David P. Boergers, Secretary
Federal Energy Regulatory Commission
888 First Street NE
Washington, DC

Re: Millennium Pipeline Project ( FERC Docket # CP98-150)

Dear Mr. Boergers:

I am writing on behalf of the Board of Directors of Federated Conservationists of Westchester County, Inc., a 36 year old not-for-profit coalition of groups and individuals dedicated to the protection of this region's natural and historic resources and the education of the public about environmental issues. Among many other activities, Federated Conservationists has been instrumental in the protection and expansion of parkland and nature preserves in Westchester, the creation of a biodiversity program in the county, and the education of the public through its newspaper Westchester Environment and programs for high school students and adults.

Please accept this as a public comment by Federated Conservationists. We are very concerned about the proposed plan to have the Millennium Pipeline traverse Westchester County by cutting through two nature preserves: the Teatown Lake Reservation and the Croton Arboretum.

Westchester County is a suburb of New York City and is accordingly an area that is highly developed and densely populated. Development has continued to reduce natural settings. Between 1988 and 1996 the amount of undeveloped land in Westchester decreased by 24%. Thus such preserved lands as exist in this area must be particularly treasured and safeguarded.

Teatown Lake Reservation is a 733 acre nature preserve which is visited by 30,000 people annually who walk its 14 mile trail system or attend one of the many educational courses offered. It is one of the most important natural resources and education centers in Westchester County.

The proposed Millennium Pipeline construction in Teatown would have an adverse affect on wildlife habitat, wildlife species and wetlands which are part of the Croton watershed. The construction would have to cross two very important wetlands containing marbled salamanders, 4-toed salamanders, spotted turtles and eastern box turtles, which are all listed on the New York State Species of Special Concern List. Following the disturbance to the wetland, invasive plants will take root and spread. The areas around the route are also nesting areas and migratory stopovers for a variety of birds including the golden-winged warbler, yellow-breasted chat, Cooper's hawk and Red-shouldered hawk, all Species of Special Concern in New York State.

Based on a study conducted for Teatown, the construction will require the removal of between 25,000 and 30,000 trees between Croton-on-Hudson and Millwood, with over 14,000 trees to be removed in Teatown alone. The proposed route would cross a section of the 33 acre Teatown Lake, a lake so shallow that the pipe may be exposed and would likely curtail the use of canoes and rowboats for educational purposes. Educational programming will suffer from all of these disruptions to the natural environment.

The Croton Arboretum protects a ten acre wetland which is used for the dual purpose of education and recreation. The proposed pipeline would similarly create a venue for the growth of invasive plants, disturb water quality, and impair the visual beauty of the area with the destruction of mature trees and their replacement by scrub and weeds.

As an environmental organization we support a greater emphasis on energy conservation and the development of clean renewable energy sources. The difficulty inherent in satisfactorily siting additional energy infrastructure in Westchester either through its heavily settled areas, where they raise safety concerns, or through the few remaining and treasured pristine natural areas, suggests that these approaches are particularly relevant in this energy market.

We thank you for considering all of these factors in the course of your review of the Millennium Pipeline proposal.

Yours,

Edna Sussman
Executive Director.

Cc: Charles Schumer, U.S. Senator
Hillary Clinton, U.S. Senator
Andy Spano, County Executive
George Latimer, Chair, County Legislature
Michael Kaplowitz, County Legislator
NYS Public Service Commission
Gail Abrams, Executive Director, Teatown Lake Reservation
Karen Bernard, Director, Croton Arboretum