cutting, trimming, or pruning oak trees should be limited to a period from July 15 through April 1 south of the tension zone, and July 15 through April 15 north of the tension zone

USH12 & CTH EW – Warrens – limit construction activities in this area during the last weekend in September due to increased traffic associated with Warrens Cranberry Festival

A variety of potential seasonal constraints related to threatened and endangered species are under consideration. Data collected from species surveys conducted in 2013 will aid in determining which of the species seasonal considerations listed below will be considered when defining the specific schedule of construction activities in known rare species locations. Generally, the seasonal considerations are listed based on rare bird nesting periods and seasonally based activity for rare herptiles and invertebrates. Details of the seasonal constraints and recommended actions are included in the Endangered Resources Review that was prepared for the Project.

8 After-Tax Cost of Capital for Wisconsin Gas LLC as per the 2013 Test Year – PSC Approved

Capital Structure.

9 The discount rate applicable at the time of the bid evaluations was 6.89%. See Section 3.2.1.

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Table 12 – Rare Species Seasonal Constraints

Species: Dates:

Loggerhead Shrike April 16 – Aug. 15

Cerulean Warbler May 1 – Aug. 24

Red-Shouldered Hawk March 1 – July 31

Kirtland’s Warbler May 1 – Aug. 30

Bald Eagle Feb.15 – July 1

Kentucky Warbler May 16 – Aug. 15

Acadian Flycatcher May 1 – Aug. 31

Slender Glass Lizard Year round depending on proposed activity

Massasauga April 1 – Oct. 15 (active period) Oct. 16 – March 31 (hibernation period)

Blanding’s Turtle May 20 – Oct. 15 (nesting habitat) March 15 – Oct. 15 (foraging/breeding habitat) October 16 – March 14 (overwintering habitat)

Wood Turtle May 20 – July 5 (breeding habitat) May 20 – Sept. 18 (nesting habitat) March 15 – Oct. 15 (upland foraging habitat) Oct. 16 – March 14 (overwintering habitat)

Karner Blue Butterfly Late May – Early June (lupine surveys) Late May – Late June (1st flight period) Mid July – Late Aug. (2nd flight period)

If additional construction time constraints are added at a later date it could affect the construction costs associated with putting the Project in service for the winter of 2015-16.

3.1.10 Description of Construction Procedures

Gas pipeline construction will begin following receipt of all permits and right-of-way (ROW) acquisition. The actual construction will begin with work area preparation. Clearing and grading will be done if necessary to provide a level area to facilitate pipe-laying operations and transport of required construction equipment. The work will be done with minimal environmental disturbance.

Prior to trenching, standard precautions will be taken to identify and avoid disturbance to any existing underground utility lines that cross the ROW. Material excavated during trenching will be temporarily piled to one side of the ROW or acquired easement, with topsoil and subsoil separated, if applicable. Any material not suitable for backfill, or in excess, will be hauled to a suitable location. Proper erosion control practices will be employed to minimize erosion during trenching and construction activities. (See Erosion Control Work Procedures in Appendix C – Environmental Information).

Road and driveway crossings will be accomplished by either open-cut, where possible, or boring under roadways. Coordination with local officials to minimize traffic disruption will take place prior to construction. The timing of construction activities will be communicated to landowners surrounding the ROW or acquired easement to minimize disruptions. Roads and driveways crossed by open cutting will be repaved. Some ground disturbance,

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including brush-clearing, will be required along the proposed route to construct the pipeline. These activities are short-term, and any areas disturbed within the existing ROW or acquired easement will be revegetated and returned to preconstruction conditions.

Pipe sections will be delivered and positioned along the ROW or acquired easement. Pipe sections will be lined-up on supports and welded to form a continuous pipeline along the trench. A qualified inspector will visually and radiographically inspect completed welds. An external coating applied at the mill will protect piping. Following inspection, a coating will be field-applied to each weld joint. Coating on the rest of the pipe will be inspected and repaired as necessary.

The trench bottom will be inspected to ensure it is free of rock and debris. If required, sand or soil bedding material will be placed in the trench bottom. The pipeline will be lowered into the trench using side-boom tractors. A final inspection will ensure the pipeline is properly placed on the trench bottom that all bends conform to trench alignment, and pipe coating is not damaged. The trench will then be backfilled, using trench excavation material and then will be compacted. Compaction will avoid future settlement. ROW and acquired easement will be restored to preconstruction conditions. Surface grading will be done to re-establish natural contours, and re-vegetation will be compatible with preconstruction condition and adjacent vegetation patterns. The pipeline also will be hydrostatically tested and caliper pigged prior to service.

3.1.11 Association with a Proposed Power Plant

This Project is not associated with a power plant.

3.2 PROJECT DEVELOPMENT AND ALTERNATIVES CONSIDERED

3.2.1 Describe System Alternatives and Why Not Selected

To address the need described in Section 3.1.3, Wisconsin Gas sought solutions from entities it deemed capable of addressing that need. The Company established a competitive bid process and developed and issued a request for proposal (RFP) for pipeline transportation services to the area. Prior to the date that proposals were due to be received in response to the RFP, We Energies – Wholesale Energy and Fuels (WEAF) department developed a detailed matrix of economic criteria and non-economic criteria by which proposals would be evaluated. Upon receipt of proposals, these pre-determined evaluation criteria were utilized to develop comparative analyses of alternatives to serve the Company’s growing markets in West Central Wisconsin.

In addition, each proposal was evaluated against the approach of continuing ongoing, stepped expansions of the NNG system to meet growing demand requirements.

A detailed discussion of the RFP and bid evaluation process is contained in the report titled; “Wisconsin Gas LLC’s RFP Process, Bid Evaluation and Calculated Life Cycle Gas Cost Savings Associated with the West Central Wisconsin Project” (provided in Appendix A – Economics).

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Evaluation of Proposals

In response to the RFP, on May 8, 2012 WEAF received multiple responses from each of the four potential service providers. None of the responses proposed expansion of the existing NNG infrastructure.

Upon review of the proposals, WEAF concluded that from an economic perspective, the bid submitted by Wisconsin Gas LLC-Customer Operations (WG-CO) was the best and lowest cost solution for Wisconsin Gas. In addition, the WG-CO bid also scored highest among the bids submitted by the four bidders in an evaluation of the non-economic criteria impacting services.

WEAF also concluded in its economic evaluations that the WG-CO proposed solution that also accommodates possible future expansion (i.e., the RFP’s Case 3 + Expansion scenario) would provide Wisconsin Gas’ customers the best value with an approximate net present value savings (versus the cost of stepped NNG expansions) of $94 million (using a 6.89%10 discount rate) or $196 million (applying a 5.00% discount rate) under “base case” demand growth conditions.

For these reasons, WEAF concluded that the WG-CO proposal provided a greater benefit to Wisconsin Gas’ customers than (i) any of the alternate bid proposals received in response to the capacity RFP and (ii) the continued approach of stepped NNG expansions.

3.2.2 Factors Considered in Evaluating Possible Routes

The following factors and associated criteria were considered when determining the possible routes:

Agricultural Properties – Follow existing tree lines, property lines, section lines, and quarter-section lines to minimize bisecting properties where practical.

Archeological Sites – Avoid or minimize disturbance of known archeological sites such as Native American campsites or cemeteries.

Costs – Minimize overall project costs and potential impacts to ratepayers by considering the shortest length, ease of construction, and operational costs after consideration for potential environmental impacts.

Existing Structures – Maintain proper clearances from existing structures and avoid conflicts with underground utilities.

Existing Utility Corridors – Utilize existing previously disturbed corridors such as placing the main adjacent to roadways, railroads, and electric transmission lines.

Historical Sites – Avoid or minimize disturbance of known historical structures by avoidance, such as routing around the structures.

10

The discount rate has been updated for the economic evaluation of the Project described in Section 3.1.8.

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Land Use – Route pipeline with consideration for long term land use. Consider impact of construction practices and the effects of trenching, backfilling, and restoration on agricultural, commercial, residential, and recreational lands. Consider long term land use and zoning requirements in selection of station locations.

Property Owners – A route with fewer property owners reduces the impact on the public. This minimizes the number of temporary and permanent easements and the number of negotiations for access, and therefore may reduce costs.

Road Right-of-Way – In general, road ROW is not the first choice for placement of large diameter gas main due to the possibility of future replacement due to road reconstruction and the potential risk of third party damage from other utilities.. However, in some cases, it is the most reasonable location for short stretches to avoid obstacles on private property.

Rock Out Cropping – Avoid routing through quarries or rock outcroppings in upland fields where practical.

Threatened & Endangered Species – Minimize disruption to habitat communities that contain threatened and endangered species by routing around known species locations or by changes to construction methods used in those areas.

Wetlands & Waterbodies – Avoid or minimize impacts to wetlands by routing around wetlands when feasible, or by using construction methods to minimize impacts to both waterways and wetlands.

Workspace - Examine possible temporary workspace issues to minimize impacts to landowners and environmental concerns; lay down areas and additional workspace for horizontal directional drilling.

3.2.3 Identify Alternative Routes that Were Not Chosen

Several alternative route segments were reviewed and evaluated during the pre-application process. During pre-application meetings with the DNR and PSC, route maps were provided to identify routes that were considered but not chosen. These routes were discussed with the DNR and PSC during these meetings to determine which would likely be permittable. A desktop review was completed using GIS environmental data to gather information on potential wetland impacts and cultural resource areas for potential routes. Various routes were also reviewed in the field to determine construction feasibility and to identify any construction obstacles that were not viewable by aerial photography.

The project was broken up into smaller areas early in the route evaluation and selection process to aide in route comparison. These areas are identified in the table below and will be referenced in the discussion of the routes that were not chosen. Refer to the Alternate Routes Not Chosen Map in Appendix B – Maps for a visual of the routes discussed below.

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Table 13 – Routes Not Chosen

Project Areas Alternate Routes Not Chosen

Viking to Fairchild (includes delivery to Augusta) R.1, R.2, R.3, R.4

Fairchild to Black River Falls R.5, R.6, R.7, R.12

Black River Falls to Tomah R.7, R.8, R.9, R.10, R.11, R.13, R.14, R.15

Reviewed route R.1 was considered a potential alternate for the Viking to Fairchild area. This route starts at the Viking pipeline and STH 27 in the Town of Ludington and follows the existing STH 27 corridor through Augusta and then follows a combination of county and local road corridors south of Augusta to Fairchild. The total length is approximately 23.4 miles. This route requires approximately 11 more miles of 16-inch pipe over the proposed route which increases the number of landowners impacted and ultimately increases the overall project costs. This route also passes through mainly privately owned land whereas a good portion of the proposed routes are located on county owned land which reduces the number of landowners impacted. This route requires crossing the Eau Claire River at STH 27 which would be difficult construction due to the river depth and width compared to the Eau Claire River crossing for the proposed route. Photos of the Eau Claire River crossing at this location are shown below. This route would also require the installation of 16-inch pipe through the City of Augusta which would require urban construction and result in a significant impact to residents in an area that is already served with distribution main. Construction of this route would also have a significant impact on a major transportation corridor from Cadott to Augusta.

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R.1 - STH 27 & Eau Claire River

R.1 - STH 27 & Eau Clair River

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Reviewed route R.2 was considered as a potential alternate for the Viking to Fairchild area. It starts at the Viking pipeline and CTH G in the Town of Wilson and follows the CTH G corridor, south on Kelley Rd, cross country past CTH M, and then parallels an existing railroad corridor and some local roads in to Fairchild. The total length of 16-inch pipe that is required for this route is approximately 20 miles in addition to 1.7 miles of 6-inch pipe to extend to Augusta. This route would require approximately 5 miles more of 16-inch pipe over the proposed route. This route requires crossing the Eau Claire River at CTH G as shown in the photo below. The northern portion of this route impacts a state wildlife area. The wetland indicator data showed the presence of numerous wetlands along the majority of the railroad corridor.

R.2 - CTH G & Eau Claire River

Reviewed route R.3 was considered as an alternate to the railroad corridor portion of R.2. This route starts at CTH M and follows the USH12 corridor south to Fairchild. Again, this was an alternate to the railroad portion of this route but did not reduce the total length and still indicated the presence of numerous wetlands.

Reviewed route R.4 passes through the Village of Fairchild and was considered as a potential alternate for the proposed common segment (Route A & B) that is located on the east side of Fairchild. R.4 starts at N Camp Rd and runs south along CTH H into the Village of Fairchild to the railroad. It then runs south along the railroad and continues east along USH10 to the proposed route west of Fairview Rd. An environmental survey was completed for this route so an impact comparison between R.4 and the proposed route

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(along N Camp Rd from CTH H to USH10) could be performed. A map of the two routes is shown below along with Table 14 which compares the environmental impacts and other pertinent impacts of each route. In addition to the environmental and landowner impacts in Table 14, R.4 is estimated to cost approximately $1,900,000 more than the comparable proposed route.

Fairchild R.4 Route Comparison Map

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Table 14 – Fairchild R.4 Route Comparison

Fairchild Reviewed (R.4) Fairchild Proposed

Wetland Count 13 6

Wetland Total Distances (ft) 10,936 5,526

Distance of Wetland Impact - Excludes Bores (ft)

Category 1 3,915 917

Category 2 1,667 1,936

Category 3 0 3

Category 4 0 0

Area of Wetland Impact - Excludes Bores (acres)

Category 1 6.74 1.58

Category 2 2.87 3.33

Category 3 0.00 0.01

Category 4 0.00 0.00

Stream Crossing Count - Bore (ft) 1 0

Stream Crossing Count - Trench (ft) 7 0

Potential Endangered Resource Areas (ft) 6,176 802

Other Factors 22 Buildings w/in 100' 2 Building w/in 100'

Newly Paved Roads

Park/Playground

1,800' ROW

Reviewed route R.5 was considered as a potential alternate for a portion of the Fairchild to Black River Falls area. It extends from Fairchild to about 6 miles north of Black River Falls. It starts at Fairview Rd and follows the USH10 corridor east and runs south along USH12 through Humbird and Merrillan to Garage Rd in the Town of Alma. This route would require urban construction through both Humbird and the Village of Merrillan resulting in a significant impact to the residents and businesses. The route is also located over 5 miles east of the desired connection to the existing Hixton distribution system. There are two cemeteries located along this route just north of Humbird and on the south side of Merrillan. The route also includes various stream (some trout streams) and waterway crossings. Construction of this route would also have a significant impact on a major transportation corridor between Fairchild and Black River Falls.

Reviewed route R.6 was considered as a potential alternate for a portion of the Fairchild to Black River Falls area. It starts from USH12 in Humbird and follows the CTH F corridor south through the Village of Alma Center, runs east along Oak Grove Rd and W & E Snow Creek Rd to USH12 in the Town of Adams. This route requires urban construction through Humbird and the Village of Alma Center resulting in a significant impact to businesses and

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residents. The portion of this route along W and E Snow Creek Rd is a fairly narrow corridor with various hills, sharp curves, and rock outcroppings indicating that the likelihood of encountering rock in the area is high.

Reviewed route R.7 was considered as a potential alternate to the two proposed routes located on the east side of Black River Falls and cross the Black River north of the City. This route is located on the west side of Black River Falls and crosses the Black River south of the City. This route continues south along CTH F from R.6, crosses I-94, follows numerous local roads until it crosses STH 54 and the Black River in the Town of Albion, and finally ends at STH 27 in the Town of Brockway. Constructability of the portion of this route that follows the CTH F corridor would be difficult given the hilly landscape, drastic grade changes, and the presence of several rock outcroppings. The photos below show the typical landscape along this portion of the route. The portion of the route that is south of I-94 crosses/parallels various streams based on the wetland indicator data available. The location of this route is also not near the desired station location on the east side of Black River Falls.

R.7 - CTH F & Prince Rd (Looking South)

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R.7 - CTH F & Prince (Looking North)

Reviewed route R.8 was considered as a potential alternate for the area between Black River Falls and Tomah. It starts at the proposed Route B (along existing electrical transmission corridor) and Levis Creek Rd in the City of Black River Falls and continues southwest along Winnebago Ave crossing I-94 to STH 54, south along STH 27 through Cataract, south along either CTH B or STH 27 to Sparta, and then east along STH 21 through Fort McCoy to Tomah. This route length is approximately 10 miles longer than the proposed route from Black River Falls to Tomah. Much of the route along STH 27 passes through very hilly terrain with many rock outcroppings as shown in the photo below. Construction of 12-inch steel pipe through the City of Black River Falls would also be required resulting in more of an impact to the residents and businesses in this area. The portion of the route along STH 21 through Fort McCoy would most likely need to be installed within road ROW or require an extended land acquisition process for federally owned land if easements were pursued in this area.

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R.8 - STH 27, N of Acorn Ave

Reviewed route R.9 when combined with the northern portion of R.8 was considered a potential alternate for the area between Black River Falls and Millston. This route would include a portion of R.8 as mentioned above and continue east from STH 27 along CTH O to Millston. The northern portion of this route would still be located through the City of Black River Falls and result in greater landowner impacts in this area than the proposed routes. A portion of the STH 27 route includes various high quality wetlands including one that is over 4,000 feet long. This route is approximately 8 miles longer than the proposed Route B and almost 5 miles longer than the proposed Route A which increases the total project cost.

Reviewed route R.10 was considered as a potential alternate for the area between Black River Falls and Tomah. It starts at the intersection of I-94 and the railroad corridor in the Town of Brockway and follows the I-94 corridor southeast through Millston to just north of Tomah. Through correspondence with the Wisconsin Department of Transportation (WDOT), it was determined that the Utility Accomodation Policy does not allow longitudinal gas installations within Interstates, freeways, and other controlled access highways. Furthermore, the WDOT stated that they will not support the placement of the proposed Project on such a critical infrastructure element such as an interstate highway. Therefore, the only option for placement of our facilities along I-94 would be adjacent to the I-94 corridor. Through further discussions with the WDOT it was determined that there are numerous scenic easements adjacent to the I-94 ROW from Black River Falls to Tomah which limit or prohibit tree removal. The purpose of scenic easements is to preserve the scenic qualities of the area. This route would require the clearing of trees along I-94 reducing the scenic aesthetics of this highly traveled and scenic interstate freeway and

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therefore result in a greater impact on the public. In addition to various wetlands along this route, a wetland over 2 miles long is located along the northern portion of this project.

Reviewed route R.11 was considered as a potential alternate to the common proposed segment through Millston. This route starts from the proposed Route A at Stanton Creek Rd and runs south along an ATV trail to CTH O, southwest along CTH O to Cranmar Rd, southeast along Cranmar Rd, southwest along an existing transmission corridor crossing I-94 to the proposed route at USH12. Almost the entire route is located within the Black River State Forest property which is a LAWCON11 federally funded property. This route was originally included as a proposed route until it was determined through a meeting with the Black River State Forest Administrator that clearing trees along this highly utilized and scenic ATV trail would be considered a recreational land use conversion triggering the federal LAWCON process. There are also two trout stream crossings with adjacent wetlands along this 1 mile route.

Reviewed route R.12 was considered as a potential alternate to the common proposed segment from Prindle Rd and E Snow Creek Rd that runs east along the electrical corridor and then south along Arnold Rd to Carol Rd in the Town of Alma (a portion of segments 4 & 5). This route starts at the intersection of Prindle Rd & E Snow Creek Rd and runs south along E Snow Creek Rd to Carol Rd. It then continues east along Carol Rd to Arnold Rd. This route would impact a greater number of landowners compared to the proposed route. The southern portion of E Snow Creek Rd consists of steep slopes and grade changes which would make construction difficult along this portion of the route. A photo showing the grade changes along this portion of the route is included below.

11

"LAWCON" means land and water conservation fund act of 1965; A federal program administered by the state.

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R.12 - E Snow Creek, W of Carol

Reviewed route R.13 was considered as a potential alternate to the portion of A.7 that runs south from Bauer Rd along an ATV trail to Castle Mound Rd and then east along Castle Mound Rd to Brockway Rd. Route R.13 starts at the intersection of Bauer Rd and the ATV trail and continues east along Bauer Rd and then south along Brockway Rd to Castle Mound Rd. This route passes through the Bauer-Brockway Barrens State Natural Area (SNA) which includes a 40 acre legally dedicated parcel. It was determined through a meeting held with the DNR that this route would only be permittable if the portion passing through the SNA was horizontally directional drilled to minimize the habitat disturbance. The meeting notes from this meeting are included in Appendix D – Agency Correspondence. The length requiring an HDD construction method within the SNA is approximately 3,900 feet which increases the costs such that it is no longer the least cost alternative. In addition to not being the least cost alternative, the route would still be located within the SNA area and impact the various wetlands along both Bauer Rd and Brockway Rd. The photo below shows Bauer-Brockway Barrens SNA which is located both to the south and north of Bauer Rd.

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R.13 - Bauer Rd & Brockway Rd Looking West

Reviewed route R.14, in combination with the Brockway Rd portion of R.13, was considered as a potential alternate to the northern portion of A.7 from the Black River Falls DR to Brockway Rd & Castle Mound Rd. Route R.14 starts near the Black River Falls DR and then runs east and south along Airport Rd (west of the RR), east along an abandoned railroad corridor to Brockway Rd, south along Brockway Rd to Bauer Rd and then continue south along Brockway Rd to Castle Mound Rd (R.13). This route is in close proximity to a Higher Education Headstart/Pre-K-12 facility and a correctional facility. This route also impacts the various wetlands located along Brockway Rd and requires crossing Indian Grave Creek twice, once along the abandoned railroad and once along Brockway Rd.

Reviewed route R.15, in combination with the Brockway Rd portions of R.13 and R.14, was considered as a potential alternate to the northern portion of A.7 near the Black River Falls DR to Brockway Rd & Castle Mound Rd. Route R.15 starts at the intersection of the railroad and the NNG pipeline located approximately 3,600’ northwest of the Black River Falls DR and continues southeast along the NNG pipeline corridor to Brockway Rd where it would continue south along Brockway Rd to Castle Mound Rd (R.13 & R.14). This route would require relocating the Black River Falls DR further northeast along STH 54 which would result in approximately 3,500 more feet of 8-inch distribution main. Construction between the homes located near Leicht Rd would be difficult due to the various houses in close proximity to the existing NNG pipeline corridor. This route also passes through the Department of Corrections property. If the project were to reroute around the Department

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of Corrections property, it would be located on Ho-Chunk trust property. This route also impacts the various wetlands located along Brockway Rd and requires crossing Indian Grave Creek twice, once along the NNG pipeline corridor and once along Brockway Rd. Approximately 3,000’ of the NNG pipeline portion of the route runs parallel or alongside Indian Grave Creek which would make construction difficult and costly along this section.

In addition to the routes discussed above, there are various smaller alternate segments that were reviewed but not chosen based on their location, length, cost, environmental impacts, construction feasibility, and narrow or non-existent construction corridors.

3.2.4 Description of Public Communications

A multi-faceted communication outreach effort has been initiated to inform and educate those affected by the proposed West Central Lateral. This effort includes, but is not limited to, the following activities:

Meetings to inform and educate stakeholders, including: employees, businesses, and state and local governments

Informational briefings and meetings with landowners

Informational mailings

Website dedicated to information regarding the project: http://www.we-energies.com/home/projects/ngaslateralinfo.htm

The Company has established a dedicated Project section on the We Energies website and a “hotline” phone number used specifically for answering West Central Lateral project questions. The Company is committed to providing various forums to answer questions regarding the Project, as well as to address concerns area residents may have.

To date, the Company’s public outreach has included:

Meeting with local officials in the Project areas to provide an overview.

Hosting open house meetings for the public.

Contacts with local businesses.

For copies of outreach mailings, visuals and handouts, see Appendix E – Public Information.

3.2.5 Pre-Application Activities with PSC and DNR

The Company has complied with the pre-application provisions of section 30.025, Wis. Stats. and Wis. Admin. Code PSC 133.05, in preparing this application.

Section 30.025, Wis. Stats., Permit procedure for utility facilities, establishes a pre-application process that involves early and active consultation among the applicant, DNR and PSC. Involvement of DNR at this stage is designed to enable the applicant to propose route(s) DNR deems “permittable” (i.e., the routes satisfy the statutory criteria for issuance by DNR of applicable permits), the Commission to approve DNR-permittable route(s), and

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DNR to issue the navigable waterway, stormwater discharge, and wetland permits for the Commission-approved route(s) within 30 days of the Commission’s CA decision.

The relevant provisions in this procedure are as follows:

1. Sec. 30.025 (lm) provides for active DNR involvement in the pre-application stage. DNR is to work with the project applicant and PSC staff to make a preliminary assessment of the project scope, make an analysis of alternatives, identify potential interested persons, and make the applicant aware of the permits that will be required, the information DNR will need to issue the permits, and the timing of those submittals.

2. Sec. 30.025(2g) provides for DNR participation in the Commission proceedings. DNR is to review each “route proposed for the utility facility, to assess whether each proposed… route can meet the criteria for proceeding under the authority of or obtaining the required permits, and shall provide that information to the commission.” DNR is to provide the Commission its assessment of the project in three categories: environmental issues, public rights in navigable waters; and route issues, including alternative routes.

3. Sec. 30.025(2s) provides that the Commission’s decision satisfies the requirement that there is no practicable alternative to the selected route.

4. Sec. 30.025(4) provides that DNR will grant or deny the applicable navigable waterway, stormwater discharge and wetland permits within 30 days of the Commission’s issuance of its CA decision.

Consistent with the provisions of ss. 30.025 (1m) and (2g), Wisconsin Gas has conducted an active pre-application process with DNR and PSC. The Company identified preliminary primary and alternate routes based on consideration of the factors listed in Section 3.2.2.

The Company, DNR and PSC staff met jointly on August 20, October 15, November 1 and December 6, 2012 and January 23, and January 29, 2013 in pre-application meetings. Numerous topical meetings were also arranged during the pre-application period.

