February 26, 2018 Edward Jakaitis Section 106 Compliance Manager Office of Archaeology and Historic Preservation 1560 Broadway, Suite 400 Denver, Colorado 80202 RE: Cheyenne Connector Pipeline Project, Weld County, Colorado Dear Mr. Jakaitis: Cheyenne Connector, LLC, an indirect, wholly owned subsidiary of Tallgrass MLP Operations, LLC (Cheyenne Connector), is proposing to construct, install, own, operate, and maintain certain facilities located in Weld County, Colorado, which comprise the Cheyenne Connector Pipeline Project (Project). The Project is regulated by the Federal Energy Regulatory Commission (FERC), and the FERC is the lead federal agency on this undertaking. The Project would include a new pipeline, with appurtenances, and five meter and regulating stations. Specifically, Cheyenne Connector proposes to construct approximately 70 miles of 36-inch-diameter steel pipeline that will transport natural gas from the proposed new Lancaster Meter and Regulating station in Section 14, Township 2 North, Range 66 West, traversing generally north and northwest, and terminating in the proposed new Connector Meter and Regulating station within the existing REX Cheyenne Hub facility in Section 5, Township 11 North, Range 66 West. Current land use in the Project vicinity includes agriculture, grazing, and previous oil and gas development. Cheyenne Connector plans to file their 7(c) Application with the FERC in March 2018. Following approval by the FERC, construction is expected to commence in April 2019 and proceed through October 2019. For the proposed Project, Cheyenne Connector requests authorization in support of its application to the FERC pursuant to Section 7(c) of the Natural Gas Act and Part 157, Subpart A, for an order approving applications for certificates of Public Convenience and Necessity. Section 106 of the National Historic Preservation Act (NHPA) requires federal agencies to take into account the effects of their undertakings on historic properties and to afford the Advisory Council on Historic Preservation a reasonable opportunity to comment on the undertaking. To help the FERC evaluate the potential effects on historic properties that may result from the proposed Project, Cheyenne Connector contracted SWCA Environmental Consultants (SWCA) to conduct a cultural resource inventory for the proposed Project. The results of the inventory are presented in the enclosed report titled Class III Cultural Resource Inventory for the Proposed Cheyenne Connector Pipeline Project, Weld County, Colorado. On behalf of Cheyenne Connector, SWCA conducted an intensive Phase I cultural resource survey for the proposed Project. SWCA recorded 141 cultural resources as a result of this survey. These include 98 newly recorded segments of 79 historic linear sites (36 previously recorded linear sites, 43 newly recorded linear sites), 13 previously recorded non-linear sites, eight newly recorded non-linear sites, and 22 newly recorded IFs. The linear sites include 44 county roads, four highways, 11 historic side roads, two railroads, 17 irrigation ditches, and one transmission line. Non-linear sites include 10 historic sites (seven homesteads/farmsteads/habitation, one field
Ed Jakaitis February 26, 2018 Page 2 irrigation system, and two trash scatters), eight prehistoric sites (four open camps, two open lithic scatters, and two stone circle/cairn sites), and three multicomponent sites (one prehistoric open camp and historic farmstead, one prehistoric open camp and historic trash dump, and one prehistoric open lithic scatter and historic trash dump). Of the ten non-linear sites, nine historic sites are recommended not eligible for inclusion in the National Register of Historic Places (NRHP) and one historic site (5WL4803) is recommended eligible. Of the eight prehistoric sites, two sites (5WL650/5WL5974 and 5WL1683) are recommended to be eligible for inclusion in the NRHP, and the remaining six sites are recommended not eligible. All three of the multicomponent sites are recommended not eligible. Linear resources that have not been recorded in their entirety and have not had a formal determination of NRHP eligibility are treated as eligible for the NRHP for the purposes of the Section 106 review. Of the 79 linear sites crossed by the Project, 75 are either eligible or needs data and four are recommended not eligible in their entirety. As the Project is currently designed, all of the supporting segments of linear sites will be crossed using standard bore or horizontal directional drilling (HDD)/bore technology; thus, there will be no adverse effect to these sites. Overall, three non-linear sites are recommended eligible for inclusion in the NRHP (5WL650/5WL5974, 5WL1683, and 5WL4803). As currently designed, the Project will not impact portions the sites that contribute to the overall site eligibility. Finally, two sites that SWCA recommends as not eligible (5WL651 and 5WL8281) are types that may retain cultural importance to Native American tribes traditionally associated with the region; as currently designed, impacts to these two sites will be avoided by the Project. The 22 isolated finds are all recommended to be not eligible for inclusion in the NRHP. As currently designed, the proposed Project will not impact any supporting segments of eligible linear resources or contributing portions of eligible non-linear resources; therefore, the undertaking will result in no historic properties affected. Additionally, as currently designed, the proposed Project will result in no historic properties affected. The proposed Project is recommended to proceed with no further work related to cultural resources. On behalf of the FERC, Cheyenne Connector respectfully asks that you initiate the NHPA Section 106 review by reading SWCA s survey report and providing comments regarding the recommendation that no historic properties will be affected by the proposed activities. On behalf of Cheyenne Connector, SWCA initiated consultation with the following Native American tribes, asking each tribe to comment on the undertaking and to identify any potential traditional cultural properties that may be affected: Apache Tribe of Oklahoma; Cheyenne and Arapaho Tribes, Oklahoma; Cheyenne River Sioux Tribe of the Cheyenne Reservation; Comanche Nation of Oklahoma; Crow Creek Sioux Tribe of the Crow Creek Reservation; Fort Sill Apache Tribe; Kiowa Tribe of Oklahoma; Northern Arapaho Tribe; Northern Cheyenne Tribe; Oglala Sioux Tribe; Rosebud Sioux Tribe; Southern Ute Indian Tribe; Standing Rock Sioux Tribe of North & South Dakota; Ute Indian Tribe; and Ute Mountain Ute Tribe.
