In its November 7, 2012 scoping comments to FERC, DEC wisely called for the use of Horizontal Directional Drilling (HDD) to minimize impacts, stating:

For streams and wetlands the preferred method for crossing is Horizontal Directional Drilling (HDD) because it has the advantages of minimizing land disturbance, avoiding the need for dewatering of the stream, leaving the immediate stream bed and banks intact, and reducing erosion, sedimentation and Project-induced watercourse instabilities. (NYSDEC Scoping Comments, Nov 7, 2012.)

Disturbingly, although the Constitution Pipeline is proposed to cross 91 wetlands and 277 streams, no commitment whatsoever has been made to use HDD in the final EIS for the project. In fact, plans by CP became worse between the draft EIS and final EIS because the few crossings where HDD had been planned have now been changed to Direct Pipe. Direct Pipe is a cheaper, inferior trenchless technique involving shallow burial and more surface disturbance.

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