These meetings included discussion of preliminary routes, including discussion of alternative routes or route portions. Based on DNR and PSC input, Wisconsin Gas eliminated certain preliminary routes and revised other portions of the route.

Based on the interaction with and feedback from DNR and PSC, the route alternatives have been finalized. As a result of the DNR and PSC input, Wisconsin Gas understands the routes presented in this application are permittable by DNR.

Another purpose of the pre-application meetings was for the agencies to consider and confirm the necessary field work, including threatened and endangered species review, and also identification of sites where more detailed environmental information would be needed to confirm permittability. As a result of these pre-application meetings, an agreement was reached with the agencies regarding the necessary review of threatened and endangered species (see Section 3.4.7 for more information on the outcome of these reviews). The agencies did not identify specific crossings for which site specific construction plans would be required as a part of this application. Typical construction cross sections have been developed and are included in Appendix H – Construction

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Figures. Site specific construction plans will be developed for certain road and water resource crossings during the detailed design of the selected route.

3.2.6 Stakeholder and landowner Interactions

Property Owner Contacts

In August 2012, municipalities along the proposed routes were informed of the West Central Lateral proposal and the plan to contact property owners to obtain permissions for environmental survey work.

The Company then met with property owners living along the proposed routes and calls were made to property owners not residing in the local area. The subject of these visits and calls was to provide an overview of the Project and obtain consent for environmental survey work.

Public Open Houses

In November 2012, “open house” public information meetings were held in Augusta, Warrens, Tomah and Black River Falls to provide property owners within a 400 foot corridor of the proposed routes the opportunity to learn more about the Project. Attendees were provided an overview of the Project and the route proposals. More than 100 people attended the information meetings. In addition to property owners, representatives from the following municipalities attended the information meetings: Eau Claire County, Town of Foster, Village of Fairchild, Town of Fairchild, City of Augusta, Town of Alma, City of Black River Falls, Town of Manchester, Town of Grant and Village of Warrens.

A second round of public information meetings was held in February 2013 in Augusta,

Warrens and Black River Falls. Detailed maps were available for residents to see their

property in relation to the proposed routes. More than 100 people attended the information

meetings.

In addition to property owners, representatives from the following municipalities attended

the information meetings: Eau Claire County, Clark County, Jackson County, Town of

Foster, Village of Fairchild, Town of Fairchild, Augusta, Town of Cleveland, Town of

LaGrange, Town of Lincoln, Town of Alma, Black River Falls, Town of Manchester, Town

of Hixton, Town of Wilson, Town of Grant and Village of Warrens.

The open houses resulted in substantial feedback related to the routing of the project,

station locations and construction techniques and schedules. Much of this feedback has

been taken into consideration and will be reflected in the more detailed design phase of the

project. In some instances where possible, minor routing adjustments were made to

accommodate property owner requests. Some of the more significant route adjustments

that were suggested at the February open houses are listed in more detail below. The

Company would consider these route adjustments pending further review including an

environmental survey to be completed this spring and consultation with landowners.

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Route Segment A.3

Property owner along CTH F south of S Alma Center Rd requested that we avoid splitting

their adjacent parcels with our proposed route. The property owner has plans for future

commercial development and is concerned about damage to their drainage tiles. A viable

solution to address the landowner’s concerns and avoid potential conflicts in the future is to

move the route one parcel to the west. The map below shows this potential route

adjustment.

Route Segment A.5

Property owners south of Kenny Rd expressed their preference to reroute to the far west

edge of their parcels versus bisecting their adjacent parcels. They continued to explain that

there was a potential for development along the current proposed route. A viable solution

to address the landowners’ concerns and avoid potential conflicts in the future is to move

the route one parcel to the west. The map below shows this potential route adjustment.

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Route Segment B.9

Property owner west of USH12 and north of Cinder Ave expressed his preference to

reroute along USH12 to avoid splitting his two parcels. He also explained that open

trenching through the bluff on his property may cause drainage issues in his fields

downstream. A possible solution to address the landowners’ concerns and avoid potential

conflicts in the future is to move the route further east to follow adjacent to USH12. The

map below shows this potential route adjustment.

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In addition to questions on routing, the majority of comments and questions related to the

amount of space needed for construction and pipe installation, the methods used for

restoration of drain tiles and crop land, compensation for easements and crop damage, as

well as construction time frame. Property owners along the route also expressed interest in

the possibility of natural gas service if the project is approved.

One-on-one meetings with property owners and stakeholders are ongoing to answer questions and provide information on the project and proposed routes.

County Parks and Forestry

In November and December 2012 and January and February 2013, the Company met with members of the Parks and Forestry Committees for Jackson, Eau Claire and Clark Counties to provide a Project overview and route proposals and to identify any issues or concerns. No issues or concerns were identified; however, questions were asked and answered about design, construction and restoration. Wisconsin Gas received guidance on requirements for placing utilities in the Eau Claire County forest and Clark County forest. Additionally, a route adjustment was identified in Jackson County (adjacent to an ATV trail instead of county forest road).

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DNR Forestry

The Company met with DNR Forestry staff in January 2013 to discuss proposed routes through the Black River State Forest. During this meeting, a consensus was reached that routing along the ATV trail east of Millston in the Black River State Forest would be eliminated from consideration due to DNR Forestry staff concerns. See discussion under Section 3.4.5. In addition, input was received regarding communicating with DNR Forestry staff during construction.

Community Interactions

The Company also contacted local elected officials in every community along the proposed routes. These include: Eau Claire, Clark, Jackson and Monroe Counties, Villages of Fairchild and Warrens, Cities of Black River Falls and Tomah and the Towns of Wilson, Foster, Bridge Creek, Fairchild, Cleveland, Mentor, Garden Valley, Alma, Hixton, Adams, Brockway, Manchester, Millston, Grant, Lincoln, Greenfield, LaGrange. All were provided with an overview of the project scope and proposed timeline to assist them in answering constituent questions. These discussions were well received with favorable comments on the need for a lateral and that issues raised during the project would be addressed.

Meetings with Wisconsin DOT and results

In November 2012, Wisconsin Gas met with the Wisconsin Department of Transportation (WDOT) to go over the Project plans and solicit any concerns with the proposed routes and construction impacts. WDOT had no issues or concerns with any of the proposed routes. However, WDOT did provide input regarding construction techniques and timing so as not to adversely affect traffic, safety, or road integrity.

In February 2013, Wisconsin Gas met with the Wisconsin Department of Transportation (WDOT) to provide an update on the Project plans and the proposed routes. Specific locations where the proposed gas line would be located or cross WDOT right-of-way were discussed for each route. While no issues or immediate concerns where identified during the meeting, the WDOT participants from the Northwest and Southwest regions stated that they would provide feedback if there was a route preference and identify any concerns for a particular route segment.

Interactions with businesses

Wisconsin Gas routinely interacts with businesses in its service territories. There has been substantial interest in the Project and Wisconsin Gas has fielded questions and discussed the proposed routes with interested business representatives. Interest comes from businesses in the agriculture, recreation, transportation and mining sectors of the local economy. In addition to discussions, Wisconsin Gas solicited letters of support from current and prospective businesses. The letters received are included in Appendix J – Letters of Support.

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3.3 GENERAL PIPELINE SITING INFORMATION

3.3.1 Route Alternatives

This section of the Filing Requirements requests presentation of at least two routes unless a determination has been made in pre-application consultations with PSC and DNR staff that only one route needs to be presented. As described in Section 3.2.5, pre-application meetings with both the PSC and DNR resulted in the elimination of alternates for small sections of the proposed alternate route segments. Alternative Routes A and B for the Project are further described below.

3.3.1.1 Description of routes and connection points

As described in Section 3.1.2, the Project is divided into 15 separate segments as shown on the Segment Polygon Map and the Segment Map in Appendix B – Maps, and identified in the table below. The following paragraphs in this section refer to the route segments when describing route locations and for analysis and comparison purposes. The table below lists the segment names along with a general description of the segment as well as the proposed main size and lengths.

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Table 15 –Route Segment Description

Segment Segment Description Pipe Size (inches)

Route A Length (miles)

Route B Length (miles)

1

16"-475psig Lateral - Viking TBS to Fairchild 16 14.8 16.4

Augusta 6"-475psig Branch 6 7.0 9.8

2 16"-475psig Lateral - Fairchild to Town House Rd, Alma 16 9.2 9.9

3 16"-475psig Lateral - Town House Rd, Alma to Avon Rd, Alma 16 4.0 4.7

4 16"-475psig Lateral - Avon Rd, Alma to Prindle Rd & Arnold Rd, Alma 16 4.1 4.1

5 16"-475psig Lateral - Prindle Rd & Arnold Rd, Alma to Odeen Rd, Adams 16 5.8 6.5

6 16"-475psig Lateral - Odeen Rd, Adams to Black River Falls DR 16 2.1 3.4

7 12"-475psig Lateral - Black River Falls DR to Millston 12 15.4 12.3

8 12"-475psig Lateral - Millston to Warrens Branch 12 7. 8 7.1

9 12"-475psig Lateral - Warrens Branch to Tomah DR 12 9.9 9.9

10 Augusta 8"-60psig Distribution 8 0.1 0.1

11 Hixton 4"-475psig Branch 4 3.0 2.1

12 Alma 6"-275psig Distribution (Route A Only) 6 0.3 0.0

13 Black River Falls 8"-60psig Distribution 8 1.9 1.9

14 Tomah 12"-60psig Distribution 12 0.2 0.2

15 Warrens 4"-475psig Branch 4 0.9 0.9

86.4 89.2

Wisconsin Gas’ Preferred Route

After evaluating and comparing the costs, environmental impacts, landowner impacts, and other construction obstacles for the Project, Route A was chosen as the Company’s preferred route. The individual segments within Route A are estimated to be lower in cost when compared to the individual segments for Route B (ref. Table 9 – West Central Lateral Cost). Additional factors which resulted in the selection of the Route A segments as preferred over the Route B segments are listed for each lateral segment below.

Route A.1 was chosen for the Company preferred route for the reasons below.

Route B.1 results in approximately 0.7 more acres of wetland impact.

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Route B.1 requires approximately 4.4 more miles of 475 psig main. This additional length is estimated to result in additional capital costs and yearly O&M costs.

Route A.1 results in more available capacity at the Augusta DR and the other downstream delivery points due to the reduced route length.

Route A.2 was chosen as the Company preferred route for the reasons below.

Route B.2 results in approximately 1.8 more acres of wetland impact.

Route B.2 impacts several known organic farms while Route A.2 completely avoids known organic farms.

Route B.2 requires approximately 0.7 more miles of 475 psig main. This additional length is estimated to result in additional capital costs and yearly O&M costs.

Route A.3 was chosen as the Company preferred route for the reasons below.

Route B.3 results in approximately 2.2 more acres of wetland impact.

Route A.3 impacts less land owners.

Route B.3 requires approximately 0.7 more miles of 475 psig main. This additional length is estimated to result in additional capital costs and yearly O&M costs.

Route A.4 was chosen as the Company preferred route for the reasons below.

Route B.4 results in approximately 0.4 more acres of wetland impact.

Although Route B.4 is approximately the same length as Route A.4, it is estimated to result in a capital cost increase.

Route A.5 was chosen as the Company preferred route for the reasons below.

Route B.5 results in approximately 9.3 more acres of wetland impacts.

Route A.5 impacts less land owners.

Route B.5 requires approximately 0.7 more miles of 475 psig main. This additional length is estimated to result in additional capital costs and yearly O&M costs.

Route A.6 was chosen as the Company preferred route for the reasons below.

Approximately 1.4 miles of Route B.6 runs parallel to USH12 towards the City of Black River Falls which would cause more of an impact to a main traffic corridor during construction.

Route A.6 is located in a more rural area whereas Route B.6 is located along a developed corridor that is much more congested and therefore resulting in more of an impact on the public.

Construction of the Black River crossing using the directional drill method would be more difficult with Route B.6 because of the more significant grade changes between the river banks.

Route A.6 impacts less land owners.

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There is an investigated and confirmed archeological site located along the USH12 portion of Route B.6, just north of W Snow Creek Rd.

Route B.6 requires approximately 1.3 more miles of 475 psig main. This additional length is estimated to result in additional capital costs and yearly O&M costs.

Route A.7 was chosen as the Company preferred route for the reasons below.

There are many more wetlands located along Route B.7 where standing water resides making construction and dewatering in these areas difficult.

The total distance of wetlands delineated along Route A.7 is significantly less than Route B.7.

There is very limited access to Route B.7 since it is mostly adjacent to the railroad corridor whereas Route A.7 is more easily accessed via adjacent roads.

Route A.7 impacts less land owners.

Although Route B.7 is approximately 3.3 miles shorter than Route A.7, it is estimated to result in a capital cost increase due to approximately 35% more directional drilling to avoid direct impact to the high quality wetlands.

Route A.8 was chosen as the Company preferred route for the reasons below.

The total distance of wetlands delineated along Route A.8 is significantly less than Route B.8.

Route A.8 impacts less land owners.

There is an investigated and confirmed archeological site located along the USH12 portion of Route B.8, just south of Aspen Ave

Although Route B.8 is approximately 0.5 miles shorter than Route A.8, it is estimated to result in a capital cost increase due to the increased amount of wetlands along the route.

Route A.9 was chosen as the Company preferred route for the reasons below.

Route B.9 results in approximately 0.7 more acres of wetland impacts.

Route A.9 impacts less land owners.

Although Route B.9 is slightly longer than Route A.9, it is estimated to result in an increased capital cost.

Route Segment Descriptions

Written descriptions for connection points and locations for each segment along the proposed routes are provided in the paragraphs below. Photos are provided where available.

Route A.1 consists of 16-inch steel main that starts at the proposed Viking TBS at the intersection of the Viking pipeline and CTH H in the Town of Wilson and will run south along CTH H into the Town of Fairchild to CTH M where Route A becomes one with Route

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B and branches to the west with a 6-inch main. The 6-inch main will run west along CTH M into the Town of Bridge Creek and then west along USH12 to approximately 500’ east of the CTH M and USH12 intersection where the proposed Augusta DR is to be located. This common portion of Segment 1 is approximately 7 miles in length. Alternate routes that were considered for this common segment include routes R.1, R.2, and R.3 which are presented in Section 3.2.3 and discussed in more detail. In summary, these routes were not chosen because of the additional 16-inch main that is required resulting in additional environmental impacts and costs. From the common segment at the intersection of CTH H and CTH M, the 16-inch continues south along CTH H to North Camp Rd and heads southeast along N Camp Rd to Black Creek Forest Rd. At this point, Route A becomes one with Route B again and continues south along N Camp Rd to Pond Rd. It then heads east along Pond Rd for approximately 2,300’ and then south cross country for approximately 4,000’ to E Main St where the future Fairchild DR is to be located. It then continues east a couple hundred feet and heads south along a tree line for about 1,100’ to USH10. This common portion of Segment 1 is approximately 2.5 miles in length. An alternate route that was considered for this common segment is route R.4 which is discussed in more detail under Section 3.2.3. In summary, R.4 was eliminated as a potential alternate based on the additional environmental impacts, landowner impacts, and costs. Some photos along route segment A.1 are shown below.

A.1 - CTH H, South of Viking

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A.1 - CTH H, South of CTH M

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A.1 - N Camp Rd, North of Black Creek Forest Rd

Route B.1 consists of 16-inch steel main that starts at the proposed Viking TBS at the intersection of the Viking pipeline and Dickerson Ave in the Town of Foster and will run south along Dickerson Ave, continue west along a gravel drive approximately 350 feet south of Willard Rd and then follows the existing electrical corridor south west to Camp Globe Rd. It then follows Camp Globe Rd south west to Horse Creek Forest Rd and follows Horse Creek Forest Rd south until it turns into Forest #4 Rd in the Town of Fairchild. At the intersection of Forest #4 Rd and Black Creek Forest Rd the 16-inch will branch to a 6-inch main that heads west along Forest #4 Rd. At the intersection of Forest #4 Rd and CTH H, Route B becomes one with Route A and the 6-inch heads south along CTH H until it intersects with CTH M where it follows CTH M west to the Town of Bridge Creek. It will continue west along USH12 to approximately 500’ east of the CTH M and USH12 intersection where the proposed Augusta DR is to be located. This common portion of Segment 1 is approximately 8 miles in length. Alternate routes that were considered for this common segment include routes R.1, R.2, and R.3 which are presented in Section 3.2.3 and discussed in more detail. In summary, these routes were not chosen because of the additional 16-inch main that is required resulting in additional environmental impacts and costs. The 16-inch will continue south along Black Creek Forest Rd until it intersects with N Camp Rd. At this point, Route B becomes one with Route A again and continues south along N Camp Rd to Pond Rd. It then heads east along Pond Rd for approximately 2,300’ and then south cross country for approximately 4,000’ to E Main St where the future Fairchild DR is to be located. It then continues east a couple hundred feet and heads south

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along a tree line for about 1,100’ to USH10. This common portion of Segment 1 is approximately 2.5 miles in length. An alternate route that was considered for this common segment is route R.4 which is discussed in more detail under Section 3.2.3. In summary, R.4 was eliminated as a potential alternate based on the additional environmental impacts, landowner impacts, and costs. Some photos along route segment B.1 are shown below.

B.1 - Dickerson Ave, North of Willard Rd

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B.1 - Black Creek Forest Rd North End

B.1 - Black Creek Forest Rd South End

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Route A.2 consists of 16-inch steel main that starts at USH10 approximately 1,400’ west of Fairview Rd in the Town of Fairchild and runs east along USH10, then turns south and runs along Fairview Rd into the Town of Cleveland. Just north of Lange Rd, the main heads southeast along the railroad into the Town of Mentor. Just west of the intersection of the railroad and CTH B, it turns south along a property line and continues cross country into the Town of Alma until it intersects with S Alma Center Rd. The main then follows S Alma Center Rd south across the Halls Creek Fishery to Town House Rd. A photo along route segment A.2 is shown below.

A.2 - Fairview Rd, North of Holmen Rd

Route B.2 consists of 16-inch steel main that starts at the same location as Route A.2 above but heads west along USH10 for approximately 1,300’, then turns south into the Town of Cleveland and runs cross country along a property line until it intersects with N Alma Center Rd. The main then follows N Alma Center Rd south until it intersects with CTH B where is turns east and follows CTH B for approximately 2,600’. It then heads south along a property line until it intersects with Giloy Rd at the Town of Cleveland and Town of Garden Valley boundary line. It then heads east for approximately 2,100’ where it turns south and then east along the edge of a farm field to route around a house and farm area. The main then heads south along the property line until it intersects with Moore Rd in the Town of Alma. It continues south along S Moore Rd which turns into S Alma Center Rd and

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follows S Alma Center Rd for approximately 2,100’ where it turns south and runs cross country across the Halls Creek Fishery to Town House Rd, approximately 2,600’ west of the intersection of Town House Rd and S Alma Center Rd.

B.2 – Gilloy Rd E Looking East at Alma Center Rd

Route A.3 consists of 16-inch steel main that starts at Town House Rd and S Alma Center Rd and runs south for approximately 300’ where it turns east to head cross country along a property line for approximately 1,300’. It then turns south and continues south along a property line to approximately 500’ north of the Village of Alma Center where it turns east to run along another property line for approximately 1,500’. It then runs cross country in a southeasterly direction for about 2,800’ to cross a creek, the railroad and STH 95 where it then follows another property line south to Old 95 Rd where it continues south along Avon Rd and along a property line to approximately 2,800’ north of Prindle Rd.

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A.3 - Avon Rd Looking South, South of Old 95 Rd

Route B.3 consists of 16-inch steel main that starts at Town House Rd, approximately 2,600’ west of the intersection of Town House Rd and S Alma Center Rd in the Town of Alma and continues cross country south along a property line until it intersects with Joos Rd. It then follows Joos Rd south into the Village of Alma Center. Joos Rd turns into W Limits Rd/S Alma Rd and it continues to follow this road south through the west side of the Village and then back into the Town of Alma. Approximately 1,400’ south of Shoemaker Rd the main turns east and runs cross country along a property line to the same end point for Route A.3 above. A photo along route segment B.3 is shown below.

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B.3 - W Limits Rd, North of STH 95

Route A.4 consists of 16-inch steel main that starts at the end point described for Route A.3 above in the Town of Alma and runs south and cross country along a property line for approximately 1,500’ where it turns east and runs cross country along another property line to Sission Rd. At this point, Route A becomes one with Route B and heads south along Sission Rd and then east along Prindle Rd. At the point where Prindle veers southeast, the main continues east along an existing electrical corridor and then south and cross country along a property line to Arnold Rd where the proposed Alma DR is to be located. It then follows Arnold Rd approximately 300’ south of Prindle Rd. This common portion of Segment 6 is approximately 2.5 miles in length. An alternate that was considered early on in the route selection process is route R.12 which is discussed in more detail under Section 3.2.3 and was not chosen because it resulted in more landowner impacts. Another potential alternate for a portion of the comment segment is to continue following Prindle Rd southeast to Arnold Rd. This alternate was not chosen because the existing corridor is narrow with steep slopes on either side of the road ROW and results in more landowner impacts. A photo along the common route segments A.4 and B.4 is shown below.

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A.4 & B.4 - Prindle Rd Looking West

Route B.4 consists of 16-inch steel main that starts at the end point described for Route B.3 above in the Town of Alma and runs east and cross country along a property line to Sission Rd. It then runs south along Sission Rd and after approximately 1,500’, it becomes one with Route A as it continues south and then east along Prindle Rd. At the point where Prindle veers southeast, the main continues east along an existing electrical corridor and then south and cross country along a property line to Arnold Rd. It then follows Arnold Rd approximately 300’ south of Prindle Rd. This common portion of Segment 4 is approximately 2.5 miles in length. An alternate that was considered early on in the route selection process is route R.12 which is discussed in more detail under Section 3.2.3 and was not chosen because it resulted in more landowner impacts. Another potential alternate for a portion of the comment segment is to continue following Prindle Rd southeast to Arnold Rd. This alternate was not chosen because the existing corridor is narrow with steep slopes on either side of the road ROW and results in more landowner impacts.

Route A.5 consists of 16-inch steel main that starts at the end point described for Route A.4 above in the Town of Alma and extends south along Arnold Rd to Carol Rd where it runs east along Carol Rd for approximately 1,400’. From Carol Rd, it heads south and cross country along a property line into the Town of Adams. The main continues south along the property line through the Town of Adams until approximately 1,300’ south of E Snow Creek Rd. At this point Route A becomes one with Route B. Route A turns east and follows a property line to USH12 and then Odeen Rd to an existing electrical corridor to the east side of the railroad. This common portion of Segment 5 is approximately 0.3 miles in

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length. There is no alternate proposed for this common segment because there is no other existing corridor in closer proximity to the Black River to connect the two routes prior to crossing the Black River. A photo along route segment A.5 is shown below.

A.5 - Cross Country at Kenny Rd, Looking North

Route B.5 consists of 16-inch steel main that starts at the end point described for Route B.4 above in the Town of Alma and runs southeast and cross country along tree lines to USH12. It continues south along USH12 to Garage Rd where the proposed Alma DR is to be located. The main then heads east along Garage Rd to the east side of the railroad and continues south along the railroad to E Gilbert Rd. From E Gilbert Rd, the main shifts east to follow North West Rd south for about 1,400’ until it continues along the railroad into the Town of Adams. At Rush Rd and N Odeen Rd it shifts to the east to follow N Odeen Rd south and then west along CTH E to the railroad. It continues south along the railroad and then follows an existing electrical corridor and N Odeen Rd west across USH12. This common portion of Segment 5 is approximately 0.3 miles in length. There is no alternate proposed for this common segment because there is no other existing corridor in closer proximity to the Black River to connect the two routes prior to crossing the Black River. A photo along route segment B.5 is shown below.

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B.5 - RR Looking South at West Rd

Route A.6 consists of 16-inch steel main that starts at the end point described for Route A.5 above in the Town of Adams and continues south along the railroad, across the Black River and into the Town of Brockway. The main continues south along the railroad until it intersects with STH 54 where the proposed Black River Falls DR is to be located. A couple of photos along route segment A.6 are shown below.

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A.6 - Electrical Corridor North of the Black River

A.6 - Black River Crossing Looking North

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Route B.6 consists of 16-inch steel main that starts at the end point described for Route B.5 above in the Town of Adams and continues south along USH12 to approximately 550’ north of Ruf Rd. At this location it heads east across the Black River and into the Town of Brockway following an existing electrical corridor. It follows the existing electrical corridor southeast to STH 54 where the proposed Black River Falls DR is to be located. A photo along route segment B.6 is shown below.

B.6 - USH12 Looking South at W Snow Creek Rd

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B.6 - Black River Crossing Looking West

Route A.7 consists of 12-inch steel main that starts at the proposed Black River Falls DR at the intersection of the railroad and STH 54 in the Town of Brockway. Approximately the first 0.5 mile south of the Black River Falls DR that runs along the railroad to W Bauer Rd is a common segment for both Route A and Route B. This is a common segment because it is the shortest and most cost effective route to get to the point where the two routes diverge and follow different corridors. Route A then diverges east from Route B along W Bauer Rd to an ATV trail approximately 4,800’ east of Krome Rd where it heads south to Castle Mound Rd. At Castle Mound Rd it turns east and runs along Castle Mound Rd to Brockway Rd where it heads south for approximately 1 mile to an ATV trail. The main then heads southeast along a combination of ATV trails and forest roads through the Town of Manchester to Hunters Haven Rd in the Town of Millston. It then heads south along Hunters Haven Rd to Stanton Creek Rd and follows Stanton Creek Rd east to Cut-off Rd. The main continues south along Cut-off Rd until it continues south along Stanton Creek Rd to an existing cleared pathway that heads southwest just northeast of I-94. The main follows this pathway southwest and across I-94 to Railroad St on the west side of I-94. At this point, Route A becomes one with Route B as it runs southeast along Railroad St through Millston to the railroad at the south end of Millston. This common portion of Segment 7 is approximately 0.5 miles in length. An alternate that was considered for this common segment is route R.11 which is discussed in more detail under Section 3.2.3. In summary, route R.11 was not proposed as an alternate because it was determined that clearing trees along this proposed scenic ATV trail corridor would result in a recreational

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land use conversion triggering the LAWCON federal process. Route R.11 also requires 2 trout stream crossings. A couple of photos along route segment A.7 are shown below.