Ed Jakaitis February 26, 2018 Page 3 If you have any questions, please contact Sarah Jennings by telephone at 720.249.3446 or via email at sarah.jennings@swca.com. Respectfully submitted, Sarah Jennings Principal Investigator, Archaeologist SWCA Environmental Consultants 295 Interlocken Blvd., Suite 300 Broomfield, Colorado 80021 CONCUR, Edward Jakaitis Section 106 Compliance Manager Date cc: Rachel Garrison Sr. Environmental Project Specialist Cheyenne Connector, LLC c/o Tallgrass Energy 370 Van Gordon Street Lakewood, Colorado 80228
May 30, 2018 Edward Jakaitis Section 106 Compliance Manager Office of Archaeology and Historic Preservation 1560 Broadway, Suite 400 Denver, Colorado 80202 RE: Revised Report Submittal for the Cheyenne Connector Pipeline Project, Weld County, Colorado (HC #72920) Dear Mr. Jakaitis: SWCA Environmental Consultants (SWCA) on behalf of Cheyenne Connector, LLC, (Cheyenne Connector) and the Federal Energy Regulatory Commission (FERC), is submitting an updated version of the Class III Cultural Resource Inventory for the Proposed Cheyenne Connector Pipeline Project, Weld County, Colorado. The revised report addresses Colorado SHPO s (SHPOs) comments from both SHPO s March 26, 2018 letter and a subsequent call between SWCA and SHPO on April 18, 2018. Since the clarifications and additional commentary have caused minor changes in pagination throughout the report, a fully revised and updated report is being submitted for ease of review and recordkeeping. Specifically, revised portions of the report include: An expanded description the NRHP-eligible Centennial Farm 5WL4803, clarifying the Area of Potential Effect s (APE s) impacts solely to portions of the site that will not result in adverse effects. Additional narrative addressing the previous, extensive testing at NRHP-eligible 5WL650/5WL5974 which demonstrate a lack of intact, subsurface cultural deposits with the current APE. A clarified description of the depositional setting at NRHP-field-recommended-eligible 5WL1683, specifically relating to deposits in the current APE which demonstrate a lack of intact, subsurface cultural deposits. Expanded language in the Geomorphological Setting and Conclusion portions of the report addressing the depositional setting in the current APE. As currently designed, the proposed Project will not impact any supporting segments of eligible linear resources or contributing portions of eligible non-linear resources; therefore, the undertaking will result in no historic properties affected. Additionally, as currently designed, the proposed Project will result in no historic properties affected. The proposed Project is recommended to proceed with no further work related to cultural resources.
Ed Jakaitis May 30, 2018 Page 2 On behalf of the FERC, Cheyenne Connector seeks concurrence that this concludes the NHPA Section 106 review by reviewing the revisions SWCA s revised survey report and provide any remaining comments regarding the recommendation that no historic properties will be affected by the proposed activities. One full copy of the revised report and the following sites forms: 5WL650/5WL5974, 5WL1683, 5WL4803, and 5WL8202 (which was inadvertently missing pages) have been resubmitted. If you have any remaining questions, please contact Sarah Jennings by telephone at 720.249.3446 or via email at sarah.jennings@swca.com. Respectfully submitted, Sarah Jennings Principal Investigator, Archaeologist SWCA Environmental Consultants 295 Interlocken Blvd., Suite 300 Broomfield, Colorado 80021 CONCUR, Edward Jakaitis Section 106 Compliance Manager Date cc: Terra Mascarenas Senior EHS Project Permitting Cheyenne Connector, LLC c/o Tallgrass Energy 370 Van Gordon Street Lakewood, Colorado 80228