A.7 - Jackson County ATV Trail North of Castle Mound Rd

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A.7 - Castle Mound Rd Looking East, East of Jackson County ATV Trail

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A.7 - Jackson County Forest Rd, West of Hunters Haven Rd

Route B.7 consists of 12-inch steel main that starts at the proposed Black River Falls DR at the intersection of the railroad and STH 54 in the Town of Brockway. Approximately the first 0.5 mile south of the Black River Falls DR that runs along the railroad to W Bauer Rd is a common segment for both Route A and Route B. This is a common segment because it is the shortest and most cost effective route to get to the point where the two routes diverge and follow different corridors. . Route B then diverges southeast from Route A along the railroad through the Town of Brockway, Town of Manchester, and into the Town of Millston. Just east of Browns Crossing Rd the main diverges from the railroad and around a Ho-Chunk trust property line. It then continues along the railroad southeast to Railroad St. At Railroad St, Route B becomes one with Route A as it runs southeast along Railroad St through Millston and back to the railroad on the south end of Millston. This common portion of Segment 7 is approximately 0.5 miles in length. An alternate that was considered for this common segment is route R.11 which is discussed in more detail under Section 3.2.3. In summary, route R.11 was not proposed as an alternate because it was determined that clearing trees along this proposed scenic ATV trail corridor would result in a recreational land use conversion triggering the LAWCON federal process. Route R.11 also requires 2 trout stream crossings. A photo along route segment B.7 is shown below.

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B.7 - RR Corridor Looking North, North of Castle Mound Rd

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B.7 - RR Corridor Looking North, South of I-94

Route A.8 consists of 12-inch steel main that starts at the end point described for Route A.7 above in the Town of Millston, heads southwest and crosses the railroad and USH12 to Millston Rd. It then follows Millston Rd south and southeast as it turns into Arcadia Ave and continues into the Town of Grant to USH12. At the intersection of Arcadia Ave and USH12 Route A becomes one with Route B and heads southeast along USH12 to approximately 1,400’ south of CTH EW in the Town of Lincoln. This common portion of Segment 8 is approximately 1.3 miles in length. An alternate was not proposed for this common segment because there is no other existing corridor that runs north to south in this area. Diverging from the USH12 corridor would result in a full 75’ of tree clearing in highland forested areas and cause accessibility issues not only during construction but for ongoing operations and maintenance. A photo along route segment A.8 is shown below.

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A.8 – Millston Rd Looking South, South of Smothers Rd

Route B.8 consists of 12-inch steel main that starts at the end point described for Route B.7 above in the Town of Millston, heads southeast along the railroad for approximately 2.8 miles until USH12 veers to the south away from the railroad. At this point, the main veers south along USH12 and follows USH12 to Arcadia Ave in the Town of Grant. At the intersection of Arcadia Ave and USH12, Route B becomes one with Route A and heads southeast along USH12 to approximately 1,400’ south of CTH EW in the Town of Lincoln. This common portion of Segment 8 is approximately 1.3 miles in length. An alternate was not proposed for this common segment because there is no other existing corridor that runs north to south in this area. Diverging from the USH12 corridor would result in a full 75’ of tree clearing in highland forested areas and cause accessibility issues not only during construction but for ongoing operations and maintenance.

Route A.9 consists of 12-inch steel main that starts at the end point described for Route A.8 above in the Town of Lincoln and runs west along a property line for approximately 500’ where it then turns south and runs cross country along property lines and/or tree lines into the Town of LaGrange. Once the main reaches the intersection of the STH 21 and CTH ET it follows CTH ET south and then continues east along Flare Ave. Approximately 1,000’ west of Flower Rd Route A becomes one with Route B and continues east until approximately 1,700’ east of Flower Rd. At this point it turns south and follows a property line to the Company’s Tomah Propane Air Plant property where the proposed Tomah DR is to be located. This common portion of Segment 9 is approximately 0.8 miles in length. An alternate is not proposed for this common segment to avoid future conflict with subdivision

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developments platted adjacent Flare Ave. A photo along route segment A.9 is shown below.

A.9 - Cross Country at Charcoal Ave Looking North

Route B.9 consists of 12-inch steel main that starts at the end point described for Route B.8 above in the Town of Lincoln and continues south along USH12 to Bluegrass Ave. At Bluegrass Ave it veers south away from USH12 to follow a property line cross country for approximately 4,000’ and then turns east to follow USH12 south again to CTH M. The main then follows CTH M west and then south to into the Town of LaGrange. At the intersection of CTH M and Elgin Ave it veers west along Elgin Ave for approximately 250’ and then runs cross country south through agricultural fields for approximately 2,600’ until it meets up with CTH M again. It continues to follow CTH M south until approximately 2,000’ south of Elk Rd where it runs south and cross country along a property line until just south of STH 21 and the railroad. It then heads east and then south along property lines through an agricultural field for approximately 4,000’ until it meets Flare Ave. At this point, Route B becomes one with Route A and continues east until approximately 1,700’ east of Flower Rd. At this point it turns south and follows a property line to the Company’s Tomah Propane Air Plant property where the proposed Tomah DR is to be located. This common portion of Segment 9 is approximately 0.8 miles in length. An alternate is not proposed for this common segment to avoid conflict with future subdivision developments in the surrounding area. A photo along route segment B.9 is shown below.

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B.9 - CTH M Looking North, Southwest of USH12

Route A.10 and B.10 consists of 8-inch plastic main that starts at outlet of the proposed Augusta DR in the Town of Bridge Creek approximately 500’ east of the CTH M and Baldwin St intersection and extends west along USH12/Baldwin St to the existing distribution main at the intersection of CTH M and Baldwin St.

Route A.11 consists of 4-inch steel main that branches from the 16” steel main approximately 200’ east and 1,300’ north of the intersection of Prindle Rd and Kass Rd in the Town of Alma. From this point, it heads south along a property line to Prindle Rd and then runs west along Prindle Rd to CTH F. At CTH F it turns south and follows CTH F to CTH FF. It then heads west along CTH FF to S Alma Rd where the proposed Hixton DR is to be located in the Town of Hixton.

Route B.11 consists of 4-inch steel main that branches from the 16” steel main approximately 1,300’ south of the intersection of S Alma Rd and Shoemaker Rd in the Town of Alma. It then continues south along S Alma Rd to CTH FF where the proposed Hixton DR is to be located in the Town of Hixton.

Route A.12 consists of 6-inch steel main that starts at the outlet of the proposed Alma DR at the intersection of Arnold Rd and Prindle Rd in the Town of Alma and extends east along Prindle Rd to the existing distribution main along USH12. There is no segment 12 for Route

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B because the proposed Alma DR for Route B is located directly adjacent to the existing distribution along USH12.

Route A.13 and B.13 consists of 8-inch plastic main that starts at the outlet of the proposed Black River Falls DR just west of the intersection of the railroad and STH 54 in the Town of Brockway and extends southwest along STH 54 to the existing distribution main at S Roosevelt Rd in the City of Black River Falls.

Route A.14 and B.14 consists of 12-inch steel main that starts at the outlet of the proposed Tomah DR on the Tomah Propane Air property northwest of the CTH ET and W Veterans St intersection in the City of Tomah and extends to the existing distribution main at CTH ET and W Veterans St in the City of Tomah.

Route A.15 and B.15 consists of 4-inch steel main that branches from the 16-inch main at the intersection of USH12 and CTH EW in the Town of Lincoln and continues east along CTH EW to approximately 1,400’ east of Arctic Rd where the future Warrens DR is to be located.

3.3.1.2 Detailed route maps

Detailed route maps are contained in Appendix B – Maps.

3.3.1.3 Aerial Photos

See Section 3.5.

3.3.1.4 GIS Data

GIS data files have been transmitted to PSC Staff.

3.3.1.5 Zoning and Land Use maps and GIS data from local units of government

A comprehensive review, including web site review, and phone calls to planning and zoning departments was performed in each of the cities, villages and counties traversed by the proposed gas pipeline routes. Available zoning and land use maps are provided in Appendix K – Planning and Zoning. Available GIS data has been transmitted in digital format to the PSC.

3.3.1.6 Floodplain maps

Maps displaying FEMA flood hazard data and potential shoreland zoning areas are provided in Appendix C – Environmental Information.

3.3.2 Land Use Plans

A comprehensive review, including web site review, and phone calls to planning and zoning departments was performed in each of the cities, villages and counties traversed by the proposed gas pipeline routes. Relevant zoning and land uses are listed in Table 2, Appendix C – Environmental Information. Available document excerpts and land use maps are provided in Appendix K – Planning and Zoning. Available GIS data has been transmitted in digital format to the PSC.

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3.4 DETAILED ROUTE INFORMATION

3.4.1 General Route Impacts

The general impacts of constructing the project along Routes A and B have been estimated and quantified and are presented in Tables 1A and 1B in Appendix C – Environmental Information. The route information is provided in separate tables for both routes, and is subdivided into segments. The results of the impact analysis are presented below.

3.4.1.1 New right-of-way (ROW)

The total length of Route A is approximately 86.4 miles and the total length of Route B is approximately 89.2 miles. The lengths and range of widths for individual segments and distribution segments within each route are provided in Table 1A.

The Total ROW Requirement for Routes A and B vary across the entire length of the project and are comprised of a combination of permanent easement and temporary workspace. The permanent easement is generally 50 feet wide, located on public and private properties outside of road ROW. The width of temporary workspace varies across the project, generally between 25 and 50 feet. This temporary workspace includes horizontal directional drill and jack and bore setup locations, as well as portions of road ROW where permanent easements are not necessary. A detailed description of the permanent easements and temporary workspaces required for the project is included in Section 3.6, CONSTRUCTION METHODS.

The Total ROW Requirement proposed for the project is provided in acres, and includes a total of all permanent easements and temporary workspaces, as measured by GIS. The locations of the permanent easements and temporary workspaces are presented on Figures 2A and 2B in Appendix B – Maps.

3.4.1.2 Existing ROW

Routes A and B share various existing ROW along parts of both routes. The amount of existing ROW shared by the permanent easements and temporary workspaces are presented on Table 1A. The existing roadway, railway, electric transmission, and gas pipeline ROWs were based on tax parcel data, GIS databases, and/or aerial photography. These existing ROWs were digitized and the amount shared with the project ROW was calculated using Esri ArcGIS Software.

3.4.1.3 Corridor sharing

The amount of ROW sharing for the project is presented in Table 1A. For each route and route segment, the percent of permanent easement and temporary workspace that is shared with existing ROWs is identified. These values were measured and quantified by GIS.

3.4.1.4 Land use and zoning

All land use information is provided in Section 3.4.2.

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A comprehensive review of zoning ordinances was performed, including web site review of ordinances and phone calls and/or meetings with planning and zoning departments. Two counties, Jackson and Eau Claire, indicated a conditional use permit may be required along with other associated land use permits. The other two counties, Monroe and Clark, identified associated land use permits, but no conditional use permits are required. The Company will follow community ordinance guidelines and obtain permits as identified before construction of the lateral.

Public utility easements are permitted within county owned forest lands, regulated by county Parks and Forest Department Forest Plans. Forest plans were reviewed and easements in county forest land includes committee and County Board approval with acceptable compensation to include forest product removal, lost future forest income and land payment for the easement area.

3.4.1.5 Buildings

A count of building types within a 600’ corridor of the proposed route alignment is presented in the Building Table in Appendix I – Engineering Information.

The building data included in the table was obtained using aerial photography and field verification where accessible. The measurements for distances from the proposed route alignments were obtained using the GIS.

3.4.2 Impacts by Land Type

The following summarizes land cover identified along the routes. The land cover along both routes was identified using aerial photography and field observations. Two sources of photography were used including the National Agriculture Imagery Program (NAIP) aerials from 2010 and Wisconsin Regional Orthophotography Consortium (WROC) aerials from 2011. Data from these sources were verified to the extent possible through field observations when field surveys were conducted on accessible properties in September through December 2012. Properties accessed during field surveys include lands along public ROW, State- and County-owned lands, and private properties where permission was granted by the landowner.

The land cover associated with each route was characterized and grouped into categories, as described in the Application Filing Requirements (3.4.2.1 Agriculture, 3.4.2.2 Forest, 3.4.2.3 Wetland, 3.4.2.4 Upland, 3.4.2.10 Residential, and 3.4.2.11 Commercial/industrial) consistent with pre-application consultations with PSC and DNR staff. The land cover types were digitized using Esri ArcGIS Software. The land cover categories are identified and described further below.

Agricultural lands observed along the routes include actively cropped fields, pastures, recently fallow fields (old field), and specialty agriculture. The specialty agricultural category includes tree farms (pine/coniferous plantations), cranberry operations, and deer farms. Fields or other areas with no evidence of recent tillage or agricultural production were not included as agricultural land. Areas determined to meet wetland criteria but were also cropped (farmed wetlands), were included in the wetlands category. A detailed discussion of agricultural lands is provided in Section 3.4.4.

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Non-agricultural uplands include grasslands and forest. Most grasslands identified along the routes consist of areas generally dominated by herbaceous vegetation, such as grassed swales or open fields not in agricultural production. These grasslands may include some limited areas dominated by shrub inclusions. The upland forests are described further and were identified based on the information presented in Section 3.4.5.

The wetlands identified along the routes include forested, non-forested, and farmed wetland types. The wetlands are described further in Section 3.4.11.

The developed lands located along both routes include residential, commercial/industrial, and roads/railroads. The residential lands are mostly comprised of subdivisions and scattered residences. For homes located within subdivisions, the amount of residential land generally totaled the length of the lots across the route. For other homes, the residential length was characterized by lawns associated with these residences. The commercial/industrial lands identified along both routes are mostly grouped together near population centers. These lands are comprised of individual businesses and adjacent grounds. The road/railroad land cover category corresponds to areas that are paved or graveled and the immediate mowed/disturbed roadside and railroad ballast areas. Other land cover such as wetlands and forests that fall within road/railroad ROW are included in those respective land cover categories.

The potential impacts to each land cover category described above were measured and calculated using ESRI ArcGIS Software. The area needed to construct Routes A and B was based on the Total ROW Requirement, which includes both proposed permanent easement (PERM) and temporary workspace (TMP). The acreages of PERM and TMP were calculated within existing (shared) ROW and new (additional) project ROW for each land cover category. As described in Section 3.4.1.2, existing roadway, railway, electric transmission, and gas pipeline ROWs were digitized based on tax parcel data, GIS databases, and/or aerial photography to create the existing ROW GIS layer, and used to calculate the amount of shared ROW.

To determine potential impacts to land cover categories along both routes, GIS layers described above were quantified, and the resulting area values outlined by route and route segments in separate tables for both routes (Table 2A and 2B, Appendix C – Environmental Information). For the purpose of calculating land cover impacts, areas of the permanent easement where horizontal directional drilling is planned, was identified and removed from the impact acreages. See Section 3.6 for a discussion of construction methods regarding directional boring.

The location and extent of public and tribal lands was evaluated for the project. The identification of public and tribal lands was based on tax parcel information and GIS databases. No tribal lands are crossed by the routes. Route A traverses through federal land (northeast corner of Fort McCoy), however entirely within public road right-of-way owned by the local township. Public lands were grouped by entity, and estimated potential impacts were compiled by route and segment in separate tables for both routes (Table 3, Appendix C – Environmental Information). The acreage of each route located on public land, and the length of public land crossed by the project was calculated by GIS. All roads and ROWs, regardless of ownership, were excluded.

Impacts to State owned lands were differentiated by property type, where available, and include lands within the Black River State Forest, Halls Creek Fishery Area, and Mill Creek

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Fishery Area. County lands included those owned by Clark, Eau Claire, and Jackson Counties; Jackson County Forest land was also identified separate from general Jackson County owned lands as a GIS data layer for the forest is readily available. Specific municipalities identified that may experience direct impacts include land owned by the City of Black River Falls, the Village of Alma Center, and the Village of Fairchild. Within Route A, approximately 37 acres of State owned land, 99 acres of County owned land, and 3 acres of municipal lands will be impacted. Within Route B, approximately 41 acres of State owned land, 68 acres of County owned land, and 0.75 acres of municipal lands will be impacted. Specific impacts within each entity can be found in Table 3, Appendix C – Environmental Information.

3.4.3 Route Summaries

Table 4 (Appendix C – Environmental Information) provides a summary of land cover impacts and residences for Routes A and B.

Route A is 456,326 feet (86.43 miles) in length, and crosses both upland and wetland areas. The upland communities include agricultural lands within existing and new ROW (311.87 acres), non-agricultural uplands on existing and new ROW (114.29 acres), upland forest on existing ROW (20.44 acres) and upland forest on new ROW (171.80 acres). Wetland communities impacted by Route A include forested wetlands within existing ROW (2.42 acres), forested wetland on new ROW (14.14 acres), and non-forested wetlands on existing and new ROW (28.70 acres). The impacts presented in this table are derived from Table 2 and do not include areas that are proposed to be constructed using HDD techniques.

Route B is 456,326 feet (86.43 miles) in length, and crosses both upland and wetland areas. The upland communities include agriculture on existing and new ROW (303.18 acres), non-agricultural uplands on existing and new ROW (115.68 acres), upland forest on existing ROW (33.62 acres) and upland forest on new ROW (152.56 acres). Wetland communities impacted by Route A include forested wetlands within existing ROW (1.36 acres), forested wetland on new ROW (11.65 acres), and non-forested wetlands on existing and new ROW (41.92 acres). The impacts presented in this table are derived from Table 2 and do not include areas that are proposed to be constructed using HDD techniques.

3.4.4 Agricultural Land

Agricultural land uses were initially identified using aerial photography derived from 2010 Wisconsin Regional Orthophotography Consortium (WROC) and verified through field observations. Fieldwork was conducted from September through December 2012 for areas within the West Central Lateral project corridor. As detailed in Table 2 (Impacts by Land Type), and Section 3.4.2, agricultural lands comprise approximately 42% of Route A, 41% of Route B, which includes the required seven branch and distribution segments for each route.

Property classified as being in agricultural use includes actively cultivated fields (including organic farms), pastures, hayfields, recently fallow fields (old field), cranberry farm, farmed

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(cropped) wetlands, deer farms, and Christmas tree farms. Fields or other areas with no evidence of recent tillage or agricultural production were not included as agricultural land.

Construction and restoration in agricultural areas will use the methods described in the Agricultural Mitigation Plan (AMP). See Appendix C – Environmental Information for the proposed West Central Lateral AMP.

3.4.4.1 Type of farming

Segments A.1, B.1, A.10 and B.10

Much of the land along both route alternatives is forested along existing road rights-of-way with scattered farm use throughout. Approximately 12 percent of Segment 1 for Route A is in agricultural land use within the proposed construction easements, while 10 percent of the proposed construction easements in Segment 1 for Route B is in agricultural land use. The primary farming practice along both routes is row crops, generally corn with areas of soybeans and alfalfa. Lands used for pasture and fallow fields were also observed along the routes. In the common Augusta 6” Branch of Routes A and B along CTH M and USH 12, forested lands gradually decrease and agricultural row cropping becomes the dominant land cover. The area of the proposed Augusta 60 psig Distribution Lateral (A. 10 and B. 10) is urbanized and no agricultural parcels are present.

Specialty Farms

Specialty farms (i.e. organic, deer, cranberry and Christmas tree) in Segment 1 are limited to one deer farm located along CTH H immediately north of Rustic Road #45 on Segment A.1 (Figure 2A, sheet 9 of 112, Appendix C – Environmental Information). As the construction easements are on the edge of the farm, impacts to these farms are expected to be minimal and temporary. No organic farmlands were identified along these segments.

Segments A.2, B.2, A.3, B.3, A.4, B.4, A.5, B.5, A.11, B.11, A.12 and B.12

Both routes in these segments are dominated by farming practices. Approximately 75 percent of Segments 2-5 for Route A is in agricultural land use within the proposed construction easements, while approximately 66 percent of the proposed construction easements in Segments 2-5 for Route B is in agricultural land use. In Segments A.2, B.2, A.3, B.3, A.4, and B.4, soybeans, corn, alfalfa, and pasture are abundant with corn being dominant. The Hixton 4” Branches (A.11 and B.11) that extend from Segments A.3, B.3, A.4 and B.4, and the Alma 275 psig Distribution (A.12 and B.12) that extend from Segments A.4 and B.4 have similar agricultural uses. Within Segments A.5 and B.5, soybeans and corn are dominant crops, with alfalfa and pasture lands scattered throughout. Non-agricultural portions for all Branches and Distribution in Segments 2 - 5 are primarily woodlots and scattered residential areas.

Specialty Farms / Organic Farms

On Route A, the easements traverse approximately 1,700 feet of identified Christmas tree farmlands south of Gilbert Road. On Route B also south of Gilbert Road, the easements similarly traverse approximately 700 feet of Christmas tree farmlands. No other specialty farmlands were identified in these segments for either route.

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On Route A (segment A.2) organic farmland is potentially both north and south of Holmen Road (also known as Fairview Road). The east edge of the potential organic farmland abuts the Route A construction easement south of Holmen Road for approximately 0.25 miles. North of Holmen Road, the construction easement comes within approximately 25 feet of the east edge of the potential organic farm land. Two other potential organic farm parcels south of Lange Road are in the vicinity of Route A (within approximately 150 feet), but do not intersect the construction easements.

On Route B (segment B.2) organic farmlands are potentially north and south of Holmen Road, and continue south to approximately one mile south of Lange Road. A total of approximately 1.75 miles of potential organic farmlands are intersected by Route B’s construction easements.

Segments A.6, B.6, A.7, B.7, A.8, B.8, A.13, B.13, A.15 and B.15

These segments are predominantly forested. Approximately 11 percent of these segments for Route A is in agricultural land use within the proposed construction easements, while approximately 11 percent of the proposed construction easements in Segments 6-8 for Route B is in agricultural land use. In Segment 6 for both routes , and the Black River Falls 60 psig Distribution Lateral (A.13 and B.13) and the Warrens 475# Branch (A.15 and B.15), land uses are forested (mostly privately owned), or are urbanized (mostly industrial).

Route A

Agriculture practices are limited in the Segments A.6, A.7 and A.8 and virtually non-existent until the Monroe County line in the southern portion of Segment A.8. Corn fields parallel Highway 12 north of Arcadia Avenue in Segment A.8.

Route B

Route B is also mostly forested in Segment B.7 and the northern portion of Segment B.8, with red pine plantations scattered throughout. There are also a few cattle pastures present in this area. Corn fields dominate the portions south of both Mills Road and Kelly Road.

Specialty Farms / Organic Farms

Cranberry farms are present on the opposite side of Castle Mound Road as the alignment in Segment A.7 and east of Fort McCoy along Arcadia Avenue Route A south of the Jackson and Monroe County line in Segment A.8. The construction easements have been identified outside the operations for the cranberry farms except one cranberry bed that is shown to be less than 0.10 acre within the easement, which will likely be avoided when a final design is developed. In segment B.8, also just south of the Jackson-Monroe county line, the construction easements mostly pass by a cranberry farm and, similar to A.8, are shown to impact less than 0.10 acre of a cranberry bed. Again, the potential impacts will likely be avoided when final designs are developed.

No other specialty farmlands or organic farmlands were identified within or near the construction easements in Segments A.7, B.7, A.8 or B.8.

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Segments A.9, B.9, A.14 and B.14

In Segment 9 of both routes and the Tomah Distribution Lateral (A.14 and B.14) land uses are primarily agricultural or urban. Approximately 71 percent of Segment A.9 and A.14 are in agricultural land use within the proposed construction easements, while approximately 75percent of the proposed construction easements in Segments B.9 and B. 14 are in agricultural land use. Agricultural land uses are dominated by corn, soybeans, pasture, and hay. Corn fields are present on both sides of Route A.9 south of Arcadia Avenue. Segment B.9 parallels Highway 12 and CTH M for a significant portion of its length. In this area, agricultural lands are abundant and parallel both sides of the route. Corn is the most dominant crop along B.9, with pasture, alfalfa, and soybeans cultivated to a lesser extent.

Specialty Farms / Organic Farms

No identified specialty farmlands or organic farms are within or abut the construction easements in Segments A.9, B.9, A.14 or B.14.

3.4.4.2 Practices potentially affected

Potential agricultural impacts of the proposed project will be short term and include temporary construction-related impacts, such as loss of crops, and potential loss of acreage due to construction of the pipeline. Potential impacts will be minimized by restoring agricultural lands to the extent practicable and also by providing compensation to producers where necessary. Because the majority of each route is along shared ROW and existing agricultural uses will be allowed within the easement, impacts to existing cropping practices and pastures should be minimal.

No clear evidence of drain tile along either route is apparent from aerial photography, nor was evidence of tile lines observed during the field investigation. However, some areas of farmland along the routes contain hydric soils and are in proximity to ditches, suggesting that tiles may exist in these locations. If tiles do exist along the selected route, there is a potential for damage during construction vehicle access and placement of the pipeline. If this occurs, the Company will restore the tiles to pre-construction conditions to the extent possible. The intent of the route siting is to minimize the loss of tillable land and any problems associated with use of agricultural equipment. If these conflicts occur, the Company will work with property owners during the real estate acquisition to accommodate property owner needs to the greatest extent practicable.

Many of the route segments in agricultural areas run along fence lines or between fields. Some of the route segments run along public road ROW. The proposed lateral would be located along the edge of the ROW and the farm field, where practicable. The objective of these route siting practices is to minimize the loss of tillable land and the potential for associated limitations to the operation of agricultural equipment, including some fields where center-pivot irrigators are utilized. If these conflicts occur despite application of the described minimization measures, the Company will work with property owners to accommodate their needs to the greatest extent practicable. Because the majority of each route is along shared ROW and farming will be allowed as part of the easement, impacts to existing cropping practices and pastures should be minimal and are temporary.

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3.4.4.3 Farmland preservation program properties

The Company plans to perform title searches for among other things Farmland Preservation Program (FPP) properties, note the properties prior to construction and restore the property according to FPP guidelines..

3.4.5 Forest Lands Segment and Route Summaries

Forested lands were identified and reviewed using aerial photography, field observations and other sources. Fieldwork was conducted in September through November 2012 within property where access was granted, constituting approximately 88% of the project corridor.

Forested lands are defined as areas where mature trees are present forming mostly closed stands (>20% canopy cover and trees with diameter breast height (dbh) of 6 inches or more) within 75 feet of the corridor centerlines and having a lineal extent of at least 75 feet within the Project corridor. Forested lands on existing ROW (converted forest) are included within this category. Narrow tree lines (e.g., wooded fence rows) or windbreaks were generally not quantified as forested cover. Forest lands on existing and new corridor for all routes are described by route segments below and tabulated in the Forest Lands Summary Table included in Appendix C – Environmental Information. Also refer to Appendix B – Maps , Figures 2A and 2B.

The following descriptions are organized along Routes A and B and north to south. Generally the routes begin on the north end of the Project in forested lands, move into agricultural lands south of Fairchild, then back into forested lands again proximate to Black River Falls and finally back in agricultural lands at the south end of the Project

Segment 1

The forested areas within and adjacent to Segments A.1 and B.1, the intersect with the Viking pipeline to the Village of Fairchild, are primarily comprised of deciduous and mixed coniferous-deciduous forested uplands with smaller portions of coniferous forests, both plantations and natural. These upland forested communities traverse the northwest part of the Central Sand Plains Ecological Landscape in Wisconsin, which is characterized by an extensive, nearly level expanse of lacustrine and outwash sand that originated from extinct Glacial Lake Wisconsin. Currently, oak, pine and aspen are the most abundant forest cover types. These segments are also located within the vegetation tension zone in Wisconsin, which is an approximate area of climatic transition where vegetative communities changed from prairie, savanna, oak and mixed hardwoods of the south to the mixed deciduous-coniferous forests of the north. As such, this area contains a mixture of both northern and southern forest community types ranging from dry to dry-mesic. These forested lands are mostly County-owned (Eau Claire and Clark County Forests) and the trees are generally between 8 and 24 inches dbh with large (30”+ dbh) deciduous trees with some white pines (Pinus strobus). Lowland hardwood swamps and floodplain forests

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are forested wetlands occurring less frequently on wet, lowland soils, floodplains and ancient lake basins.

Dominant species commonly observed within deciduous and mixed coniferous-deciduous upland forests include red oak (Quercus rubra), red maple (Acer rubrum), white pine, white oak (Q. alba), quaking aspen (Populus tremuloides), and big-tooth aspen (Populus grandidentata). The understory shrub layer was mostly comprised of hazelnut (Corylus spp.), huckleberry (Gaylussacia baccata), and witch hazel (Hamamelis virginiana) in upland areas. Upland herbaceous vegetation was comprised mainly of Pennsylvania sedge (Carex pensylvanica), early low blueberry (Vaccinium angustifolium) and bracken fern (Pteridium aquilinum).

Jack pine (Pinus banksiana) is the most dominant tree within the driest coniferous forest lands and is generally 8-14” dbh. Mixed coniferous-deciduous forests primarily had white pine as the coniferous dominant. Smaller areas of white pine forests were present along this segment. Red pine (Pinus resinosa) was rarely found outside plantations, but was the dominant species within and ranged from 8-20” dbh. Understory of these areas was dominated by scrub red oak and Hill’s oak (Quercus ellipsoidalis) within jack pine forests while white pines and red maple saplings were prevalent within mixed coniferous-deciduous and white pine forested areas; these plantations had limited understory present. Herbaceous layers within the coniferous and mixed forests were similar to deciduous woodlands.

Forested wetlands were generally composed of lowland hardwood swamp and floodplain forest dominated by red maple and quaking aspen with black ash (Fraxinus nigra) locally common in small areas. Understory shrub layer within these wetlands had winterberry (Ilex verticillata), muscle-wood (Carpinus caroliniana) and tag alder (Alnus incana) as its main components. Wetland herbaceous vegetation consistently had cinnamon fern (Osmunda cinnamomea), tussock sedge (Carex stricta), and swamp dewberry (Rubus hispidus) as dominants.

Land use of all forest types within Segment 1 is primarily recreation and timber management due to the presence of a large amount of County-owned property. Logging operations were noted predominantly on private properties with deciduous composition and small areas of County-owned forestland. However, agricultural land use dominates the Augusta Branch portion of this Segment. Cropped and pastured land dominates this portion with small, segmented blocks of forested land, comprised primarily of a mixed coniferous, deciduous dominated canopy of white pine and red maple.

Segments A.2, B.2, A.3, B.3, A.4, B.4, A.5, B.5, A.11, B.11, A.12 and B.12

Forested areas along these segments, from the Village of Fairchild to the City of Black River Falls, were found within and immediately south of the vegetation tension zone, and varied somewhat from those found in Segment 1 above. These segments are located at the interface between the Central Sand Plains

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(described above) and Western Coulee and Ridges Ecological Landscapes in Wisconsin, which is characterized by its highly eroded, unglaciated topography with steep sided valleys and ridges, high gradient headwater streams, and large rivers with extensive floodplains and terraces (e.g., Black River). Forest lands were mainly smaller, fragmented areas under private ownership. Much of the area was converted to agricultural land, limiting forested areas to land mostly unsuitable for agricultural practices (e.g. steep slopes and wetlands). Mixed coniferous-deciduous upland forest were the predominant type, with smaller areas of deciduous forest, limited coniferous forests, and forested wetlands.

Dominant species observed in these segments were similar to those found within Segments A.1 and B.1 described above, with a few notable differences included in the route descriptions below. Within deciduous areas, black cherry (Prunus serotina) and box elder (Acer negundo) were more prevalent. Red pine was more common within natural coniferous forested areas outside of plantations, while jack pine was limited to the very southern portion of this segment along Route A.5. Glossy buckthorn (Rhamnus frangula), an ecologically invasive shrub, was increasingly more common in Segments A.5 and B.5, and has displaced many of the native understory species identified in the Segments A.1 and B.1.

Routes along these segments include two distribution lines for both routes: A.11, B.11, and A.12/B.12. Lands within these segments were comprised mainly of cropped agricultural use with limited, small forest blocks (if any) present.

Route A

Though both Routes A & B were primarily agricultural in these segments, Route A had less agriculture land and more forest lands than Route B. Forests were primarily upland mixed coniferous-deciduous in small (<40 acre) blocks. Red maple, red and white oak, and quaking aspen were the most prevalent species found at 10-20” dbh. Large white pines were present in some forested wetlands. Understory and herbaceous species are similar to forested areas described in Segments A.1 and B.1 above, however glossy buckthorn has displaced many of the native species in the southern part of this route.

Route B

This route had primarily agricultural land and contained small mixed deciduous woodlots as previously described. Red pine was present to common along this route on areas with steep topography, limiting agricultural use. A large, wetland complex in segment B.5 had an increase in box elder abundance compared to Route A.5.

Forested wetlands were primarily deciduous, hardwood swamps dominated by red maple, similar to those found in Segments A.1 and B.1 described above. In the northern portion of this route, forested wetlands were confined to swales in farmland often associated with waterways. Large white pines were present in some of these areas. Segment B.5 had a large wetland complex with a higher abundance of invasive species in both the shrub and herbaceous layers (e.g., glossy buckthorn and reed canary grass) compared to Segments A.1 and B.1.

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Forest land recreational uses were limited within this more agricultural landscape due to smaller than average size of wooded areas with timber management being more prevalent.

Segments A.6, B.6, A.7, B.7, A.8, B.8, A.13, B.13, A.15 and B.15

These segments, which go from the City of Black River Falls to north of the City of Tomah, have larger, contiguous forested areas under private ownership and the Black River State Forest (near Black River Falls and Millston to the Jackson/Monroe county line). These segments are also located at the interface between the Central Sand Plains and Western Coulee and Ridges Ecological Landscapes and immediately south of the vegetation tension zone previously described. Deciduous forests are similar in composition and structure to previous segments and are dominated by red maple, red and white oak in greater abundance compared to northern portions of the project corridor with some larger specimens present (24-30”+ dbh). All forest types have an increased abundance of blackberry (Rubus allegheniensis) and glossy buckthorn in the understory.

Composition of the forest lands changed south of the Jackson and Monroe county line from large, contiguous blocks dominated by deciduous tree species to smaller, broken areas of forest with a trend towards more mixed coniferous-deciduous forest land, except within wetlands. Agricultural land is more abundant in these segments, including cranberry operations north of Warrens and general farming and pasture land south of Warrens. Red maple and oaks are the predominant deciduous species mixed with white pine in the southern portion of the segments.

Forested wetlands in these segments were similar to the above segments. Red maple and quaking aspen were the dominant tree species with box elder locally common. The shrub and herbaceous layer were again dominated by invasive species in most locations. White pine – red maple swamps were also found in this segment and are mainly restricted to the margins of extinct Glacial Lake Wisconsin. Coniferous bogs were also present.

These segments cross two portions of the Black River State Forest: 1) Perry Creek Basin just south of the City of Black River Falls, and 2) Robinson Creek Basin around the Millston area to the Jackson and Monroe County line. The Perry Creek Basin was primarily upland forest with a mix of quaking aspen and white oak deciduous forest. In mixed coniferous-deciduous forest areas, white pine was the prevalent species. Shrub layer in this section was dominated by invasive glossy buckthorn. The Robinson Creek Basin along this segment was primarily mixed coniferous-deciduous west of Interstate 94 (I-94). White pine and red/white oak were the dominant species with red maple displacing oak species in wetter areas. Deciduous forests here were dominated by red and white oak with black oak (Quercus velutina) locally common. East of I-94 was predominantly jack pine upland coniferous forests with a mix of scrub red oak. In both areas, the understory was dominated by native species compared to sections farther north.

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Use of forested lands varies greatly within these segments. Large, privately owned forests north of the Monroe County line were mainly used for recreation. The Black River State Forest was primarily managed for recreational use with areas of timber management and harvest. South of the county line, forest lands became predominantly small, scattered blocks (<40 ac) confined to where land is unsuitable for agricultural use. These areas were mainly used for small timber harvests and recreation.

Segments A.9, B.9, A.14 and B.14

Forested lands along these segments were primarily small, broken blocks surrounded by agricultural land. Deciduous and mixed coniferous-deciduous forests were the dominant upland type and was similar in composition to that described in Segments 6-8 Forested wetlands in these segments were similar to the above segments. Red maple and quaking aspen were the dominant tree species with box elder locally common. The shrub and herbaceous layer was again dominated by invasive species in most locations.

These segments end at the Tomah distribution segments (A.14 and B.14). This final portion of the project corridor is a nearly even mix of cropped agricultural lands and single family residential lands with one business parcel containing a small, hardwood swamp dominated by glossy buckthorn and red maple.

3.4.6 Conservation Easements

Managed Forest Lands and Forest Crop Law

Information regarding lands with Managed Forest Lands (MFL) and the Forest Crop Law (FCL) conservation easement agreements was obtained from the DNR GIS Public FTP Site on November 13, 2012. The proposed routes cross MFL easements as identified in Table 16 and Table 17, below.

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Table 16 – MFL Route A

Segment Tax Parcel ID Acres

A.1 1800222506013300001 0.1483

A.1 1800222605231100001 1.6480

A.1 1800222605234100001 0.0986

A.1 1800222605234400001 0.7243

A.1 1800222605242300001 0.3416

A.1 1800222605341400001 1.3669

A.1 1801022505023200001 0.4065

A.1 1801022505023300001 0.9202

A.1 1801022505063300001 0.6474

A.2 006-0088.0000 0.2258

A.3 006-0496.0000 0.6584

A.7 010-0249.0000 2.2604

A.7 010-0250.0000 2.2897

A.7 010-0269.0000 2.2815

A.7 010-0968.0000 1.9766

A.7 032-0013.0000 0.8225

A.7 032-0178.0000 0.0801

A.8 036-0552.0005 0.8903

Total 17.7870

Table 17 – MFL Route B

Segment Tax Parcel ID Acres

B.1 1800222506013300001 0.1483

B.1 1800222605244400001 0.0273

B.1 1801022505023200001 0.4065

B.1 1801022505023300001 0.9202

B.1 1801022505063300001 0.6474

B.2 020-0004.0000 0.5792

B.5 006-0981.0000 2.0597

B.7 010-0644.0000 0.7659

B.7 032-0043.0000 2.6205

B.7 032-0051.0000 1.4616

B.7 032-0054.0000 2.6914

B.7 032-0056.0005 2.5807

B.7 032-0061.0000 2.7210

B.7 032-0064.0000 0.0511

B.7 032-0065.0000 2.4464

B.7 032-0149.0000 0.9537

B.9 020005930000 0.4847

Temp. Access Road 13

032-0054.0000 0.0002

Total 21.5658

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Landowners may enter into MFL agreements on parcels 10 acres or greater in size. At least 80% of MFL must be forested and 20% may include public utility easements. If the forested portion of the parcel falls below 80%, the landowner is required to pay $300.00 plus the difference between the tax paid under MFL and the tax if not in MFL, times the number of years the land has been enrolled in MFL for the entire parcel. For example, if a parcel is 80 acres, enrolled for 14 years and the utility easement reduces the forested portion below 80%, the payment is estimated as follows: $300,00 plus 14 years x 80 acres x the current tax difference. If an easement area reduces the forested portion below 80% of a given parcel, We Energies will compensate landowners the designated penalty. Managing the timber removal within MFL will be coordinated with DNR Foresters.

According to information provided on the DNR GIS Public FTP Site, there are no FCL lands along the route segments for this project.

U.S. Department of Agriculture Programs

Farm programs are subject to annual enrollment and may change when the legislature passes a new farm bill. Conservation programs provide cost-sharing and rental payments under the U.S. Department of Agriculture (USDA), and are administered by the Farm Service Agency (FSA). Technical assistance for some program land is provided by the USDA Forest Service and the Natural Resource Conservation Service (NRCS). NRCS's natural resources conservation programs help people reduce soil erosion, enhance water supplies with groundwater recharge, improve water quality, increase wildlife habitat, and reduce damages caused by floods and other natural disasters. Programs encourage farmers to convert highly erodible cropland or other environmentally sensitive acreage to vegetative cover, such as cultivated or native bunchgrasses and grasslands, wildlife and pollinator’s food and shelter plantings, windbreak and shade trees, filter and buffer strips, grassed waterways, and riparian buffers. Existing programs identified are as follows:

Conservation Reserve Program (CRP)

Conservation Reserve Enhancement Program (CREP)

Environmental Quality Incentives Program (EQUIP)

Wildlife Habitat Incentive Program (WHIP)

Conservation Stewardship Program (CSP)

Wetland Reserve Program (WRP)

Grassland Reserve Program (GRP)

State Acres for Wildlife Enhancement (SAFE)

Meetings were held on February 12 and 13, 2013 with each county’s USDA FSA and NRCS offices to determine if lands along the proposed gas lateral routes are enrolled in a USDA conservation program. These programs are not recordable contracts and are subject to the Freedom of Information Act (FOIA). The four county USDA NRCS offices provided a list of landowners participating in NRCS programs. On January 24, 2013 We Energies

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emailed a request to release landowner names that may be enrolled in either FSA or NRCS programs to the Management Services Division of USDA Privacy Officer in Kansas City, Missouri.

Landowner names provided by the USDA for each county were compared to landowners located on the routes and the results are as follows:

NRCS

Eau Claire County: No landowners identified as participating in a program

Clark County: 1 landowner identified on both routes as participating in a conservation program.

Jackson County: 9 landowners identified on both routes are as participating in a conservation program

Monroe County: 1 landowner identified on both routes as participating in a conservation program

FSA

Eau Claire County: 3 landowners on both routes are participating in a conservation program

Clark County: No landowners on both routes are participating in a conservation program

Jackson County: 3 landowners on both routes are participating in a conservation program

Monroe County: 3 landowners on both routes are participating in a conservation program

Due to FOIA, FSA and NRCS will provide name of landowner participating in a program within their respective county. No enrolled program or parcel information may be identified or provided. To determine the location of enrolled land and type of program, We Energies will contact landowners identified as enrolled in a program and prepare an authorization letter (approved by FSA/NRSC) to release program information to We Energies. Each program will be reviewed to determine the impact the lateral may have to land enrolled in a program, including restrictions to construction time and the impact to a landowner if construction results in a temporary impact or permanent impact to the land enrolled in a program. Temporary impact may include review and approval by county FSA committee, construction time limitations, and specific seed mixture for restoration and penalties for permanent removal of land from a program. Wisconsin Gas will reimburse the landowner for penalties that may be associated with permanent removal from a program. Since programs may change or landowners may enroll annually in programs, land agents will inquire at the time of easement acquisition as to lands enrolled in a conservation farm program.

Land and Water Conservation Fund

The Company has worked closely with DNR staff to identify which properties intersecting the Project routes have received LAWCON funds, and to determine whether the proposed construction methods would trigger a 6(f)(3) recreational use conversion and federal review process. Three properties that have been identified as potentially affected by the Project

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are the Black River State Forest, the Alma Center Park acquisition, and the Buffalo River “The Partners” acquisition. Each property is discussed in more detail below.

Black River State Forest

Per consultation with the DNR, it has been determined that the Black River State Forest (BRSF), located in Jackson County, has received LAWCON funds and as such is mandated to be retained and used for public outdoor recreation. Furthermore, the proposed routes for the Project will traverse the BRSF. As stated in the Land and Water Conservation Fund State Assistance Program Manual, effective date October 1, 2008, the DNR may allow underground utility easements, such as proposed by the Project, without a 6(f)(3) conversion provided that the underground utility easements do not impact the recreational use of the property and the site is restored within 12 months to its original surface condition. On January 17, 2012 the Company met with Peter Bakken and Larry Whaley (BRSF personnel) to review the proposed routes and construction techniques within the BRSF in detail. It was determined by BRSF personnel that the proposed routes and construction techniques would not affect the recreational use of the BRSF, provided that the routes are not co-located with exclusive ATV trails. The Company subsequently removed one route portion so that no routes are co-located with exclusive ATV trails. The proposed routes do intersect ATV trails at several locations, and do co-locate with ATV trails for portions of existing township roadway, but these instances were not viewed by BRSF personnel as an impact on the recreational use of the forest.

As a result of these consultations, the DNR has determined that there will not be a 6(f)(3) conversion as a result of the proposed Project within the BRSF. This determination is outlined in a letter from the DNR dated March 4, 2013 (Appendix D – Agency Correspondence).

Other Conservation Easements

In addition, We Energies researched conservation groups in the area that may be actively pursuing conservation easements, Mississippi Valley Conservancy, West Wisconsin Land Trust, Eau Clair County Stewardship Committee and DNR Land Conservation Department. To determine if these groups acquired easements in the proposed project construction area, a grantor/grantee search of county records in each county was performed. No conservation easements were found on either route. For further documentation, a title report for each parcel will be requested after CA application submittal.

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3.4.7 Endangered, Threatened, Special Concern Species and Natural Communities

Information regarding the presence of rare species (Endangered, Threatened, Special Concern or Federally Protected) within two miles of the proposed routes (Route A and Route B) was obtained through a review of the Wisconsin Natural Heritage Inventory (NHI) database. The NHI database revealed sixty-four non-historic Endangered, Threatened, Special Concern, or Federally Protected species, twenty-eight natural communities and two other natural features within two miles of the proposed routes. Subsequent to the review of the NHI data, The Company, with its consultant Stantec Consulting Services Inc. (Stantec), completed field surveys on accessible properties to characterize habitat within and adjacent to the proposed routes. The habitat characterization information was used to evaluate the likelihood of NHI-listed species to be found within or in close-proximity to the proposed routes.

In addition, the NHI database was queried for similar data within two miles of associated facilities such as interconnections, regulator stations, equipment staging areas, and off right-of-way access routes. Because of the proximity of these facilities to the two proposed routes, most of the species and natural community data is the same. The only differences include five Threatened or Special Concern species and three Natural Communities that are recorded within two miles of specific associated facilities and not within two miles of Routes A or B. Also, there are 16 Endangered, Threatened or Special Concern species and four Natural Communities recorded within two miles of Routes A or B that are not included within the two mile search radius for the associated facilities.

An Element Occurrence (EO) is the record of a rare species and the approximate location of where it was observed. Of the sixty-nine non-historic Endangered, Threatened, Special Concern, or Federally Protected species recorded within two miles of the proposed routes or associated facilities, one or more EO for each of 26 species are intersected by or immediately adjacent to Route A, one or more EO for each of 19 species are intersected by or immediately adjacent to Route B and one or more EO for each of 20 species are intersected by or immediately adjacent to the associated facilities.

None of the species were observed along either route or associated facility during initial field investigations/habitat assessments. However, all sixty-nine of the species were deemed to have at least marginal habitat along one or both of the proposed routes and one or more of the associated facilities.

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Routes A and B both traverse a combination of grassland, forest, wetland and agricultural land primarily within or adjacent to existing utility and road rights-of-way (ROW), which are subject to periodic disturbance. The majority of associated facilities are closely related to Routes A and B, and fall within the land uses described above. Segments that follow cross country alignments are primarily agricultural. Habitat quality in agricultural areas was generally not suitable for the listed species. Where the routes traverse grassland, forest or wetland habitat the risk of direct impact is elevated for a number of habitat specialist species identified within two miles of the proposed project. For the most part, construction related impacts to suitable habitat will be temporary and restored following construction. In some locations habitat for certain species will be permanently expanded as a result of tree and shrub clearing. The Company and Stantec have been consulting with the DNR to identify species and associated habitat that may warrant additional investigation. Once a route has been selected, if necessary, The Company may survey the areas with suitable habitat for selected species and implement avoidance measures if a species is subsequently identified to be present. Alternatively, if suitable habitat for certain species exists within the construction footprint, presence of the species may be assumed and appropriate avoidance measures will be implemented. If for some reason avoidance measures cannot be implemented, The Company will provide supplemental information required for the issuance of an Incidental Take Permit (ITP).

Stantec is completing a Proposed Endangered Resources Review that includes both Routes A and B, and associated facilities. When completed this document will be reviewed and certified by the DNR prior to selection of the final route. Upon certification, a report describing the methods and results of the Endangered, Threatened, and Special Concern species investigation will be submitted to the DNR- Bureau of Endangered Resources for review and comment and to the Commission concurrent with its submittal to the DNR. A copy of the cover letter submitted with the Endangered Resources Report will be located in Appendix C – Environmental Information. A redacted version of the Endangered Resources Report will be provided as a supplement to Appendix C – Environmental Information.

3.4.8 Archeological and Historic Resources

Great Lakes Archaeological Research Center, Inc. (GLARC) conducted a Phase I archaeological investigation and an historical architectural survey for the West Central Lateral Project. GLARC’s investigation was completed in the fall of 2012, and their report and an accompanying Archeological Investigation Summary table is provided separately to PSC on a CD (also available on PSC’s ERF server).

Archaeological Resources

The Phase I survey was initiated for all previously reported archaeological sites that either intersected the centerlines of the proposed routes (A and B) or fell within a 200 foot buffer zone established around the route centerlines. A total of 34 archaeological/ burial sites fell within the established survey corridor. Landowner permission was obtained to access, or survey was not needed on, 23 of the 34 sites. GLARC will survey the remaining 11 sites after access is gained from landowners and seasonal / weather conditions allow.

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The 34 sites are listed in Table 4.1 (page 23 of GLARC’s report). Construction easements will not affect the cultural resources in all but two of the surveyed sites. The two sites with intact cultural resources that intersect the construction easements are described below. The other 23 sites do not require additional survey and GLARC recommends that the Project proceed utilizing the proposed routes without design modifications.

Peasley Site: One new site (The Peasley site - 47JA0610) was found during GLARC's Phase I surveys within a previously recorded archaeological site (47JA0202). The Peasley site is a village/campsite related to a Woodland occupation. 47JA0202 is a historic battlefield between the Ho-Chunk and Chippewa Native American tribes. 47JA0202, including the Peasley site, is described and depicted on page 50 of GLARC's report, and depicted on Figures 4.26 - 4.28 on pages 55, 57and 58. Because of the potential for the Peasley site to be eligible for the National Register of Historic Places under Criterion D, the portion that is within proposed route B will be avoided by extending the horizontal directional drill for the adjacent Snow Creek. The drill is expected to range between 10 and 15 feet below ground surface, outside the potential impact zone. GLARC recommends monitoring during construction to ensure that the site is not disturbed.

Aspen View Site: The Aspen View site (47MO0717) is described on page 66 of GLARC's report, and depicted in Figures 4.42 and 4.43 on Page 65-70. Aspen View is a multi-component site with both Native American settlement artifacts and a foundation of a structure dating from the 1940's. GLARC's Phase I investigation on October 31, 2012 did not recover prehistoric materials during shovel testing. However, based on the results of a previous Phase II archaeological study by Recker et al. (2009), the site does have the potential to be eligible for listing on the NRHP. The ROW for USH 12 was subjected to a Phase II evaluation by Recker et al. (2009) and the ROW was determined to not have potential to yield significant information regarding pre-contact Native American settlement due to previous ground disturbance by underground utilities and road construction. Therefore, if construction activities are confined within the ROW for USH 12, the Aspen View site can be avoided. Construction plans in the vicinity of the Aspen View Site are to extend the Aspen Ave. jack and bore road crossing to avoid impacts to this archaeological site by remaining at least eight feet below ground surface. GLARC recommends monitoring during construction to ensure that the site is not disturbed.

Architectural - Historical

A survey of historical standing structures was conducted for both routes in November 2012. There are five properties listed in the Architecture History Inventory within the route easements, of which four are potentially eligible for the National Register of Historic Places (NRHP), but are not currently listed in the NRHP. It is the Company’s intent that construction will not cause any changes to buildings or structures on these properties. In addition the physical setting on these properties, including trees and other vegetation, will not be altered by construction activities.

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Table 18 – Historical Architectural Survey Summary

Site ID Historic Name Current Name Address County

Town-

ship Range Section

Quarter-

Quarter Quarter

29811 PRINDLE SCHOOL PRINDLE RD Jackson 22N 4W 4 SW NE

30492AVON-PRINDLE

SCHOOLSAVON RD Jackson 22N 4W 4 SW NE

59413 ST. JOSEPH CHURCH FAIRVIEW RD Jackson 24N 5W 12 NE SW

70247

RAD RATOLEST

WISCONSINU, CISLO 196

ZAPADNI CESKO BRAT

LODGE RATOLEST

WISCONSIN, #196

WFLA

N7311 ODEEN

RDJackson 22N 4W 35 SE SE

74316 Blencoe BlockW12201 STATE

HIGHWAY 95Jackson 23N 5W 36 NE NE

91897Chicago and

Northwestern Railroad

Chicago and North-

western RailroadBLACK RIVER Jackson 21N 4W 1 NW SW

The four NRHP potentially eligible sites are as follows:

1) Blencoe Block (AHI 74316) is a 19th Century Inn / Tavern / Store, described on page 87 of GLARC’s report, and is associated with the development of Alma Center. According to GLARC, it appears to be eligible for the NRHP. It is on the opposite side of the road as Route B in Alma Center, at W12201 STH 95, Town of Garden Valley (AHI 74316). It is shown on Figures 5.1-5.2 (pages 88-89) of GLARC’s report. No above-ground construction including impacts or alterations to buildings, trees or other vegetation will occur in the vicinity of Blencoe Block.

2) Lodge Ratolest (AHI 70247) is a building and property associated with the Zabadni Cesk Bratrske Jenota, a Czech fraternal organization located at N7311 Odeen Rd in the Town of Adams. Because of this association it has been determined to be eligible for the NRHP under criterion A. It is described on Page 87 and shown on Figures 5.3-5.4 (pages 90-91) of GLARC’s report. Lodge Ratolest is on a parcel that is adjacent to a common segment for both routes. No impacts or alterations to the building, setting or vegetation on the parcel are expected from construction.

3) Chicago and Northwestern Railroad Bridge (AHI 91897) is an historical bridge over the Black River that may be eligible for the NRHP under Criterion C. It is described on page 87 and shown on Figure 5.5 (page 92) of GLARC’s report. This bridge is located northeast of Black River Falls along Route A in the Town of Brockway. No construction impacts to the bridge, its abutments, or its setting are expected because horizontal directional drilling will be used in this section.

4) Avon-Prindle Schools (AHI 30492 & 29811) are two schools that may be NRHP eligible under the criteria of good examples of mid-late 19th Century rural schools that were influential in the development of education in Jackson County. The schools are described on pages 87and 89 and shown on Figures 5.6-5.8 (pages

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93-95) in GLARC’s report. The parcel on which these schools are located is a common segment for both routes. Planned construction methods used on this parcel will not cause alterations to the buildings, their setting, or vegetation on this historical property.

3.4.9 Access Issues

Temporary construction access will be required and typically will be from existing public and private roads. Preliminary access routes have been noted on the aerial maps provided (Figures 2A and 2B, Appendix C – Environmental Information). Where necessary, access ramps will be constructed from the public and private roads to the project right of way so that existing drainage patterns are preserved. Additional temporary access roads identified during final design will be assessed for potential environmental and cultural impacts. This assessment will review the proposed temporary routes for wetlands, waterways, endangered/ threatened species, and cultural sites. The construction contractor may, for convenience or safety reasons, seek to arrange alternate access with private landowners. If additional temporary access for either project route is proposed at a later date, the Company will complete an assessment for potential environmental and cultural impacts. If any additional proposed temporary access routes adversely impacts environmental or cultural areas of concern, the proposal will be abandoned. If the review indicates no environmental or cultural impacts, a copy of the review with a description of the proposed construction activity would be provided to the PSC and DNR.

Upon approval of a project, the preliminary access plan may be amended based on negotiations with local landowners and/or contractor requirements. For both project routes, temporary off-ROW access will be pursued to minimize potential environmental impacts associated with temporary stream crossings, wetland crossings, or other sensitive resources.

Access methods may also include the use of low ground pressure equipment, or construction mats. The goal of these alternative construction access methods is to prevent or minimize the temporary construction-related ground disturbances in order to reduce the potential for creating conditions that would be conducive to introducing non-native plants or disrupting desirable plant communities.

There are 19 temporary off-ROW preliminary access easements that are proposed to be utilized to construct the Project. Fourteen of these are situated along private lanes or roads with either a current or prior use history. These existing roads consist of either gravel or bare ground, and they provide private access to parcels for agricultural and recreational use. Two of these access routes are similarly located along existing private roads, but may need to be widened slightly to accommodate construction equipment. Three access easements are situated between Highway 12 and the Union-Pacific railroad in Jackson County and are not co-located with existing access roads. Project off ROW temporary access easements are not anticipated to impact any adjacent wetlands or waterways, if present. All temporary access routes and their locations are indicated below.

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Table 19 – Temporary Access Routes

Access Road Mapset Page Size (ac)

1 A 1 0.1

2 A 41 1.4

3 A 41 1.4

4 A 52 1.5

5 A 54 0.7

6 A 57 2.5

7 A 57 0.2

8 A 59 0.2

9 B 70 0.3

10 B 70-71 6.0

11 B 72 0.9

12 B 73 1.2

13 B 73-74 1.1

14 B 81 0.3

15 B 84 0.1

16 B 84 0.1

17 B 85 0.1

A 88

B 93

19 A 93-94 0.4

Total 20.2

18 1.7

Two of the nineteen proposed access routes are located within known cultural resource sites, including access roads 7 and 19. Proposed access road 7 occurs partially in cultural resource 47JA0525. Known as the Cynthia Jean site, approximately 0.14 acres of the proposed access road footprint is within this site. The site consists of a lithic scatter that includes a stage II bi-face. Initial field work did not cover the access road foot print. Therefore, further investigation will need to be completed in the spring when the ground thaws to determine if any impacts to the site will occur. Cultural resource 47MO0044, the Lavern site, is present under a portion of access road 19. Approximately 0.14 acres of the site occurs within the footprint of the proposed access road. The site is described as a campsite/village and specimens from the site have been lost. This site has not been investigated due to lack of land owner permission. Further investigation will need to be completed in the spring when the ground thaws and permission is granted.

3.4.10 Waterway Permitting Activities

The Company anticipates needing permits (Wis. Stat. § 30.123) for utility installation and temporary stream crossings along both routes, and is therefore seeking approval to cross streams using Temporary Clear Span Bridges (TCSB) for equipment access, and dredging (trenching) as the preferred pipeline installation method. In addition, the Company is

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seeking permits from the U.S. Army Corps of Engineers for utility crossings under Section 404 of the Clean Water Act (CWA), including state certification under Section 401 of the CWA. Included in Appendix C – Environmental Information is a completed joint state-federal permit application Form 3500-53 for impacts to waterways.

A summary of all waterways intersecting Routes A and Route B is presented in the Environmental Inventory Tables referenced in the Wetland Delineation Report (Tables 6A and 6B) and in, Tables 5A and 5B (Supplement to Form 3500). These Tables are provided in Appendix C – Environmental Information. These regulated activities and crossings are listed in Tables 5A and 5B. In general, TCSB’s will be needed for equipment access across streams where construction will not utilize Horizontal Directional Drilling (HDD) construction techniques (i.e. open cut trench stream crossings). Additionally, photographs for stream crossings are embedded in the GIS data transmitted in digital format to the PSC.

The waterways and waterbodies identified on the DNR Hydrography GIS data is shown on Figures 2A and 2B (Appendix B – Maps). A total of 23 and 19 waterways and waterbodies were found not to be present during field investigations along Routes A and B, respectively. The locations and notes regarding these potential waterways and waterbodies are provided in the tables below:

Table 20 – List of waterways/waterbodies found to not be present along Route A

Route-

Segment

Figure

2A Page Waterway Type

Figure 2A

Parcel # Comments

A1 3 USGS intermittent stream 6-9 P12 No defined channel; 06-09_S1 nearby

A1 8 USGS intermittent stream 9-9 P8 No defined channel present east side of CTH H

A2 31 USGS intermittent stream 19-10 P3 No defined channel; upland grass waterway

A3 41 USGS intermittent stream 27-11 P2 No defined channel-corn standing 9/24/2012

A4 44 USGS intermittent stream 29-12 P5 No defined channel within 29-12_W5

A4 46 USGS intermittent stream 29-13 P7/ P14 No defined channel within 29-13_W5 & W3

A4 47 USGS intermittent stream 29-14 P15 No defined channel within 29-14_W2

A5 52 USGS intermittent stream 31-15 P35 No defined channel present

A5 53 USGS perennial stream 32-15 P29 No defined channel within 32-15_W1

A7 60 USGS intermittent stream 37-17 P22/ P50 No defined channel present

A7 70 USGS intermittent stream 41-23 P8 No defined channel or wetland present

A8 82 USGS intermittent stream 48-27 P8 No defined channel or wetland present

A8 83 USGS intermittent stream 48-27 P26 No defined channel or wetland present

A8 83 USGS intermittent stream 48-28-P34 No defined channel or wetland present

A8 84 USGS intermittent stream 48-28-P60/ P64 No defined channel or wetland present

A8 85 USGS intermittent stream 49-29-P22 No defined channel or wetland present

A8 88 USGS intermittent stream 51-30-P10 No defined channel or wetland present

A9 91 USGS intermittent stream53-29 P15 & 53-

30 P13No defined channel or wetland present

A9 93 USGS intermittent stream 55-30 P18/ P39No defined channel or wetland present; flows into

55-30_W2

A9 94 USGS intermittent stream 56-30 P43/ P39 No defined channel or wetland present

A9 95 USGS intermittent stream 57-30 P27 No defined channel or wetland present

A9 96 USGS intermittent stream 57-30 P40No defined channel or wetland present within or

adjacent to 57-30_W2

A11 101 USGS intermittent stream 29-11 P19/ P4 No defined channel or wetland present

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Table 21 – List of waterways/waterbodies found to not be present along Route B

Route-

Segment

Figure

2B Page Waterway Type

Figure 2B

Parcel # Comments

B2 42 USGS intermittent stream 24-11 P21 No defined channel within or adjacent to 24-11-W1

B2 43 USGS intermittent stream25-10 P20 &

25-11 P19

No access for field surveys; no visible channel on

aerial

B3 49 USGS intermittent stream29-12 P7 &

28-12 P10No defined channel within 28-12_W1

B4 51 USGS intermittent stream 28-13 P17 No defined channel - grass waterway

B4 51 USGS intermittent stream29-13 P7/ P10/

P14No defined channel within 29-13_W3/ W5

B6 63 USGS perennial stream 35-15 P95 35-15_S2 (Allen Creek) within culvert

B6 64 USGS intermittent stream 36-15 P114 35-15_S4/ S5 within culvert

B6 64 USGS waterbody 36-15 P40 No waterbody within 36-15_W2

B7 68 USGS perennial stream 38-16 P13 No defined channel within 38-16_W2

B7 68-69 USGS perennial stream 39-17 P37 No defined channel to extend 38-16_S1

B7 73 USGS waterbody 41-20 P22 No waterbody present within 41-20_W10

B7 78-79 USGS waterbody 43-23 P2/ P17 No waterbody present within 43-23_W3

B8 88 USGS intermittent stream 48-28 P51/ P68 No defined channel present

B8 90 USGS intermittent stream 49-29 P22 No defined channel present

B9 94 USGS intermittent stream 51-30 P16No defined channel present within or adjacent to 51-

30_W2

B9 96 USGS intermittent stream 53-30 P19/ P27No defined channel present within or adjacent to 53-

30_W3

B9 100 USGS intermittent stream 56-30 P37 No defined channel present

B9 101 USGS intermittent stream 57-30 P26 No defined channel present within 57-30_W5

B11 104 USGS intermittent stream 29-10 P10 No defined channel present within 29-10_W1

The use of TCSB’s for Route A and B have been avoided and minimized by utilizing HDD boring and/or equipment access from either side of the streams, or by routing around them within existing public ROW to the extent practicable. The Company will work with private landowners to identify potential alternate access routes on properties to further minimize the number of stream crossings on the selected route. This may help eliminate some of the temporary stream crossings if the Company obtains alternate access approval via private landowners. However, the Company is requesting permits for all potential waterway crossings on the selected route in the event further avoidance is not possible.

Construction along Route A would involve trenching across a total of 28 waterways and would require 24 TCSB’s as listed by segment in Table 5A. The difference between these is that in segments where construction is proposed in the road bed, the trench will cross the waterway in the location of an existing culvert and not in the streambed itself. Trenching across waterways and related use of TCSB’s are needed in most of the segments along Route A to install the pipe and cross intermittent and perennial streams including Pea Creek, Black Creek, Mud Creek, and 26 other streams. A total of 21 waterways are designated by the DNR as trout streams, seven (7) are designated by DNR as outstanding or exceptional waterways, and nine (9) other waterways are otherwise designated as Areas of Special Natural Resource Interest (ASNRI’s) as listed in Tables 5A and 6A.

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Construction along Route B would involve trenching across a total of 43 waterways and would require 38 TCSBs as listed by segment in Table 5B. Trenching across waterways and related use of TCSB’s are needed in most segments along Route B to install the pipe and cross intermittent and perennial streams including Glenn Creek, Robinson Creek and 41 other streams. A total of 20 waterways are designated by the DNR as trout streams, seven (7) are designated by DNR as outstanding or exceptional waterways, and 13 other waterways are otherwise designated as ASNRI’s as listed in Tables 5B and 6B.

Stream characteristics for all waterway crossings (e.g., width, depth, substrate, approach slope, etc.) along Routes A and B are included on Tables 6A and 6B. Stream crossing locations are shown on Figures 2A and 2B. Detailed plans and/or drawings of a standard TCSB are contained in Appendix H – Construction Figures and described in Section 3.6.3.

3.4.11 Wetlands

3.4.11.1 Wetland Delineation

Wetlands were identified and delineated using the conservative approach described in the subsection below and summarized in the Wetland & Waterway Investigation Report is provided separately on a DVD. This report includes methods, results, summary tables, data forms, figures, photographs, and/or references to related supporting documentation. One purpose of the investigation was to determine the type and extent of wetlands located within Routes A and B, distribution/branch lines, construction access locations, and laydown yards.

3.4.11.2 Conservative Approach to Identify Wetlands and Their Boundaries

A conservative approach was used to identify wetlands and their boundaries. Remote sensing tools were initially used to identify potential wetlands in relation to Wisconsin Wetland Inventory (WWI) mapping. Field surveys were conducted within properties where access permission was granted to refine the remote sensing data by ground-truthing procedures. Approximately 85% of the wetlands were delineated in this way. Ground-truthing included identifying wetlands, classifying wetlands by type, recording dominant wetland and adjacent upland plant species, general observations about wetland hydrology and soils, noting presence of invasive species, locating wetland boundaries, and taking photographs. This method generally did not include soil sampling (i.e., digging soil pits) to observe or document hydric soil indicators or subsurface wetland hydrology indicators. The location of wetland boundaries was placed at obvious breaks in topography and/or where non-hydrophytic vegetation was more prevalent. Where the determination was not easily ascertained by vegetation, NRCS soil survey data, WWI mapping, and readily-observed surficial hydrology indicators were used to help identify wetland boundaries. Wetland boundaries were located with GPS and mapped using GIS.

A limited number of wetlands and waterways were identified using only remote sensing resources as well as field/aerial sketching (without ground-truthing or locating boundaries with GPS). The desktop, remote sensing method included aerial photograph interpretation in relation to WWI mapping and NRCS soil survey data to identify potential wetlands/waterways and digitize their approximate boundaries. Field/aerial sketching was

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also used to identify wetlands/waterways on properties where access permission was not granted in 2012, but the features were readily observed from adjoining public roads or other accessible property and sketched on aerial photographs in the field. As indicated above, these procedures were conducted to a limited extent on approximately 15% of the wetlands within the Project corridor. Consequently, additional unmapped or unidentified wetland/waterway features likely exist within portions of the Project corridor that were not accessible. Therefore, the presence/absence of additional (unidentified) features and accuracy of field/aerial sketched features will be field verified along the selected route after additional property access and/or PSC Order is granted and prior to construction.

A total of 305 wetlands were identified and delineated within Route A; while along Route B, a total of 425 wetlands were identified and delineated. These totals include only the wetlands that intersect, or are adjacent to, the construction easements along the routes and the distribution/branch lines. A variety of wetland types were identified including hardwood swamp, floodplain forest, bogs, white pine – red maple swamp, alder thicket, shrub carr, wet and sedge meadows, shallow marsh, shallow open water, ephemeral ponds, farmed wetlands, and excavated ponds. Wetlands delineated along Routes A and B are shown on Figures 2A and 2B respectively in the Wetland & Waterway Investigation Report (Appendix C – Environmental Information) and are listed in Environmental Inventory Tables (Tables 6A and 6B) for each route. The environmental survey corridor included a review of more land than is needed for construction; therefore, not all wetlands identified and delineated will be crossed to construct the Project on the selected route. Wetland crossings by route are described below.

3.4.11.3 Wetland crossings

Wetlands are present along Routes A and B and distribution/branch lines. The locations of wetland crossings are shown on Figures 2A and 2B in the Wetland & Waterway Investigation Report (Appendix C – Environmental Information). Anticipated wetland crossings are also summarized in Tables 5A and 5B Supplemental documents to Form 3500-53 (Appendix C – Environmental Information). Information contained in the aforementioned tables includes route/segment, feature ID, wetland type, dominant species, crossing length, estimated impacts, presence or absence of invasive species, sensitive wetlands, and DNR designated waters and Areas of Special Natural Resource Interest (ASNRI’s).

The aforementioned figures and tables provide a detailed comparison of wetland crossings by route. In summary, a total of 125 wetlands having a total combined impact area of 44.50 acres would be crossed by Route A. Alternatively, a total of 179 wetlands having a total combined impact area of 54.69 acres would be crossed by Route B. These totals include the distribution/branch laterals that would be part of each route.

Wetlands, waterways, and other sensitive natural resources to be crossed by Route A, Route B, and the distribution/branch lines are summarized in Tables 5A and 5B. Information contained in these tables includes segment/route, feature ID and type, location data, length of waterway crossing, crossing methods (e.g., HDD, trench), sensitive wetlands and ASNRI’s, wetland/waterway impacts and permits required. This information is

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provided specifically for state and federal wetland/waterway permitting purposes (also refer to Sections 3.4.10, 3.10.1 and 3.10.2).

An important objective of the Project planning and preliminary design process was to avoid and minimize impacts to wetlands, waterways, and other sensitive natural resources to the extent practicable. These measures are described in more detail in Sections 3.4.10 Waterway Permitting and 3.10 DNR Permits/Approvals. However, due to clearing, equipment access, and trenching construction methods, temporary impacts to wetlands, waterways, and other sensitive natural resources are unavoidable. The Company and its contractors will take steps to further minimize impacts to wetlands, waterways, and other sensitive natural resources during the final design and access planning phase associated with the selected route and as noted in the subsection below by reference to other related sections of this application.

3.4.11.3.1 Ppresence or absence of invasive

Field surveys of the proposed project corridors were completed in Fall 2012. During the field surveys, staff documented plant community types and dominant species along waterways, in wetlands that were field delineated, and on uplands. Furthermore, observed invasive species were documented by providing their location, abundance and composition. A general summary of observed terrestrial invasive species, as defined in NR 40, Wis. Adm. Code is provided below.

The following Restricted species were observed:

Reed canary grass (Phalaris arundinacea)

Glossy buckthorn (Rhamnus frangula)

Common buckthorn (Rhamnus cathartica)

European bush honeysuckle (Lonicera x bella)

Spotted knapweed (Centaurea biebersteinii)

Japanese knotweed (Polygonum cuspidatum)

Leafy spurge (Euphorbia esula)

Common reed (Phragmites australis)

There were no Prohibited species observed. Reed canary grass was the most prevalent species, present in many locations, such as in wetlands and along waterways, and occurring in high densities, frequently over 50 percent cover. Spotted knapweed occurred in low to moderate densities, typically along roadsides, railroads, and ATV trails. Glossy buckthorn was a frequent occurrence in forest understories, usually occurring in low to moderate densities. Honeysuckle and common buckthorn both occurred rarely and in low densities. Leafy spurge occurred along a roadside in low density. Japanese knotweed occurred once, in moderate density along a roadside. Common reed occurred once in a wetland at high densities.

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There were no observations of aquatic invasive species along the project corridor. All of the water bodies crossed by the corridor are too small to provide habitat for zebra mussels, and current distribution mapping for zebra mussels (Dreissena polymorpha) and Viral Hemorrhagic Septicemia virus shows that there is very low likelihood of these species being present along the project corridor. If further consultation with regulators indicates a possibility of other aquatic invasive species, Wisconsin Gas will identify and implement appropriate Best Management Practices (BMPs) for aquatic species.

3.4.11.4 Sensitive wetlands and areas of special natural resource interest

The determination of sensitive wetlands and Areas of Special Natural Resource Interest (ASNRI) was based on review of available resources to determine if any wetlands to be affected by the Project are considered sensitive including any wetlands in or adjacent to the following: i) an ASNRI listed in sec. NR 103.04, Wis. Adm. Code, ii) surface waters identified as Outstanding or Exceptional Resource Water (ORW or ERW) in Ch. NR 102, Wis. Adm. Code, and iii) other sensitive wetlands as listed in sec. NR 103.08(4)(c)3 including deep marsh; wet prairie not dominated by reed canary grass; fresh wet meadow and sedge meadow not dominated by reed canary grass and located south of Hwy 10; coastal marsh; interdunal or ridge and swale complex; wild rice dominated emergent aquatic; open bog, bog relict, and muskeg, including all bogs located south of Hwy 10; floodplain forest; ephemeral ponds in wooded settings; hardwood swamp located south of Hwy 10; conifer swamp located south of Hwy 10; and cedar swamp located north of Hwy 10. Sources reviewed included direct field observations; DNR designated waters database; DNR surface water data viewer; Chs. NR 19, 102, and 103 Wis. Adm. Code; and DNR managed lands/public lands database.

An environmental feature ranking system was developed to help identify ASNRI’s and rate the overall quality of wetlands and waterways identified within the Project corridor. Waterway quality is ranked on a scale of 1 to 4, where 1 is low, 2 is medium, 3 is high, and 4 is exceptional. The rankings are weighted and based on state designated trout stream or cold water resource; designated Public Rights Feature (PRF), ORW, or ASNRI; listed Element Occurrence (EO) of listed aquatic species; and physical characteristics of the waterway. Wetland quality is also ranked on a scale of 1 to 4 as described above based on specific type of wetland as listed above and in sec. NR 103.08(4)(c)3; potential listed species habitat present based on field assessment; plant diversity and invasive species present; wetland hydrology; and other listed EO’s. Sensitive wetlands and other waters and features identified as ASNRI’s are shown in Figures 2A and 2B, listed and ranked in the Environmental Inventory Tables for each route (Tables 6A & 6B) in the Wetland & Waterway Investigation Report (Appendix C – Environmental Information), listed in Tables 5A and 5B (Appendix C – Environmental Information), and are briefly summarized by route below.

Sensitive wetlands and ASNRI’s identified along Route A includes numerous unnamed intermittent and some perennial streams, South Fork of Eau Claire River, Horse Creek, Black Creek, and numerous hardwood swamps, sedge meadows, shallow open water and coniferous swamp wetlands located south of USH 10. Sensitive wetlands and ASNRI’s identified along Route B include numerous unnamed streams, Horse Creek, Glenn Creek,

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Robinson Creek, and numerous hardwood swamps, wet/sedge meadows, bogs, coniferous swamp, and deep marsh wetlands located south of USH 10.

Implementation of BMPs combined with standard environmental protection procedures will avoid and minimize impacts to wetlands, surface waters and other sensitive natural resources to the extent practicable. These measures are described in the Construction Methods (Sec. 3.6), Material Management (Sec. 3.7), Dewatering Plan (Sec. 3.8), Associated Facilities Information (Sec. 3.9), and DNR Permits and Approvals (Sec. 3.10) sections.

3.5 Mapping Wetland and Waterway Crossings

Topographic, Project Location and Orthophotography and Environmental Features map sets are contained in Appendix B – Maps.

3.6 CONSTRUCTION METHODS

3.6.1 General Construction Methods

Several construction techniques will be utilized to install the pipeline. The basic techniques used will be open trench, jack and bore, and horizontal directional drilling. Typical construction drawings of these techniques are included in Appendix H – Construction Figures and will be described in further detail in the Section 3.6.

3.6.1.1 Construction equipment

Construction equipment used on these types of projects include: dozers, graders, excavators, trenchers, dump trucks, back hoes, side booms, ATV’s, road bore rigs, horizontal directional drill rigs, pickup trucks, rock trenchers, vacuum excavators, rippers, tillers, rock picking machines, welding rigs and trucks, and x-ray trucks.

3.6.1.2 Size of trench

Typically the size of the trench will be approximately four feet wide by six feet deep. Areas where the soil has limited cohesion, the trench width may need to be widened to allow for benching or sloping, ensuring adequate depth of cover for the gas pipe is achieved. In agricultural lands, trench depth should be sufficiently deep enough to allow a minimum of four feet of cover over the top of the pipeline to avoid possible interference with farming equipment.

3.6.1.3 Construction disturbance zone

For the portions of the project that are constructed in agricultural lands a permanent easement of 50 feet and a temporary construction easement of 50 feet will be used. For portions of the project adjacent to road right-of- way and in non-agricultural lands a 50 foot permanent easement will be used adjacent to the road right of way and the non-paved right-of- way will be utilized for temporary work space. To minimize disturbance to environmentally sensitive areas such as wetlands, waterways, and forests a 75 foot wide

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corridor consisting of a 50 foot permanent easement and 25 foot temporary construction easement will be used.

3.6.1.4 Staging and temporary work areas

At this time several staging areas have been identified. All proposed staging areas that have been determined will have an environmental and cultural assessment completed to determine if any adverse impacts exist. Additionally the contractor hired for the project may, for convenience or safety reasons be able to arrange alternate staging areas with private landowners. If additional staging areas are proposed at a later date the company will complete an assessment of the site for potential environmental and cultural impacts. If the proposed staging area could have an adverse impact the proposal will be abandoned. If the review indicates no impacts, a courtesy copy of the review with a description of the proposed construction activity will be provided to the PSC and DNR.

Waterway and road and rail crossings will usually require additional temporary work space (ATWS) to facility the horizontal directional drilling or jack and boring equipment. In general the ATWS for horizontal directional drilling will be an additional 25 feet adjacent to the 75 foot wide construction corridor for a span of 200 feet, and the ATWS for the jack and boring equipment will be an additional 50 feet adjacent to the typical 75 foot wide construction corridor for a span of 100 feet. All anticipated ATWS is shown on the aerial maps supplied in Appendix B – Maps.

3.6.1.5 Construction methods

3.6.1.5.1 Agricultural lands

Construction activities that will take place in agricultural lands will be within a 100 foot easement. (50 foot permanent and 50 foot temporary) Construction techniques will follow best management practices along with agricultural inspection oversight to minimize impacts to agricultural land. Erosion control measures will be installed to lessen the potential for soil mixing and topsoil will be stored separately from subsoil. Topsoil will be stripped off the trench line and subsoil storage area. If glacial till or cobble layers are present in the soil horizon it will be stockpiled separately. After the pipeline is installed in the trench, the subsoil will be placed back in the trench and the topsoil redistributed to maintain soil productivity. To minimize the potential for soil compaction in agricultural areas certain construction techniques may be suspended when warranted due to wet weather conditions or soil decompaction techniques utilized. Pipeline construction may also inconvenience farmers by cutting livestock fences within the construction work area. Measures to protect livestock and crops during excavation activities will be determined in cooperation with landowners. Precautions will be taken to adequately protect, repair, and replace damaged drainage systems. Tile lines that are cut or removed during the trenching process will be repaired promptly after the pipeline has been installed in the trench.

3.6.1.5.2 Forest lands

Construction activities that will take place in forest lands will be narrowed to a 75 foot easement (50 foot permanent and 25 foot temporary) to minimize the loss of trees. In the

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majority of forest lands the company plans to use existing corridors of cleared space that range from 30 to 75 feet or greater. The corridors can range from existing forest roads, township roads, and all-terrain vehicle trails. Right of way clearing will be conducted in accordance with permit stipulations and will be limited to the extent needed for construction and operation of the pipeline. Where tree clearing is required the trees will be cut and stacked along the right-of-way based on landowner preference. Landowners will have the option of retaining ownership of cleared brush or timber. Trees, stumps, and brush that the landowner does not choose to retain will be taken care of by burning, mulching, or other approved means. Pipeline construction may inconvenience traffic along the rural roadways in these forest lands. Care will be taken to coordinate construction activities to the local municipalities to ensure emergency vehicles and local traffic will have adequate access.

3.6.1.5.3 Surface waters, and wetlands

Construction activities that will take place in surface waters, and wetlands will be narrowed to a 75 foot easement (50 foot permanent and 25 foot temporary) for areas intended for open cut and a 50 foot easement in areas that will be horizontally directionally drilled. This reduced easement area is intended to minimize the impacts to wetlands and waterways. Waterways will be crossed using techniques described in Section 3.6.3.1Wetland crossings will use techniques described in Section 3.6.4. With each of these techniques, appropriate best management practices will be implemented to minimize the duration and extent of the construction related disturbance.

3.6.2 Roads and Driveway Crossings

Road and driveway crossings will be accomplished by either open-cut where possible, or by jack and boring under roads where open cut is not possible or practical. The jack and boring method is used to cross roadways or railways with minimal disruption to traffic. Typically, the pipe easement area and additional temporary work space is stripped of topsoil which is stockpiled on one side of the workspace. Bore pits are excavated on each side of the obstruction that will be crossed. The entrance and exit bore pits are generally 20 feet by 30 feet in size and range in depth from 6 to 12 feet depending on the depth of cover required for the pipe being installed. The excavated materials from the bore pits will be stockpiled next to the topsoil. If groundwater is encountered in the bore pits it will be pumped from the pits into a dewatering structure. Access pads are installed to allow equipment to move from one side of the road to the other. Tires are also placed on the road surface to allow tracked equipment to cross the roadway without damaging the paved surface. The auger boring machine is set up in the entrance pit and a casing pipe is jacked under the obstruction while the earth is removed by the auger rotating inside casing pipe. The new carrier pipe is attached to the casing pipe and is either pushed or pulled under the road or railway. After the new carrier pipe is installed and tied into the rest of the pipeline the bore pits will be backfilled with the stockpiled spoil. Access pads and dewatering structures will be removed and the stockpiled topsoil will be replaced to the original grade. Temporary erosion control measures will be removed after permanent erosion control measures are installed and vegetation is re-established. Typical constructions drawings of a jack and bore set up along with dewatering structures and access pads are attached in Appendix H – Construction Figures.

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Coordination with local officials to minimize traffic disruption will take place prior to construction. The Company will obtain applicable federal, state, county, township, and municipal permits before conducting road crossings. Construction timing will be communicated to landowners surrounding the right-of-way or acquired easement area to minimize disruptions. Open cut roads and driveways will be backfilled after pipe installation to allow proper access at all times. If an open cut road crossing requires extensive construction time, provisions will be made for detours or otherwise permit traffic flow while construction is underway. Roads and driveways that are open cut will be restored or repaved.

3.6.3 Waterway Crossings

Waterways will be crossed by either open cutting or horizontal directional drill (HDD). An environmental feature ranking system was developed to help identify Areas of Special Natural Resource Interests (ASNRI) and rate the overall quality of waterways identified within the project corridor. Waterway quality is rated on a scale of 1 to 4, where 1 is low, 2 is medium, 3 is high, and 4 is exceptional. Waterway quality is based on potential listed species habitat present based on field assessment; plant diversity; wetland hydrology; and other listed environmental observations (EO’s). Sensitive waterways, wetlands and features identified as ASNRI are listed and ranked in the environmental inventory tables for each route (Appendix C – Environmental Information; Tables 1A & 1B). The quality, size, and location were all determining factors as to which waterways were selected for open cutting or HDD. Please refer to Table 5A & 5B for anticipated waterway crossing methods that are anticipated for the proposed routes.

3.6.3.1 Crossing technique

3.6.3.1.1 Dry Open Trench with bypass system

Dam and Pump

The dam and pump crossing method is appropriate for small streams with low flow rates that are sensitive to sediment loading. This technique involves damming the water upstream and downstream of the crossing site with sand-bags, sheet piling, or other materials that do not add sediment to the stream. Water is pumped from the upstream side around the construction area to the downstream side. Because the stream flow is pumped around the construction area, this method results in minimal sedimentation. Pump sizing will be determined by the on-site environmental inspector in cooperation with the DNR, based on the site specific conditions at the time of construction. Water levels will be monitored throughout the pumping operation and adjustments made if necessary to maintain flow. To prevent the inadvertent uptake of fish or debris during pumping, the intake hose will be screen and suspended above the streambed. The discharge hose will be directed to an energy dissipation device such as plywood boards or a splash pup on the downstream side of the dam to prevent scouring of the streambed. After the crossing site between the upstream and downstream dams is isolated, a portable pump will be used to evacuate standing water from between the dams to create a dry construction area. The water will be discharged into a dewatering structure of straw bales and silt fence, or into a geotextile filter bag located away from the stream banks. The trench will be excavated

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across the streambed and a section of pipe long enough to span the stream will be installed. Following the pipe installation the trench will be backfilled with the excavated material and restored as directed per permit conditions. The dams and pumps will be removed and the stream flow will resume across the restored streambed. Water body crossings will not be initiated during high-flow conditions or if heavy rainfall is anticipated. Crossings using the dam and pump method will be completed with 24 to 48 hours. Typical construction drawings of the dam and pump method, along with dam structures, dewatering structures, temporary bridges, and slash pups are attached in Appendix H – Construction Figures.

Dry Flume

The flume crossing involves diverting the flow of the stream through flumes places in the stream channel. The flume crossing method is suitable for small to intermediate streams that have a moderate stream flow, a relatively straight channel, are free of large rocks or boulders and are sensitive to sediment loading. A sufficient number of flume pipes will be placed in the stream to accommodate the highest anticipated flow during the time of construction as well as minimize water velocities at the discharge end to prevent scouring of the streambed. Flumes will be aligned in the stream parallel to the water flow. After the flumes are placed in the stream, sand or pea gravel bags will be used to construct an upstream bulkhead designed to direct the stream flow through the flumes. A similar bulkhead will be installed at the downstream end of the flumes to prevent backwash from entering the construction area. After the stream flow is diverted through the flumes, adjustments to the dams will be made to minimize leaks. A portable pump will be used to pump excess water from between the dams into the dewatering structures. (i.e., straw bales/silt fence structure or geotextile filter bag) located away from the stream. After the crossing site is isolated, a trench will be excavated underneath the flumes and a section of pipe long enough to span the stream will be pulled beneath the flume. Following the pipe installation the trench will be backfilled with the excavated material and restored as directed per permit conditions. The dams and flume pipes will be removed and stream flow will resume across the restored streambed. Typical construction drawings of the flume method along with dam structures, and temporary bridges are attached in Appendix H – Construction Figures.

Wet Trenching

The wet-trench crossing method involves excavating a trench across the waterbody using either backhoes or excavators operating from the stream banks. Temporary extra work space will be required on each side of the waterbody to stage the crossing but will be set back from the waterbody boundaries. Clearing of vegetation between the extra work space and the waterbody will be limited to the construction right-of-way and minimized wherever practical. Temporary bridges may be installed to allow access of equipment across the waterbody. To provide a safe and level work area and allow for engineering constraints (e.g., pipe bending limitations), stream banks and approaches may be graded during construction. Spoil excavated during trenching will be temporarily stored in sediment containment barriers (i.e., silt fence and/or staked straw bales) a minimum of 10 feet from the edge of the stream unless permitted by the permitting authority. An earthen trench plug will be placed between the upland trench and the in-stream trench to prevent silt-laden

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runoff from the disturbed upland areas from entering the waterbody and limit the intrusion of water into the upland areas of the trench. The trench plug will remain in place until just prior to pipe installation. Once the trench is excavated across the waterbody, the trench plugs will be removed and a prefabricated section of pipe will be lowered into the trench. If trench dewatering is necessary to complete the tie-in welds, dewatering will be conducted so that the heavily silt-laden water will not flow into the waterbody. Following the pipe installation the trench will be backfilled with the excavated material and restored as directed per permit conditions. After backfilling, the affected right-of-way will be re-graded to pre-construction contours. Disturbed waterbody banks will be stabilized with geotextile fabric, erosion control matting, or similar materials. Disturbed soils will be seeded, fertilized, and mulched in accordance with re-vegetation requirements and applicable permit conditions. Temporary bridges will be removed. When permanent erosion control measures are installed and vegetation is re-established, temporary erosion control measures will be removed. When using the wet trench crossing method the disturbance is to be completed in less than 24 hours.

3.6.3.1.2 Horizontal Directional Drill

The horizontal directional drilling (HDD) method is a complex crossing technique that is sometimes suitable for wide water bodies where there is a need to avoid disturbance of the bed and banks or disruption of navigation. HDD is also used to cross environmentally sensitive areas where minimizing excavation disturbance is crucial. The feasibility of HDD is largely dependent on the local geologic setting. The company will conduct geotechnical studies to confirm that conditions at the anticipated HDD crossings are suitable for this technique. Because HDD avoids disturbances of the water body’s bed and banks, it eliminates in-stream sedimentation associated with trenching. Environmental impacts associated with this technique include the potential for pressurized drilling mud, typically bentonite, to seep to the surface through natural fractures called “frac-outs”. To minimize any adverse effects associated with frac-outs, Work Procedure ENVR-745 will be followed. (See Appendix C – Environmental Information, ENVR - 745) The following points will be incorporated into the HDD process.

The bore path will be monitored for evidence of a frac-out for prompt response

Appropriate containment materials will be on-site such as silt fence, hay bales and sand bags.

Vacuum excavation will be readily available on short notice to respond quickly to a frac-out

Additionally, extra work space is required on both sides of the crossing to accommodate the drilling machine and associated equipment. Typically this space is approximately 100 feet by 200 feet. A typical layout of the HDD equipment is provided in Appendix H – Construction Figures. The HDD process contains several stages to complete a crossing. In the first stage a drill machine will be set up and a small diameter pilot hole will be drilled under the obstacle to be crossed along a prescribed profile. Electromagnetic sensors will be used to guide the drill bit. Once the pilot hole is completed, it will be enlarged, using reaming tools, to accept the pipeline. The reaming tools are attached to the drill string at

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the exit point of the pilot hole and are rotated and drawn back to the drilling rig. During this process, drilling mud will be continuously pumped into the hole to remove the soil cuttings and maintain the integrity of the hole. Water from the water body being drilled or other suitable location will be appropriated in accordance with the applicable permits and used to prepare the drilling mud slurry. The intake pump used to collect water will be protected with either a slotted pipe or mesh cage. Typical drawings of this set up are attached in Appendix H – Construction Figures. Once the hole has been sufficiently enlarged, a prefabricated section of pipe will be attached behind the reaming tool on the exit side of the crossing and pulled back toward the drill rig, completing the crossing. The company will temporarily store used drilling mud and cuttings on site and will employ appropriate measures such as containment pits or berms to prevent flow of the material back to wetland, waterways, or environmentally sensitive areas. After the crossing is completed, the material will be placed in an approved upland area or disposed of in accordance with applicable permits or regulations.

In the event that an HDD crossing is unsuccessful, due to either bore refusal or severe frac-out problems the Company would at that point intend to cross a wetland or waterway using an open trench technique. The open trench techniques that would be employed for wetland crossings are described in Section 3.6.4.1. Prior to any change in crossing technique the Company would contact the applicable agencies for concurrence.

3.6.3.2 Pre and Post Project Diagrams

Once a final pipeline route has been selected the Company will prepare a project-specific set of construction drawings and Erosion Control Plan that will have all crossings shown on a plan and profile (cross-section) concept. Please refer to typical stream crossing techniques supplied in Appendix H – Construction Figures.

3.6.3.3 Access Roads Associated with Temporary Bridges

Temporary bridges will be accessed from the proposed pipeline right-of-way. Please refer to Section 3.4.9 with regard to specific additional access roads required to access the pipeline right-of-way. Typical drawings of temporary bridges that may be needed to move equipment over waterways are included in Appendix H – Construction Figures. Once a final pipeline route has been selected access roads as well as temporary bridges will be shown on the construction drawings and Erosion Control Plan.

3.6.4 Wetlands Crossings

3.6.4.1 Crossing Methods

Wetlands will be crossed by either open cutting or horizontal directional drill (HDD). An environmental feature ranking system was developed to help identify Areas of Special Natural Resource Interests (ASNRI) and rate the overall quality of wetlands identified within the project corridor. Wetland quality is rated on a scale of 1 to 4, where 1 is low, 2 is medium, 3 is high, and 4 is exceptional. Wetland quality is based on potential listed species habitat present based on field assessment; plant diversity; wetland hydrology; and other listed environmental observations (EO’s). Sensitive wetlands and other waters and features

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identified as ASNRI’s are listed and ranked in the environmental inventory tables for each route (Appendix C – Environmental Information; Tables 1A & 1B), and also listed in Tables 5A and 5B.

Similar to waterways, the quality, size, and location were all determining factors as to which wetlands were selected for open cutting or HDD. Please refer to Table 5A & 5B for anticipated wetland crossing methods that are anticipated for the proposed routes.

For wetland areas that are designated as open cut the construction right of way will be reduced from a 100 foot corridor to a 75 foot corridor. For the open cut method the topsoil will be segregated from the subsoil and placed on timber mats when applicable. It is anticipated that from 22,457 to 26,442 cubic yards of material will be excavated from the wetlands and temporarily stockpiled depending on the route or route segments that are chosen. The trench will be dewatered using a pump(s) and dewatering structure(s) as needed. The pipe will be lowered into the trench and weighted with either concrete coated pipe or ecobags (geotextile fabric bags filled with sand or other aggregate) as needed to keep it in place. See Appendix H – Construction Figures for a typical detail.

Wetlands crossed by HDD will follow the process mentioned in 3.6.3.1.2. If the additional temporary work space or access required for directional drilling encroaches any wetland boundaries the area will be matted with timber mats to minimize the disturbed area where the drilling machine and related equipment would travel or set up at the beginning and end of the proposed bore area.

With either method of crossing any disturbed slopes or banks will be stabilized with geotextile fabric, erosion control matting, or similar materials. Disturbed soils will be seeded, fertilized, and mulched in accordance with re-vegetation requirements and applicable permit conditions. Temporary bridges will be removed. When permanent erosion control measures are installed and vegetation is re-established, temporary erosion control measures will be removed.

3.6.4.2 Excavated materials from wetlands

See above.

3.6.4.3 De-watering methods

See above.

3.6.4.4 Erosion control methods

See above for erosion control methods.

Control of invasive species

The following Invasive Species Best Management Practices (BMPs) will be utilized during construction along the right-of-way (ROW) to comply with Wis. Admin Code Ch. NR 40. The intent of these practices is to limit the spread of invasive species (IS), which are common along the ROW. The IS observed on the ROW are classified as “Restricted”, which means that no one may transport, transfer, or introduce these species; however, transport for identification, control or disposal is allowed.

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Potential avenues of spread from existing IS populations on the ROW include clearing activities, woody material handling, soil stockpiling and movement, and vehicle travel along the ROW. IS may also spread onto the ROW from populations outside of the ROW, imported on equipment, or materials such as contaminated seed, mulch, soil, or aggregate. Propagules can include seeds, pieces of live stems, rhizomes and root systems. Aquatic IS may spread on equipment or through use of contaminated water when trenching through waterways.

All personnel on the project will be required to follow appropriate Invasive Species Best Management Practices (Table 22, below) for the life of the project, from planning and construction to clean-up and restoration. BMPs will apply on the ROW, work areas, access routes, staging areas and laydown yards.

The Company will use the information about terrestrial and aquatic invasive species to identify appropriate BMPs to minimize the introduction and spread of invasive species during construction as outlined in NR 40, Wis. Adm. Code, and if applicable, in reference to the Wisconsin Council on Forestry’s Invasive Species Best Management Practices for Transportation and Utility Rights of Way. These BMPs may include the following: avoidance of infested areas, removal or control of small populations of plants, scheduling construction activities during the plant’s dormant period, and cleaning of equipment prior to accessing uninfested areas.

Table 22 – Invasive Species Best Management Practices Activity / BMP Name

BMP Description1 Comments

General (Applicable to all Activities)

Training Provide appropriate resources and training in identification, control and prevention of known IS to corridor workers.

Refer to A Field Guide to Terrestrial Invasive Plants in Wisconsin & other applicable sources

Scouting Prior to implementing activities, scout for, locate and document IS infestations.

Refer to Section 3.4.11.3.1 for invasive species noted incidental to other surveys

Evaluate Consider the need for action based on: 1) the degree of invasiveness, 2) severity of the current infestation, 3) amount of additional habitat or hosts at risk for invasion, and 4) feasibility of control with available methods and resources.

Planning Plan activities to limit the potential for introduction and spread of IS prior to construction and revegetation

Cleaning Prior to moving equipment to the job site, clean soils, seeds, plant parts or invertebrates from exterior surfaces, to the extent practical.

Clean vehicles and equipment prior to mobilization to the site. Use designated equipment cleaning stations if needed.

Soil Disturbance & Veg Management

Avoid Avoid IS populations when feasible during soil disturbance and vegetation management activities.

Minimize Minimize soil disturbance and the potential spread of IS, which may include using existing roads, access points, staging areas, and alternative construction methods.

Stabilize Stabilize disturbed soils using erosion control/stormwater management BMP's and/or technical standards as soon as possible.

See Erosion Control Plan.

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Activity / BMP Name

BMP Description1 Comments

Control Determine need for treatment based on presence of IS and ensure that IS control treatments are applied within the appropriate time window.

Control/treatment only with landowner approval

Staging Locate and use staging areas that are free of IS to avoid spreading seeds and other viable plant parts.

Transport of Materials

Avoid Take steps to avoid the movement of IS to non-infested areas during transport activities.

Material Sources

Use soil, aggregate and plant material from sources that are free of IS.

Material Handling

Prior to transporting materials, manage the load to limit the spread of IS.

Manage Stockpiles

Manage stockpiles to limit the spread of IS.

Disposal Do not transport woody materials that may contain IS. If you must transport woody material that may contain IS, transport to a designated area for appropriate disposal.

Reuse & Recycle

Keep and reuse onsite materials rather than importing new materials when feasible.

Revegetation & Landscaping

Species Selection

Use native and non-invasive seed and plant materials for temporary cover crops, permanent revegetation and landscaping. Ensure the species specified in the plans are being used.

Seeding/Planting

Revegetate disturbed soils as soon as feasible to minimize IS establishment.

Natural Revegetation

Allow natural revegetation of the ground layer to occur only where site conditions permit.

Monitoring Monitor the revegetation site for IS and take action as needed.

Aquatic - Moving Equipment between Waterway Construction Locations2

Inspect Inspect and remove aquatic plants, animals, and mud from all equipment.

Drain Drain all water from all equipment and gear, including tracked vehicles, barges, silt or turbidity curtains, hoses, sheet pile and pumps.

Water must be drained back to the original water body, a sewer connected to a wastewater treatment plant, or to an upland location.

Dispose Dispose of unwanted aquatic plants and animals in an appropriate way.

Disinfect Disinfect equipment and gear by either: Washing with ~212º F water (steam clean), OR drying thoroughly for 5 days after cleaning with soap and water and/or high pressure water, OR disinfecting with either 200 ppm Virkon Aquatic for 20- to 30-minute contact time. Note: Virkon is not registered to kill zebra mussel veligers nor invertebrates like spiny water flea. Therefore this disinfectant should be used in conjunction with a hot water (>104º F) application.

Wash water must not be discharged to a water body. Options for disposal include a sewer connected to a wastewater treatment plant, or to an upland location.

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1 BMP's descriptions are adapted from the Invasive Species Best Management Practices for Transportation and Utility

Rights-of-Way manual (Wisconsin Council on Forestry, January 6, 2010) 2 If no aquatic invasives are identified on the project, equipment for construction through waterways shall be inspected,

drained, and disinfected prior to being brought onto the ROW, but do not need subsequent disinfection between waterway

locations.

An Environmental Monitor (EM) will be required to assess the project area for IS throughout the construction oversight period. Additionally, the construction contractor will report any observed or recognized IS infestations to the EM. The EM will report any infestations of IS to Wisconsin Gas, and will coordinate with both Wisconsin Gas and contractors to plan and implement Invasive Species BMPs.

Wisconsin Gas may choose to control new terrestrial IS infestations identified during the course of construction activities and until permanent vegetation is established. These infestations may be treated with herbicides or mechanically. The contractor applying herbicide is required to obtain any necessary permits and/or certifications prior to herbicide application. He/she must also keep proper documentation of location and timing of herbicide use and be prepared to provide such documentation to Wisconsin Gas or the EM upon request. Treatment will conform to manufacturers’ specifications.

3.6.4.5 Pre- and post-construction crossing diagrams

Once a final pipeline route has been selected the Company will prepare a project-specific set of construction drawings and Erosion Control Plan that will have all crossings shown on a plan and profile (cross-section) concept. Typical wetland crossing diagrams provided in Appendix H – Construction Figures.

3.6.4.6 Use of construction mats

Timber mats are anticipated to be used in areas where the Company intends to minimize vegetative disturbance, segregate top soil and spoil, and support equipment. Timber mats will also be placed in the wetland areas of the construction right-of-way when access roads are required to transport construction vehicles. Typical drawings in Appendix H – Construction Figures depict the typical use of timber matting required for the project.

3.6.4.7 Work space management and impacts

In wetland areas the construction corridor will be narrowed from the typical 100 foot width to a 75 foot width to keep the construction impacts to a minimum. Where site characteristics deem necessary timber mats would be placed in the 75 foot corridors so the top soil and spoil that is excavated can be segregated and stockpiled effectively, while keeping the surrounding vegetation and soil disturbance to a minimum. The Company also intends to used existing corridors, such as forest roads and all-terrain vehicle trails to lessen any construction impacts to wetlands.

3.6.4.8 Spoil management

Spoil that is excavated in wetlands will be stockpiled in the construction right-of-way. If a topsoil or organic soil layer is present in the wetland, it will be placed in a separate

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stockpile from the clay, sand, or mineral subsoils. Stockpiles will be placed adjacent to the trench to ensure that the soil (and associated seedbank) is replaced as closely as possible to their original location. When necessary to keep top soils and sub soils segregated as well as minimizing construction disturbances, timber mats will be utilized.

3.6.5 Site Restoration

Site restoration will focus on the areas disturbed during construction. These areas may be categorized in two ways: 1) soil disturbance; and 2) vegetation disturbance.

Soil disturbance will be limited to the four-foot wide trench and the pits needed for road and railroad borings and horizontal directional drilling. Soils disturbed by vehicular rutting greater than 6 inches deep will be leveled and restored. Wetland soils in the workspace proximate to the construction trench will be protected from equipment and stockpiling by the use of timber matting which will keep soil disturbance to a minimum and minimize compaction. Soils in the Project area are predominantly sandy and can be unstable which will be a consideration. If the trench walls are unstable and collapse during construction, the trench width may become slightly wider.

Vegetation disturbance will be temporary in nature except in forested areas where a portion of the 50-foot wide easement must remain clear of woody vegetation. In these forested areas, trees and shrubs will be cut as needed within the permanent and temporary easements to create the required workspace. Precautionary protocols during construction (described in Section 3.6.4.4) and post-construction seeding and management are expected to prevent and minimize invasive species spread and encourage the re-establishment of native species in communities dominated by native species. In certain disturbed wetlands, vegetation monitoring and management will be completed for 5 growing seasons following construction and will focus on the relative abundance and diversity of native species in those communities where invasive species were not dominant prior to construction.

The Company will use the information about terrestrial and aquatic invasive species collected during the field surveys to identify appropriate BMPs to minimize the introduction and spread of invasive species during construction as outlined in NR 40, Wis. Adm. Code, and if applicable, in reference to the Wisconsin Council on Forestry’s Invasive Species Best Management Practices for Transportation and Utility Rights of Way. These BMPs may include the following: avoidance of infested areas, removal or control of small populations of plants, scheduling construction activities during the plant’s dormant period, and cleaning of equipment prior to accessing uninfested areas. An Invasive Species Management Plan has been developed for the Project as described in Section 3.6.4.4.

Re-vegetation will be completed in areas of perennial vegetation disturbed by construction activities. The Company will not seed active or rotated croplands unless specifically requested to do so in writing by the landowner or land management agency. Seedbed preparation requirements for agricultural land are specified in the Agriculture Mitigation Plan (Appendix C – Environmental Information).

Erosion and sediment controls will be implemented as needed and maintained until final restoration and stabilization are achieved (see Section 3.6.6). After construction is

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complete, the wetland and non-wetland grades will be restored to original elevations including soil segregation and proper replacement and revegetation. Excess spoil materials will be removed from all wetlands and disposed of at an approved upland disposal site.

In all non-agricultural areas, to facilitate periodic inspections and surveys, a corridor centered on the pipe and up to 10 feet wide may be maintained in an herbaceous state, and trees located within 15 feet of the pipe that are greater than 15 feet in height may be cut and removed. Use of herbicides or pesticides within 100 feet of wetlands or waterbodies will be approved by the appropriate land management or state agency.

The Company will restore and stabilize stream/waterbody banks by installing temporary sediment barriers and other erosion control measures such as erosion control matting, as required within 24 hours of completing the crossing. For dam and pump or flumed crossings, bank stabilization will be completed before returning flow to the waterbody channel.

Wetland and non-wetland riparian areas where soil disturbance has taken place (typically limited to the construction trench) and where adjacent areas are not infested with invasive species will be re-vegetated, , with a native seed mix. Four seed mixes are expected to be developed for use to re-vegetate plant communities that were dominated by native species prior to construction: 1) Forested (wet meadow) wetland, 2) sedge meadow wetland, 3) forested upland, and 4) upland prairie-meadow. Prior to seeding, the seedbed will be prepared for optimal germination of the species in the mix. Species composition of the seed mixes will be agreed upon during discussions with regulatory agency staff during their review of the joint permit application. Such areas that were infested with invasive species will be re-vegetated with an annual cover crop of rye.

In non-wetland riparian areas, seeding and subsequent maintenance will be limited to a riparian zone at least 25 feet landward of the ordinary high water mark for the width of the disturbed portion of the construction easements. In wetland riparian areas and in wetlands without waterbodies, seeding and subsequent maintenance will be limited to the area disturbed within the wetland. Wetland areas protected by timber matting during construction may not require seeding and will be evaluated to determine need for seeding (either cover crop or a native seed mix) upon removal of the matting.

The Company will monitor restoration by conducting inspections of disturbed areas, including wetlands and non-wetland riparian areas/shoreline zones, for up to five growing seasons following construction to determine the success of re-vegetation. Monitoring in wetlands and non-wetland riparian areas that were dominated by native species prior to construction will include quantified floristic quality measurement techniques that involve transects-intercepts and quadrats at intervals agreed upon by agency staff during the permit application review period. Re-vegetation will be considered successful if the floristic quality (i.e. Floristic Quality Index or mean Coefficient of Conservatism) of the herbaceous species in the re-vegetated areas is equal to or greater than the adjacent undisturbed areas.

In forested areas, through specific management techniques agreed upon by agency staff during the permit application review period, native trees and shrubs that were temporarily cleared for construction will be managed to re-forest via natural recruitment. After 5

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growing seasons, the composition of the reforested areas is expected to be consistent with a typical state of succession of the adjacent forested community. In non-forested areas species composition will be managed to favor non-woody species until it has been documented to be a stabilized plant community based on agreed upon criteria.

If species composition in all re-vegetated areas is not of equal or higher floristic quality based on the agreed upon criteria, the Company will develop and implement a remediation plan to successfully re-vegetate those areas. Floristic quality includes identification and quantification of prohibited or restricted invasive species listed in NR 40. Efforts will continue until re-vegetation is successful based on the agreed upon criteria.

3.6.6 Erosion Control Plan

Construction of the gas main replacement will result in soil disturbances exceeding one acre, which will require completion of a NR216 Stormwater Notice of Intent and a site-specific stormwater management and erosion control plan. Wisconsin Gas has a company-approved standard erosion control plan, as included in Appendix C – Environmental Information. Once a final pipeline route has been selected Wisconsin Gas will prepare a project-specific Erosion Control Plan (ECP). These materials will be prepared and submitted to DNR prior to construction. No construction activity will occur on the site until this permit is issued and appropriate erosion prevention measures are installed. Throughout construction, best management practices (BMPs) for stormwater management and erosion control will be utilized. Typical construction standards and practices to be followed are found on the DNR website: http://dnr.wi.gov/topic/stormwater/construction/.

3.6.6.1 Erosion Control Methods and Materials

Erosion control methods and materials will vary depending on the specific construction activities, time of year, and site soil and slope conditions at the time of construction. Examples of BMPs that could be instituted for this project may include the following:

Establishing perimeter sediment control practices as necessary such as vegetated

buffers and silt fence;

Maintaining existing vegetative cover during construction to the maximum extent

practicable;

Seeding, mulching, and/or polymer application for stabilizing areas disturbed by

construction activities;

Installing tracking pads at strategic access points to reduce offsite migration of

sediment; and

Preventing channel or gully erosion using stone check dams or temporary ditch

checks as necessary;

Other BMPs will be utilized as conditions warrant. Erosion control detail drawings will be included with the ECP.

Best Management Practices will be implemented in accordance with Wisconsin Gas’s typical construction practices and DNR technical standards for construction site erosion and sediment control. When applicable, only materials identified on the Wisconsin

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Department of Transportation’s Product Acceptability List (PAL) will be used for implementation of the ECP.

3.6.6.2 Erosion Control Measure Site Plan

The ECP will contain site maps showing the pipeline route and ROW; along with construction information, natural resource features, site physical features, and erosion control information. Other information as detailed in the Application Filing Requirements Section 3.6.6.1.2 will be included as necessary once a final route has been selected.

3.6.6.3 Sequence of Erosion Control Measures

The ECP will outline the anticipated sequencing for the pipeline construction along with minimum construction-time erosion control practices. A general description of construction phases will be outlined in the ECP and include clearing and grubbing, pipe and associated facility installation, and restoration.

3.6.6.4 Off-site Diversion Methods

Depending on site conditions, off-site diversion methods may be used as a construction-time erosion control practice for the proposed pipeline. The ECP will outline the materials and methods if off-site diversions are necessary.

3.6.6.5 Provisions for Inspection and Maintenance

During active construction, qualified Wisconsin Gas staff or representatives will inspect erosion and sediment control practices a minimum of once per week, and within 24 hours following a rainfall of 0.5 inches or more in accordance with Wis. Admin. Code ch. NR 216 and the WPDES General Permit Conditions. Written documentation of the inspection will be maintained by Wisconsin Gas or their designated representative. The documentation will describe site conditions and any corrective measures taken, if applicable. All corrective action will be taken within 24 hours of inspection unless soil conditions are such that taking the corrective action will cause excessive erosion, soil disturbance, or environmental impact. The decision for the timing of the corrective action will be made by the qualified Wisconsin Gas staff or its representatives with documentation provided to the appropriate agencies.

3.7 MATERIAL MANAGEMENT PLAN

3.7.1 Access Point Locations

The majority of access points will occur at locations where the proposed route crosses public or private right-of-way. Additional access points have been included on the aerial maps provided and indexed on Table 19 in Section 3.4.9. All access points will have had an environmental and cultural review conducted prior to any construction activities. Any access points with adverse impacts will be abandoned. Please see Section 3.4.9 for additional information on access issues.

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3.7.2 Haul Routes

Haul routes for equipment and materials have yet to be determined for the project. Conversations regarding timing, weight limits, clearances, and safety as it relates to proposed haul routes will be discussed with the Wisconsin Department of Transportation as well as the highway departments for Eau Claire, Clark, Jackson, and Monroe Counties.

3.7.2.1 Inbound materials

It is anticipated that the majority of pipe for the project will be brought in via rail. The Company’s contractor would unload the pipe off the railcars and on to flatbed truck trailers. From that point the pipe material would be transported by truck to a nearby laydown or staging area. Valves, fittings, and minor items such as pipe primer, wrap, and epoxy coating would be brought in by truck to one of the laydown or staging areas. Aggregate materials, such as sand and gravel will be trucked in from nearby quarries that have yet to be determined.

3.7.2.2 Outbound materials

Any materials that are excavated and deemed not suitable for backfill, mainly spoils that contain rock will be transported off site, unless prior arrangements with landowners have been made. These materials will be transported to local fill areas or quarries that have yet to be determined. Horizontal directional drilling mud (bentonite) will be removed from the drilling sites and placed in an approved upland area or disposed of in accordance with applicable permits or regulations.

3.7.2.3 Clean fill materials

Clean fill materials will be brought in from nearby quarries that have yet to be determined. The typical clean fill materials will consist of sand for padding around the newly installed pipeline if needed, crushed stone for driveway and shoulder restoration, clean washed stone for stream bank and slope restoration, and rip rap for steep sloped areas to prevent wash outs.

3.7.2.4 Contaminated materials

At this time it is not anticipated that contaminated materials will be encountered. If contaminated material is encountered, the Company would follow Environmental Procedure EN-1205 – Management and Handling of Impacted Soils Encountered During Routine Underground, Excavation or Trenching Work. That procedure is provided in Appendix C – Environmental Information.

3.7.2.5 Others

No other materials are anticipated.

3.7.3 Stockpile Areas

All stockpile areas will be confined to the construction right-of way or designated staging areas.

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3.7.3.1 Material to be stockpiled

Timber that is cut down prior to pipeline excavation will be cut to the desired lengths per landowner preference and stacked along the right-of way edge. Top soil that is segregated will be graded to the edge of the temporary easement area. In wetland areas topsoil and subsoil may be stockpiled on timber mats. Subsoil that is excavated will be stockpiled along the pipe right of way. Sand and gravel that is used for bedding material or driveway and shoulder restoration will be stockpiled along the right-of-way.

It is anticipated that most of the stockpiled material will be placed in areas where protection will not be required. In areas deemed environmentally sensitive were stockpiling cannot be avoided appropriate erosion control measure such as silt fence, hay bales, and wattles will be used to protect the stockpiled areas.

3.7.3.2 Provide a plan view diagram indicating stockpile area locations

Material that will be stockpiled will be on the construction right-of-way. The typical drawings attached in Appendix H – Construction Figures depict where the excavated soil will be stockpiled.

3.7.4 Equipment Staging Areas

There are seven proposed equipment staging areas (laydown yards) that have been identified and located at varying locations along the project corridor. They are numbered 1-7 as they occur north to south. A majority of these areas are pre-existing, barren lands that are predominantly open-pit mining operations. The Company intends that sites will be selected where no environmental impacts will occur. Prior to final site selections, field determinations and delineations of environmental features would be completed with the intent to avoid potential impacts. Review of these seven areas was completed via a desktop analysis of aerials, Wisconsin Wetlands Inventory and soils maps and was not field reviewed.

The locations of these staging areas are shown on the Environmental Features maps for both routes (Figures 2A and 2B, Appendix C – Environmental Information). Below are a list of the sites and descriptions:

Table 23 – Map Index: Staging Areas

Staging

Area

Total Size

(Acres) Route A Map Set Route B Map Set

1 18.5 Page 22 of 115 ---

2 3.1 Page 111 of 115 Page 116 of 121

3 113.8 Page 112 of 115 Page 117 of 121

4 58.6 Pages 112-114 of 115 Pages 118-120 of 121

5 39.3 Page 108 of 115 Page 114 of 121

6 11.4 --- Page 64 of 121

7 30.6 --- Pages 67 & 115 of 121

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Staging Area 1:

This site is located along segment A1 north of the Village of Fairchild, southeast of the intersection of CTH-H and Black Creek Road. This laydown area is an existing, barren land that was a small, open pit sand mine. Based on the desktop review there is one wetland that is approximately three acres in size that may be present on the property. There are no known cultural resources present at this location.

Staging Area 2:

This site is immediately southeast of the Village of Humbird, adjacent to and east of HWY 12/27. This property is currently a gravel staging/parking area for a large Christmas tree farm. Based on the desktop review, no wetlands are within its boundaries. Cultural resource 47CL0124, the Halls Creek Upland site is present at this location and approximately 0.63 acres of the site occurs within this staging area. The site is described as a Late Woodland campsite/village found during shovel testing of the highway right-of-way in 2009. Several artifacts were recovered at that time. Further field investigation will need to be completed to determine the limits of the site. That portion of this staging area determined to occur with the cultural site will not be utilized for construction staging as to avoid impacts to the site. If any portion of this site is intact, construction fencing will be placed around the limits of it to avoid impacts related to construction.

Staging Area 3:

This site is located east of the project corridor, between the villages of Humbird and Merillan, south east of the intersection of HWY-12 and Cherry Road. A frac-sand distribution and railroad spur border the north side of the staging area while the area itself is currently cropped agricultural land. Based on the desktop review, four wetlands totaling approximately 10.5 acres in size and one waterway may be present on this site. There are no known cultural resources present at this location.

Staging Area 4:

This site is off the project corridor, north of the city of Black River Falls at the intersection of Leicht, Paul, and W Mission Roads. This staging area is in two portions of an existing open pit mine. Based on the desktop review, one wetland approximately 3.5 acres in size and a waterway may be present in the western portion of the mine. There are no known cultural resources present at this location.

Staging Area 5:

This site is north of the City of Black River Falls adjacent to the intersection of Paul, West Mission and Liecht Roads. This property appears to have a history of mining or other similar ground disturbance. Based on the desktop review, no wetlands or waterways are present on this site. Cultural resource 47JA0002, unnamed site, is present at this location and approximately 0.69 acres of the site occurs within the staging area. The site is described as a campsite. Further field investigation will need to be completed to determine the limits of the site. That portion of this staging area determined to occur within the cultural site will not be utilized for construction staging as to avoid impacts to the site. If any portion of this site is intact, construction fencing will be placed around the limits of it to avoid impacts related to construction.

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Staging Area 6:

This site is directly north of the City of Black River Falls, at the southeast corner of the HWY-12 and Riverview Drive. This property was once a small-scale industrial facility that has been since abandoned & torn down, leaving a large concrete footprint. Based on the desktop review one wetland approximately one acre in size may be present in the southern portion of the mine. There are no known cultural resources present at this location.

Staging Area 7:

This site is east of the City of Black River Falls, off the project corridor between Airport and Timber Roads, and within a small commercial subdivision on undeveloped grassland with small jack-pine wooded portions. Based on the desktop review, one wetland approximately 4.5 acres in size may be present in the southern portion of the site. There are no known cultural resources present at this location.

3.7.4.1 Where equipment will be stored on-site

Any equipment that is not located at one of the staging areas will be stored for short durations on the construction right-of way. It will be located in the temporary easement, construction easement, or additional temporary workspace. A plan view of how the equipment will typically be stored on site is located in the typical construction drawings located in Appendix H – Construction Figures.

Spill control will be handled according to the Company’s environmental procedure EN-1203 Environmental Incident Response Manual. A list of suggested spill control materials and quantities to have on site is listed below. The complete environmental procedure EN-1203 is attached in Appendix C – Environmental Information.

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3.7.5 Field Screening for Contaminants

At this time there are no contaminants known to exist on-site. If suspected contaminants are encountered the Company’s environmental procedure EN-1203 would be followed. EN-1203 lists the procedures and protocols to be followed to test and determine the contaminant encountered. If a contaminant is encountered work would cease in that affected area until the contaminant is determined and the correct remediation and/or disposal plan is communicated.

3.7.6 Contaminated Materials

At this time there are no contaminants known to exist on-site. If any contaminants are determined the Company’s environmental procedure EN-1203 would be followed. Appropriate DNR staff experienced in solid and/or hazardous waste will be contacted as required under state statute. PSC environmental staff and the DNR Office of Energy staff will be notified as well.

3.7.7 Excavation Methods

The materials that will be excavated will be comprised mostly of topsoil, subsoil, and rock. All excavated material is expected to be stockpiled along the pipeline right-of-way. In upland areas it is anticipated that dozers will scrape the top soil layer of earth to the far side of the right-of-way. In wetland areas the wetland topsoil would primarily be separated during the trench excavation rather than disturb the entire pipeline right-of-way. After the top soil has been segregated, excavators will dig the pipeline trench and place the subsoil next to the topsoil in the pipeline right-of-way. If rock is encountered that cannot be removed with an excavator, a rock saw, trencher, or rock pick would cut in the trench to the desired depth of cover. In general excavated materials will not be exported from the site. Rock that is removed and not suitable for backfill may be trucked off site to a quarry or other approved disposal area.

3.7.8 Dewatering of Excavated Materials

If free water is found present in excavated materials, the excavated materials will be stockpiled in the pipeline right-of-way and allowed to dewater. Care will be taken to divert any silt laden water from entering a water body with the use of silt fence, wattles, or other similar materials. The company intends on performing additional geotechnical work that would assist in locating areas of high water tables. Pumps and dewatering structures are also anticipated to remove as much water from a trench to minimize free water in excavated materials.

3.7.9 Estimated Volumes of In-channel and Upland Excavated Materials

The volumes of excavated materials are shown in the tables below. It is anticipated that the trench will be approximately 6 feet deep and 4 feet wide to yield 0.88 cubic yards of soil per lineal foot. All excavated material will be replaced in the excavated trench, with the exception of rock that is unsuitable for backfill. Initial projections estimate approximately 3 percent of rock throughout the upland area excavations.

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Table 24 – Excavated Material

Route A Excavated Material (Cubic Yards)

Reused Material (Cubic Yards)

Disposed Material (Cubic Yards)

Upland 291,681 282,930 8,751

Waterway 164 164 0

Wetland 22,219 22,219 0

Route B

Upland 278,159 269,814 8,345

Waterway 158 158 0

Wetland 24,389 24,389 0

3.7.10 Estimated Volumes and Location of Re-used Excavated Materials

The volumes of reused materials are shown in the table above. All excavated material will be replaced in the excavated trench, with the exception of rock that is unsuitable for backfill. Initial projections estimate approximately 3 percent of rock throughout the upland area excavations.

3.7.11 Off-site Disposal Plans

All soil removed by construction of the pipe trench will be replaced in the trench at the same location upon completion of installation of the pipe. No soil will be removed from the site. Rock that is removed from the pipe trench that is not suitable for backfill will be taken to either a local quarry or approved disposal area to be determined upon final route selection.

Any drilling mud will be taken to an approved upland area or disposed of in accordance with applicable permits or regulations.

At this time there are no contaminants known to exist on-site. If any contaminants are determined the Company’s environmental procedure EN-1203 would be followed. Appropriate DNR staff in solid and/or hazardous waste will be contacted as required under state statute. PSC environmental staff and the DNR Office of Energy staff will be notified as well.

3.8 DEWATERING PLAN

3.8.1 Dewatering/Diversion of Flow

Dewatering areas of standing water will typically be accomplished with the use of pumps. The standing water will be pumped into a vegetative buffer or a dewatering structure depending on the surrounding conditions. Diversion of flow in a stream will be

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accomplished by either a pump and dam method or a flume method. Typical dewatering and diversion plans are attached in Appendix C – Environmental Information. Once a final pipeline route has been selected the Company will prepare a project-specific set of construction drawings as well as an Erosion Control Plan (ECP). These drawings and plans will be prepared and submitted to DNR prior to construction. No construction activity will occur on the site until this permit is issued and appropriate erosion prevention measures are installed. Throughout construction, best management practices (BMPs) for stormwater management and erosion control will be utilized. Typical construction standards and practices to be followed are found on the DNR website: http://dnr.wi.gov/topic/stormwater/construction/.

3.8.2 Downstream Impact Minimization

Construction will be coordinated on this project to coincide with normal or low flow conditions. If a rain event is anticipated that could adversely affect a water body crossing construction activities will be delayed or a different construction method will be employed. The weather forecast will be consulted prior to any work in a waterway to ensure that construction is not planned on those days when rain is anticipated.

3.8.3 Possible System Overload Scenarios

Please refer to Section 3.8.2, above.

3.8.4 Impacts of System Overload

Please refer to Section 3.8.2, above.

3.8.5 Discharge Locations

Once a final pipeline route has been selected the Company will prepare a project-specific set of construction drawings as well as an Erosion Control Plan (ECP). These drawings and plans will be prepared and submitted to DNR prior to construction. No construction activity will occur on the site until this permit is issued and appropriate erosion prevention measures are installed. Throughout construction, best management practices (BMPs) for stormwater management and erosion control will be utilized. Typical construction standards and practices to be followed are found on the DNR website: http://dnr.wi.gov/topic/stormwater/construction/.

3.8.6 Back-up System

It is anticipated that a back-up system will not be necessary as no construction will occur in waterways during rain or high flow events.

3.8.7 High Flow Plan

Construction around waterways in high flow conditions will not occur. Weather forecasts will be consulted and in the event flooding is likely to occur, equipment and materials will be transported to areas of high ground. These areas could be sections of the pipeline right-of-way or staging areas where flooding will not adversely affect the equipment or materials.

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3.8.8 Contaminated Water

At this time, the Company has no reason to believe that contaminated water will be located within the project construction area. If the on-site construction or environmental staff suspect that water within the construction site is contaminated the environmental consultant will ensure no construction disturbance or activity takes place within the waterway. This may be accomplished using flagging, signage or verbal directions to on-site staff. In the event that contaminated water is suspected to be present on the construction site, the Company’s Environmental Incident Response Team or an experienced and licensed (if required) environmental consulting firm will be immediately notified. Appropriate DNR staff in solid and/or hazardous waste will be contacted as required under state statute. PSC environmental staff and the DNR Office of Energy staff will be notified as well.

3.9 ASSOCIATED FACILITIES INFORMATION

The Project includes the installation of one Town Border Station (TBS), five distribution District Regulator Stations (DR’s), and various valve assemblies as shown in Table 6 – Associated Facilities in Section 3.1.2.3. They are listed in Table 6 in order from north to south. The two DR’s for the villages of Fairchild and Warrens are also described here in anticipation of providing service to these potential new franchises.

3.9.1 Location and Layout

Diagrams showing the proposed station locations, layout, and dimensions are contained in Appendix I – Engineering Information. Diagrams showing the layout and dimensions of a typical 16-inch valve assembly and 12-inch valve assembly are also presented in that Appendix. The locations for the valve assemblies will be determined once a final route is selected by the PSC and follow the design requirements identified in Table 6. Maps showing the station footprint with aerial photography are included in the Aerial Photography Maps in Appendix B – Maps. The table below lists each proposed station and the associated map page number for reference.

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Table 25 – Map Index: Project Location and Orthophotography

Aerial Photography Maps

Station Name Route A

Page Number Route B

Page Number

Viking Town Border Station (TBS) 1 1

Augusta District Regulator Station (DR) 20 23

Future Fairchild District Regulator Station (DR) 27, 28 31

Hixton District Regulator Station (DR) 98 106

Alma District Regulator Station (DR) 49 55

Black River Falls District Regulator Station (DR) 59, 102 66, 107

Future Warrens District Regulator Station (DR) 112 117

Tomah District Regulator Station (DR) 97 103

3.9.2 Purchases Land Requirements

The Company does not intend to purchase land for this project. The Company’s proposed facilities are to be located within road ROW, on landowner easement, or on existing Company owned land. However, Viking plans to purchase up to a 20 acre parcel to accommodate facilities at the TBS. Viking has provided information indicating that the 20 acre parcel will have a width of approximately 1,016 feet and a depth of approximately 857 feet. This parcel is proposed to be orientated such that the 857 foot side is parallel to either the CTH H ROW in the Town of Wilson for Route A or the Dickerson Ave ROW in the Town of Foster for Route B.

3.9.3 Landscaping

The landscaping for the proposed stations and valve sites will conform to the local surroundings and comply with local and municipal guidelines when permits are acquired.

3.9.4 Plat and Topographic Maps

The Aerial Photography Maps identified in Section 3.9.1 include plat detail. Maps showing the station footprint with topography are included in the Topographic Maps in Appendix B – Maps. The table below lists each proposed station and the associated map page number for reference.

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Table 26 – Map Index: Topographic

Topographic Maps

Station Name Route A

Page Number Route B

Page Number

Viking Town Border Station (TBS) 1 1

Augusta District Regulator Station (DR) 9 9

Future Fairchild District Regulator Station (DR) 12 13

Hixton District Regulator Station (DR) 19 20

Alma District Regulator Station (DR) 21 22

Black River Falls District Regulator Station (DR) 25 26

Future Warrens District Regulator Station (DR) 37 37

Tomah District Regulator Station (DR) 41 42

3.9.5 Access Roads

There are two proposed options for accessing the proposed Viking TBS for Route A. One option is via a proposed access driveway that follows an existing cleared pathway approximately 100 feet north of the Viking pipeline and CTH H intersection. It would extend in the southwesterly direction for approximately 300 feet until it enters the station facility. Another option for access to the station site is via a proposed access driveway that follows the proposed 16-inch outlet pipe easement. This is approximately 250 feet south of the Viking pipeline and CTH H intersection. It would extend west from CTH H approximately 200 feet until it enters the station facility. The proposed Viking TBS for Route B will be accessed via the adjacent roadway, Dickerson Ave. The proposed access driveways for the TBS’s will have a typical width of approximately 30 feet to accommodate standard utility vehicles and larger odorant delivery trucks. The proposed DRs and valve assembly sites will be accessed via the adjacent roadways with an access driveway with an approximate width of 15 feet to accommodate standard utility vehicles. All access driveways will be constructed in accordance with the applicable permits and will maintain current drainage patterns.

3.9.6 Construction Methods and Erosion Control

Associated facilities are anticipated to be constructed within the same timeframe of the pipe installation. At the associated facility locations applicable erosion control measures will be installed prior to construction. The area will be cleared, graded and top soil segregated and stockpiled. The facilities will be fabricated and installed per applicable construction drawings. Concrete slab foundations will be poured where required and buildings placed over the regulation, instrumentation, heating, & odorization facilities. Fencing will enclose the site to keep the facilities secure and a gravel pad is typically placed around the above grade appurtenances. A gravel access drive is typically built to the facility to allow company vehicles to safely enter the facility location from the roadway.

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Throughout construction, best management practices (BMPs) for stormwater management and erosion control will be utilized. Typical construction standards and practices to be followed are found on the DNR website: http://dnr.wi.gov/topic/stormwater/construction/

When permanent erosion control measures are installed and vegetation is re-established, temporary erosion control measures will be removed.

3.9.7 Environmental information

There are nine associated facilities in the project corridor. These facilities are shown on the Project Location and Orthophotography Figure and other Figures in Appendix B – Maps. In the design phase, the specific locations of district regulator stations (DRs) will be adjusted (if necessary) so that no archaeological-historical, rare species, wetland, or waterway impacts will occur. Valve assemblies will also be located as part of the design, however all valve assemblies locations will be directly over the proposed pipe alignments, outside archaeological-historical, rare species, wetlands and waterways, and entirely within the permanent easement. Therefore valve assemblies, even though not depicted, will not impact any additional resources. Facilities 3, 4, 5, 6 and 8 as shown in the table below each encompass approximately a 10,000 square foot area during construction. Facilities 7 will encompass approximately 22,500 square foot area during construction. Facility 9 will cover approximately a 40,000 square foot area during construction. DR permanent impacts will include the building (240 square feet in size), a gravel pad and an access road. The remainder of the 10,000 square foot area at the DRs may not be impacted entirely, and will be limited to temporary impacts related to construction. The proposed Viking TBS facilities will each encompass an area approximately 160,000 square feet and consist of a building, gravel pad, and several above grade appurtenances.

All facility locations are located adjacent to roads within the corridor boundaries and consist of upland agricultural, old field, and forested lands. Descriptions are listed below:

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Table 27 – Associated Facilities Impact

Facilties Description Mapset Page Size (ac) Land Cover Type

Size (ac) of Crop

Impact

1 Viking TBS - Route A A 1 3.6731 Hardwood Forest N/A

2 Viking TBS - Route B B 1 3.6731 Hardwood Forest N/A

A 20

B 23

A 27

B 31

A 49

B 55

A 98

B 106

A 66

B 107

A 112

B 117

A 97

B 103

Total Route A 0.92

Total Route B 0.92

Pine plantation 0.23

0.5165 Developed N/A

Old field N/A6

Black River Falls Distric

Regulator (DR) Station7

Old field N/A9

3 Corn 0.230.2296

4 0.2296 Corn 0.23

0.22965 Soybean 0.23

Hixton Distric Regulator

(DR) Station

Augusta Distric Regulator

(DR) Station

Future Fairchild District

Regulator (DR) Station

Alma Distric Regulator

(DR) Station

Tomah District Regulator

(DR) Station0.9183

0.2296

8Future Warrens District

Regulator (DR) Station0.2296

3.9.7.1 Land Use and Zoning

The 2012 land cover for Viking Interconnect Facilities total 7.58 acres of forest land. Facilities shown in the above table as 3, 4, 5 and 8 are on 0.92 acre of active farm land, while Facilities 6 and 9 are on 0.75 acre of old field. Finally, Facility 7 is located on 0.52 acre of developed land for a substation. Half of the land cover on facility 7 is a driveway to the substation, while the other half is surrounding upland shrub land.

A comprehensive review of zoning ordinances was performed, including web site review of ordinances, and phone calls and/or meetings with planning and zoning departments for the proposed regulator stations in each of the counties, villages and townships the stations are located. The Company will follow community ordinance guidelines and obtain permits as identified before construction of regulator stations.

3.9.7.2 Agriculture Impacts

Routes A and B have a proposed impact of 0.92 acre on agricultural land. In 2012, Facilities 3 and 4 were planted in corn, as shown in the table above. Facility 5 appears to be planted to soybean after a desktop aerial review. Facility 8 is in a pine plantation. In 2012, Facilities 6 and 9 were old field, and therefore not included in the active agricultural land totals.

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3.9.7.3 Forest Land Impacts

A total of 7.58 acres of forest land within the facility locations is expected to be impacted, as shown in the table above. Facilities 1 and 2 cover the most forested area, each covering 3.67 acres. Facility 1 is an upland deciduous hardwood forest dominated by Quercus rubra, Carpinus caroliniana, and Hamamelis virginiana. Facility 2 is an upland deciduous hardwood forest dominated by Quercus rubra, Acer rubrum, and Corylus americana. Facility 8 is in a pine plantation, and covers 0.23 acres.

3.9.7.4 Endangered, Threatened, and Special Concern Species

The proposed location of Facilities 1 and 2 are currently associated with a mixed hardwood forest complex. There are no endangered, threatened or special concern species Element Occurrences within one mile of these interconnection points. The land use associated with Facilities 3 through 8 is either active agricultural cultivation or developed. No impacts to endangered, threatened, or special concern species or their associated habitat is potentially affected by these facilities. Facility 9 is located at the periphery of the high potential range for a protected butterfly species and suitable habitat may be present. Field surveys will be conducted to verify the habitat suitability. If suitable habitat is available, the area will be surveyed to determine if the species is present.

3.9.7.5 Archeological and Historic Resources

There are no impacts to historic and archeological sites by the proposed facilities.

3.9.7.6 Waterway Impacts

There are no impacts to waterways within the boundaries of the proposed facilities.

3.9.7.7 Wetland Impacts

There are no impacts to wetlands within the boundaries of the proposed facilities.

3.10 DNR PERMITS AND APPROVALS

A large number of DNR permits are anticipated to be required for this project. As described in Section 3.2.5, the Company has prepared this application utilizing a pre-application process and the procedures set out in sec. 30.025, Wis. Stats., and reflected in the PSC and DNR Application Filing Requirements for Natural Gas Pipeline Construction Projects. As requested by those Filing Requirements. The Company prepared a Water Resources Application for Project Permits (WRAPP) Form 3500-053 and applicable attachments for all DNR and USACE permits and approvals required for construction of the utility facilities proposed in this application. A copy of the WRAPP and attachments are contained in Appendix C – Environmental Information. Additional detailed technical information supporting the WRAPP is contained in this application.

Compensatory wetland mitigation will be completed for impacts to wetlands caused by the construction of the gas lateral. Wetland mitigation is expected to be partially fulfilled by restoring wetland areas that are directly impacted by construction. Compensating for temporal and permanent loss of functions and values may be accomplished either by

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purchasing credits from one or more mitigation banks that have applicable service areas and that are approved for credit sale prior to construction. If no wetland mitigation bank sites are available for credit sale, the Company will then pursue permittee-responsible mitigation through the restoration of wetlands along the project route. A compensation site plan would be prepared and approved prior to issuance of the wetland permit. The ratios for determining acre-credits to be purchased or restored have yet to be determined, but are expected to follow the guidelines that are currently being developed by the Corps and the DNR. It is expected these ratios will be set based on wetland classifications and functions, as well as the level (i.e. temporary or permanent) of impact as determined by the Corps and DNR. The Company will continue to work with both agencies to reach a satisfactory compensation plan for the proposed impacts from the Project.

3.10.1 Supplemental Documentation to Form 3500-053

Supplemental documentation to Form 3500-053 is provided in Tables 5A and 5B in Appendix C – Environmental Information. This documentation includes Routes A and B and their segments, wetland and waterway features, construction methods, location data, wetland/waterway impacts, Areas of Special Natural Resource Interest (ASNRI) designations, and permits and approvals required. It is anticipated that DNR application fees are not required for this Project.

3.10.2 Practicable alternatives analysis

The Practicable Alternatives Analysis (PAA) is required under the AFR, sec. 281.36, Wis. Stats. and Ch. NR 103 Wis. Admin. Code. DNR guidelines and information requirements for the PAA for projects impacting wetlands were used to evaluate alternatives and to avoid and minimize wetland impacts to the extent practicable while fulfilling the basic project purpose. This information is used by the DNR and the Corps to verify that the Project will comply with applicable laws, regulations and permit eligibility standards and conditions. The following sections and references further document the PAA process.

3.10.2.1 Siting and route selection process

The Company evaluated system alternatives to meet the growing requirements of its customers as explained in Section 3.2 PROJECT DEVELOPMENT AND ALTERNATIVES CONSIDERED. This included identifying alternative routes and route segments and developing specific factors to evaluate them. In general, these factors included land ownership, existing road ROWs and utility corridors, land use, agricultural properties, existing structures, workspace required, costs, rock out-crops, cultural resources, endangered resources, wetlands and waterways. The factors and associated criteria are described in Section 3.2.2.

During preliminary planning and design, environmental impacts were evaluated in detail along two alternative routes (i.e., Routes A and B). Field surveys were conducted to identify, delineate, locate and map wetlands and waterways along these alternative routes as well as various other routes and segments that were considered but subsequently eliminated early in the planning process. As such, wetlands and waterways were factored into the preliminary planning, design, alternatives analysis and overall route selection

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process; and avoiding and/or minimizing wetland and waterway impacts has been a decision factor in the siting and route selection process. This process included project siting, comprehensive review of alternative routes, preferred route selection, design considerations, construction methods, construction site access planning, siting associated facilities and restoration methods.

Under this analysis, the Company determined that some wetland and waterway impacts are unavoidable. The analysis concluded Route A is the Company’s preferred route having the least amount of wetland and waterway impacts and is capable of being implemented after taking into consideration cost, available technology, and logistics in light of overall project purposes. Furthermore, the Company developed standard construction methods, restoration methods, and construction schedules in consideration of environmental issues and seasonal constraints, that will further avoid and minimize wetland and waterway impacts to the extent practicable as described below and provided in other sections of this application by reference.

3.10.2.2 How proposed route avoids and minimizes wetland impacts

Due to the size, length and linear nature of this large utility project, some wetland and

waterway impacts are unavoidable. The following measures either have already been or

will be implemented to avoid and minimize impacts to wetlands and waterways to the

extent practicable:

Routes and segments were modified early in the planning process to avoid and

minimize wetland and waterway impacts based on desktop and field reviews.

The construction disturbance zone will be kept to the minimum needed to complete the

work. Routes are designed with the minimum amount of permanent and temporary

easement or workspace needed to install the pipeline. A 75-foot wide construction

corridor consisting of a 50-foot wide permanent easement and 25-foot wide temporary

construction easement will be utilized at wetland/waterway crossings. This is reduced

from the proposed 100-foot wide construction corridor in agricultural uplands and areas

outside of sensitive environmental features.

For the trenching construction method, the size of the trench will be kept to the

minimum dimensions needed to safely install the pipe. Typically the size of the trench

will be approximately 4 feet wide by 6 feet deep.

Construction staging areas (laydown yards), access roads, and other temporary work

spaces are planned and located to avoid or minimize wetland and waterway impacts.

The Company screened these areas for potential environmental impacts. If during final

design any temporary work area is found to have a potential significant adverse

environmental impact, it will be abandoned and an alternative area will be identified by

the Company.

The Horizontal Directional Drilling (HDD), a boring construction method, is a complex

crossing technique that will be used where feasible, depending on site conditions, and

as needed to bore under waterways and sensitive wetlands to avoid and minimize

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environmental impacts. This includes placing bore pits outside wetlands and waterways

to avoid and minimize disturbance to bed and banks, disruption of navigation, and

dredging or excavation. This construction method is described in detail in Section

3.6and listed on Tables 5A and 5B in Appendix C – Environmental Information. Standard

HDD construction methods or techniques may be modified if necessary after taking into

consideration available technology, logistics, feasibility, and cost.

Construction access will typically be from existing public roads and/or utility ROWs

(together, “access routes”) to the extent possible. Unpaved field and forest roads will

also be used where possible. Locations of wetlands and waterways have been field or

aerial reviewed along proposed access routes to avoid and minimize impacts (see

Section 3.4.11). Timber matting will be used as needed to cross wetlands along access

routes. Additional access routes identified during the final design and construction will

be screened for potential environmental impacts. If any access route is anticipated to

cause significant adverse impacts, it will be abandoned and an alternative access route

will be identified by the Company. Access will be shifted within the permanent and

temporary workspace as needed to further avoid and minimize disturbance.

Timber or composite matting, low ground-pressure vehicles and/or other acceptable

methods or equipment will be used to cross wetlands when the ground is unfrozen,

wetland soils are unstable (e.g., organic, peat/muck, wet alluvial, etc.), wetland type is

indicative of unstable conditions (e.g., sedge meadow, shallow marsh, floodplain, and

others), and/or seasonal conditions require (i.e., wet conditions or time of year).

Ice roads may also be used to cross unstable wetlands during winter construction

under frozen conditions, if approvals are obtained in time to begin construction under

winter conditions. Specifically, wetland crossings require the use of matting or ice roads

if construction activities could result in rutting of 6 inches or greater. If the wetland to be

crossed has dry, stable and cohesive soils or is frozen, matting or ice roads may not be

needed when construction equipment causes rutting less than 6 inches. In these cases,

construction may proceed in a manner similar to upland construction. Ruts in wetlands

less than 6 inches will not require repair or restoration. In general, matting is considered

a temporary impact and is removed upon completion of the work (typically within 2

weeks after placement of mats during growing season).

Temporary Clear Span Bridges (TCSBs) will be used to cross waterways where

needed. This typically includes waterways that will be crossed using open trench

installation methods. TCSBs will comply with all applicable DNR permit eligibility

standards and conditions.

Erosion and sediment controls will be implemented as needed and maintained until

final restoration and stabilization is achieved (see Section 3.6.6).

After construction is complete, the wetland grade will be restored to original elevations

including soil segregation, proper replacement, and revegetation. Excess spoil

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materials will be removed from the wetland and disposed of at an approved upland

disposal site (see Section 3.6.5).

The construction schedule may be modified as needed to address permit conditions or as a result of consultations with the agencies with regard to timing of protective protocols for specific environmentally sensitive features.

3.10.2.3 Construction and restoration methods

Construction methods that will be used to minimize wetland impacts are described above and provided in detail in Section 3.6. Restoration methods that will be used to restore topography to pre-construction conditions and revegetation, including follow-up monitoring, maintenance and management are detailed in Section 3.6.5.

3.10.3 Storm Water Management

This application includes a request for coverage under the Wisconsin Pollutant Discharge Elimination System (WPDES) Construction Site Storm Water Runoff General Permit No. WI-S067831-4, for land disturbing construction activities. Refer to the WRAPP and related erosion and sediment control and storm water management procedures contained in Appendix C – Environmental Information. Also refer to Sections 3.6.6 Erosion Control Plan, 3.7 MATERIAL MANAGEMENT PLAN, and 3.8 DEWATERING PLAN for additional details and related supporting documentation concerning erosion control and storm water management procedures.

3.10.4 Endangered/Threatened Species Incidental Take

The Company and Stantec have been consulting with the DNR to identify species and associated habitat that may warrant additional investigation. Stantec is completing a Proposed Endangered Resources Review that includes routes A (15 segments) and B (14 segments), two interconnections, eight regulator stations, seven staging areas (laydown yards, and 19 temporary off-ROW access routes.

The Proposed Endangered Resources Review document will identify potential follow-up actions such as additional fieldwork to assess habitat suitability and/or species specific presence/absence surveys. When completed, this document will be reviewed and certified by the DNR prior to selection of the final route. The location, methods and timing for additional fieldwork will be coordinated with the DNR and conducted during the 2013 field season, if necessary. If Endangered or Threatened species are identified to be present as a result of this field work the implementation of avoidance measures will be analyzed. Alternatively, if suitable habitat for certain species exists within the construction footprint, presence of the species may be assumed and appropriate avoidance measures will be implemented. If for some reason avoidance measures cannot be implemented, the Company will provide supplemental information required for the issuance of an Incidental Take Permit (ITP).

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3.11 OTHER AGENCY CORRESPONDENCE

3.11.1 Company correspondence

Copies of Wisconsin Gas correspondence to other state, federal, and local government agencies are provided in Appendix D – Agency Correspondence. Future correspondence will be filed as it is sent.

3.11.2 Agency responses

Copies of agency responses to Wisconsin Gas inquiries regarding the West Central Lateral are provided in Appendix D – Agency Correspondence. Future correspondence will be filed as it is received.

3.11.3 State Permits

Permits for wetland and waterway crossings are required under Wis. Stat. §. 30.025 and Wisconsin Administrative Code NR 103. The Company has been coordinating with the DNR Office of Energy and Environmental Analysis since September 2012, and numerous meetings have occurred with staff to discuss all of the various resource issues. Permits for utility installations within state owned road right-of-way will be applied for once a final route has been selected.

Table 28 – State Permits

Agency Interest or Permit Contact Application/ Notice Date

Status

Public Service Commission

CA for construction of natural gas pipeline

Michael John Jaeger 03/28/2013 Response Pending

Department of Natural Resources

Ch. 30 (bridges and disturbance below OHWM)

Ben Callan (608) 266-3524 website

3/28/2013 Response Pending

Department of Natural Resources

Section 401 Clean Water Act; Wis. Stat. ch. 281.36 Wetland Permit (includes cultural, T&E, invasives coordination) .

Ben Callan (608) 266-3524

3/28/2013 Response Pending

Department of Natural Resources

Construction Site Erosion Control/ stormwater mgt GP

Ben Callan (608) 266-3524

3/28/2013 Response Pending

Department of Natural Resources

LAWCON impact determination

Lavane J Hessler (715) 839-3709

02/12/2013 Response Received 03/04/1013 - determination of no authorization required

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Agency Interest or Permit Contact Application/ Notice Date

Status

Department of Transportation

Utility in ROW TBD

3.11.4 Local Permits

The Company works with staff representatives of the local units of government with jurisdiction in the construction zones. If permits or other authorizations are needed, the Company applies per local ordinances (County, Town, Village or City). Public safety-related permits or authorizations generally include road crossing permits, road weight limits, noise abatement ordinances (usually involving hours or times of construction), building permits (for such construction as regulator stations), and other similar public safety concerns for which permits or authorizations may be required by local ordinance.

Local ordinances also often address siting and location issues for the construction of utility facilities, or land use issues including recreational uses, environmental protection and aesthetics. These types of authorizations include conditional use permits or zoning permits or variances which often involve quasi-judicial proceedings and which involve the exercise of discretion on the part of the local unit of government on whether the authorization or permit may be granted.

Local permitting needs were researched and are summarized below. The Company continues to work with local units of government in the Project area to identify any additional required permits.

Table 29 – Local Permits

Agency Interest or Permit Contact Application/ Notice Date

Status

Clark County Zoning

Ch.22 Shoreland and Wetland Zoning (incl. Filling, Grading); Forests

Steve Kunze (715)743-5130

Eau Claire County Dept. of Planning & Development - Land Conservation Div.

Storm Water Management and Erosion Control (Ch. 17.05)

Kelly Jacobs (715)839-6226

Eau Claire County Dept. of Planning & Development - Land Use Controls Div.

Ch. 18 Zoning Ordinance; Shoreland Zoning and Floodplain Zoning

Rod Eslinger (715)839-4743

Jackson County Forests and Parks Department

Ch. 14.07 County Forest Use Regulations

Jim Zahasky 715-284-8475

Jackson County Zoning Department website

Conditional Use Permit to cover: Ch. 16 Shoreland Zoning - (includes filling, grading, Erosion Control); Ch. 20 Floodplain Zoning

Terry A. Schmidt Zoning Administrator (715)284-0220

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Agency Interest or Permit Contact Application/ Notice Date

Status

Monroe County – Zoning ordinance website zoning guidance

Public utility pipelines allowed in all zones; coordination req’d. Ch. 44, Art. II, Div. 4-Co. Forest Use Regulations; Ch. 47 Zoning; Ch. 50 Floodplain Zoning; Ch. 53 Shoreland - Wetland Zoning (incl. erosion control)

Alison Elliot Zoning Director (608)269-8939

City of Augusta (Eau Claire Co.)

Ch. 9 Zoning, Article VIIIA- Floodplain and Shoreland-Wetland Zoning

Zoning Coordinator (715)286-2555

City of Black River Falls (Jackson Co.)

Ch. 18 Shoreland-Wetland and Floodplain Zoning (conditional use permit)

Bill Arndt (715)284-2315

City of Tomah Zoning Department (Monroe Co.)

Shoreland and Wetland Zoning Article

Shane Rolff (608)374-7429 [email protected]

3.11.5 Federal Permits

The U.S. Army Corps of Engineers (USACE) has jurisdiction over wetlands and other waters of the U.S. under Section 404 of the Clean Water Act. The proposed project is expected to require an individual permit. Wetland fill impacts will be temporary, however due to maintenance requirements within the 50 foot permanent easement the type of wetlands (where applicable) will be permanently converted from a forested system to an open system. Although all major rivers and streams will be avoided via horizontal directional drilling, temporary impacts to waterways will be required for trench excavation, temporary bridges and restoration.

Mitigation for impacts to wetlands and waterways is required by the USACE.

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Table 30 – Federal Permits

Agency Interest or Permit Contact Application/ Notice Date

Status

U.S. Army Corps of Engineers Clark & Eau Claire Co.- 651-290-5324 Jackson Co.- 651-590-5902 Monroe Co.- 651-290-5905

Section 404, Clean Water Act (NOTE: mitigation req’d. for >10,000 wetland impact)

Kyle Zibung (715) 345-7911 ext. 5877 website

3/28/2013 Response Pending

U.S. Army Corps of Engineers

Section 10, Rivers and Harbors Act (for Black River crossing)

Kyle Zibung (715) 345-7911 ext. 5877

3/28/2013 Response Pending

3.11.6 Other Permits

Railroad permits will be applied for once the final route is approved. Route A has 9 railroad crossing and Route B has 7 railroad crossings.

3.12 PROPERTY OWNER INFORMATION

Lists for the following are contained in Appendix F – Lists. PSC Staff have been provided the lists in Microsoft Excel format.

Private and Public Property Owners along Each Pipeline Route

Municipalities and Planning Commissions Affected

Local Media Contacted

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Appendices

Appendix A – Economics

Updated Gas Cost Savings Analysis report

RFP Process, Bid Evaluation and Calculated Life Cycle Gas Cost Savings Associated with the West Central Lateral Project report

Appendix B – Maps

Overview Map

Segment Polygon Map

Segment Map

Alternate Routes Not Chosen Map

Topographic Maps – Route A

Topographic Maps – Route B

Map Index - Aerial Based Maps

Aerial Photography Maps – Route A

Aerial Photography Maps – Route B

Environmental Features (Fig 2A) – Route A

Environmental Features (Fig 2B) – Route B

Flood Zone & Shoreland – Route A

Flood Zone & Shoreland – Route B

Organic / Specialty Farms – Route A

Organic / Specialty Farms – Route A

Appendix C – Environmental Information

Forestry Table

Agricultural Mitigation Plan

WRAAP

Route and Environmental Tables

The following are provided electronically (CD to PSC and filed to ERF):

1. Wetland and Waterway Investigation Report

2. Endangered Resources Review

3. Cultural Resource Investigations Report (GLARC report) with summary table

4. Erosion Control Work Procedures

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5. Environmental Incident Response Manual

6. Management and Handling of Impacted Soils

Appendix D – Agency Correspondence

Letters

Agency Meeting Summaries

Consultation Forms

Email Correspondence

Appendix E – Public Information

Appendix F – Lists

Appendix G – Gas Distribution System Resolutions

Appendix H – Construction Figures

Appendix I – Engineering Information

Table 1B - Distance to potentially sensitive buildings

Facilities Drawings

Appendix J – Letters of Support

Appendix K – Planning and Zoning

Codes

Maps